Swagelok.com® Privacy and Data Protection Policy
Last updated August 12, 2015
SWAGELOK’S COMMITMENT TO PRIVACY
Swagelok Company, its subsidiaries and its authorized sales and service centers (collectively, “Swagelok” or “we,” “us,” or “our”) respect your right to privacy and are committed to protecting your information and/or data. This policy (the “Policy”) summarizes what information we may collect through Swagelok.com® and any authorized sales and service center website (collectively, the “Sites”), how the information may be used, with whom it may be shared, and other important topics relating to your privacy and data protection.
Please read this Policy carefully, because by using the Sites, you are acknowledging that you understand and agree to the terms of this Policy. In addition, please review the Terms and Conditions of Use, which govern your use of the Sites and any content you submit to the Sites.
1. INFORMATION COLLECTED
Information You Provide To Us
Generally you can visit the Sites without providing personal data, unless otherwise mentioned in the Sites themselves. For instance, at Swagelok.com, you may register with an authorized sales and service center, which enables you to place orders electronically with your selected authorized sales and service center. If you choose to register and place an order, you will be asked to provide certain personal data, including your name, e-mail address, company name, telephone number, job title, market, billing and shipping information (“Personal Information”).
The collection, processing and the use of Personal Information collected during registration with your authorized sales and service center requires your consent. The consent may be declared electronically. You may withdraw your consent at any time by sending an e-mail to email@example.com or write to us at Swagelok Company, Information Security, 6262 Cochran Road, Solon, Ohio 44139 USA.
In addition, if you choose to communicate with us by e-mail or otherwise complete on-line forms or other documents, this information may also be collected in your profile. Moreover, if you choose to use the “forward to a friend” function, or link to referenced documents or sources, this information is used to analyze site usage metrics.
Information We Collect Automatically
information about the type of browser you use;
details of the web pages you have viewed;
your IP address; and
the hyperlinks you have clicked.
We use this data to determine the general physical location of your computer or device and understand what regions of the world our visitors to the Sites are coming from. We also may use this Personal Data to enhance the Sites.
2. USE OF PERSONAL INFORMATION
The following persons or entities may have access to the Personal Information that you provide to Swagelok: Swagelok, and its employees, and Swagelok authorized sales and service centers and their respective employees. We will take reasonable care to protect data and limit access only to Swagelok employees or Swagelok authorized sales and service center employees who have a legitimate business reason to view the Personal Information. All parties who have access to your Personal Information are required to keep it confidential and may not use it for any purpose other than to provide you services within the normal business activities of Swagelok and its authorized sales and service centers. Such normal business activities may include, for example:
communicating with you about your account, products, services, events, surveys and promotions by Swagelok (including by sending you marketing communications);
sending you samples, products and information;
processing payment for products or services purchased by you;
processing payment for products or services sold by you to Swagelok;
providing you with access to certain areas and features of the Sites;
verifying your identity to ensure security for the other purposes listed here;
processing, evaluating and responding to your requests, inquiries and applications; and
for purposes disclosed at the time you provide your Personal Information or otherwise with your consent.
3. SHARING AND TRANSFERRING OF YOUR PERSONAL INFORMATION
We will keep your Personal Information private and will not disclose it to other parties, unless such disclosure is necessary to: (a) comply with federal or state law, a court order or other legal process; (b) protect our rights or property; (c) enforce any of our Terms and Conditions of Use; or (d) in connection with the sale of the company. Swagelok will not disclose any Personal Information to a third party without providing prior notice and obtaining your specific consent. However, we may share non-Personal Information, such as aggregate user statistics, demographic data, and usage data with third parties. When sharing any Personal Information with a third party, Swagelok will require that party to use and protect your Personal Information in a manner that is consistent with this Policy.
In the event that we transfer the Personal Information collected to other countries where we do business, we will do so only for the purposes described herein. When any Personal Information is transferred, it will be protected as stated in this Policy.
4. CHOICE AND ACCESS
We will give notice to you regarding the types of third parties to which we disclose any Personal Information, and provide choice regarding the types of Personal Information we disclose. You can choose to opt-out of having Personal Information stored in our systems at any time by sending an e-mail to firstname.lastname@example.org or by writing us at Swagelok Company, Information Security, 6262 Cochran Road, Solon, Ohio 44139 USA. As stated herein, unless otherwise authorized by the individual, Swagelok will not disclose Personal Information to a third party. For sensitive Personal information, we will provide an affirmative or explicit (opt in) choice if: (i) the personal information is to be disclosed to a third party; (ii) used for a purpose other than those for which it was originally collected; or (iii) subsequently authorized by the individual through the exercise of opt in choice. You can request the Personal Information that Swagelok has collected about you at any time by sending an e-mail to email@example.com or by writing us at Swagelok Company, Information Security, 6262 Cochran Road, Solon, Ohio 44139 USA. You can also have factual inaccuracies in this information corrected, or request that your Personal Information be removed, by contacting us.
5. HOW WE PROTECT YOUR PERSONAL INFORMATION
Swagelok’s computer systems are protected by firewalls and other security methods. In the event of a breach of our systems and unless a law enforcement agency informs us that notification would impede a criminal investigation, you will promptly be notified by e-mail, at the e-mail address you provided to us, of any unencrypted personal information that was or was reasonably believed to have been acquired by an unauthorized person.
Swagelok uses Personal Information only for the purposes for which it was collected or subsequently authorized by the individual. To the extent necessary for those purposes, Swagelok will take reasonable steps to ensure that Personal Information is accurate, current, and reliable for its intended use.
Swagelok uses a self-assessment approach to ensure compliance with this Policy. This includes a periodic assessment to verify the Policy is accurate and being adhered to. If you have concerns, please contact us and Swagelok will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of personal information.
6. SAFE HARBOR
Swagelok certifies that it abides by the Safe Harbor Agreement between the United States, the European Union, and Switzerland with respect to the collection, use, and retention of Personal Information. This Policy adheres to the seven Safe Harbor privacy principles of Notice, Choice, Onward Transfer, Access, Security, Data Integrity and Enforcement with respect to Personal Information from its associates, distributors, suppliers and customers, and may be amended to ensure continued compliance with the requirements of the Safe Harbor principles.
Learn more about the U.S. Department of Commerce Safe Harbor Agreement.
If a complaint or dispute cannot be resolved through our internal process, Swagelok agrees to cooperate with the Data Protection Authorities (DPAs) of the EU countries in the investigation and resolution of complaints and will comply with any advice given by DPAs, to remedy issues arising out of any failure to comply with the Principles.
7. CHILDREN’S PRIVACY
The Sites are not directed to children under the age of 13 and we do not knowingly collect Personal Information from children under the age of 13 on the Sites. If we become aware that we have inadvertently received Personal Information from a visitor under the age of 13 on the Sites, we will delete the information from our records.
8. CHANGES TO THE PRIVACY, DATA PROTECTION AND COOKIES POLICY
This Policy may be updated periodically and without prior notice to you to reflect changes in our information practices. We will post a prominent notice on Swagelok.com to notify you of any significant changes to our Policy and indicate at the top of the Policy when it was most recently updated.
9. LINKS TO OTHER SITES
The Sites may contain links to other websites for your convenience and information. We are not responsible for the privacy practices or the content of linked websites. Please refer to the privacy policies of those third-party websites.
10. HOW TO CONTACT US
If you have any questions or comments about this Policy, please contact us by:
6262 Cochran Road
Solon, Ohio 44139 USA
Via e-mail to: firstname.lastname@example.org