Privacy Statement

PRIVACY STATEMENT

This Privacy Statement (��ٳٲ��ٱ𳾱�Գ��) aims to inform you on how IMCD uses your personal data that we collect (i) when you visit www.imcdgroup.com, the website of any IMCD affiliate or the MyIMCD customer portal website (“IMCD Websites��) or (ii) when we do business with you or the company you work for.

It also informs you of the procedures we have in place regarding the disclosure and protection of such information. If you have any questions about this Statement, please contact IMCD using one of the methods listed in the “Contacting IMCD�� section below.

Responsibility

Any personal data provided to or collected through the IMCD Websites, is controlled ultimately by IMCD N.V., a company registered in the Netherlands under registration number 51470497, with registered address at Wilhelminaplein 32, 3072 DE Rotterdam, the Netherlands.

Children younger than 16 years

The IMCD Websites are not intended to be used by children under the age of 16 and we do not knowingly collect any personal data from such users. If we become aware that any user under 16 has provided personal data to us without consent from its parent or guardian, we will promptly delete such data.

Collection and processing of personal data

How do we collect your data?

(A) Personal data provided by you

When you visit the IMCD Websites or do business with IMCD, we collect your personal data in various ways. Through the IMCD Websites, we may collect information that is directly and voluntarily provided to us, for example when filling out a contact form, subscribing to a newsletter, registering for an event or filling out a survey.

(B) Personal data received from your employer or public available sources

When we do business with you or with the company you work for, we may have received your personal data from you personally, your employer, or from public available sources.

(C) When you use our websites, we collect information using cookies and similar technologies

When you use the IMCD Websites, we also collect information about your visit through cookies and similar technologies (e.g. web analytics tools). More information about how cookies work, the purposes for which we use cookies and how you can withdraw consent for the placed cookies can be found in our Cookie Statement.

What data do we collect?

Types of information that IMCD may collect:

name, age, gender, company name and job title
business contact information, such as your company e-mail address and/or your business address
any preferences and interests indicated by you when subscribing to our newsletter
other information relevant to any request submitted by you through the IMCD Websites, or otherwise, and provided voluntarily, for example when you fill in our online contact form
browser type
browser language
IP address
details of the webpages visited, including viewed webpages, links clicked and downloads

Purpose of collection and processing

When you visit the IMCD Websites

We use the personal data that we collect when you visit the IMCD Websites, for the following purposes:

maintaining, improving and further securing the IMCD Websites
customising the IMCD Websites according to your preferences
compiling IMCD Websites user statistics
providing feedback on queries or comments
suggesting products and services which may be of interest to you
offering the opportunity to receive a newsletter or take part in promotions
tailoring content or advertisements to match your preferred interests or to avoid showing you the same information repeatedly
providing purchase information and product information
facilitating support requests and sample requests (if applicable)

In general, IMCD's data processing for the abovementioned purposes will be based on the legitimate interests of IMCD, including IMCD's commercial, business and research interests. In specific cases, IMCD's data processing may (also) be based on consent or a necessity to comply with legal obligations.

When we do business with you

When we do business with you or the company you work for, we use the personal data that we collect from you, through the IMCD Websites or otherwise, to register you as a (contact person for a) customer or supplier, to perform a contract with you or the company you work for and to manage our relationship with you.

The grounds for such processing are set out in the table below.

Purpose of use	Type of data collected / processed	Legal basis for processing
Registration of a new customer/supplier relationship	Name and (business) contact details, such as pre- and surname, e-mail, telephone number and (business) address	To enable IMCD to perform a contract with you or the company you work for
Processing and delivery of orders and sending you invoices or collecting payment	Name and (business) contact details, such as pre- and surname, e-mail, t elephone number and (business) address Financial data, such as your company’s bank account and any transaction data	To enable IMCD to perform a contract with you or the company you work for Necessary to comply with legal obligations Necessary for IMCD’s legitimate interests (for example to collect debts due to IMCD)
Managing our relationship with you, including sending you notifications of changes to our business terms or this Privacy and Cookie Statement	Name and (business) contact details, such as pre- and surname, e-mail, telephone number and (business) address	To enable IMCD to perform a contract with you or the company you work for Necessary to comply with legal obligations
Asking and enabling you to take part in / complete surveys	Name and (business) contact details, such as pre- and surname, e-mail, telephone number and (business) address	Necessary for IMCD’s legitimate interests (for example, to identify supplier/customer needs, to develop and grow our business or to improve the quality of our products and services)

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Data recipients

IMCD sometimes hires other companies (third parties) to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases and processing payments. When we employ another company to perform a function of this nature, we only provide them with the information that they need to perform their specific services. All such companies will be required to adequately safeguard your personal data, subject to agreements that correspond to the requirements of applicable laws.

In all instances we only ever pass your information that is collected with cookies and similar technologies to third parties to help our own marketing efforts. We will never sell your personal data or give third parties permission to use it for their own, separate purposes. For more information on how IMCD uses cookies, please read our Cookie Statement.

We may share your personal data within our group for specific purposes. The ��Ϸ��վ carries out its business operations using centralised databases and systems. Those central databases and systems may be hosted or managed by one group company for other group companies. In addition, for efficiency purposes, certain operational functions may be performed by one group company for other group companies. We may also share your personal data within our group for internal administrative purposes, to improve our services to you or because we are required to do so by law. Our group companies may only use your personal data as required for the relevant business function and in accordance with this Statement.

Data transfer to outside of the EU

IMCD may transfer certain personal data to recipients outside the EU for the purposes mentioned above. This is done because our affiliate companies, partners, or service providers provide their services from countries outside the EU. If this seems necessary, IMCD will ensure that adequate safeguards are in place to comply with the requirements for the international transfer of personal data under applicable privacy laws. For transfers of personal data to countries outside the European Economic Area, IMCD may use European Commission-approved Standard Contractual Clauses as safeguards. IMCD will provide more information about such data transfers and safeguards upon request.

How we will communicate with you

We may communicate with you via e-mails or newsletters with information on IMCD, market information, information on our products, or services we believe could be of interest to you. We will only communicate with registered users. If you do no longer want to be a registered user for market(ing) content, you may “opt out�� by following the “opt out�� instructions in the e-mail footer or newsletter (see below).

Securing your personal data

We are committed to ensuring that your personal data is secure. To ensure an appropriate level of security and, in particular, in order to prevent any accidental or unlawful destruction, loss, alteration, disclosure, intrusion of or unauthorised access to these data, we have put in place appropriate technical and organisational measures as required by applicable legal provisions to safeguard and secure your personal data.

Your rights

You may contact our Privacy Officer (see “Contacting IMCD�� below) to exercise any of the rights you are granted under applicable data protection laws, including (A) the right to access your data, (B) the right to rectify your data, (C) the right to erase your data, (D) the right to restrict the processing of your data, (E) the right to data portability, and (F) the right to object to processing.

(A) Right to access

You may ask us whether we collect or use any of your personal data and, if so, to receive access to that data in the form of a copy.

(B) Right to rectification

You have the right to have your data rectified if it is inaccurate or incomplete. Upon request, we will correct inaccurate personal data about you and supplement incomplete personal data about you.

You have the right to have your personal data erased. This means that we will delete your data. Erasure of your personal data only takes place in certain cases, as prescribed by law and listed in Article 17 of the General Data Protection Regulation (GDPR). This includes situations where your personal data is no longer necessary for the purposes for which it was originally processed, and situations where your data was processed unlawfully.

(D) Right to restriction of processing

You have the right to obtain a restriction on the processing of your personal data. This means that we will suspend the processing of your data for a certain period. Circumstances which may give rise to this right include situations where the accuracy of your personal data is contested and we need some time to verify its (in)accuracy. This right does not prevent us from continuing to store your personal data. We will inform you before the restriction is lifted.

(E) Right to data portability

Your right to data portability entails that you may ask us to provide you with your personal data in a structured, commonly used and machine-readable format, and have such data transmitted directly to another controller, where technically feasible. Upon request and where this is technically feasible, we will transmit your personal data directly to the other controller.

(F) Right to object

You have the right to object to the processing of your personal data. This means you may ask us to no longer process your personal data. This only applies if the 'legitimate interests' ground (including profiling) constitutes the legal basis for processing (see “Purposes of collection and processing�� above). You can object to direct marketing at any time and at no cost to you if your personal data is processed for these purposes, which includes profiling to the extent that it is related to direct marketing. If you exercise this right, we will no longer process your personal data for such purposes.

Withdrawal of consent

You may withdraw your consent at any time by following the specific instructions concerning the processing for which you provided your consent. For example, you can withdraw consent by clicking the unsubscribe link in the e-mail or adjusting your communication preferences in your account. You may also contact IMCD’s Privacy Officer (see “Contacting IMCD�� below). More information on how you can withdraw your consent for cookies and similar technologies we use when you visit our websites, can be found in our Cookie Statement.

Questions, comments or complaints

If you have any questions, comments or complaints about this Statement, please feel free to contact us (see ‘Contacting IMCD��). If your concerns have not been addressed to your satisfaction, you have the right to file a complaint with the competent national Data Protection Authority. In the Netherlands, the in The Hague is responsible for monitoring compliance with privacy regulations.

Retention period

IMCD will retain any personal data obtained through the IMCD Websites and through the process of doing business with you for the period necessary to fulfil the purposes outlined in this Statement unless a longer retention period is required or permitted by law.

Contacting IMCD

In relation to this Statement and the exercise of your rights hereunder, you can contact IMCD by using one of the following options:

by e-mail to: [email protected]
by (postal) mail to:
��Ϸ��վ B.V. (for att. of the Privacy Officer)
Wilhelminaplein 32
3072 DE Rotterdam
The Netherlands
or by telephone to: 0031 10 �� 290 86 84

Links to other websites

The IMCD Websites may contain links to enable you to visit other websites of interest easily. However, once you have used these links to leave our site, you should note that we do not have any control over these websites. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such websites and such websites are not governed by this Statement. For more information on how they handle your personal data, please check their privacy and/or cookie policies (if available).

Updates

This Statement was last updated on 27 September 2021. We may update this Statement from time to time. We will inform you of any changes before they come into effect.

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