Responsible Data Controller
Categories of Data Processed
Purpose of Processing
Legal Basis for Processing
Third Party Links
For California Residents – Your California Rights
Changes to this Policy
Responsible Data Controller. This Website is operated by Olin. Olin is responsible for the processing of your Data. We have appointed a global Data Protection Officer whose contact details you will find at the end of this Policy. Olin has designated Blue Cube Germany Assets GmbH & Co. KG, Werk Stade, Bützflether Sand 2, D-21683 Stade, Germany, as their EU representative with regard to their respective obligations under the General Data Protection Regulation (Regulation 2016/679) (“GDPR”) with effect from May 25, 2018.
Categories of Data Processed. Olin processes the following categories of Data when you use our Website:
Log data. We collect log data through automatic means, such as your IP address, details concerning the access to our Website, such as date and time, status and data volume transferred, products you viewed or searched for, information on your browser (type of browser and version number) and other technical device information, and details of the Website that you used to access our Website. Olin saves this data in a log file every time a page is viewed. Olin is unable to assign this data to individual, identifiable persons without additional information, such as information from an Internet provider on the subscriber, which Olin regularly does not have access to without a concrete reason, such as, for example, in the case of suspicions of a legal infringement.
Contact form data. If you are contacting Olin through a contact form Olin processes the Data as shown in the contact menu provided on our Website – in particular email address and your request, as well as first name, last name, salutation and telephone number, or any other data that you choose to submit to Olin.
Content You Submit. If you choose to submit content, such as a photograph or review, we will process and may publicly post the content you provide.
Customer Support. In order to handle your customer support request we collect your first name, last name, postal address, telephone number, email address, age group and questions or comments that you submit.
Product Support. If you submit a product support request, we will ask you to provide us your first name, last name, telephone number, email address, postal address, and your age group.
Newsletter. If you register for our newsletter we will collect your name, email address, IP address, and time of registration for the newsletter. The newsletter may contain marketing materials regarding our products and services or third party products and services that may be of interest to you. We will use your email address to send you the newsletter. You may revoke your consent to receive our newsletter at any time with future effect by clicking on the link provided in each newsletter email or sending a message to firstname.lastname@example.org.
Our Websites’ web pages may embed plugs-ins, widgets or other apps of various external social media platforms. When you encounter those embedded objects, your internet browser may make a direct connection to the social media platform’s service and may share with the social media platforms information such as which of our Websites you have visited, information about your public profile, or content you have posted.
Rebates. For users in the United States, if you request a rebate, we will collect your name and zip code to calculate the rebate. In order to request a rebate, you need to save the form that you can download from the Website to your computer, print it out and send it via postal service to the address displayed. When you “save and print” your Data in the rebate form, we will store and process your Data at that time, but will not process your rebate until you submit and we receive the rebate request form through the mail. Please note that the rebate offer is handled by Repco Logistics, 8405 St. Charles Rock Road, St. Louis, MO 63114, USA. To check on the status of a rebate, you will need to provide your name, zip code, and email address used to submit the rebate request.
Geo-location data. If you visit the section of our Website that includes mapping or location functionality, including Website features that provide directions to a location where our products are available, we will collect your precise geo-location information (using technologies such as HTML5 Geolocation API) if you have enabled geo-location data sharing through your browser settings. We may also collect other location data that you manually provide to us through the Website.
Search function. If you use the search function on our Website, the five most recent searches are tracked in your browser’s local storage across the sessions.
Purpose of processing. Olin collects your Data in order to enable you to use the Website, to answer your contact requests, provide services you have requested, or enable the use of the features and services describe above. If you have opted-in to receive regular updates on the status of your product support request, Olin will use your email address to send you such updates.
You have the option to refrain from affirmatively providing certain Data (such as contact form Data, rebate information, etc.) or you may provide Olin with incomplete information. However, you may not be able to use the Website in such case at all or to the fullest extent that the Website permits. Olin will not use your Data for automated decision-making. We do not create any personalized profiles for direct marketing purposes. The analysis of your user behavior through our cookies takes place after shortening your IP address so that the assignment to a specific person is no longer possible.
Legal Basis for Processing. Olin is entitled to process your Data as set out above because you are visiting our Website. If you subscribe to any service for which Olin is asking you to provide consent, the legal basis of processing your Data will be your consent. You may revoke your consent at any time with effect for the future by sending an email to the contact information. We may process your personal data to comply with a legal obligation.
If you have subscribed to a newsletter or a service, Olin may send you additional information about similar services or products. You may object to the sending of this additional information at any time with effect for the future. Please send an email in this regard to the contact information at the end of this Policy, or contact us using the contact methods provided in any such communication.
Recipients. We may share your Data with the following entities:
- Olin Employees and Other Olin Companies.Olin will grant access to your Data to those employees who are responsible for technical administration, maintenance and the further development of the Website, the provision of the services you may have subscribed for, and other purposes described above.Olin may also provide some of the services through contractual arrangements with other Olin companies (i.e., intra-group) who process Data on our behalf.
- Third Party Service Providers. In addition, Olin engages external IT service companies to maintain its IT systems, and other service providers who assist Olin to operate the website, to help with Olin’s business functions, or to provide the services you have requested.For example, Olin uses third party service providers to help distribute its email newsletters, to manage email marketing subscriber lists and send emails to subscribers, and to fulfill rebate requests. These third party service providers may be able to access your Data when performing their services. Olin will contractually obligate these recipients to confidentiality, to safeguard your Data from disclosure, and to utilize an adequate level of data protection. For example, if legally required, Olin will require such third parties to sign the EU or Swiss Model Clauses; you may request a copy of the Clauses by contacting us.
- With Your Consent.Olin may also transfer to your Data to third parties, including for marketing purposes, with your consent.For example, when you fill out a rebate form, you have the option to consent to receive unrelated marketing and other communications from Olin and other affiliated and non-affiliated third parties.If you provide such consent, you may receive additional marketing and other communications from Olin and the other affiliated and non-affiliated third parties.Unless you consent, we will not share your Data with third parties for the third parties’ direct marketing purposes.
- Public Postings. When you voluntarily disclose your Data in any public areas on this Website (such as by uploading a photograph or review), that Data, along with any information disclosed in your communication, can be collected and used by third parties and may result in unsolicited messages from third parties. Such activities are beyond our control. If you do not want your comments or photographs to be viewed by third parties, you are advised not to make any public submissions.
- Legal Purposes. To the extent permitted by applicable local law, we share your Data with government authorities or courts in order to comply with any legal obligation, or to protect the rights, property or safety of Olin, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
- Corporate Change.Finally, to the extent permitted by applicable local law, Olin may transfer your Data to a third party as part of a merger, acquisition, bankruptcy, transfer, sale, corporate change, or any other transaction involving all or a portion of Olin’s assets or in connection with the purchase or some or all of another company.
Retention. We will retain your Data for the statutory retention periods. Your log data will be deleted within seven days after your use of the Website. Permanent cookies will be kept for six months; Permanent cookies used for website customization will be stored indefinitely; cookies to calculate rebates will be kept as long as they are required for calculation; and newsletter data will be retained for the time you have subscribed to our newsletter and six months after you have revoked your consent. We will follow these retention periods unless otherwise required by law.
Security. We maintain reasonable administrative, technical and physical safeguards to protect your Data against loss, misuse, unauthorized access, disclosure, alteration or destruction.
Third Party Links. Our Website may, from time to time, contain links to and from the Website of our partner networks, third party organizations and affiliates (including our “careers” website, which is hosted by a third party). If you follow a link to any of these websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
Social Plugins. We currently use social media plugins on our Website. These social media plugins collect information about your visit to the Website and your use of the social platform services (for example, buttons or likes) on the Website. The server of the social media platform operator receives a message about which specific web page of our Website you are visiting. If you click on a button of a social media platform while you are logged in to your account with the social media website, the operator collects information about the URL recommended or visited by you, your IP address, and other browser-related information via your social media profile. Your profile saves your recommendation or any other action you took, such as a re-tweet, and makes it publicly available. We have no influence on the amount of data that the social media platforms collect through the social plugin.
We may be using the following social media plugins:
Facebook. www.facebook.com which is operated by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA ("Facebook"). The plugins are identified by one of the Facebook logos (white "f" on blue tile or a "thumbs-up" sign).
Twitter. Twitter which is operated by Twitter Inc., 795 Folsom Street, Suite 600, San Francisco, CA 94107, USA. For the Twitter data protection disclaimer, see: https://twitter.com/privacy.
Your Rights. In the case that the GDPR applies to you because you are located in the EU and you are using the Website in relation to the offering of goods or services, you have the following rights. These rights can be exercised by contacting us by using the contact information at the end of this Policy:
- Obtain information on your Data in order to check and verify such Data,
- Receive a copy of your Data,
- Correction, deletion or restriction of the processing, which also includes the right to have incomplete or incorrect Data rectified by supplementary information,
- Right to object to the processing,
- You may receive your provided Data in a structured, common and machine-readable format and transfer this Data to another controller as long as you have consented to the processing or the processing is based on a contract.
In addition, you have the right to file a complaint with the regulatory authorities in connection with the processing of your Data.
Changes to the Policy
Any changes we make to the Policy in the future will be posted on this page. We encourage you to visit this area frequently to stay informed, as your continued use of our Website following the posting of changes to this Policy means that you consent to such changes. If you have signed up to a service that is provided through the Website, you will be notified by email of any changes to the Policy.
Contact: Olin Data Protection Officer, Megan Rosenberg, email@example.com or +1.314.355.8285
Effective Date: August 16, 2018
Last Updated: August 16, 2018