Swagelok Privacy and Data Protection Policy

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SWAGELOK PRIVACY POLICY

Last updated March 14, 2023

Introduction

This privacy policy (the “Policy”) explains how Swagelok Company, its subsidiaries (together, “Swagelok”), and the authorized independent distributors of Swagelok products that post this notice (“Sales and Service Centers”) (Swagelok and the “Sales and Service Centers” are referred to as “we” or “us”) collect, use, share, and otherwise process personal information collected through the website swagelok.com, through certain associated websites (e.g., [geographic location or promotional name].swagelok.com) and through associated online content, including blogs, instructions, catalogs, technical drawings, webinars, applications including configurators, or industry-specific resources controlled or owned by Swagelok (collectively, the “Sites”).

In this Policy, personal information means information that (either in isolation or in combination with other information) enables you to be directly or indirectly identified (“Personal Information”). Please read this Policy carefully as it sets out information relating to how we handle your Personal Information. Additionally, please review the Terms and Conditions of Use, which govern your use of the Sites and any content you submit to the Sites at swagelok.com^® Terms and Conditions | Swagelok.

Swagelok, in addition to the Sales and Service Centers, which are independently owned and operated, may have access to Personal Information on individuals covered by this Policy. A list of the entities that may have access to your Personal Information as outlined in this Policy can be found here.

Personal Information Swagelok Collects

Personal Information You Provide to Us

From Websites, Webinars, Trainings, Certifications, or Events. We may collect Personal Information that you choose to send or provide to us. For example, we collect your Personal Information when you use the Sales and Service Center Locator or register for an account with a Sales and Service Center to view pricing, request quotes, or order products online. We also collect your Personal Information when you attend trainings, you request technical drawings, or when you contact us with questions or other customer service needs. Personal Information requested may include your name, email address, company name, telephone number, job title, market, billing (including payment information), and shipping information. Similarly, while using the Sites, you may be asked to provide feedback by submitting a response to an online survey and, if you respond, your Personal Information, including cookies and IP information, will be submitted (subject to the cookie policy and your tracking preferences). Providing feedback via a survey is entirely optional.

From Purchasing Products. We also collect the Personal Information you choose to send or provide to us when you place an order with Swagelok or a Sales and Service Center to purchase Swagelok Product. Personal Information requested when a purchase is made may include your name, e-mail address, company name, telephone number, job title, market, billing (including payment information), and shipping information.

From Applying for a Position with Swagelok. The Sites may include a link to the swagelok.com Careers section. Any Personal Information submitted through the Careers portion of the Sites (jobs.swagelok.com), by upload, or via email will be governed by our Applicant Privacy Policy and is provided in connection with your creation of an applicant profile. Personal Information collected from you during the application process is detailed in the Applicant Privacy Policy.

Personal Information We Automatically Collect

When you visit the Sites, we collect Internet or other electronic network activity information through the use of cookies and other trackers. Depending on your tracking preferences, the information we collect may include but is not limited to your device’s Internet Protocol (“IP”) address, referring website, type of browser you use, what pages your device visited, and the time that your device visited our Site. We may use various technologies to learn your geographic location, including by collecting your IP or other device information, which may depend on your device's settings for location services. We may also rely on tools, including a firewall, to prevent spam and other security risks related to the use of abusive automated software. You can choose your preferences on the use of cookies and other trackers by accessing the preference center on our Sites. Visit our  Cookie Notice for more information on the types of cookies and other trackers we use on our Sites.

Personal Information We Collect from Trusted Partners

We may receive information from third parties such as technical product partners, advertising and marketing partners, public databases, and social media platforms to supplement and confirm the accuracy of the Personal Information you may choose to send. If we collect this information, this policy governs how we use that information.

Our Use of Personal Information

We may use Personal Information we collect for the following reasons:

to respond to your inquiries and fulfill your requests
when it is necessary to perform our obligations or exercise our contractual rights
when it is necessary to comply with applicable laws or regulations
for our legitimate interests, including:

managing and promoting the Swagelok brand
selling products and processing payments
improving upon the products we sell
to administer our Sites and events
for internal operations including troubleshooting, data analysis, testing, statistical, and survey purposes
to operate our business

to communicate with you concerning products and information about our products
to improve our Sites to ensure that content is presented most effectively for you
where we have your consent (if and as required under applicable law) to use your Personal Information for marketing. Where we rely upon your consent, you have the right to withdraw consent by contacting us.

Information We Share with Others

We may obtain, transfer, or share information, including Personal Information, about persons in the following circumstances:

when we have your consent
as between Swagelok and the Sales and Service Centers, to accomplish the purposes set forth in this Policy
as between Swagelok and service providers, to perform tasks on our behalf. Our service providers include payment processing providers, website analytics companies, cybersecurity and fraud prevention companies, help desk companies, CRM services, email service providers, and technical drawing repository services (including Thomas, a Xometry Company, when you visit cad.swagelok.com and download technical drawings)
when you attend events, certifications, or trainings, we may share Personal Information with your employer to allow for the verification of your Swagelok certifications
to enforce our legal rights and comply with valid requests by public authorities, including to meet national security or law enforcement requirements, and as otherwise allowed based on our legitimate interests or legal obligations

How Long We Store Personal Information

We retain Personal Information for different time periods, and for as long as required, to meet one or more of the following:

the needs and purposes for which the Personal Information was collectedt
to be able to bring or defend against legal claimst
when industry, legal, or regulatory obligations require us to retain it

Your Choice and Access Rights

You can control the information we collect and use in the following ways:

Location Information: You can disable location-based services on your mobile device or web browser by adjusting the settings on your device or browser. This will prevent our Site from accessing your location information. Note that some services may not be available if you disable location-based services.
Emails: You may opt-out of our marketing emails by following the instructions listed in any email communications that you receive or by contacting us using the contact details provided under the “How to Contact Us” section below.
Social Media: This Policy does not cover the privacy and security practices of social media platforms on which we have social media pages. Please review the terms, policies, and settings of those social media platforms if you have questions about how they collect and use your data.
Online Advertising: For information about opting out of third-party advertising, visit: NAI Opt-Ou t or DAA. You will leave this Site for a separately managed online site where you can specify your preferences. You can also click on the icon that may appear on some of our advertising served through this technology. We may use more than one third-party company for placing this advertising, which would require you to opt out of each company.
Google Analytics: You can opt out of Google Analytics across all websites you use. To do so, visit this website.
Postal Marketing: To opt-out of other forms of marketing (such as postal marketing), please contact us using the contact details provided under the “How to Contact Us” section below.

Your International Privacy Rights

We may transfer your Personal Information to organizations located in countries other than the one in which the Personal Information was collected. For purposes of this section, the term “Personal Information” includes “Personal Data” as defined by applicable law. If you are located in the EEA, the United Kingdom, or Switzerland, you may have certain rights and protections under applicable laws regarding the processing of your Personal Information. Each of these laws generally affords data subjects the right to:

Know whether we’re processing your Personal Information
Request a copy of the Personal Information we hold about you
Request that we correct inaccurate or incomplete Personal Information we hold about you
Request that we erase your Personal Information, subject to exceptions under applicable law
Request that we transfer any Personal Information we hold about you to another company
Under certain circumstances, restrict certain types of processing
Object to having decisions made about you by automated processes or profiling
Withdraw your consent
Lodge a complaint with the supervisory authority

How to Submit a Request

You always have a right not to disclose information to us, but you may need to provide Personal Information in order to purchase Swagelok products. Where we receive your request to exercise one of your rights, we will respond without undue delay and within the time required by applicable law. Time frames for responses may be extended in certain circumstances. Generally, we will provide you with requested information free of charge, except where requests are manifestly unfounded or excessive. In these circumstances, we may charge a reasonable fee or may refuse to act on the request. We will advise you of any fees prior to proceeding with a request. We may ask for additional information to verify your identity before carrying out a request. Please note that we may still use any aggregated and de-identified Personal Information that does not identify any individual and may also retain and use your Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our Agreements.

If you would like to make a complaint about how we handle your Personal Information or make a complaint about a breach of data protection laws, please contact us using the contact details provided under the “How to Contact Us” section below.

If you are located in the EEA, the United Kingdom, or Switzerland and you wish to exercise any of your rights, please submit your request by emailing us at infosec@swagelok.com. There are exceptions to the rights of individuals in relation to their Personal Information and your rights may be limited in some circumstances.

Data Protection Authority

If you have a concern about our processing of Personal Information that we are not able to resolve, you may have the right to lodge a complaint with the Data Protection Authority where you reside. Contact details for your Data Protection Authority can be found using the links below:

For individuals in the EEA: https://edpb.europa.eu/about-edpb/board/members_en

For individuals in the UK: https://ico.org.uk/global/contact-us/

For individuals in Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/deredoeb/kontakt.html

Legal Basis for Processing

We will process your Personal Information only where we have a lawful basis for doing so. These lawful bases for processing are set forth in applicable data protection law and, depending on the relevant circumstances and jurisdiction, our processing will be on the basis of one or more of the following: (a) the performance of a contract to which you are a party; (b) compliance with our legal obligations; or (c) for our legitimate interests (this includes pursuing our general business interests). In addition, in some circumstances we may process your information where you have provided your consent. Please note that you have the right to withdraw any such consent by contacting us using the contact details below.

Your California Privacy Rights

Residents of California have certain rights concerning the processing and use of their Personal Information (as defined by California law). The rights described herein are subject to exemptions under applicable law. Under California law, you may have the right to:

Know, access, and confirm your Personal Information
Delete the Personal Information we have about you
Correct inaccuracies in your Personal Information
Obtain your Personal Information in a portable and readily usable format
Opt-out of the use or processing of your Personal Information for profiling or targeted advertising
Opt-out of the sale of your Personal Information

You have the right not to receive discriminatory treatment for the exercise of any of these privacy rights. We will not discriminate against you because you have exercised any of your rights.

You may also have a right to pursue legal action for improper handling of your Personal Information.

How to Submit a Request

If you wish to exercise the rights listed above and are a resident of California, you may submit a request by emailing infosec@swagelok.com, by calling us toll-free at 1-833-435-1121, or by using this form. We will provide your Personal Information to you in writing in a readily usable format. If you choose to submit your request via email, you must include “Privacy Rights Request” in the subject line and clearly provide us with the following information: what type of request you are making, your full name, email address, and valid physical address. You may only make one request per email.

We are required to provide you with access to your Personal Information or delete your Personal Information only in response to verifiable consumer requests. We will compare the information you provide to us in your request to any information we may have in our possession to verify your request. You may be asked to provide us with information such as your home address, email address, and telephone number. We may also contact you to request additional information in relation to your request. Please promptly respond to any follow-up inquiries so that we may verify your identity. If you request that we provide you with specific pieces of information about you or that we delete Sensitive Personal Information (as defined by California law), we may apply heightened verification standards. The information you provide must match the information we have in our possession. This measure is in place to help ensure that Personal Information is not disclosed to any person who does not have the right to receive it. The information collected through this process will be used for verification purposes only.

Authorized Agent

Please note that you may authorize an agent to exercise any of these rights on your behalf by contacting us toll-free at 1-833-435-1121 or by submitting the request via this form. If you use an agent, we will take measures to verify your agent’s authorization similar to the verification described above for fulfilling any access or deletion requests. We may require more information to ensure proper verification of you and your agent’s identity and authorization.

Categories of Personal Information Disclosed for a Business Purpose

We share Personal Information about you with service providers and third parties for business purposes, such as operational purposes and other purposes related to providing you with the services you seek from us.  For more information about the business purposes for which we disclose Personal Information, see “Our Use of Personal Information” and see “Personal Information Swagelok Collects” for what types of information may be shared.

“Do Not Sell” Rights; Sharing for Cross-Context Behavioral Advertising, Profiling, or Targeted Advertising

We may disclose your Personal Information for the following purposes, which are not a sale: (i) for reasons mentioned above; (ii) if you direct us to share Personal Information; (iii) to comply with your requests under applicable law; and (iv) as otherwise required or permitted by applicable law. We may “sell” or “share”, as defined by applicable law, the following categories of Personal Information: Identifiers, commercial information, and inferences.

California Consumer Privacy Rights Requests Disclosure

We did not receive any consumer requests from January 1, 2021–December 31, 2021 to which we were legally obligated to respond.

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. To the extent that you disclose your Personal Information to third parties, including any third-party website linked from any of our websites, you are subject to the privacy customs and policies of those third parties. Please refer to the privacy policies of those third-party websites.

Security

Information for Visitors from Outside the United States

Swagelok is headquartered in the United States of America, but its products are distributed world-wide, including by Sales and Service Centers located across the globe. We may transfer, store, and process Personal Information of individuals covered by this Policy in the United States or in other global locations.

We will protect your Personal Information and will transfer data in accordance with the European Commission approved standard contractual clauses, other countries’ approved transfer mechanisms, or as otherwise permitted by law.

General Security

Swagelok implements organizational, technical, and physical security controls to protect Personal Information from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Despite these measures, data transmissions over the Internet are not 100% secure, and we cannot guarantee or warrant the security of any information you transmit via the Site. You are responsible for maintaining the security of your credentials used to access the Sites, and you must report suspected unauthorized activity to us.

Children’s Privacy

The Sites are not directed to children under the age of sixteen (16), and we do not knowingly collect Personal Information from children under the age of sixteen (16). If we learn we have inadvertently received Personal Information from a visitor under the age of 16, we will delete the information from our records.

Changes to this Policy

This Policy is subject to change. When required by applicable law, we will alert you to material changes to this Policy by, among other possible means, placing a notice on the Sites or sending you an email (if you have registered your email). You can see when this Policy was last updated by checking the date at the top of this page. You are responsible for periodically reviewing this Policy.

How to Contact Us

If you have any questions or comments about this Policy, please contact us by:

Writing to:
Data Privacy Officer
Swagelok Company
31500 Aurora Road
Solon, Ohio 44139 USA
or
via email to: infosec@swagelok.com