(Last updated: Sep. 24th, 2021)
1.1 Arkema with its registered office at 420 rue d’Estienne d’Orves 92700 Colombes, France, and other companies in the Arkema group collect and use certain Personal Information. Arkema is responsible for ensuring that it uses that Personal Information in compliance with data protection laws.
“Arkema”, “we” or “us” means Arkema and other companies in the Arkema group.
“Personal Information” means all kinds of information related to identified or identifiable natural persons recorded by electronic or other means. [KWM1] In addition to factual information, it includes any expression of opinion about an individual and any indication of the intentions of Arkema or any other person in respect of an individual.
2. THE SERVICES WE PROVIDE
(A) Request information through the “Contact section” of our websites ("Arkema Websites");
(B) Create and access your personal account available through Arkema’s websites (see paragraph 3.2);
(C) Request samples and/or Order Arkema’s products;
(D) Track purchase orders and sample requests.
3. THE TYPES OF PERSONAL INFORMATION WE COLLECT
3.1 Arkema Websites and related functions include basic businesses and value-added businesses. In collecting information, you are not necessarily required to provide us with your Personal Information. For basic businesses, if you choose not to provide it, we may be unable to provide you with relevant services and respond to or solve any problems with which you are confronted. For value-added businesses, you may decide whether or not you permit us to collect your information. If you refuse to do so, it may cause relevant value-added businesses to be unavailable, but will not compromise your use of our basic businesses.
3.2 [KWM1] Many of the services offered by Arkema require us to obtain Personal Information about you in order to perform the services we have been engaged to provide. In relation to each of the services described at paragraph 2.1 above, we will collect and process the following Personal Information about you:
1) Information that you provide to Arkema.
This includes information about you that you provide to us. The nature of the services you are requesting will determine the kind of Personal Information we might ask for, though such information may include basic personal and professional Personal Information.
· To create and maintain your personal account
You have the possibility to create a secured personal account on Arkema’s Websites protected by a personal log-in and password. In order to create this account, you will have to register via the “My Account” section of Arkema’s Websites and to provide us with your [Please insert the information fields that may be collected in this scenario, such as email address, password, first name and last name].
This personal account will allow you to access additional content on Arkema’s product ranges and services (documentation, videos, etc.). If you refuse to provide the above-mentioned information, we will not be able to create a personal account for you, and you will be unable to experience such value-added services, but your access to the basic functions of Arkema Websites will not be affected.
Please note that registration as personal account holder is exclusively reserved to professionals.
· To provide you with consultation services
We provide you with multiple categories of consultation services, including finance, business, media and human resources. When you choose different categories of consultation services, we may collect different types of personal information so as to provide you with more targeted services.
In general, when you choose to ask for more information and quotes via Arkema Websites, we may need you to provide us with your first name, last name, email address, company name, host country, host region, professional profile, job title, product family you are looking for, type of market, type of application, type of request, and your message. In addition, you can choose whether to provide us with your phone number and job function, so that we can provide you with more personalized services. If you refuse to provide the aforementioned mandatory information, we will not be able to provide you with relevant consultation services, but your access to the basic functions of Arkema Websites will not be affected. Furthermore, if you refuse to provide the optional information, it will not affect your use of the basic functions of consultation services.
2) Information collected when you use Arkema Websites
When you visit Arkema Websites, cookies are used to collect technical information about the services that you use, and how you use them. For more information on the cookies used by Arkema please see our Cookie Notice.
4. HOW WE USE YOUR INFORMATION
4.1 Your Personal Information may be stored and processed by us in the following ways and for the following purposes:
· for ongoing review and improvement of the information provided on Arkema Websites to ensure they are user friendly and to prevent any potential disruptions or cyber attacks;
· to proceed with the orders of products and/or the requests of samples of Arkema’s products and to deliver them;
· to assess the satisfaction of the users of Arkema’s websites;
· to personalise the content of Arkema’s websites according to the user’s interests;
· to conduct analysis required to detect malicious data and understand how this may affect your IT system;
· for statistical monitoring and analysis of current attacks on devices and systems and for the on-going adaptation of the solutions provided to secure devices and systems against current attacks;
· to understand feedback on Arkema Products and to help provide more information on the use of those products and services quickly and easily;
· to communicate with you in order to provide you with services or information about Arkema and Arkema Products;
· for in-depth threat analysis;
· to understand your needs and interests;
· for the management and administration of our business;
· in order to comply with and in order to assess compliance with applicable laws, rules and regulations, and internal policies and procedures; or
· for the administration and maintenance of databases storing Personal Information.
4.2 However when we use Personal Information we make sure that the usage complies with law and the law allows us and requires us to use Personal Information for a variety of reasons. These include:
· the user’s consent has been obtained;
· our processing is necessary for the conclusion or performance of a contract to which the user is a contracting party or for conducting human resource management under the labor rules and regulations developed in accordance with the law and a collective contract signed in accordance with the laws;
· our processing is necessary to fulfill statutory functions or statutory obligations;
· our processing is necessary to respond to public health emergencies or protect the life, health or property safety of natural persons under emergency circumstances;
· Personal Information is processed within a reasonable scope to conduct news reporting, public opinion-based supervision, or other activities in the public interest;
· Personal Information that has been disclosed by the users themselves or other Personal Information that has been legally disclosed is processed within a reasonable scope in accordance with laws;
· under any other circumstance as provided by any law or regulation.
6. DISCLOSURE OF YOUR INFORMATION TO THIRD PARTIES
6.1 We may share your Personal Information listed in Section 3 within the Arkema group of companies for the purposes described above.
6.2 We may also share your Personal Information outside of the Arkema group in the following scenarios:
· We may share your certain Personal Information listed in Section 3 to the extent required by law, for example if we are under a duty to disclose your Personal Information in order to comply with any legal obligation (including, without limitation, in order to comply with tax reporting requirements and disclosures to regulators), or to establish, exercise or defend our legal rights;
· If we sell our business or assets, in which case we may need to disclose your Personal Information listed in Section 3 to the prospective buyer for due diligence purposes; and
· If we are acquired by a third party, in which case the Personal Information listed in Section 3 held by us about you will be disclosed to the third party buyer.
and contact information of the recipient, purpose and method of processing and type of personal information, and shall obtain the individual's separate consent.
Based on the above provision, Arkema is suggested to disclose the name and contact information of the agents and contractors hereby.
7. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
7.1 Arkema is a global business. Our customers and our operations are spread around the world. As a result we collect and transfer Personal Information on a global basis. That means that we may transfer your Personal Information to locations outside of your country.
7.2 Where we transfer your Personal Information to another country outside the PRC, we will ensure that it is protected and transferred in a manner consistent with legal requirements. In relation to data being transferred outside of the PRC, for example, this may be done in one of the following ways:
· the cross-border transfer has passed the security assessment organized by the authorities in accordance with the applicable laws and regulations;
· we have been subject to the personal information protection certification by a specialized institution in accordance with the provisions issued by the authorities;
· we have entered into a contract with the overseas recipient in accordance with the model contract developed by the authorities, agreeing on both parties' rights and obligations; or
· in other circumstances the law may permit us to otherwise transfer your Personal Information outside the PRC.
8. HOW WE SAFEGUARD YOUR INFORMATION
8.1 We have extensive controls in place to maintain the security of our information and information systems. Client files are protected with safeguards according to the sensitivity of the relevant information. Appropriate controls (such as restricted access) are placed on our computer systems. Physical access to areas where Personal Information is gathered, processed or stored is limited to authorised employees.
8.2 As a condition of employment, Arkema employees are required to follow all applicable laws and regulations, including in relation to data protection law. Access to sensitive Personal Information is limited to those employees who need to perform their roles. Unauthorised use or disclosure of confidential client information by an Arkema employee is prohibited and may result in disciplinary measures.
8.3 When you contact an Arkema employee about your file, you may be asked for some Personal Information. This type of safeguard is designed to ensure that only you, or someone authorised by you, has access to your file.
9. HOW LONG WE KEEP YOUR PERSONAL INFORMATION
9.1 How long we will hold your Personal Information for will vary and will be determined by the following criteria:
· the purpose for which we are using it – Arkema will need to keep the data for as long as is necessary for that purpose;
· legal obligations – laws or regulation may set a minimum period for which we have to keep your Personal Information.
9.2 Personal Information processed to answer your queries made via Arkema’s websites will be stored for the duration necessary to answer this query.
9.3 Personal Information processed to send to you promotional information will be stored for a maximum period of three years as from our last contact or last commercial transaction.
10. YOUR RIGHTS
10.1 In all the above cases in which we collect, use or store your Personal Information, you may have the following rights and, in most cases, you can exercise them free of charge. These rights include:
· the right to obtain information regarding the processing of your Personal Information and access to the Personal Information which we hold about you;
· the right to withdraw your consent to the processing of your Personal Information at any time. Please note, however, that we may still be entitled to process your Personal Information if we have another legitimate reason for doing so. For example, we may need to retain Personal Information to comply with a legal obligation;
· in some circumstances, the right to receive some Personal Information in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to Personal Information which you have provided directly to Arkema;
· the right to request that we rectify your Personal Information if it is inaccurate or incomplete;
· the right to request that we erase your Personal Information in certain circumstances. Please note that there may be circumstances where you ask us to erase your Personal Information but we are legally entitled to retain it;
· the right to object to, or request that we restrict, our processing of your Personal Information in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your Personal Information but we are legally entitled to refuse that request; and
· the right to lodge a complaint with the relevant data protection regulator if you think that any of your rights have been infringed by us.
· the right to provide instructions regarding the processing of your Personal Information after your death.
· You can exercise your rights by contacting us using the details listed in paragraph 11 below.
10.2 If you prefer not to receive promotional information by email from Arkema, you can click on the self-service unsubscribe links contained within our emails.
11. QUESTIONS AND CONCERNS
11.1 If you have any questions or concerns about Arkema’s handling of your Personal Information, or about this Policy, please contact our Privacy Officer using the following contact information:
Address: Arkema – Direction Juridique 420 rue d’Estienne d’Orves – 92700 Colombes – France
E-mail address: firstname.lastname@example.org
We are usually able to resolve privacy questions or concerns promptly and effectively. If you are not satisfied with the response you receive from our Privacy Officer, you may escalate concerns to the applicable privacy regulator in your jurisdiction. Upon request, Arkema’s Privacy Officer will provide you with the contact information for that regulator.