United Kingdom

DATA PRIVACY & COOKIE POLICY

D A T A   P R I V A C Y   P O L I C Y

INTRODUCTION

Protection of personal data and compliance with current data protection regulations is one of our priorities. In this policy we explain how we may process the personal data you provide to us through the contact forms and channels on our website (“Website”).

The data received will be processed with the utmost reserve and confidentiality. We have also put in place all the technical and organizational measures at our disposal to ensure the availability, integrity and resilience when processing personal data.

DATA CONTROLLER

The data controller of your personal data and its contact details are indicated in the table below. We have appointed a Data Protection Officer ("DPO") whose contact details are also indicated below:

LAWFULNESS OF THE PROCESSING

We will process your data in accordance with one or more of the following legal bases:

1. Consent of the concerned person. If you give us your consent, we will carry out the processing related to the scope of the consent and the purposes informed. The concerned person may revoke consent at any time.
2. Execution of a contract. We will process your data if this is necessary for the performance of a contract or for the implementation of pre-contractual measures, in order to supply you with our products or services, as well as to fulfill the obligations set out in such contract.
   
   
3. Legal obligation. According to this legal basis, we may also process your data in order to fulfill an obligation established by law.
   
   
4. Legitimate interest. We may process your data when it is necessary for the satisfaction of overriding legitimate interests that we have as Data Controller. Please contact us if you would like more information about the preponderance of the legitimate interest in each case.

CATEGORIES OF PERSONAL DATA

The following personal data is collected by Nexeo Plastics UK Limited (“Nexeo Plastics”) from its users, customers, and candidates using the Website, including with the use of cookies:

1. Customer or company name, first and last name of contact person, job title of contact person, legal address, shipment address, email address, telephone, VAT number or ID number, industry or end market, application, process methods, information on product requirements, and consumption levels.
   
   
2. If you file your CV with Nexeo Plastics, the following data will be collected: name, contact details (including postal address, email address and telephone), image and professional and academic background.

PURPOSES OF PROCESSING

We may process your personal data for the following purposes:

1. Manage the commercial relationship with our customers. This purpose includes activities such as managing customers’ account information, processing orders placed on the Website, analyzing orders and any other information gathered through the Website, or providing service alerts, announcing product safety recalls and other internal administrative purposes.
   Legal basis: performance of a contract.
   
   
2. Job application management. Regarding candidates applying for jobs, data collected by Nexeo Plastics is used in order to consider candidates for potential job opportunities at Nexeo Plastics.
   Legal basis: request of the data subject prior to entering into a contract and express consent to retain your data for future job opportunities.
   
   
3. Sending commercial communications. We may send you commercial communications (such as, for example, newsletters) with information about products, services, events and promotional activities related to different subjects. Addressees can at any time unsubscribe by accessing their Account Information or following the instructions included in these communications. An unsubscribe link will be included in each of such communications.
   Legal basis: express consent.
   
   
4. Contacting us. If you wish to contact us through the channels provided, we will process your data in order to process and respond to your questions and/or requests. We may also contact you for any questions related to our products or services, if necessary.
   Legal basis: legitimate interest.
   
   
5. Nexeo Plastics Hotline. The data that we collect through our compliance hotlines, as well as those that we collect during the internal investigation phase in the event that it is decided to initiate one, will be processed for the purpose of receiving and investigating reports of irregular conduct related to our companies and to adopt, where necessary, appropriate corrective measures and/or to file legal actions. The communication may be made both anonymously and in an identifying manner. The data provided by the complainant will be kept for the legally established retention periods.
   Legal basis: legal obligation and/or public interest.
6. Cookies. We use cookies in our Website. For further information about which cookies are being used on this Website and how they can be disabled, please see our Cookie Policy below.

Any other purpose will be communicated to you before proceeding with the processing of your data.

DATA RECIPIENTS

Nexeo Plastics will be sharing your personal data with Nexeo Plastics, LLC, a US company with an address at 1780 Hughes Landing Blvd., Suite 1000, the Woodlands, TX 77380, as well as with the rest of the subsidiaries and affiliates of Nexeo Plastics, LLC. The subsidiaries and affiliates of Nexeo Plastics are located in the United States, Germany, The Netherlands, Belgium, Sweden, Denmark, Spain, Italy, Poland, Portugal, Ireland, Czech Rep, Norway, Switzerland (as approved by the decision of adequacy no. 2000/518/EC by the European Commission, dated July 26, 2000), Austria, and the other locations identified on Nexeo Plastics Website here. Where an international data transfer takes place, appropriate safeguards will be applied according to data protection regulations (see “International Data Transfers” section below).

The data also may be communicated if required by an administrative or judicial authority, or if you have previously authorized us to do so. We also inform you that some of our data processors may have access to personal data. Those data processors are contractually obliged to maintain the confidentiality of the personal data and they cannot use it for purposes other than those for which they were collected.

INTERNATIONAL DATA TRANSFERS

In the event that any of our service providers process personal data in a third country, we will implement appropriate safeguards to protect your personal data. In the absence of an adequacy decision, the main measures adopted by our companies when an international transfer of personal data takes place are the signing of standard contractual clauses approved by data protection authorities or other appropriate safeguards according to the General Data Protection Regulation (“GDPR”).

RETENTION PERIODS

Your data will be kept for the time strictly necessary to achieve the purposes of the processing, without prejudice to their retention for the purpose of making them available to the competent authorities and for the establishment, exercise, or defense of claims. In this case, the data will be kept apart with adequate security measures until the end of the limitation period, at which time they will be deleted.

EXERCISE OF RIGHTS

You have the right to exercise the following rights:

1. Access: you have the right to know what data is included in the files we process in relation to your person.
   
   
2. Rectification: you have the right to be able to correct, complete or update your personal data at any time.
   
   
3. Erasure: you may request the deletion of your personal data from our systems and files.
   
   
4. Objection: you may object to the processing of your data (e.g., to receive our commercial communications, as well as for personal reasons) unless our legitimate interest prevails over yours.
   
   
5. Portability: you have the right to obtain a copy of all data you have provided to us and, where technically feasible, you have the right to request that your personal data be transferred to another data controller.
   
   
6. Limitation of processing: you may request the limitation of the processing of your data where (i) the accuracy of your personal data is verified after you have challenged its accuracy, (ii) the processing of your data is unlawful and you object to the erasure of your data; (iii) companies no longer need the personal data for the purposes of the processing, but you need them for the establishment, exercise or defense of claims, (iv) you object to the processing for the performance of a task carried out in the public interest or necessary for the fulfillment of a legitimate interest, while verifying whether our legitimate interest prevails over yours.

You may exercise any of these rights free of charge, as well as withdraw the consent given at any time or make a query or suggestion regarding the processing of your personal data, by sending a letter by post to the corresponding data controller (whose contact details can be consulted through the following link), or by e-mail to [email protected]  (Nexeo Plastics’ DPO), including the subject "Data Protection" and, when necessary to prove your identity, enclosing a copy of your ID card or equivalent document.

If you consider that your data has not been processed correctly, you also have the right to file a complaint to the competent data protection supervisory authority. You can contact our DPO via the addresses above to help you identify which is the supervisory authority in each case.

C O O K I E   P O L I C Y

When you visit our website (“Website”), you will be informed about the use of cookies. You can configure the cookies you want to install by different categories. By accepting our cookie notice or by configuring their installation, you may be giving your consent to their use on your device. You can also consult our cookie policy at any time, at the bottom of our Website in "Cookies Policy".

GENERAL INFORMATION ABOUT COOKIES

A "Cookie" is a text file that a website stores in the user's browser. Cookies facilitate the use, navigation, and operation of the Website. Cookies can be used, for example, to manage the user's session or to personalize the contents of a web page to the user's preferences.

Cookies can be "session" cookies, which are deleted once the user leaves the web page that installed them, or "persistent" cookies, which will therefore remain on the device until a specific date.

Likewise, cookies may be "own" cookies, when they are sent to the user's device from a computer or domain managed by Nexeo Plastics, or "third party" cookies when they are sent to the user's device from a computer or domain managed by service providers contracted by Nexeo Plastics.

More information about cookies can be found at www.allaboutcookies.org

COOKIES WE USE ON OUR WEBSITE

• Technical Cookies. This Website may use internal use cookies that are essential for the operation of the Website, such as, for example, those that allow to maintain user's session active. The deactivation of these cookies may prevent the correct performance of some functionality of the Website.
  
  
• Personalization Cookies. They allow remembering information for the user to access the Website with certain features that may differentiate its experience from that of other users, such as, for example, language, appearance, or content of the web service.
  
  
• Analytical Cookies. They allow us to collect statistics on user activity on the Website, optimize browsing and to guarantee the best possible service from our Website. Among others, they also allow us to know the frequency of your visits, the duration of such visits or the browser used.
  
  
• Marketing or Advertisement Cookies. They make it possible to measure the effectiveness of online marketing campaigns and to offer the user marketing content of their choice. Some marketing managers may use these cookies to show you advertisements on other websites as well.

Cookies used on our Website and their categories are as follows:

COOKIES CONFIGURATION

At any time, the user has the ability to accept or reject the installation of cookies, or to reject the installation of a certain type of cookies, through the cookies manager enabled for this purpose, by modifying the preferences of its web browser, or by deleting all or some of the stored cookies after each session. Likewise, the user can also activate private browsing or the do not track function of its browser to prevent the installation of cookies.

Please note that blocking cookies may affect all or some of the functionality of our Website. We recommend that you consult your browser's help to learn about the different options on how to manage cookies. You can also consult the following links in this regard (please note that the following links may have been updated or modified by the browser developer): Apple Safari, Google Chrome, r 11, Microsoft Edge, Mozilla Firefox.

When you visit our Website for the first time, we will offer you the possibility of configuring which cookies you wish to install through a cookie notice. You can object to the installation of any category of cookies, except for technical cookies, which are necessary for the proper functioning of the Website.

If you first accepted the installation of a specific category of cookies and now you wish to oppose their installation or maintenance, you must delete the cookies already installed through the configuration of your browser. Please note that if you delete cookies from your browser, it is possible that your opt-out preferences of the previous providers may also be deleted.

MORE INFORMATION

For more information about the processing of your data by Nexeo Plastics as well as to exercise any of your rights, please see our Data Privacy Policy.