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Norman Hay Group: Website Privacy Notice

Welcome to the Norman Hay plc Website Privacy Notice.

This Privacy Policy is issued on behalf of Norman Hay and its Group Companies. When we say “we,” “us,” “our” and “Norman Hay” we are referring to the relevant company in the Norman Hay Group responsible for processing your data. We are incorporated in England and Wales, providing chemicals, sealants, surface coatings and process plant.

This Privacy Notice aims to give you specific information on how we collect and process your personal data through your use of this specific website, as well as any other sites or mobile applications owned by Norman Hay plc and its Group Companies. The website, and any web pages, interactive features, applications, blogs, social networks or other online, mobile or wireless offerings that post a link to this Privacy Notice, whether accessed via computer, mobile device or other technology, manner or means. While using our websites, and as described in more detail below, we may collect Personal Information about a website visitor, customer, person or email address on or related to a Contact.

We are committed to protecting any data that we collect concerning you. By using our websites you agree to the use of the data that we collect in accordance with this Privacy Notice.

We have appointed a Data Privacy Manager who is responsible for overseeing questions in relation to this notice. If you have any questions, including any requests to exercise your legal rights, please email privacy@normanhay.com.

Why we process your data

We process your personal data primarily on the basis of Legitimate Interest as a business but only if necessary for the purpose we collected it for. We will also process data on the basis of contractual and transactional obligation where necessary. We may process your data for;

•Sales and marketing activities such as calls, emails and other types of communications

•Understanding how you interact with the website and social media

•Account activity such as, email, written and verbal communications and agreements

•To perform obligations under a contract with you or a business you may work for

We will only store your data, for as long as we need it to undertake any of the processes listed above.

How we collect information about you

a. About You: When you use our websites, send us an email or communicate with us in any way, you are voluntarily giving us information that we collect.

That information may include either your name, email address, IP address, phone number, as well as details including occupation, location, survey responses and feedback. By giving us this information, you agree to this information being collected, used, disclosed, transferred within the EU (our main data storage centre is located in England) and stored by us as described in this Privacy Policy.

b. Automatically: When you browse our website we may collect usage information about your visit to our website and your web browsing. That information may include your IP address, your operating system, your browser ID, your browsing activity, and other information about how you interacted with our website or Service. We may collect this information as a part of log files as well as through the use of cookies or other tracking technologies. Our use of cookies and other tracking technologies is discussed more below, and in more detail in our Cookie Policy here.

c. IP address lookup: We use third parties to provide information about visitors to our websites. When you visit our website we will record your IP address. This address will be matched against public and proprietary IP address databases to provide us with information about your visit. This information may identify the organisation to whom the IP address is registered but not individuals. In some limited cases i.e. single person companies, it may be possible to identify personal data from publicly available ICANN data.

d. Website Cookies and link tracking: Cookies allow us to provide important site functionality, so you don’t have to re-enter lots of information. They also allow us to remember what links and pages have been clicked or viewed during a session. If you have provided us with personal data, completing a contact form for example, we may associate this personal data with other information. This will allow us to identify and record what is most relevant to you. By using your browser controls, you are always in control of the cookies we store and access on your computer. More information on how to control cookies and limit personal data processing can be found at youronlinechoices.com/uk/five-top-tips. For comprehensive information on how to change your cookie settings in a wide variety of different web browsers, visit www.aboutcookies.org.

Google Analytics Cookies: Google Analytics is a website monitoring tool that allows users to see volumes of website visitors, their source, and to analyse how the content of their website is viewed and navigated. This in turn allows optimisation of the content and pages and the marketing programmes that drive traffic to the website. Google Analytics does not store any personal information about website visitors, but does use persistent cookies to identify repeat visitors. You may universally opt-out of all Google Analytics tracking used by all websites by visiting the following url – https://tools.google.com/dlpage/gaoptout

GatorLeads and Lead Forensics Cookies: GatorLeads and Lead Foresnics are software tools used on a number of Group Company websites. They identify the business or organisation that website visitors belong to, based on a reverse IP Lookup. They use cookies to process this identification, and personal information about individual users is stored. The cookies used store information about your current web browsing session (pages viewed, time on site etc) and the dates and times of previous

Email Marketing Post-Click Tracking Cookies: These cookies are used to report on the pages that have been viewed by visitors to the site who have followed links from our email marketing campaigns. This analysis helps us to understand additional content that is viewed by the contacts in our database and therefore allows us to improve and tailor future campaigns to those contact’s specific areas of interest.

For more information about our use of cookies and other tracking technologies, as well as how to opt out of the use of cookies, please refer to our Cookie Policy here.

e. We also collect, use and share Aggregated Data such as statistical or firmographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

f. Who will see your data: Your data will only be seen and used by employees of Norman Hay plc and its Group Companies. We operate a role-based access policy for personal data. What this means, is that an employee will only have access to personal data, if they need that access to do their job. We do not share the personal data of prospects or customers with any third parties.

How we use your information

We will only use your personal data when the law allows us to. We may disclose Personal Information and use personal data acquired from and provided by yourself to fulfil any of your requests and to send you appropriate and useful communications.

We use your data for the following purposes:

a) To send you informational and promotional content in accordance with your marketing preferences. You can stop receiving our promotional emails by following the opt-out instructions included in every email.

Types of communications: By processing your Personal Information under Legitimate Interest, you will receive any specific piece(s) of information you requested, as well as allowing us to send you appropriate relevant and useful communications. This includes but is not limited to; invitations to our industry events and webinars, our latest content (whitepapers, guides, reports, infographics, videos and case studies) and suggestions about products or services that may be of interest to you. If you are a Customer of Surface Technology or SIFCO ASC, you will also receive monthly surface finishing updates. These updates will highlight surface engineering news, innovations and information on the range of services these companies provide.

At any time, you can update your preferences (or completely unsubscribe/opt-out of our marketing) by clicking the opt-out link in any emails you receive from us. The link will always be in the footer of the email. You can also stop receiving emails from us using that same link.

b) To manage our relationship with you which will include i) notifying you about changes to our terms or privacy policy; ii) asking you to take s survey

c) To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

d) To meet legal requirements, including complying with court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms.

e) To provide information to representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, or security requirements.

f) To prosecute and defend a court, arbitration, or similar legal proceeding.

g) To respond to lawful requests by public authorities, including to meet national security or law enforcement requirements.

h) To transfer your information in the case of a sale, merger, consolidation, liquidation, reorganisation or acquisition. In that event, any acquirer will be subject to our obligations under this Privacy Policy, including your rights to access and choice. We will notify you of the change either by sending you an email or posting a notice on our Website.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosing Information

We do not disclose any personal information obtained about you from this website to third parties except when we need to do so in order to complete the transaction – e.g. when arranging for a courier company to deliver goods that you have ordered. We may also use the information to keep in contact with you and inform you of developments associated with our business. You will be given the opportunity to remove yourself from any mailing list or similar device. If at any time in the future we should wish to disclose information collected on this website to any third party, it would only be with your knowledge and consent.

We may from time to time provide information of a general nature to third parties – for example, the number of individuals visiting our website or completing a registration form, but we will not use any information that could identify those individuals.

Public Information and Third-Party Websites

a) Social media platforms and widgets. Our websites may  include social media features. These features may collect information about your IP address and which page you are visiting on our Website, and they may set a cookie to make sure the feature functions properly. Social media features and widgets are either hosted by a third party or hosted directly on our website. We also maintain presences on social media platforms including Facebook, Twitter, and LinkedIn. Any information, communications, or materials you submit to us via a social media platform is done at your own risk without any expectation of privacy. We cannot control the actions of other users of these platforms or the actions of the platforms themselves. Your interactions with those features and platforms are governed by the privacy policies of the companies that provide them.

b) Links to third-party websites. Our websites include links to other websites, whose privacy practices may be different from ours. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites. If you submit Personal Information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit.

International Transfers

The personal data we collect from you may be transferred to, and stored outside the European Economic Area (EEA). We will only transfer your personal data to countries that have been deemed to provide an adequate level of personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries or contact the Data Privacy Manager at privacy@normanhay.com.

Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Your Legal Rights

You have certain rights given to you by law, that means you have an amount of control over your personal data that we process.

1.Access to Your Personal Data: This right allows you to confirm that your personal data is being processed and to allow you to check if the processing is lawful.

2.Correcting Any Mistakes: The right of rectification allows you to instruct an organisation that is processing your personal data, to rectify any mistakes.

3.Right to be Forgotten: You have the right to instruct an organisation to erase your personal data.

4.Stop Processing: The right to stop the processing of your personal data

5.Moving Data: The right to data portability means that under certain circumstances you will be able to ask for your personal data to be transferred from one organisation to another.

6.Right to Object to Direct Marketing: You have the right to object to the processing of your personal data for the purposes of direct marketing.

7.Object to Profiling: Under certain circumstances, you are able to object to profiling and/or automated decision making.

Please make sure you contact our Data Privacy Manager at privacy@normanhay.com if you wish to exercise any of your rights or if you have any questions about the processing of your personal data.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Changes to this Notice

Any changes to our Privacy Notice will be placed here and will supersede this version of our Notice. We will take reasonable steps to draw your attention to any changes. However, to be on the safe side, we suggest that you read this Notice each time you visit our website to ensure it still meets with your approval.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your business relationship with us.

Contacting us

If you have any questions about this Privacy Notice, or if you want to know what information we have collected about you, please email us at privacy@normanhay.com. You can use this email address to correct any factual errors in that information or require us to remove your details from any contact list under our control.

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