ZEON CHEMICALS L.P.

PRIVACY NOTICE

Revised:  May 25, 2018

Introduction

Zeon Chemicals L.P. (“ZEON” or “We”) knows that you care how information about you is used and shared, and we appreciate your trust that we will do so carefully and sensibly.  ZEON respects your privacy and is committed to protecting it through our compliance with this Notice.

We are providing you this Privacy Notice because we collect some of your personal data during your interactions with ZEON.

This Notice describes the types of information we may collect from you or that you may provide when you visit  www.zeonchemicals.com (our “Website”) and/or interact with ZEON. It also describes our practices for using, retaining, protecting, and disclosing that information, and your rights to that information.

By visiting our site or interacting with us, you consent to the terms of this Privacy Notice. ZEON, at its discretion, may periodically update this Privacy Notice, and we encourage you to regularly review it for updates. By continuing to visit our site and interact with us following any periodic updates, it means that you also consent to the terms of those changes.

Scope

This Notice applies to information we collect:

• On this Website
• In email and other electronic messages between you and ZEON
• In ZEON’s Customer Relationship Management software

It does not apply to information collected by us offline or through any other means, including on any other website operated by other ZEON global affiliates.

Data Collection

Data You Provide to Us

We collect several types of personal data directly from you, including:

• Personal contact information such as name and contact details
• Copies of your communications with us (including email address), if you contact us
• Business information such as email address, job title, employer
• For applications of employment to ZEON, we additionally collect employment history, resume, employment applications, and related documents

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may automatically collect certain information about your equipment, browsing actions, and patterns. The technologies we use for this automatic data collection may include Cookies. For further details, see aboutcookies.org.

Data from Others

We may receive information about you from third parties, for example, our business partners. Such information may include personal contact information such as name, email address, phone number, and address.

Data Use

We use your personal data for the following purposes:

• To carry out our obligations arising from any contracts entered into between you and us, such as providing services and customer support, processing orders, delivering orders, and billing.
• To personalize and improve your experience with the Website by showing you content that we think you might be interested in and displaying the content according to your interests and preferences.
• To understand your needs to provide better products, services, and special offers.
• To administer the Website and ensure it is working as intended, such as by diagnosing problems with our server and providing other technical support.
• To communicate with you. We may use your details so that we can send you information about ZEON and ZEON’s partners, provide you with notices about your orders, and respond to your inquiries or requests.
• We may use your data to produce aggregated information that is anonymous and does not identify you personally.
• To fulfill any other purpose for which you provide it.

Data Retention

Our data retention of  your information depends on the circumstances under which we acquired it unless a longer or shorter retention period is required or permitted by law:

Type of Information	Reason for Information
Customer and prospective customer contact information collected in connection with an order or an inquiry	For fulfillment of a contract or legitimate interests in providing customers with information about our products and services
Customer and prospective customer information collected for use in marketing additional products and services	Legitimate interests in direct marketing and providing you with information about the services we offer, and about which you have expressed an interest or that we believe will be of benefit to you
Contact information collected in connection with an application for employment at ZEON	For processing of application for employment and compliance with labor relations laws and regulations

Data Sharing

We do not share your personal information to anyone outside of ZEON except to:

• Affiliated companies of ZEON Group, under the umbrella of Zeon Corporation (parent company)
• Our partners, business service providers, and other third parties we use to support our business and carry out services on our behalf. Any third parties that we may share your personal data with are bound by contractual obligations to keep personal information confidential and secure and use it only for the purposes for which we disclose it to them. When they no longer need your data to fulfill this service, they will dispose of the details in line with ZEON’s mandated procedures.
• Comply with any court order, law, or legal process, including to respond to any government or regulatory request.

We may provide advertisers with aggregated information, which is anonymous and does not personally identify you, without restriction.

Safeguarding Personal Data

The personal data we hold is stored and processed securely in line with the information security measures and guidance standard in our industry.  We have implemented reasonable and appropriate physical, technical, and administrative security measures to protect against loss, misuse, unauthorized access, disclosure, alteration or destruction of the personal data under our control.

Cross Border Personal Data Transfers

We are a member of ZEON Group (parent company: Zeon Corporation), which operates in countries worldwide. If you reside outside of the United States, your personal data may be transferred to, stored, and processed at ZEON Group servers located in the United States, Japan, and the European Union. The United States has personal data privacy laws that are different from those of the European Union.  We have implemented safeguards for personal information that is transferred outside of the European Union. The safeguards ensure compliance with the data protection requirements of the GDPR as well as your rights appropriate to the processing of your personal data.

Privacy of Children’s Information

Our Website is not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13. If you believe we might have any information from or about a child under 13, please email us at privacy@zeonchemicals.com.

Personal Data Rights

You have the following rights concerning your personal data that we hold and process that you can exercise at any time:

• Right of access – you have the right to request a copy of the information that we hold about you.
• Right of rectification – you have a right to correct personal data that we hold about you that is inaccurate or incomplete.
• Right to be forgotten –you can ask for the personal data we hold about you to be erased from our records.
• Right to object – you have the right to object to certain types of processing such as direct marketing.
• Right to judicial review — in the event that we refuse your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in the process below.

All of the above requests will be forwarded on to other parties holding and processing your personal data where appropriate.

Contact Information

Please contact our Privacy Coordinator at privacy@zeonchemicals.com if you have any issues with your personal data held at ZEON.

Complaints Regarding Personal Data

If you wish to raise a complaint on how we handle your personal data, you may contact our Privacy Coordinator as follows:

By Email:         privacy@zeonchemicals.com

By Mail:         

Zeon Chemicals L.P.
Attn:  Legal
4111 Bells Lane
Louisville, KY 40211 USA

By Telephone: +1 (502) 775-7777

By accessing our Website or communicating with us, you consent that the jurisdiction for any and all disputes that are unable to be amicably resolved by contacting to our Privacy Coordinator is Louisville, KY USA, except as otherwise specified by law.

Changes and Updates to the Privacy Notice

This Notice may change from time to time. The date of the most recent update is May 25, 2018.