SDS Europe - English Customer Data Privacy Policy 1. Overview GOJO is committed to maintaining the accuracy and security of your personal information. This Global Privacy Policy (“Privacy Policy”) explains what types of personal information we may collect about you in the course of our business, why it is collected, how we use your personal information and when we might transfer your personal information to a third party. It also explains the rights you have to request that we provide you with a copy of the personal information we maintain about you; that we correct the personal information we maintain about you; and, other legal rights you have concerning the personal information we maintain about you. This Privacy Policy is effective on January 1, 2020. It replaces all other privacy policies that we issued. In this Privacy Policy the term: a. “Individual” means a living natural person, and includes all actual and potential customers of GOJO, end users of GOJO products, users of our websites and others about whom we collect, use, store and transfer personal information. Individual does not include our employees, prospective employees and contractors for whom we have a separate privacy policy. We also use “you” or “your” in this Privacy Policy to refer to Individuals. “GOJO” means GOJO Industries, Inc. and all of its subsidiaries and affiliates, except those which maintain their own privacy policies. GOJO is also referred to as “we”, “us” and “our”. If you live in the European Economic Area (“EEA”), the State of California, USA or the State of Nevada, USA, you may have additional rights concerning the personal information we maintain about you. Those are described in Your Rights if You Live in the EEA Your Rights if You Live in California Your Rights if You Live in Nevada This Privacy Policy describes a broad range of data processing activities. It is built upon current law, fair information practice principles and best practices. 2. GOJO is a Global Company Headquartered in the United States GOJO is a global company with its headquarters in Akron, Ohio, U.S.A. Your personal information may be transferred to GOJO locations and to third parties located in the United States and other countries or territories which do not offer the same level of data protection as the country in which you reside. Regardless of the country in which your PI is collected, processed or stored, we will process your PI in accordance with this Privacy Policy. 3. What is Personal Information? Personal information (“PI”) means any information that (i) directly and clearly identifies an Individual (for example, your name) or (ii) can be used in combination with other information to reasonably identify an Individual (for example, your gender, age or work address). 4. What is Sensitive Personal Information? Sensitive personal information (“Sensitive Information”) is a subset of PI that is more sensitive in nature than PI. It reveals race, religion, national origin, political opinions, union membership, sexual preferences, sexual orientation, genetic data and biometric data. 5. What PI Do We Collect? We may collect, store and use different types of PI about you. The types of PI may include: First and last name, home address, business name and address, internet protocol address, email address and business and mobile telephone numbers; Signature, account number and password and credit card number; The amount of time during which you have had an account with GOJO; Gender, date of birth and marital status; and; Browsing time, cookies information, website history and social media account identifier. While it is unusual for us to do so, we may sometimes collect Sensitive Information in limited instances 6. Do We Collect the PI of Children? No. GOJO does not knowingly acquire or retain PI about children under the age of eighteen and will delete such information if collected or processed in error. 7. Who Gives Your PI to Us? We collect your PI from you when you: Interact with us using one of our websites before and after becoming a customer or end user; Ask us to provide our products or services to you, and you give us your PI with your request; Communicate with us by telephone, email, one of our websites or hard copy correspondence; Visit one of our websites which include cookies and similar technologies. (See, Section 8 below regarding our use of cookies.); or, Reply to one of our promotions, request a product sample, enter a sweepstakes or contest or subscribe to promotions from us, including by email. If you fail to provide your PI to us when requested, we may not be able to perform all our legal and contractual obligations or carry out all activities such as providing you with marketing materials. We will make it clear if and when this situation arises and what the consequences of not providing your PI will be. We also collect your PI from third party parties such as: Those who provide your PI to us so that we can contact you with information about GOJO products and services; and, Our distributors and marketing representatives. 8. Cookies GOJO uses different types of cookies and similar technologies on its websites. Some of those technologies collect your PI. See, our Cookie Policy. 9. On What Legal Basis Does GOJO Collect and Process Your PI? There are a number of reasons why GOJO collects and processes your PI. Those reasons include: You have given us consent. The consent can be in writing. Or it can be verbal; We must process your PI in order to perform a contract between you and GOJO. For example, we need your PI to send you marketing materials you requested or to fulfill a sweepstakes; Processing is needed for GOJO to comply with a legal obligation. For example, GOJO needs certain PI to enable us to process your purchase order; and, Other reasons allowed by law. 10. How Do We Use the PI We Maintain About You? GOJO uses your PI to: Manage all aspects of our relationship with you. This includes sending you promotional materials, fulfilling product orders, delivering services such as PURELL SMARTLINK™, communicating with you on pricing and discounts and scheduling dispenser installations; Respond to your questions; Determine how our websites are being used; Improve website content; and, Provide you with targeted information. 11. Aggregate Data In some instances, GOJO may use your information in combination with information belonging to other Individuals. In this process, we use various methods to remove the identifying portions of any PI from your information before combining it with the information of other Individuals. The output of this process is aggregate data, which is incapable of identifying you or any other Individual. We use this aggregate data for several reasons, including making improvements to our products and services and how we deliver them to you. 12. Does GOJO Share Your PI with Third Parties? GOJO does not sell your PI to third parties for monetary payment. GOJO may transfer your PI to third parties where GOJO does not receive a monetary payment. Example of these transfers include: When you request us do to so, or provide your consent to us to do so; To Service Providers. A “Service Provider” is a company or person which processes your PI for a GOJO business purpose under a written contract between GOJO and the Service Provider. Examples of a business purpose are processing product orders, fulfilling sample requests and providing promotional services; and, To our distributor partners and marketing representatives to assist in their sales efforts. GOJO will also provide your PI to a third party in following situations: If GOJO sells a business, your PI may be sent to the buyer of that business. If GOJO buys a business, it may acquire the PI of customers and prospective customers of that business; When required by law or by order of a court or other government agency; When GOJO determines it is needed or desirable to protect our safety and the safety of our employees and others; When the PI we transfer is available to the public in government records; and, When we seek the advice of professional advisors such as attorneys and accountants. 13. Your Rights Regarding Your PI You have the right to be informed about why GOJO collects your PI and how GOJO uses your PI. This Privacy Policy provides you with that information. You also have the rights described in A. – H. below. To exercise any of these rights, please contact: If you are an individual who lives in Europe, use this link to send your request. If you are an individual who lives in any other part of the world, including the United States, use this link to send your request; or, Contact us at 1 800-563-2190. When you contact GOJO to exercise any of the rights you have, as described below, we may request information from you to enable us to confirm your identity. We will use reasonable means to confirm that the Individual making the request is you. If we cannot verify that the Individual making the request is you, GOJO may deny the request. There will be no charge to request and receive your PI. If GOJO cannot provide you with access to your PI, we will inform you of the permissible reasons why we may not do so. In addition, GOJO may not always be able to fulfill your request to your satisfaction. In some cases, GOJO may be prohibited by law, agreement or legitimate interest to fully comply with your request. When those situations arise, GOJO will inform you of why we are unable to fulfill your request. You have the following rights: A. Access. Upon request, we will provide you with access to the PI we have collected about you. B. Correction (also known as Rectification) GOJO attempts to be sure that your PI in our possession is accurate, current and complete. If you believe that the PI GOJO has collected and is storing about you is incorrect, incomplete or outdated, you may request the revision or correction of that PI. C. Deletion (also known as the ‘Right to be Forgotten’) You may request that we delete the PI which GOJO maintains about you. GOJO may retain your PI for as long as we believe it is necessary to fulfill the purposes for which the PI was collected. There are instances where applicable law allows or requires us to refuse to delete your PI. In the event that we cannot delete your PI, we will inform you of the reasons why. D. Restrict Processing You may request that GOJO restricts processing your PI under certain circumstances, including if you believe the PI is not accurate. E. Portability You have the right, if possible given GOJO’s then current automated systems and data architecture, to receive from GOJO your PI in machine readable format.. F. Objection You have the right in limited circumstances to object to GOJO processing your PI. G. Automated Processing You have the right to ask us to stop using your PI for automated processing such as profiling. H. Withdraw Consent Where GOJO collects and processes your PI based on your consent, you have the right to withdraw consent. I. Lodge a Complaint You also have a right to file a complaint with the appropriate government agency if you believe GOJO has not complied with this Privacy Policy or has violated the law. 14. Retention of your PI We will retain your PI for as long as necessary to fulfil the purposes for which it was collected, and to allow us to satisfy any legal, accounting and reporting requirements. 15. Security of Collected Information We are committed to protecting the security of the PI we collect from you. GOJO uses reasonable physical, technical and administrative safeguards to help protect the information from destruction, loss and unauthorized or inappropriate access or use. 16. Who Can I Contact about My Rights Under this Privacy Policy? Use the contact information located in Section 13 above. The contact point differs depending on the country in which you reside. 17. Changes to this Privacy Policy The effective date of this Privacy Policy is January 1, 2020. We may change this Privacy Policy at any time. A revised version of this Privacy Policy will be available on our website. Your Rights if You Live in the European Economic Area 1. Data Controllers The General Data Protection Regulation defines a “controller” as a person or entity which determines the purpose for processing PI. The data controllers are: GOJO Industries – Europe Ltd Units 5 & 6 Stratus Park Brinklow, Milton Keynes MK10 0DE United Kingdom; GJF Holding SAS 8 rue Léon Jouhaux 77183 Croissy-Beaubourg France; Laboratoires Prodene Klint 8 rue Léon Jouhaux 77183 Croissy-Beaubourg France; and, Prodene GmbH Im Trutz Frankfurt 55 60322 Frankfurt Germany 2. Transfers of PI Outside the EEA If you reside inside the EEA and we transfer your PI outside the EEA, we will put in place one of the required safeguards so that the transfer complies with European data protection law. GOJO relies upon the European Commission’s approved standard contractual clauses when transferring your PI to a country, such as the United States, whose privacy laws are not seen as being adequate by the Commission. A copy of the standard contractual clauses we have in place may be requested at GOJOGDPR@GOJO.COM. 3. Post-Mortem Rights Where permitted by law, You may define guidelines as to the storage, erasure and communication of your PI after your death. These guidelines may be general or specific. Your Rights if You Live in California In addition to other rights already discussed in this Privacy Policy, if you are a California consumer, as defined by the California Consumer Privacy Act of 2018 (“CCPA”), California law may provide you additional rights with respect to your PI. The CCPA defines PI very broadly. Any PI we collect is collected for the commercial purpose of effectively providing our products and services to you, as well as enabling you to learn more about, and benefit from, our products and services. In addition, if a California consumer exercises his or her rights under the CCPA, we shall not discriminate against that consumer by denying him or her our goods or services, charging different prices or rates to similarly situated consumers or providing a different level or quality of our goods or services. 1. Transferring Your PI to Third Parties A. Sell. GOJO does not sell your PI to third parties for monetary compensation. GOJO may transfer your PI to third parties where GOJO does not receive a monetary payment. California law defines “sell” as selling, releasing or disclosing your PI for a monetary payment or something else of value received in return. If you wish to direct us to not sell your PI, you may do so by the following methods: Submit your request using this link; or, Contact us by email at donotsell@gojo.com. We may sell (but not for monetary compensation) the following types of PI to third parties who are not Service Providers: First and last name, business name and address and business and mobile telephone numbers. B. Transfer to Service Providers. We may transfer your PI to a third party Service Provider for a business purpose. We transfer the following types of PI to third party Service Providers for a business purpose: First and last name, business name and address, business and mobile telephone numbers and signature; GOJO account number; and, Social media account names. 2. Transferring Your PI to Third Parties for Third Direct Marketing California law permits you to request from us additional information if we transfer, or share, your PI with third parties for their direct marketing purposes. GOJO does not transfer, or share, your PI with third parties for their direct marketing purposes. 3. Do Not Track Our websites use cookies and similar technologies. For additional information about how we use cookies and similar technologies, click the link here to read our Cookie Policy. Please be aware that our websites do not respond to Do Not Track browser settings and do not participate in any Do Not Track Frameworks that would allow us to respond to you. Your Rights if You are a Resident of Nevada Nevada law may allow you to direct us to not sell, for money compensation, certain of your PI. However, please be aware that GOJO does not sell PI to third parties for monetary compensation. New packaging solutions are being used for emergency response. PURELL ES™ Everywhere System - Designed to fit. 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