Vendor Privacy Notice
Scope and Overview
Jost Chemical Company and its foreign subsidiaries, Jost Chemical Europe SPRL and Jost Chemical Poland Sp. z o. o., are committed to protecting the privacy and security of your personal data. This Privacy Notice describes how Jost Chemical Company and its subsidiaries, affiliates, and related entities (collectively, “Jost,” “we,” or “us”) collect and process personal data about you during and after your commission of a sale with Jost. This Privacy Notice only applies to current and former vendors located in the European Union or United Kingdom.
This Privacy Notice describes the categories of personal data that we collect, how we use your personal data, how we secure your personal data, when we may disclose your personal data to third parties, and when we may transfer your personal data outside of your home jurisdiction. This Privacy Notice also describes your rights regarding the personal data that we hold about you including how you can access, correct, and request erasure of your personal data.
We will only process your personal data in accordance with this Privacy Notice unless otherwise required by applicable law. We take steps to ensure that the personal data that we collect about you is adequate, relevant, not excessive, and processed for limited purposes.
Collection of Personal Data
For purposes of this Privacy Notice, personal data means any information that alone, or in combination with other information Jost has or is likely to have access to, can or does identify a particular individual. Personal data excludes anonymous or de-identified data that is not associated with a particular individual. To carry out our activities and obligations as a supplier, we may collect, store, and process the following categories of personal data, which we require for the purpose of administering the supplier/vendor relationship with you:
- Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.
- Records of sales with Jost.
- Correspondence regarding sales.
- Location of employment.
- Photograph for identification purposes.
- Other personal details that you otherwise voluntarily provide to us.
The personal data listed in this notice is mandatory in order for us to administer the supplier/vendor relationship. Failure to provide or allow us to process mandatory personal data may affect our ability to accomplish the purposes stated in this Privacy Notice.
We will collect the personal data that we process directly from you.
Use of Personal Data
We only process your personal data where applicable law permits or requires it, including where the processing is necessary for the performance of our contract with you, where the processing is necessary to comply with a legal obligation that applies to us as your supplier, for our legitimate interests or the legitimate interests of third parties, to protect your vital interests, or with your consent if applicable law requires consent. We may process your personal data for the following legitimate business purposes and for the purposes of performing the contract with you:
- Business management and planning.
- Assessing qualifications for a particular job or task.
- Complying with applicable law.
We will only process your personal data for the purposes we collected it for or for compatible purposes. If we need to process your personal data for an incompatible purpose, we will provide notice to you and, if required by law, seek your consent. We may process your personal data without your knowledge or consent only where required by applicable law or regulation.
We may also process your personal data for our own legitimate interests, including for the following purposes:
- To prevent fraud.
- To ensure network and information security, including preventing unauthorized access to our computer and electronic communications systems and preventing malicious software distribution.
You will not be subject to decisions based on automated data processing without your prior consent.
Collection and Use of Special Categories of Personal Data
The following special categories of personal data are considered sensitive under the laws of your jurisdiction and may receive special protection:
- Racial or ethnic origin.
- Political opinions.
- Religious or philosophical beliefs.
- Trade union membership.
- Genetic data.
- Biometric data.
- Data concerning health.
- Data concerning sex life or sexual orientation.
- Data relating to criminal convictions and offences.
Jost will not collect or process the previously defined special categories of personal data even when you voluntarily provide them unless provided for the performance of the contract or as applicable law otherwise permits.
Where we have a legitimate need to process special categories of personal data about you for purposes not identified above, we will only do so only after providing you with notice and, if required by law, obtaining your prior, express consent.
We will only disclose your personal data to third parties where required by law or to our employees, contractors, designated agents, or third-party service providers who require such information to assist us with administering the supplier/vendor relationship with you, including third-party service providers who provide services to us or on our behalf. Third-party service providers may include, but are not limited to, data storage or hosting providers. These third-party service providers may be located outside of your home jurisdiction.
We require all our third-party service providers, by written contract, to implement appropriate security measures to protect your personal data consistent with our policies and any data security obligations applicable to us as your supplier. We do not permit our third-party service providers to process your personal data for their own purposes. We only permit them to process your personal data for specified purposes in accordance with our instructions.
We may also disclose your personal data for the following additional purposes where permitted or required by applicable law:
- To other members of our group of companies (including outside of your home jurisdiction) for the purposes set out in this Privacy Notice and as necessary to perform our contract with you.
- As part of our regular reporting activities to other members of our group of companies.
- To comply with legal obligations or valid legal processes such as search warrants, subpoenas, or court orders. When we disclose your personal data to comply with a legal obligation or legal process, we will take reasonable steps to ensure that we only disclose the minimum personal data necessary for the specific purpose and circumstances.
- To protect the rights and property of Jost.
- During emergency situations or where necessary to protect the safety of persons.
- Where the personal data is publicly available.
- If a business transfer or change in ownership occurs and the disclosure is necessary to complete the transaction. In these circumstances, we will limit data sharing to what is absolutely necessary, and we will anonymize the data where possible.
- For additional purposes with your consent where such consent is required by law.
Cross-Border Data Transfers
Where permitted by applicable law, we may transfer the personal data we collect about you to the United States and other jurisdictions that may not be deemed to provide the same level of data protection as your home country, as necessary to perform our contract with you and for the purposes set out in this Privacy Notice. If you are located in the EU, we utilize Standard Contractual Clauses approved by the European Commission and in compliance with EU-U.S. Privacy Shield in order to secure the transfer of your personal data to the United States and other jurisdictions.
We have implemented appropriate physical, technical, and organizational security measures designed to secure your personal data against accidental loss and unauthorized access, use, alteration, or disclosure. In addition, we limit access to personal data to those employees, agents, contractors, and other third parties that have a legitimate business need for such access.
Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, as required to satisfy any legal, accounting, or reporting obligations, or as necessary to resolve disputes. To determine the appropriate retention period for personal data, we consider our statutory obligations, the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes we process your personal data for, and whether we can achieve those purposes through other means. We will retain personal data for the duration of the supplier/vendor relationship and the subsequent two (2) years following the completion or termination of a contract for legal protection purposes.
Under some circumstances we may anonymize your personal data so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent. Once you are no longer a vendor of the company, we will retain and securely destroy your personal data in accordance with applicable laws and regulations.
Rights of Access, Correction, Erasure, and Objection
Under certain circumstances, you have the right to:
- Request access to your personal information. This enables you to receive a copy of the personal information we hold about you and to check that we are collecting and using it lawfully.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to use it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.
- Request the restriction of collecting and using your personal information. This enables you to ask us to suspend the usage of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the data portability of your personal information to another party.
- Right to lodge a complaint to supervisory authority.
- Right to withdraw the consent. In circumstances where you have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time.
To review, verify, correct or request erasure of your personal information, object to the processing of your personal data, request that we transfer your basic personal information to another party or withdraw the consent, please contact firstname.lastname@example.org in writing. To lodge the complaint to supervisory authorities, please contact directly the Data Protection Authority in your jurisdiction.
In order to meet your request, we may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it. Exercising your rights is free from charges. However, we have right at our sole discretion to refuse to fulfil or charge a reasonable fee for fulfilling of several similar consecutive requests or requests that are manifestly unfounded or excessive. We are also entitled to decline requests on statutory grounds in which cases we will inform you of such decline including the grounds for the decline.
Changes to This Privacy Notice
We reserve the right to update this Privacy Notice at any time, and we will provide you with a new Privacy Notice when we make any updates. If we would like to use your previously collected personal data for different purposes than those we notified you about at the time of collection, we will provide you with notice and, where required by law, seek your consent, before using your personal data for a new or unrelated purpose. We may process your personal data without your knowledge or consent only where required by applicable law or regulation.
If you have any questions about our processing of your personal data or would like to make an access or other request, please contact us at: email@example.com If you are unsatisfied with our response to any issues that you raise, you have the right to make a complaint with the data protection authority in your jurisdiction.
We have appointed Jost Chemical Europe SPRL as our EU representative to help ensure our compliance with applicable law. Please direct any questions relating to our processing of your personal data to our EU representative at: Rue du Bois Portal 30/1-3, 5300 Andenne, Belgium, or by phone at +32-85-552-655.
Effective Date: October 23, 2019