Introduction

Solvay recognizes and supports the privacy interests of all persons, and respects these interests when Solvay collects and processes Personal Information. In particular, Solvay respects the privacy of its customers, suppliers and employees and other individuals with whom Solvay has business interactions. In addition to the restrictions and obligations of this Policy, Solvay complies with the applicable national laws that protect the privacy of Personal Information, including the EU General Data Protection Regulation 2016/679), effective on and after May 25, 2018, and all laws and regulations in the jurisdictions in which Solvay conducts its business.

 

Scope

This Policy applies to:

(1) Personal Information that is collected, maintained, used or otherwise processed by any Global Business Unit, Function/Business Support Activity or Affiliate of Solvay. This Policy is global, applying to all Solvay locations. It is the imperative basis for using Personal Data and can only be replaced by stricter national regulations; 

(2) Personal Information in any format, including computerized records and electronic information as well as paper-based files; and 

(3) Personal Information that Solvay collects and uses for its own business purposes.

In some cases, Solvay processes Personal Information that belongs to other companies in particular in the framework of Transitional Services Agreements. In these cases, Solvay shall protect the Personal Information in compliance with this Policy, comply with all laws that regulate the information, and use information only as authorized by the data owner as specifically set out in a Transitional Services Agreement. 

The terms of this Policy are also intended to apply to agents and contractors that handle and process Personal Information on behalf of Solvay.

 

Definitions

For purposes of this Policy, the following definitions shall apply:
“Personal Information” (or person’s information) - also called Personally Identifiable Information (PII) or Personal Data- means any information that can be used to identify directly or indirectly a person. It includes any information that enables an individual to be identified either from that piece of data alone, or from that data and other data that is available or likely to be available such as his/her name, home address, email, identification number, salary and benefits information. There is no distinction between Personal Information about an individual in their private, public or work roles, as all are covered by this Policy.

Processing” means any operation or set of operations which is performed upon Personal Information, whether or not by automatic means, such as collection.

Sensitive Personal Information” means Personal Information that reveals medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or information specifying the sex life or sexual orientation of the individual.

 

Privacy principles

(1) Collection or use of data - Purposes

Solvay collects and uses the Personal Information to support and further its businesses. Solvay  processes Personal Information only for limited, explicit and legitimate purposes and always in accordance with applicable law. The types of information and the purposes for which we collect Personal Information may include:

For Employees

Solvay collects and uses Personal Information as needed for human resources and employment processes from current and prospective employees and independent contractors.

For Customers, Vendors, Suppliers and Subcontractors

Although our customers, vendors, suppliers and subcontractors are mostly companies, Solvay collects Personal Information about individuals who are employed by them. This business contact information and other personal details are used to administer existing and future business arrangements.

Others

Additional Personal Information may be collected, used and disclosed for the purposes for which it was collected and for legal compliance purposes, including regulatory reporting, investigation of allegations of wrongdoing, and the management and defense of legal claims and actions, and compliance with subpoenas, court orders and other legal obligations. For example, we may collect information about individuals that visit our facilities.

Solvay collects this information only in a reasonable and lawful manner.

(2) Privacy notices -Transparency
Where required, Solvay informs individuals about its processing of their information and also makes this information available upon request. In particular, its privacy notices contain:

  • the type of information we collect;
  • the purposes for which we collect Personal Information;
  • the types of parties to whom we disclose Personal Information;
  • the privacy and information safeguards we employ; and
  • how to access, correct or erase Personal Information (if appropriate).

Solvay also offers transparency with regard to international information transfers. Where possible, privacy notices include information about how Personal Information may be used within the Solvay Group and by third parties, the purposes of such transfers, the potential recipients, and the safeguards that Solvay has put into place to help ensure an adequate level of protection for the transferred information.

(3) Lawfulness and fairness of the processing

Solvay processes Personal Information lawfully and fairly in relation to the individual. This implies that all processing is based on legitimate grounds, such as the necessity of the processing for (i) preparing and/or performance of a contract with the individual, (ii) compliance with a legal obligation imposed on Solvay, (iii) protection of vital interests of the individual, (iv) performance of a task carried out in the public interest, or  (v)  legitimate  interests  pursued  by  Solvay  or  by  a  third  party  except  where  such interests are overridden by the interests or fundamental rights and freedoms of the individual which require protection of Personal Information.

In addition, where consent of an individual for the collection, use, or disclosure of Personal Information is required by law, contract or agreement, Solvay must receive such consent prior to the processing or transfer of the Personal Information.

(4) Sensitive information

There are certain types of Personal Information that Solvay considers to be particularly sensitive and for which Solvay provides additional and appropriate privacy protection and confidentiality. Solvay will only collect and use this Sensitive Personal Information where there is a legal basis, or where the individual’s consent has been obtained or where there are compelling business reasons if legally permitted.

(5) Accuracy of information

Solvay employs reasonable means to keep Personal Information reasonably accurate, complete, and up- to-date, as needed for the purposes for which it was collected.

(6) Information disclosure

Internal Disclosure

In general, Personal Information may be shared within Solvay, where legally permitted for reasonable and appropriate corporate purposes. However, even within Solvay, access to Personal Information is restricted to those employees, agents, or contractors who need access to carry out their assigned functions.

External Disclosure

Disclosure of Personal Information beyond the employees, agents, or contractors of Solvay, may be made only as permitted or required by law or legal process, or pursuant to an agreement, business necessity, or with the consent of the individual. In particular:

    Employees
Solvay may disclose Personal Information about workers and employees to a range of third parties who provide its employees with services, such as payroll or benefits management.

    All Individuals
Personal Information may always be disclosed in connection with legal compliance initiatives, in response to a government request for information or as part of the due diligence, negotiation and completion of a sale or transfer of all or part of our businesses.

 
(7) The location of Personal Information and international transfer

Personal Information may be stored and processed at Solvay national, regional or global headquarters, at the locations of a Solvay Affiliate or of our service providers, at one or more of our international data centers and in the cloud via our service providers and always in accordance with the applicable laws.

The international footprint of Solvay involves a large number of transfers of Personal Information between different Solvay entities, as well as to third parties located in various countries. Solvay endeavors to ensure that appropriate safeguards are implemented to secure such information transfers in conformity with applicable laws.

(8) Protecting Personal Information

To help protect the confidentiality of Personal Information, Solvay employs security safeguards appropriate to the sensitivity of the information. These safeguards include reasonable administrative, technical and physical measures to protect the confidentiality and security of Personal Information against anticipated threats and unauthorized access to the Personal Information. Solvay also maintains an effective Data Protection & Privacy incident and breach management program. When required by applicable law, Solvay will report Personal Information breaches to the relevant authority and/or to inform the affected person.

(9) Access and Correction - Rights of individuals

Solvay shall generally provide individuals upon request with an opportunity to examine their own Personal Information, confirm the accuracy and completeness of their Personal Information, and have their Personal Information updated, if appropriate. Solvay provides individuals with a reasonable opportunity to object to the collection, use, and disclosure of their Personal Information.

(10) Retention

Solvay endeavors not to retain the Personal Information longer than is allowed under applicable laws.

 

Responsibilities/Accountabilities

It is the responsibility of all employees to assist in the protection of Personal Information, by acting in accordance with this Policy. Each employee is also responsible for helping to ensure that the Personal Information Solvay holds is accurate and up-to-date. 

Solvay has established a Data Protection & Privacy Office which is responsible for coordinating the Solvay privacy compliance efforts as well as for deploying effective communication and training related to this Policy. Where required by national law, Solvay will appoint Data Protection Officers at national or local levels. 

It is the responsibility of each Global Business Unit, Function/Business Support Activity or Affiliate of Solvay, and of every employee to ensure compliance with this Policy when processing Personal Information and to report to the Data Protection & Privacy Office any non-compliance or violation. 

The Data Protection & Privacy Office is responsible for defining and updating this Policy. 

Any violation of this Policy may result in appropriate actions, including disciplinary actions, mitigation actions and discontinuation of business relations, subject to and in conformance with applicable laws.

Solvay appreciates your interest in its products and services and your visit to our Websites. The Solvay Group (“we”) are strongly committed to maintaining your privacy when you visit our Websites and we want you to feel comfortable visiting our Websites. The protection of your privacy in the processing of your personal data is an important concern to which we pay special attention during our business processes. We will do everything possible to guarantee that the data you provide us will remain confidential and are used only for the purpose described here. Personal data collected during visits to our Websites are processed by us according to the legal provisions valid for the countries in which the Websites are maintained. In addition, this privacy policy covers also the processing of Customer and Partner Data which is applicable company-wide for Solvay. Solvay’s website may include, however, links to other websites which are not covered by this privacy policy. Solvay respects your privacy and your personal data.

This privacy policy (referred as “Policy”) describes the personal data collected or generated and processed when you use Solvay’s websites (referred as “Websites”), for example Solvay.com, Solvay.fr or Solvay.de. This Policy describes the types of personal data collected when you use our Websites and how your personal data is used, shared and protected. It also explains the choices you have relating to your personal data and how you can contact us.

 

Who is responsible for the processing of your personal data?

The Solvay entity primarily responsible for the processing of your personal data collected on the Website(s) is Solvay SA. Solvay SA may share your request with the relevant Solvay affiliate(s) of the Solvay Group, who will obey the principles described in this Policy and inform you of their identity in due course. 

 

Which information do we collect and when?

We ask you for certain personal data to provide you with the products or services you request. For example, when you renew an order, request to receive information, create an account, subscribe to our newsletters, or interact with our Websites. This personal data includes your:

  • Contact details including first name, last name, email address, organization, role, telephone number and physical address
  • Login and account information, password
  • Other necessary personal details

You are responsible for ensuring that the personal data you provide is truthful, correct, non-ambiguous and up-to date.

When interacting with our Websites, data is automatically collected and shared with Solvay by the technology platforms providing the experience. For example your web browser or mobile device may share certain data with Solvay as those devices interact with Solvay’s websites. More information about these practices is included in the Cookies section below. This data includes:

  • Device IDs, network access
  • Cookies, IP addresses, reference headers, data identifying your web browser and version, and web beacons and tags

 

Why and how do we process your personal data?

We use the personal data we collect from you in the following ways:

To provide the features of the Websites you request 

When you use our Websites, we will use your data to provide the product or service you have selected. For example, if you make a query on Solvay.com, we will use the contact information you give us to communicate with you about your query. This processing of your personal data will be based on your consent to receive our communications, or on the basis of it being necessary in order to take steps at your request prior to and when entering into a contract with you, as the case may be. 

In many cases, to use particular features within our Websites, you may need to provide Solvay with additional data or additional consent to use particular data in a certain way. We will be unable to provide these features if you do not allow us to process your personal data.

To communicate information about our products, services, events and for other promotional purposes

When you create a Solvay user account, we may use the information you provide as well as information from other Solvay sources, such as your use of Solvay’s Websites, your visits, and your participation in Solvay events (possibly through other Solvay affiliates) to send you personalized communications on products and services that may be interesting for you. This processing of your personal data will be based on your consent to the use of cookies for personalization purposes, and your consent to receiving our communications.

To operate, improve and maintain our business, products and services

We may use the data you provide to us to operate our business. For example, when you renew an order, we may use that information for accounting, auditing and other internal functions. As another example, when you apply for a position at Solvay, we may use data for human resources statistics. This processing of your personal data is performed on the basis of our legitimate interest to operate and improve our business, products and services.

For general research and analysis purposes

We use data about how our visitors use our Websites and Services to understand customer behavior or preferences. For example, we may use information about how visitors to Solvay.com search for and find products to better understand the best ways to organize and present product offerings. This processing of your personal data will be based on your consent to the use of analytics cookies, as well as on our legitimate interest in analyzing the use of our website where non-cookie technology is used.

Other purposes

We may also use your personal data in other ways and will provide specific notice at the time of collection and obtain your consent where necessary.

 

Who do we disclose your personal data to?

We may share your personal data with Solvay affiliates for the purposes outlined above in accordance with the information provided at the time of collection of your personal data. 

Third party service providers may also process personal data on Solvay’s behalf, for example to process job applications, shipping and deliveries, manage and service our data, distribute emails, research and analysis, manage customer relationships, manage brand and product promotions as well as administering certain services and features.

 

How do we protect and manage your personal data?

We take the security of your data seriously. The organization has internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by its employees in the performance of their duties. Please read the ‘SOLVAY Data Protection and Privacy Policy’ for more details on how SOLVAY generally manages personal data. Access to databases or systems holding data about you are restricted to authorized users.

We take appropriate measures to maintain the confidentiality of your personal details. We use a variety of methods to help us to ensure the security of your data and to prevent third parties from viewing them, such as Secure Socket Layer (SSL) encryption, and firewalls.

Where we engage third parties to process personal data, they do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organizational measures to ensure the security of data in order to accomplish their respective missions.

We may disclose your data to third parties 1) to comply with the law requiring such disclosure; 2) to protect the personal safety of the public and the users; 3) to protect national security; 4) to enforce our rights in litigations or investigations; or 5) to prevent a crime.

 

International Data Transfers 

The personal data we collect or generate in the context of our Websites will essentially be stored in the EU. However, some of the data recipients with whom Solvay shares your personal data may be located in countries other than the country in which your personal data originally was collected. The laws in those countries may not provide the same level of data protection compared to the country in which you initially provided your data. Nevertheless, when we transfer your personal data to recipients in other countries, including the USA, we will protect that information as described in this Policy and in compliance with applicable law.

If you are located in the European Economic Area (“EEA”) or Switzerland, we take measures to comply with applicable legal requirements and ensure adequate protection for the transfer of personal data to recipients in countries outside of the EEA or Switzerland, for instance through data transfer agreements based on the EU Commission’s model clauses, or a Privacy Shield certification.

 

Retention of Your Data

We retain your personal data for as long as necessary to fulfil the purposes for which we collect it, except if required otherwise by law. Depending on the purpose, the period for which we retain your personal data may vary. To provide the features of the Websites you request, we may keep your personal data for as long as needed to provide the service you requested, and for no longer than the applicable statute of limitations thereafter. We will retain your personal data until you withdraw your consent or for a maximum duration of three years after our last contact with you or the end of our contract with you for the purpose of communicating information about our products, services, events and for other promotional purposes. Personal data used to operate, improve and maintain our business, products and services may be retained for the duration of the provision of the products or services, and for no longer than the applicable statute of limitations thereafter. We will retain your personal data for no longer than three years starting from the date of its collection for general research and analysis purposes.

 

Are you allowed to access, modify or erase your Personal Data? 

You have the right to access, modify, erase, request the restriction or oppose the processing of your personal information or request the portability of the personal data you contributed, without any expenses and at any moment, and you may request from us to erase your personal data on your behalf. Where the collection and processing of your personal data is based on your consent, you have the right to withdraw your consent with respect to our use of your personal data. 

You also have the right to lodge a complaint with the competent supervisory authority.
We are not responsible for third parties who have had access to your data from any other source other than our database and if they do not suppress your details from their databases.

We do not guarantee that our services will be available continuously. In case of an interruption of service, we are not responsible for the possible loss of your personal data.
We reserve the right to erase your details without your consent and we are not responsible for the possible loss or suppression of your personal data.

To opt-out of receiving Solvay communication, please click on “unsubscribe” at the bottom of one of our emails. 

You can contact us to exercise your rights via the contact details in the “Questions and Feedback” section below or by sending an email to privacy@solvay.com.

 

How do we use Cookies and Pixel Tags

Solvay receives and records information, which may include personal data, from your browser when you use our Websites. We use a variety of methods, such as cookies and pixel tags to collect this information, which may include your (1) IP-address; (2) unique cookie identifier, cookie information and information on whether your device has software to access certain features; (3) unique device identifier and device type; (4) domain, browser type and language, (5) operating system and system settings; (6) country and time zone; (7) previously visited websites; (8) information about your interaction with our Websites such as click behavior, purchases and indicated preferences; and (9) access times and referring URLs.

Our sites use cookies technology. Cookies are small text files that contain a small amount of information that is downloaded on your device when you visit a website or an application. Cookies are then sent back to the original website or application or to other websites or applications that recognize those cookies upon each subsequent visit. Cookies are useful because they allow a website or application to recognize your device and to put this information in connection with other information about you. Certain cookies will be sent to your device when you visit our sites, subject to your consent where required.

Cookies perform multiple functions, such as allowing you to navigate between pages efficiently, remembering your preferences, push personalized information based on your browsing history, and more generally improving your user’s experience. We use cookies for session management in order to authenticate visitors and to keep information such as visitors’ country, language and other preferences. This enables us to provide services to our customers and improve their online experience. All session cookies are temporary and expire once the session is closed or expired.

The use of cookies may involve a treatment of personal data. However, most cookies do not collect information that identifies you directly but instead collect general information such as how you arrived on a website and how you used the website.

We use analytics cookies and pixel tags to obtain aggregate data about site traffic and site interaction, to identify trends and obtain statistics which help us collect information on how users use our site.  We use the information we get from such cookies to improve our Websites and services. These cookies may be used to count the number of visitors to the Websites, to determine the most viewed pages or to analyze user behavior (e.g. visit duration, consulted pages, referring pages). These data are used to calculate statistics. Thanks to these statistics, we know how to improve our Websites and how to provide you with better services. To opt-out of the use of these analytics cookies, please use this link: https://preferences-mgr.truste.com.

Pixel tags (also called web beacons or web bugs) are typically used by a third party to monitor the activity of a website. A pixel tag can be detected by viewing the source code of a web page and looking for any IMG tags that load from a different server than the rest of the website. Turning off the browser's cookies will prevent pixel tags from tracking the user's activity. The pixel tag will still account for an anonymous visit, but the user's unique information will not be recorded.

We use ‘social buttons’ to enable our users to share web pages. These are buttons for third party social media sites. Through these social buttons, these sites may collect personal data about you such as log information about your activities on the Internet. Please review the respective terms of use and privacy policies of these sites to understand exactly how they use your information and to find out how to opt-out, or delete, such information.

Browsers are usually set to accept cookies. If you do not agree, in whole or in part, with our use of cookies as described in this Policy, you can disable them or otherwise change your device or browser settings so that cookies, or certain types of cookies, cannot be placed on your device anymore. You can also delete cookies already in place on your hard drive if you wish. 

Please note that cookies may be necessary to provide you with certain features (e.g. customized delivery of information) available on our sites and that the blocking of certain cookies may limit your use of our Websites. However, please note that disabling a cookie or category of cookie will not delete an existing cookie from a browser, so this will need to be done separately from within your own browser.

By using the Websites, you accept that we use cookies in accordance with this Policy and with the settings of your device or browser.

 

Changing Your Cookie Settings on Your Browser

While we provide the means to opt-out from the use of cookies above, for a comprehensive and up-to-date summary of every third-party accessing your web browser (through Solvay Websites or otherwise), we recommend installing a web browser plugin built for this purpose. You can also choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings on each browser and device that you use. Each browser is a little different, so look at your browser Help menu to learn the correct way to modify your cookies. If you turn cookies off, you may not have access to many features that make our Websites more efficient and some of our services will not function properly.

 

Using Solvay Websites with Third-Parties

Our Websites allow you to interact with a wide variety of other digital products and services. For example, our Websites can integrate with third-party platforms to improve your overall digital experience. Your privacy rights on third-party platforms will be governed by their respective policies. The policies of those platforms govern the data that resides there.

Our Websites may provide links to other (third-party) websites and apps for your convenience or information. Linked sites and apps have their own privacy notices or policies, which we strongly encourage you to review. To the extent any linked websites or apps are not owned or controlled by us, we are not responsible for their content, any use of the websites, or the privacy practices of the websites.

 

Children

Solvay does not knowingly collect personal data from children without insisting that they seek prior parental consent if required by applicable law.

 

Changes to Solvay’s Privacy Policy

Applicable law and our practices change over time. If we decide to update our Policy, we will post the newest version on our Websites. We strongly encourage you to read our Policy and regularly check for any changes.

 

Questions and Feedback

If you have any questions, remarks or suggestions about this Privacy Statement and the practices of the Websites, please contact Solvay’s Data Protection and Privacy Office who will redirect you, if applicable according to local legal requirements, to the Data Protection Officer in your country, by sending us an email at privacy@solvay.com