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.
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.
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.
(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:
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.
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
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.
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:
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.
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.
Solvay endeavors not to retain the Personal Information longer than is allowed under applicable laws.
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.
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
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.
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 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 email@example.com.
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.
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.
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.
Changing Your Cookie Settings on Your Browser
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.
Solvay does not knowingly collect personal data from children without insisting that they seek prior parental consent if required by applicable law.
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 firstname.lastname@example.org.