Overview

EcoPoxy Inc. and its affiliates (also known as "EcoPoxy", or "we" or "us") value your interest in our products and services and your use of https://www.ecopoxy.com/eu (the “Site”) and other sites and portals operated by Ecopoxy (collectively with the Site, the "Websites"). 

The protection of your privacy and personal data is an important concern to which we pay special attention in all our business activities which is why we have developed this privacy policy (the “Privacy Policy”). This page contains the Privacy Policy for the Websites, and for web applications, mobile applications, tools, forums, chatbots, or social media pages offered by EcoPoxy on the Websites, and for any online services offered by EcoPoxy, including but not limited to providing information on our various products such as epoxies for coatings, castings, laminating, adhesive, and metallic pigments; color glitters; and retail locations (together with the Websites, the “Service”).  

Personal data collected during the use of the Service is treated by us in accordance with the legal regulations valid for the countries/regions in which the Websites are maintained. However, the Websites may include links to other websites or applications which are not necessarily covered by the Privacy Policy. In this case, we recommend that you carefully read the privacy policies of those websites.

EcoPoxy is engaged in safeguarding the rights of individuals in accordance with the General Data Protection Regulation (reference EU2016/679) of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (the "GDPR"), as well as with each applicable national personal data protection law and regulation (collectively, "Data Protection Laws and Regulations").

 

Content of the Privacy Policy

The Privacy Policy will inform you about the personal data we collect when you access or use the Service; how we handle and disclose your data; how you can monitor the use and disclosure of your data; and how we safeguard your personal data.

By accessing or using the Service, you consent to the collection, use and disclosure of personal data by EcoPoxy in accordance with the Privacy Policy. You may choose not to provide us with personal information.  However, if you make this choice we may not be able to provide you with the application, service or information that you requested.

We recommend that you read the entire Privacy Policy to ensure that you are fully informed. However, you can access specific sections of the Privacy Policy based on the type of information you are looking for by clicking on the links below.   

1.     What do we mean by personal data?

2.     What are the purposes of the processing of your personal data?

3.     What personal data do we collect and use?

4.     With whom do we share your personal data?

5.     What is the basis for the processing of your personal data?

6.     How long will your personal data be stored?

7.     Will your personal data be transferred to a third country outside the European Economic Area (the “EEA”)?

8.     What are your rights and how do you exercise them?

9.     How can you withdraw your consent to the collection, use and/or disclosure of your personal data?

10.  To what extent will decision making be automated?

11.  How do we safeguard your personal data?

12.  Who do you contact if you have a question, complaint or claim regarding our compliance with the Privacy Policy?

13.  Do the Websites use cookies and, if so, what types of cookies are used and how can you manage them?

14.  Do we use third party advertising partners? If so, how can you opt out of targeted advertising?

15.  How can you unsubscribe from our commercial electronic messages such as messages regarding new products or services?

16.  If changes are made to the Privacy Policy, will I be notified? If so, how?

 

What do we mean by personal data?

Personal data is any information that relates to an identified or identifiable living individual. Different pieces of information, which collected together can lead to the identification of a particular person, also constitute personal data.

Personal data that has been de-identified, encrypted or pseudonymised but can be used to re-identify a person remains personal data and falls within the scope of the GDPR.

Examples of personal data:

·       a name and surname;

·       a home address;

·       an email address such as name.surname@company.com;

·       an identification card number;

·       location data (for example the location data function on a mobile phone);

·       an Internet Protocol (IP) address;

·       a cookie ID;

·       the advertising identifier of your phone;

 

What are the purposes of the processing of your personal data?

When accessing or using the Service, EcoPoxy will collect and process your personal data in conformity with the Privacy Policy. Your personal data may be used for the following purposes:

Marketing

We may use your personal data for marketing and promotional purposes, involving communications via email or equivalent electronic means.  For example, we may use your e-mail address, to send you news and newsletters, special offers, promotions, or to contact you regarding services or information that we believe will be of your interest.

We may also display advertising on the Websites or manage and serve our advertising on other sites. See Section 14 on targeted advertising and how you may opt out.

Website Browsers / Administration

We use your personal data for administrative purposes, including to enable us to better identify how our clients access and use the Service; to provide information to prospective partners, service providers, regulators and others; to implement and maintain security, anti-piracy, fraud prevention and other services designed to protect our clients, partners and us; and to enforce our policies, guidelines and processes.

Communication

We use your personal data to communicate with you, including responding to inquiries, comments, requests and/or complaints you submit to EcoPoxy.  We may also send emails, SMS, messages through social media accounts, newsletters, regular mail or other communications you have consented to receive from EcoPoxy.

Customer support service

We use your personal data for customer support service purposes, including providing the Service to you, for technical support or similar purposes and for establishing and managing customer accounts.

Research and development

We use your personal data for research and development purposes, including improving the Service, customer experience of the Service, and for other research and analysis dedicated to improving our products, services, business, operations and processes.

To protect us and others

When we reasonably believe it is necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of policies, terms and other policies.

Legal Compliance

We use your personal data to comply with applicable legal obligations, including responding to an authority or court order.

 

What personal data do we collect and use?

When you use or access the Service, EcoPoxy may collect and use any or all of the following personal data if the data is reasonably required to provide the Service to you:

·       name;

·       company name; and

·       any information generated as a result of using the Websites, such as IP address, the date and length of visit to the site, the pages you view etc. 

 

With whom we could share your personal data?

EcoPoxy may disclose your personal data to:

·       authorised persons working for or on behalf of EcoPoxy;

·       EcoPoxy Group and the affiliates of EcoPoxy, based on a need to know basis and for the purposes as stated in Section 2 of the Privacy Policy;

·       authorized persons working for or on behalf of EcoPoxy;

·       our agents, service providers and consultants (e.g., third party service providers and consultants who provide the variety of products and services that we need, such as procurement services, compliance and security services, etc.);

·       other authorized third parties in connection with a reorganization or sale of EcoPoxy business and/or assets; and

·       police or government authorities when necessary to comply with applicable law.

Canada, Switzerland and the United States of America are where most of Ecopoxy’s processing of personal data takes place and below is a list of countries/regions where EcoPoxy operates:

Austria, Belgium, Bulgaria, Croatia, Republic of Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, Australia, Brazil, Chile, Mexico, Costa Rica, Panama, New Zealand, Norway, Russia, Turkey, United Kingdom, Uruguay.

 

What is the basis for processing of your Personal Data?

We process your personal data in accordance with the provisions laid down in the GDPR and the applicable Data Protection Laws and Regulations. The legal bases for the processing of your personal data are:

·       processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract;

·       you have given consent to the processing of your personal data for one or more specific purposes;

·       processing is necessary for compliance with a legal obligation to which we are subject;

·       processing is necessary in order to protect your vital interests or of another natural person;

·       processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;

·       processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data.

 

For how long will your Personal Data be stored?

We treat and store your personal data for as long as it is necessary to fulfil our contractual and legal obligations. If your personal data is no longer required to fulfil contractual or legal obligations, it will be deleted, unless further processing is necessary, for example to preserve specific evidence under applicable Data Protection Laws and Regulations or in the context of prescription laws.

 

Will your personal data be transferred to a third country outside the EEA?

EcoPoxy processes your personal data mostly in the EEA.  Occasionally personal data is transferred to EcoPoxy affiliates on a need to know basis, including entities outside the EEA. This transfer is subject to appropriate confidentiality safeguards.

 

What are your rights and how to exercise them?

Under certain circumstances and in accordance with the GDPR, you have the following rights:

Right of Access
The right to make a written request for details of your personal data and a copy of that personal data.

Right to Rectification
The right to have inaccurate information about you corrected or removed.

Right to Erasure (‘Right to be Forgotten’)
The right to have some or all of your personal data erased.

Right to Restriction of Processing
The right to request that your personal data is only used for restricted purposes.

Right to Automated Decisions
The right to contest any automated decision made where such a decision is based solely on automated processing, including profiling, which produces legal effect concerning you or similarly significantly affects you, unless you have expressly consented to it or it is necessary for entering into, or performance of, a contract for the provision of services to you or otherwise authorized by applicable law. For more information on automated decision making, please see Section 10 of the Privacy Policy.

Right to Object
The right to object to processing of your personal data in cases where our processing is based on the performance of a task carried out in the public interest or we have let you know the processing is necessary for our or a third party’s legitimate interests.

Right to Data Portability
The right to ask for the personal data you have made available to us to be transferred to you or a third party in machine-readable format.

Right to Withdraw Consent
The right to withdraw any consent you have previously given us to handle your personal data. If you withdraw your consent, this will not affect the lawfulness of our use of your personal data prior to the withdrawal of your consent.

To exercise any of these rights, please contact us as provided in Section 12 of the Privacy Policy. These rights are not absolute and they do not always apply in all cases.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request in order to help us respond efficiently to your request.

You will not have to pay a fee to access your personal data (or to exercise any of the above rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

If you have any complaints regarding our privacy practices as data controller, you have the right to make a complaint at any time to your local Supervisory Authority. We would, however, appreciate the chance to deal with your concerns before you approach your Supervisory Authority so please contact us as provided under Section 12 of the Privacy Policy.

 

You may withdraw your consent to the collection, use or disclosure of your personal data by EcoPoxy at any time, subject to legal or contractual restrictions and reasonable notice.  In certain circumstances, your withdrawal of consent may result in the inability of EcoPoxy to continue providing aspects or optimization of the Service to you. Please contact EcoPoxy for more information regarding the implications of withdrawing consent.

 

To what extent will decision-making be automated including profiling?

As a matter of principle, we do not use fully automated decision-making processes. In the event that we use such processes in individual cases we will, if prescribed by law, specifically inform you of this and of your rights in this respect.

Your personal data will not be processed automatically with the objective of evaluating certain personal aspects (profiling). In the event that we should process your personal data with the objective of conducting profiling, we will, if prescribed by law, specifically inform you of this and of your rights in this respect.

 

Safeguarding Your Personal Information

EcoPoxy is committed to safeguarding your personal information. EcoPoxy uses appropriate security measures to protect personal data against risks such as loss or theft, unauthorized access, disclosure, copying, misuse, modification or destruction, and any other unlawful form of processing of the personal data in our possession regardless of the format in which it is held. The methods of protection and safeguards used by EcoPoxy include, but are not limited to:

● Administrative safeguards such as privacy and security policies and procedures, privacy and data protection training for EcoPoxy staff;

● Technical safeguards such as security testing, vulnerability scans, and technological measures, including the use of passwords, encryption, firewalls, and secure coding frameworks. For example, we use encryption technology, such as Secure Socket Layers, to secure personal data you submit to us and to prevent such information from being intercepted and read as it is transmitted over the Internet to our servers;

● Physical safeguards such as locked filing cabinets, and need-to-know access for EcoPoxy employees.

EcoPoxy also ensures that its employees with access to personal data are made aware of the importance of maintaining the confidentiality of personal information.

EcoPoxy takes care in disposing of or destroying personal data to prevent unauthorized parties from gaining access to the information.

While EcoPoxy is committed to safeguarding your personal data, we cannot ensure or warrant the security of any personal data we collect either directly or automatically from you, and you do so at your own risk.

EcoPoxy cannot guarantee that such personal data may not be accessed, disclosed, altered, or destroyed by breach of any of our security safeguards. To the degree that personal data is of a sensitive nature, in the event of a breach, there may be a risk of significant harm to you which includes bodily harm, humiliation, damage to reputation or relationships, loss of employment, business or professional opportunities, financial loss, identity theft, negative effects on the credit record and damage to or loss of property. 

EcoPoxy also cannot guarantee that information sent or received over the Internet is secure and does not make any representation or warranty concerning the security of personal data communicated to or from EcoPoxy via the Internet or regarding the interception by third parties. 

How can I contact EcoPoxy in respect of my personal data?

If you have any questions, complaints or claims about the our compliance with the Privacy Policy, such as the way your personal data has been processed, you can first contact EcoPoxy, which is available for queries or complaints, at the following e-mail address: info@ecopoxy.com or you can write to: EcoPoxy EU AG, Bahnhofstrasse 10, 6300 Zug. Switzerland.

Cookies

By continuing to browse the Websites, we understand that you accept the use of cookies. You may withdraw this consent at any time. You can also manage and control the cookies we use on our website by using cookie tools.

What are cookies?

Cookies are small text files that a website asks your browser to store on your computer or mobile device. Cookies are widely used to make websites work more efficiently by saving your preferences. They are also used to follow your internet use as you browse, make user profiles and then display targeted online advertising based on your preferences.

They ease navigation, and increase the user-friendliness of websites and applications. Cookies also help us to identify the most popular sections of the Websites. This enables us to provide content that is more accurately suited to your needs, and, in doing so, improve the Service. Cookies can be used to determine whether there has been any contact between us and your device in the past.

Personal details can be saved in cookies, provided that you have consented. For example, cookies may be used to facilitate secure online access so that you do not need to enter your user ID and password again.

Which cookies do we use?

Please find hereafter specific information for each cookie that we use on the Websites:

How can you disable or delete cookies?

If you choose not to accept cookies, you can still access and use the Websites. Most browsers automatically accept cookies. You can prevent cookies from being stored on your device by setting your browser to not accept cookies. The exact instructions for this can be found in the manual for your browser. You can delete cookies already on your device at any time. However, if you choose not to accept cookies that are strictly necessary for the provision of the Service provided by the Websites, it may result in a reduced availability of the Service.

For the purpose of statistical analysis, we use analytics tools such as Adobe Analytics, or Google Analytics. You may object at any time to the collection and analysis of statistical data regarding your access to and use of our Websites by contacting us using the “contact us” function within our Websites.

To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org.

  

Targeted Advertising and How You May Opt Out

We may use third party advertising partners such as advertising networks, exchanges, and social media platforms to display advertising on the Sites or to manage and serve our advertising on other sites. You have a variety of options to opt out of interest based advertising ranging from browser controls, add on utilities such as ad blockers, and other opt out tools.

Unsubscribe from Commercial Electronic Messages

If you no longer wish to receive commercial electronic messages from EcoPoxy regarding our new products or services, promotions or other similar communications, you may unsubscribe by clicking the "Unsubscribe" button in the footer of our marketing emails, or, contact us. Please note that, after you unsubscribe, EcoPoxy may still send electronic communications to you in certain limited circumstances, such as to provide you with Service notifications and billing information, or to provide information that EcoPoxy is legally obligated to provide you.  

Modification of the Privacy Policy

EcoPoxy will update the Privacy Policy from time to time in order to reflect the changes in our practices and services and also to remain compliant with the GDPR and Data Protection Laws and Regulations. We will inform you of any substantial modification in how we process your personal data. We may inform you of such modifications through the Service. For example, we may place a prominent notice on the Websites or e-mail you to let you know of an updated Privacy Policy.

The Privacy Policy was last updated in November 2020.