NEXEO SOLUTIONS, INC. PRIVACY STATEMENT
We value the privacy of our user’s (“you” or “your”) information and are always striving to make your experience better. This Privacy Statement describes our information practices and, in particular, how we collect, use and share the Personal Information, as defined herein, that we gather through our Services, as defined below.
This Privacy Statement applies to data collected on the Nexeo Solutions, Inc. and its subsidiaries and affiliates, including but not limited to Nexeo Solutions, LLC (“Nexeo”) website and associated digital properties that link to this Privacy Statement and through Nexeo’s interactive advertisements (the “Services”).
The Services do not include other Nexeo websites that do not link to this Privacy Statement and/or that have separate privacy statements tailored specifically for activity on those websites. If you have any questions about this Privacy Statement, please contact us through the options provided in the Contact Us section below.
By using the Services, you are consenting to the terms of this Privacy Statement.
Definition of Personal Information
We define the term “Personal Information” to mean any information that we directly associate with a specific person, or that reasonably can be used to identify a specific person. For example, this includes your name, home address, phone number, email address and any other information that we tie to these elements.
Personal Information does not include “aggregated information,” which is information that we collect about a group or category of persons or services. It also does not include “de-identified information,” which is information from which we or our agents have removed information that can be used to specifically identify a person. This Privacy Statement does not apply to our collection, use or disclosure of aggregated or de-identified information.
How We Collect and Use Personal Information
There are three categories of information that we collect through the Services.
1.Information You Provide
On some of our web pages you may be able to ask questions and register to receive information. On these pages, we will ask you for the Personal Information necessary for us to respond to you. If you opt not to provide us with Personal Information, you can still access our websites; however, you may be unable to participate in certain promotions or receive product information offered through the Services. Examples of Personal Information you may choose to provide include:
- Contact information, such as your name, address, e-mail address, and phone number, which we use to communicate with you and fulfill your requests;
- Shipping address and related transaction information, which we use to complete a transaction you have requested, fulfill your order, and deliver the products;
- Inquiries you make, including the content of your voice and email messages, which we use to respond to your inquiries
- Demographic information, including, but not limited to, information about your age, gender, zip/postal code, general preferences and interests, product preferences and transaction details, which we use to better understand and analyze our customer population, support our operations, including inventory and product management, to deliver relevant offers and ads, and to improve our products and services, including the Services; and
- Communication preferences, including marketing preferences, which we use to manage how we engage with you.
Referrals: Occasionally, you may have the opportunity to forward product sampling opportunities or other information on the website to friends, relatives, or other contacts or to send messages from the Services to friends, relatives, or other contacts. This referral information you provide to facilitate this communication is used on a one-time basis or stored only for analysis purposes, and is not further used by us to re-contact referred individuals, except in circumstances where we obtain consent from the people you have referred to receive communications from us.
2.Information Collected Automatically
We use various technologies to collect other types of data that do not directly reveal your identity (“Other Information”). If we associate Other Information with Personal Information, we will treat the combined information as Personal Information in accordance with this Privacy Statement.
Logging Functionality: As is true of most websites, we may collect certain information automatically, both directly and indirectly, and store it in log files. This information may include web log information (such as your web browser, operating system, pages visited, etc.), the date and time you visited our site, the pages you visited, the referrer (the website you came from), the type of browser you are using (e.g., Firefox, Chrome, Internet Explorer), the type of operating system you are using (e.g., Windows XP or Mac OS), and the domain name and address of your Internet Service Provider (e.g., AOL). We generally only use this data for purposes such as security, fraud detection and protecting our rights.
Cookies and Web Beacons: When you use the Services, we may collect Other Information about you through the use of “cookie” technology or with “web beacons” (also called “single-pixel gif” or “web pings”) or other similar technologies. We use this information to manage our websites and email messages and to collect and track information about you and your activities over time.
Cookies. When you use the Services, we may store some information on your computer in the form of a small text file, also called a “cookie.” Cookies help us in many ways to make your visit to our website more enjoyable and meaningful to you. For example, cookies avoid you having to log in every time you come back to one of our websites and they can store items in your shopping cart for later purchase. They also allow us to tailor a website or advertisement to better match your interests and preferences. Most browsers can be configured not to accept cookies or to indicate when a cookie is being sent. Our cookies cannot read data off of your hard drive, cannot read cookie files created by other websites and cannot track any Personal Information about you.
Most internet browsers allow you to remove or manage cookie functions and adjust your privacy and security preferences. For information on how to do this, access the “help” menu on your internet browser, or visit http://www.aboutcookies.org/how-to-control-cookies/. Please note, however, that disabling our cookies may result in a less enjoyable experience with the Services.
Web Beacons. Web beacons are site instrumentations that help us to determine, for instance, whether a page has been viewed or not and, if so, how many times. When you ask us to send you information on a promotion or a newsletter, we may use web beacons to establish how many of the e-mails are actually opened. In general, any electronic image viewed as part of a web page, including an ad banner, can act as a web beacon.
Analytics: We use analytics providers, such as Google Analytics, to help us evaluate and measure the use and performance of the Services. To opt out of the aggregation and analysis of data collected about you on the Services by Google Analytics, visit http://tools.google.com/dlpage/gaoptout and download and install the Google Analytics Opt-out Browser Add-on.
3.Information We Obtain from Third Party Sources
We may receive additional Personal Information from third party sources that we may append to existing user information, such as email and address verification. We use this supplemental information to better understand our consumers, deliver relevant offers and advertising and improve our operations, the Services and our advertising and marketing campaigns.
Additional Uses of Personal Information
In addition to the uses described above, we may use your Personal Information for the following purposes:
- Operating our business, delivering our products and services, managing your account, and for any other lawful, legitimate business purposes;
- Contacting you to respond to your requests or inquiries;
- Processing and completing your transactions, including, as applicable, order confirmation and delivering products or services;
- Providing you product or service alerts, new product or service announcements, savings awards and other information;
- Contacting you about programs, products or services that we believe may be of interest to you, or sharing with you special offers from other companies;
- Providing you with personally tailored promotional information, offers and other information;
- Conducting market research, surveys, and similar inquiries to help us understand trends and customer needs across product categories or customer groups;
- Alerting you about product safety announcements or recalls;
- Administering sweepstakes and promotions or contacting you regarding a contest prize;
- Preventing, investigating or providing notice of fraud, unlawful or criminal activity or unauthorized access to or use of Personal Information, our website or data systems; or to meet legal obligations; and
How We Share and Disclose Personal Information
We share your Personal Information with third parties only in the ways described in this Privacy Statement.
Service Providers: We may share your Personal Information with our vendors, contractors or partners (collectively, “Service Providers”) in connection with services that these Service Providers perform on our behalf or for your benefit. The services they provide for us include mailing product samples, contacting the winners of our contests, marketing, analytics, fulfilling orders, processing payment, verifying user data such as mailing addresses or preventing fraud.
Affiliates: We may share you information with affiliated legal entities within the Nexeo family of companies for purposes and uses that are consistent with this Privacy Statement.
Business Transfers: Your Personal Information may be disclosed as a part of a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets, and could be transferred to a third party as one of the business assets in such a transaction. It may also be disclosed in the event of insolvency, bankruptcy or receivership.
Your Ad Choices
We support the self-regulatory principles of the Digital Advertising Alliance (“DAA”). We work with a variety of advertisers, advertising networks, advertising services and analytics companies (“Ad Partners”) that use different technologies to collect data about your use of the Services (such as pages visited and ads viewed or clicked on) in order to deliver relevant advertising.
These technologies may include the placement on our Services of cookies or web beacons, and other data collection technologies by these Ad Partners to track how our Services are being used, to track where you go online and what you do after you leave our Services, to link various devices you may use and to serve you more relevant ads. These advertisements may appear on our Services or other internet services that you visit.
For more information about how Ad Partners use the information collected by the technologies on our Services and about your options not to accept cookies placed by some of these companies on our Services, please visit the DAA’s opt-out page. You may also opt out of additional third party advertising networks by going to the Network Advertising Initiative’s website and following the directions.
The opt-outs described above are device-and browser-specific and may not work on all devices. If you choose to opt out through any of these opt-out tools, this does not mean you will cease to see advertising. Rather, the ads you will see will just not be based on your interests. In addition, when you opt out of using one of these methods, our Ad Partners will continue to collect information for any other purpose permitted by the DAA’s rules. You can opt out of future information collection from our Services by ceasing use of the Services.
Please note that this Privacy Statement does not cover the practice of our Ad Partners. Nexeo does not have control over these third party technologies or the information contained in them.
Privacy of Children
This website is not designed for, or directed to, children under the age of 13 and we do not knowingly collect or solicit Personal Information from individuals in this age group. We encourage parents to take an active role in their children’s online activities and to talk with their children about disclosing personally identifiable information to websites. If a parent or guardian becomes aware that his or her child under 13 has provided Personal Information to us, we encourage the child’s parent or guardian to contact us through the options provided in the Contact Us section below to request that we remove the information from our systems.
Accessing and Updating Your Information
You may review or update your Personal Information by contacting us through the options provided in the Contact Us section below. We will retain your Personal Information for as long as your account is active or as reasonably useful for commercial purposes. We will retain and use your Personal Information as necessary to comply with our legal obligations or data retention policies, to resolve disputes and to enforce our agreements.
Links to Other Sites
The Services may contain links to websites operated by third parties. Please be aware that this Privacy Statement does not apply to, and we are not responsible for, the practices of third parties that collect your Personal Information. We encourage you to read the privacy statements for those linked websites to learn about their information practices.
Special Notice to Residents of the EU
Our EU Privacy Shield Statement applies to the Personal Information that we receive from citizens of the European Economic Area. We adhere to the principles of the Privacy Shield agreed upon between the United States of America and the European Union. For more information about the Privacy Shield principles, please visit https://www.privacyshield.gov.
Changes to this Privacy Statement
Managing Your Communication Preferences
If you have provided use with your contact information, we may send you email messages, direct mail offers or other communications regarding products or services, depending on the method of communication selected. You may ask us not to do so when you access the Services or change your preferences by updating any accounts you have with us. At any time, you may elect to discontinue receiving commercial messages from us by submitting an opt-out request to the contact information below or by following the instructions in the form of the communication you received, as described below.
Printed Materials: To opt out of receiving printed marketing materials at your postal address, such as advertisements or flyers, please write to us at the address in the “Contact Us” section below. Please be sure to include your name and mailing address exactly as they appear on the printed materials you received.
Emails: To opt out of receiving marketing materials via email, please send an unsubscribe request to the email address below or click on the unsubscribe link at the bottom of the email that was sent to you and follow the directions on the resulting web page.
How to Contact Us
If you have any questions or comments about this Privacy Statement or other privacy-related matters, you may contact us in the following ways:
Nexeo Communications & Corporate Affairs
3 Waterway Square Place, Suite 1000
The Woodlands, TX, USA 77380
NEXEO EU PRIVACY SHIELD PRIVACY STATEMENT
This EU Privacy Shield statement describes how we collect, use, and disclose personal information that we receive in the United States from the European Union (“Personal Data”). We adhere to the US-EU Privacy Shield Principles (“Privacy Shield”) of Notice, Choice, Onward Transfer, Security, Data Integrity, Access, and Recourse with respect the Personal Data. For further information about the Privacy Shield and to review our self-certification, please visit the U.S. Department of Commerce’s website at https://www.privacyshield.gov.
Categories of Individual Data Subjects We may obtain Personal Data in the United States about (i) website visitors, (ii) customers, suppliers, vendors and service providers, and (iii) our current and former EU employees. Our practices with respect to such Personal Data are described below.
Customers, Suppliers, Vendors and Service Providers We may obtain various types of Personal Data about employees and agents of our customers, suppliers, vendors, and service providers. Such data may include contact information (names, titles, addresses, phone and fax numbers, and e-mail addresses); information about products and services ordered or provided; financial and payment information; user IDs, passwords, and information collected through Internet-based and e-commerce activities, and other transaction-related data.
We may use Personal Data for legitimate business purposes, including delivery of products or services; to establish or maintain business relationships; to provide access to Internet-based and e-commerce activities; to perform accounting functions; satisfy our legal obligations; satisfy administrative functions; prevent prohibited or illegal activities, and enforce our legal agreements; and to conduct other activities as necessary or appropriate in connection with servicing and developing business relationships.
Employees and agents of our customers, suppliers, vendors, and service providers may contact us to access or correct Personal Data that we maintain about them by sending an e-mail to firstname.lastname@example.org, or by using the Contact Information section at the end of this EU Privacy Shield statement.
EU Employees We process Personal Data collected from our EU employees for business purposes, such as i) matters relating to day-to-day business operations, job functions, compensation, employee benefits, performance assessments, and training, ii) offering services and benefits to employees, iii) maintaining contact with current and former employees, and iv) compliance with our legal obligations.
Employees located in the EU should contact their local human resources manager to ask questions or obtain additional information about our practices with respect to Personal Data. Job applicants should also consult any additional terms that apply when they submit their applications or resumes.
Choice We will seek your consent prior to using the personal information in a manner incompatible with the purposes we describe in our EU Privacy Shield statement, purposes disclosed at the time of collection, or purposes subsequently authorized.
We will not transfer your data to third parties for purposes beyond the below mentioned without your express permission. We will request you to opt in for any transfer of information and if you choose not to provide that permission we will refrain from sending personal data to third parties for use outside of its intended purpose.
Other Necessary Disclosures and Onward Transfer We may disclose Personal Data to agents, suppliers, vendors, service providers, and subcontractors to perform services for legitimate business purposes. We require those organizations to protect Personal Data with appropriate safeguards as listed in the Privacy Shield Principles. Such organizations are prohibited by law or by contract from using Personal Data for purposes other than purposes disclosed at the time of collection, purposes disclosed in this EU Privacy Shield statement, or purposes subsequently authorized.
These organizations include financial institutions; human resources service providers; healthcare administrators; healthcare providers; employee stock plan administrators; database managers; customer service providers; and other organizations that provide financial services; accounting services, auditing services, actuarial services, tax preparation services, IT infrastructure, IT support, and IT development services, employee training services, customer relationship management services, and other technical, logistical, and administrative services. These organizations may perform functions such as fulfilling orders, analyzing data, providing training, administering and providing healthcare services, sending payment and wire transfers, providing customer service, providing IT support and systems management, and providing other financial, technical, logistical, or administrative functions.
We may disclose Personal Data in connection with the sale or transfer of all or part of its business. Personal Data disclosed for this purpose will still be protected in accordance with the relevant Privacy Shield Principles.
We may disclose Personal Data where required or permitted by law or by an order or requirement of a court, administrative agency, or other government entity, or by court rules concerning the production of records; where we have reasonable grounds to believe that use or disclosure is necessary to protect the rights, privacy, property, or safety of others; where we have reasonable grounds to believe that the information relates to breach of an agreement or violation of the law that has been, is being, or is about to be committed; or where it is necessary to enforce or apply our legal agreements, to pursue remedies, or to limit our damages.
Data Security and Data Integrity We take reasonable precautions to protect personal data on computer servers from loss, misuse and unauthorized access, disclosure, alteration, and destruction. We also make reasonable efforts to keep personal data reliable for its intended use, accurate, current, and complete. We retain information for as long as reasonably required for business purposes or to comply with our legal obligations.
Access At your request, we will provide you with reasonable access to your personal information, so that you can review what we have stored and, if you choose, request corrections to it. You may request access by writing to us at the address listed in the Contact Information section below. After you request access, we will provide the personal information that you request as soon as practically possible.
Recourse, Enforcement, Liability Please contact us with any questions or concerns related to this EU Privacy Shield statement by using the contact information given below. We will investigate and attempt to resolve complaints or disputes regarding personal information in accordance with this EU Privacy Shield statement. We are accountable for Personal Data that we receive under the Privacy Shield, including any Personal Data that we subsequently transfer to a third party as described in the Privacy Shield Principles. In particular, we remain responsible and liable under the Privacy Shield Principles if the third-party agents that we engage to process Personal Data on our behalf do so in a manner that is inconsistent with the Privacy Shield Principles, unless we are able to prove that we are not responsible for the event giving rise to the claim. We have agreed to participate in the dispute resolution procedures of the panel established by the EU data protection authorities (DPAs) to resolve disputes pursuant to the Privacy Shield Principles. For complaints that have not been satisfactorily addressed, you may contact the EU DPAs panel directly using the information provided at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. In the event that we or the assigned recourse mechanism is unable to resolve a complaint, binding arbitration may be pursued through the Privacy Shield Panel.
We are subject to the investigatory and enforcement powers of the Federal Trade Commission (“FTC”). Subsequently, we may be required to disclose Personal Data that we handle under the Privacy Shield in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
We have elected to use the self-assessment method for verifying our compliance with the U.S. Department of Commerce Privacy Shield Program.
Nexeo Communications & Corporate Affairs
3 Waterway Square Place, Suite 1000
The Woodlands, TX, USA 77380