Data Protection Policy
1. General remarks
Armacell (the Company) is committed to protecting the privacy of your personal information. For the purpose of applicable data protection law, in particular the General Data Protection Regulation (Regulation (EU) 2016/679) (“DP Law”), the Company is the data controller. You will see the Company referred to as Armacell International S.A., Armacell GmbH, and other group entities on the site. Our Privacy Notice explains what we do with any personal information which we collect from you, including when you use our website and when you interact with us in other ways. If you have any questions regarding our Privacy Notice, please contact us at the address on the Contact Us page of this site (see Sec. 18).
This Data Protection Policy explains how we process, e.g. collect, use and disclose, your personal information when you visit the site and when you contact us, whether by email, post, fax or telephone using the contact options on the site. The information you provide to us may then be shared with other companies in the Armacell group (“Group”) provided we have a legal basis for such transfer. Where we refer to the Company, this will also include the Group unless we explain otherwise.
- We only collect personal information about you where it is necessary or you have consented, and we ensure that we only collect information that we need.
- We will not send you marketing material unless you have given us permission to do so or we may do so under the applicable law.
- We will not sell your personal information to third parties.
- We use third-party suppliers to help us provide an excellent service to you. Where we share personal information with those suppliers, we have the appropriate contracts and/or controls in place, which will assess the security of their processing arrangements.
- We protect your personal information with an appropriate combination of technical and organisational measures.
- We may record and monitor our calls with you, for the reasons listed in Section 3.
- We retain your data for as long as is necessary. Please see Section 9.
- You have the rights to your information. These are detailed in Section 13.
- If you have a complaint, please see Section 15 and Section 18.
2. What type of personal information do we collect?
The personal information we collect from you is used primarily to enable us to provide the specific service you require, securely.
Personal information can include the following:
- your title, forename and surname;
- your personal or work related (depending on which you choose to submit) e-mail address;
- your personal or work related contact details (depending on which you choose to submit) such as your telephone number(s), fax numbers and postal address;
- employer details and occupation;
- your contact and marketing preferences;
- if you take a survey or interact with us in various other ways, demographics information and information about subjects that may interest you;
- information necessary for legal compliance; and/or
- Your electronic identification data such as Internet Protocol (IP) address, website connection history and website journey.
3. The legal basis for our use and other processing of your personal information under DP Law
This will include (as relevant):
- processing your personal information so that we may perform our obligations under a contract with you, based on Art. 6 (1) lit. b GDPR (details see below under “Your Contract”);
- processing for legitimate interests provided these are not overridden by your interests and fundamental rights and freedoms (this includes our own legitimate interests and those of other entities in our group of companies), based on Art. 6 (1) lit. f GDPR (details see below under “Legitimate Interests”);
- processing which is necessary for compliance with our legal obligations laid down by European Union law (where relevant) and by English Laws applicable to Armacell in the United Kingdom, based on Art. 6 (1) lit. c GDPR (details see below under “Our Legal Obligations”);
- Your consent may also be a lawful reason for processing your personal data in certain cases, based on Art. 6 (1) lit. a GDPR (details see below under “Your Consent”). This means your freely given, specific, informed and unambiguous consent which may be collected from you, for instance: when you agree to receive marketing communications from us or when you agree to take part in surveys or market research (as relevant). You should be aware that you are entitled under DP Law to withdraw your consent where you have given it to us at any time. If you do this and if there is no alternative lawful reason for us to rely on to justify our processing of your personal data, this may affect our ability to provide you with some of our services.
In summary, we need certain categories of personal data in order to provide you with our products and services. Certain other personal data is processed for our Legitimate Interests in cases where this does not result in prejudice to you. Certain other personal data is processed based on your consent.
4. What other personal information do we collect and why?
In this section we explain the personal information we collect from you when you interact with us online and offline. Where we explain why we use this information, we have also referred to the relevant legal basis which we consider applies to the processing, as explained in the section above. Presenting the information in this way will make it easier for you to understand your rights in relation to your personal information, and this is explained further below in the sections headed “Your rights to access your personal information” and “Your rights under DP Law”.
We automatically collect standard internet and website log information to understand how our website visitors behave, which we use to improve your experience online. This may include information about your Internet Service Provider, your operating system, browser type, domain name, the Internet Protocol (IP) address of your computer (or other electronic Internet-enabled device), your access times, the website that referred you to us, the web pages you request and the date and time of those requests, the type of device you used.
When you use any of the services below, you may need to provide us with some additional personal information so that we can liaise with you in order to deal with your request or query. If you do choose to provide us with your personal information, we will collect that information for the use and the purposes described in this Notice, in particular:
- contact us by email using the information on our websites;
- create an ArmaPlus Key account;
- be notified of products and/or services that may be of interest to you based on your purchase history, subject to the restrictions detailed in Sec. 12 below.
Our Legal Obligations and/or Legitimate Interests
- we may also record phone conversations to offer you additional security, resolve complaints, for staff training purposes and to improve our service standards.
- sign up to receive our various newsletters by email or generally be notified of products and/or services that may be of interest to you.
5. How we use your personal information
We have explained below the purposes for which we may use information about you. As with the section above, we have explained why we use your information with reference to the relevant legal basis. Presenting the information in this way will make it easier for you to understand your rights in relation to your personal information, and this is explained further below in the sections headed “Your rights to access your personal information” and “Your rights under DP Law”:
We may use your personal information for the following legitimate interests:
- to respond and/or deal with your request or enquiry;
- to improve our products and services and to ensure that content from the websites is presented in the most effective manner for you and for your computer (or other electronic Internet-enabled device);
- to administer the websites;
- to contact you (directly, either by the Company, Group or through a relevant partner or agent) by e-mail or phone for any of the above reasons, subject to the restrictions as detailed in Sec. 12 below;
- where necessary as part of any restructuring of the Company or sale of the Company's business or assets;
- to analyse trends and website user journeys in using and accessing our websites;
- monitoring and recording of telephone calls and email communications where necessary for compliance with regulatory rules or self-regulatory practices or procedures relevant to our business, for quality, training and security purposes.
- to perform any contract the Company has with you;
- for internal record keeping.
- subject to your consent where required under applicable laws, to carry out direct marketing (via telephone or postal mail) and/or e-mail marketing; see sec. 12 for details.
Our Legal Obligations
- for compliance with our legal and regulatory obligations.
This list is not intended to be exhaustive and may be updated from time to time as business needs and legal requirements dictate. Some of the personal information that we maintain will be kept in paper files, while other personal information will be included in computerised files and electronic databases.
When you visit one of our webpages, we may file information on your computer in the form of a cookie. Cookies are small text files which are sent by a web server to your browser and stored on the hard disk of your computer. For this purpose, also tracking-pixel may be used that help to recognize a user’s device in a similar manner. When using the term “cookie”, this refers to cookies in the technical sense as well as tracking pixel and other technologies.
Apart from the internet protocol address no personal data concerning the user is stored. We use session cookies that are required to operate the website and provide a service requested by you (these are referred to as “cookies necessary for technical purposes”). E.g. this information serves to recognise you automatically when you visit sub-websites or our website and to make navigation easier for you. For example, cookies allow us to adapt a website to your interests and language preferences or – to the extent required – to save your password so that you do not need to enter it again each time.
You can also view our websites without cookies. If you do not want us to recognise your computer you can prevent cookies being stored on your device by selecting “do not accept cookies” in your browser settings. Please see your browser manufacturer’s instructions for more details on how to do this. Please note that deactivating cookies in total (hence also the above mentioned cookies necessary for technical purposes) may limit the functions our website offers.
7. Google Analytics
Our website uses Google Analytics, a web analysis service provided by Google Inc. (“Google”). Google Analytics also uses so-called “cookies” (see Section 6), text files which are stored on your computer and enable an analysis of the use of the website.
The information generated by the cookie on your use of this website is transmitted to a Google server in the USA and stored there. The information does not contain any personal data and will not be used to identify you. In particular, your IP address will not be saved completely, but rather anonymised by deleting the last digits of the IP address.
Google uses this information to analyse your use of the website in order to compile reports on website activities for us and provide further services connected with website and Internet use. Google will pass this information on to third parties if this is required by law or if third parties process this information on Google’s behalf. Under no circumstances will Google create a connection between your IP address and other data stored by Google.
You can revoke your given consent into the use of Google Analytics with future effect and prohibit the future collection and storage of data at any time by deleting all cookies and deactivating the future saving of cookies by using the respective settings on the browser you are using or by using Google Analytics’s deactivation add-on (http://tools.google.com/dlpage/gaoptout?hl=en) if this is available for your browser.
8. Data Anonymisation
We may convert your personal data into statistical or aggregated data in such a way as to ensure that you are not identified or identifiable from that data. We may use this aggregated data to conduct market research and analysis, including to produce statistical research and reports. For example, we may produce reports on which of our product and services are most popular. We may share aggregated data in several ways, including for the same reasons as we might share personal data (see below).
9. How long do we keep your personal information for (and what’s the criteria used to determine this)?
Your personal data will not be kept for longer than is necessary to fulfil the specific purposes outlined in this Notice and to allow us to comply with our legal requirements.
The criteria we use to determine data retention periods includes the following:
(i) Retention in case of queries. We may retain it for a reasonable period (up to 24 months) after you have enquired regardless of the reason why you contacted us.
(ii) Retention in accordance with legal and regulatory requirements. We may further retain your personal data for a longer period because of a legal or regulatory requirement. Some or all of these criteria may be relevant to retention of your personal data collected in connection with our products and services.
If you would like further information about our data retention practices please contact us (see below).
10. Does the Company share my personal information with third parties?
Your personal information will be made available within the Company for the purposes mentioned above (or as otherwise notified to you from time to time), on a ‘need-to-know’ basis and only to responsible management, accounting, legal, logistics, audit, compliance, information technology and other corporate staff who properly need to know these details for their functions within the Company. Please note that certain individuals who will see your personal information may not be based at the Group or in your country (please see below).
We may share personal information within the Group as needed for reasonable management, service offering, order or customer request fulfilment and for use by those companies for the other purposes described in this Notice.
Your personal information may also be made available to third parties (within or outside the Company or Group) providing relevant services under contract to the Company, or the Group (see below for further details) to help us provide our services and products to you. Third parties in this context means other corporate entities within the group, providers to the Company or Group of responsible management, accounting, legal, logistics, audit, compliance, information technology, marketing and other services. This may also include providers of data storage and database hosting services, IT hosting and IT maintenance services. These companies may use information about you to perform functions on our behalf.
We will not sell your personal information to any third party other than as part of any restructuring of the Company or Group or sale of a relevant Group business.
We may disclose specific information about you upon lawful request by government authorities, law enforcement and regulatory authorities where required or permitted by law.
11. Will my personal information be transferred abroad?
We have explained above how your personal information may be shared outside of the Company and the Group. As part of this, including for instance where we work with service providers, your personal information may be transferred to countries outside the European Economic Area (EEA) which do not have equivalent standards of protection under their legislation and on these occasions we take other steps to protect the data as required under DP Law. When we do transfer your data outside of the EEA, we ensure that any party with access to your information has implemented the necessary security and privacy measures, to ensure that your personal data is kept secure and confidential as outlined in this policy. You may obtain more details and a copy of the appropriate or suitable safeguards we employ by contacting us under the contact details provided in Sec. 14.
12. Managing your marketing preferences
We may wish to provide you with information about new products, services, promotions and offers, which may be of interest to you. We may also invite you to take part in market research or request feedback on our products and services. This communication may occur by email, telephone, post or SMS. We will seek your consent for this where necessary under DP Law.
You have the right to object to the processing of your personal data for marketing purposes at any time; such direct marketing may include profiling to the extent that it is related to such direct marketing (Art. 21 (2) GDPR). This means inter alia that you can change your mind about receiving marketing communications from us when you have previously consented to this. You can, for example, opt-out of receiving such communications by clicking the “unsubscribe” link on any email that we send to you.
Please note that marketing communications are not the same as “information only” communications and that consents are not usually required in order for us to communicate with you about the products or services you have enquired, using contact details you have provided for this purpose.
We use links to other internet presences of us on websites and services of third parties, e.g. to social media channels such as Facebook, Twitter or Youtube. These third parties are exclusively responsible for the data processing by such other service providers on their websites and their data protection notices apply.
14. Your rights under DP law
You have a number of other rights in respect of your personal information under applicable DP Law. These may include (as relevant):
- the right to access or obtain copies of your personal information that we hold (Art. 15 GDPR);
- the right to rectification, including to require us to correct inaccurate personal data (Art. 16 GDPR);
- the right to request the erasure of your personal data where it is no longer necessary or legally mandatory for us to retain it (Art. 17 GDPR);
- the right to request restriction of processing concerning your personal data (Art. 18 GDPR);
- the right to data portability for the information you have provided to us, including to obtain personal data in a commonly used machine readable format in certain circumstances (Art. 20 GDPR);
- the right to object to a processing on the basis of legitimate interest, in which case we are entitled to demonstrate our compelling reasons (Art. 21 para. 1 GDPR);
- the right to object at any time to the processing of your data for direct marketing purposes (Art. 21 para. 2 and 3 GDPR);
- the right to object to automated decision making including profiling (if any) that has a legal or significant effect on you as an individual (Art. 22 GDPR); and
- the right to withdraw your consent to any processing for which you have previously given that consent (Art. 7 (3) GDPR).
To exercise your right to access your personal data, please write to: Data Protection Officer, Armacell GmbH, Robert-Bosch-Straße 10, 48153 Münster, Germany or via e-mail at dpo.eu(at)armacell.com.
15. Your right to complain to the data privacy supervisory authority
Without prejudice to any other administrative or judicial remedy you might have, you have the right to lodge a complaint with the competent Data Protection Authorities if you consider that we have infringed applicable data privacy laws when processing your personal data. European Data Protection Authorities can be contacted using the following link: http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.
16. Keeping you informed
We will keep your details on record until we have completely dealt with your request, enquiry or application and then for a reasonable period afterwards, in accordance with data protection and other applicable legislation.
The Company may keep your details on record for as long as is necessary for the purposes set out above and will then endeavour to delete your details in accordance with data protection and other applicable legislation.
17. Changes to this notice
We keep this Notice under regular review. We may change this Notice from time to time by updating this page in order to reflect changes in the law and/or our privacy practices. The date at the top of this Notice will be updated accordingly and we encourage you to check this from time to time for any updates or changes. Where you have provided us with your email address, we may also contact you to let you know that we have updated the Notice. We may also take that opportunity to ask you if you would like to update your marketing preferences.
This Notice does not extend to your use of, provision of data to and collection of data on any website not connected to us to which you may link to by using the hypertext links within our websites.
18. Contact/address details
If you have any questions about this Notice, please contact us.