Privacy Policy

Privacy Policy of www.imerys-graphite-and-carbon.com

Some Personal Data of the users of this website are collected by its owner.

Imerys Graphite & Carbon Ltd (hereinafter “the Owner”) is the Owner of its website, and it pays particular attention to protecting the personal data of each user of its website. The Owner undertakes to provide the highest level of protection in order to comply with the Swiss Federal Act on Data Protection (hereinafter “FADP”) of 19th June 1992 (as amended), and the European Regulation 2016/79 of 27th April 2016 (hereinafter “GDPR”). The Owner has therefore implemented procedures aimed at meeting the requirements set forth by said regulations, and in particular the GDPR.

The present privacy policy exposes how the Owner uses the personal data it collects from the users of its website.

This document has a section dedicated to Californian consumers and their privacy rights.

This document can be printed for reference by using the print command in the settings of any browser.

Owner and Data Controller

Imerys Graphite & Carbon Ltd
Str. Industriale 12
6743 Bodio

Switzerland

Owner contact email: graphiteandcarbon.ch@imerys.com

Types of Data collected

Among the types of Personal Data that the Owner collects, by itself or through third parties, there are: Cookies; Usage Data; first name; last name; company name; country; email address; phone number, various types of Data; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example).

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.

Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this website.

Users are responsible for any third-party Personal Data obtained, published or shared through this website and confirm that they have the third party’s consent to provide the Data to the Owner.

How do we collect your Data ?

By using the contact form on the website.
By using or view or website via your browser’s cookies.
By providing feedback on our message boards or via emails.
By registering online or placing an order for any of our product and services.

How we will use your data?

  1. General Section

To process your orders.
To deal with your enquiries and requests.
To have a better assessment of the user’s needs.
To send marketing communications.

In particular, where you have agreed to a particular use of your data (for marketing purposes, e.g.), we process your data on the base of your consent. You may withdraw that consent at any time by contacting us. See our contact details below.

In particular, the Owner may process Personal Data relating to users of the website if one of the following applies:

  • users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to GDPR;
  • provision of data is necessary for the performance of an agreement with the user and/or for any pre-contractual obligations thereof;
  • processing is necessary for compliance with a mandatory legal obligation to which the Owner is subject (Swiss executive judicial or administrative order);
  • processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract. Form more clarification requests, please contact us (see our contacts details below).

For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.

  1. Detailed Section

Personal Data is collected for the following purposes and using the following services:

  • Advertising
    This type of service allows User Data to be utilized for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on this Application, possibly based on User interests.
    This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
    Some of the services listed below may use Cookies or other Identifiers to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside this Application. For more information, please check the privacy policies of the relevant services.
    In addition to any opt-out feature offered by any of the services below, Users may opt out by visiting the Network Advertising Initiative opt-out page.
    Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.
    Google Ad Manager
    Google Ad Manager is an advertising service provided by Google LLC or by Google Ireland Limited, depending on the location this Application is accessed from, that allows the Owner to run advertising campaigns in conjunction with external advertising networks that the Owner, unless otherwise specified in this document, has no direct relationship with. In order to opt out from being tracked by various advertising networks, Users may make use of Youronlinechoices. In order to understand Google’s use of data, consult Google’s partner policy.
    This service uses the “DoubleClick” Cookie, which tracks use of this Application and User behavior concerning ads, products and services offered.   Users may decide to disable all the DoubleClick Cookies by going to: Google Ad Settings.
    Personal Data processed: Cookies; Usage Data.
    Place of processing: United States – Privacy Policy; Ireland – Privacy Policy. Privacy Shield participant.
    Category of personal data collected according to CCPA: internet information.
    This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.
    Google Ads Similar audiences
    Similar audiences is an advertising and behavioral targeting service provided by Google LLC or by Google Ireland Limited, depending on the location this Application is accessed from, that uses Data from Google Ads Remarketing in order to display ads to Users with similar behavior to Users who are already on the remarketing list due to their past use of this Application.
    On the basis of this Data, personalized ads will be shown to Users suggested by Google Ads Similar audiences. Users who don’t want to be included in Similar audiences can opt out and disable the use of advertising cookies by going to: Google Ad Settings.
    Personal Data processed: Cookies; Usage Data.
    Place of processing: United States – Privacy PolicyOpt Out; Ireland – Privacy PolicyOpt Out. Privacy Shield participant.
    Category of personal data collected according to CCPA: internet information.
    This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.
  • Analytics
    The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
    Google Analytics (Google Ireland Limited)
    Google Analytics is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services.
    Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
    Personal Data processed: Cookies; Usage Data.
    Place of processing: Ireland – Privacy PolicyOpt Out. Privacy Shield participant.
    Category of personal data collected according to CCPA: internet information.
    This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.
    Google Ads conversion tracking (Google Ireland Limited)
    Google Ads conversion tracking is an analytics service provided by Google Ireland Limited that connects data from the Google Ads advertising network with actions performed on this Application.
    Personal Data processed: Cookies; Usage Data.
    Place of processing: Ireland – Privacy Policy. Privacy Shield participant.
    Category of personal data collected according to CCPA: internet information.
    This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.
    Google Analytics Advertising Reporting Features
    Google Analytics on this Application has Advertising Reporting Features activated, which collects additional information from the DoubleClick cookie (web activity) and from device advertising IDs (app activity). It allows the Owner to analyze specific behavior and interests Data (traffic Data and Users’ ads interaction Data) and, if enabled, demographic Data (information about the age and gender). Users can opt out of Google’s use of cookies by visiting Google’s Ads Settings.
    Personal Data processed: Cookies; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); various types of Data as specified in the privacy policy of the service.
    Place of processing: United States – Privacy PolicyOpt Out; Ireland – Privacy PolicyOpt Out. Privacy Shield participant.
    Category of personal data collected according to CCPA: identifiers; internet information.
    This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.
  • Backup saving and management
    This type of service allows the Owner to save and manage backups of this Application on external servers managed by the service provider itself. The backups may include the source code and content as well as the data that the User provides to this Application.
    Backup on Google Drive (Google Ireland Limited)
    Google Drive is a service to save and manage backups provided by Google Ireland Limited.
    Personal Data processed: various types of Data as specified in the privacy policy of the service.
    Place of processing: Ireland – Privacy Policy. Privacy Shield participant.
    Category of personal data collected according to CCPA: internet information.
  • Contacting the User
    Contact form (this Application)
    By filling in the contact form with their Data, the User authorizes this Application to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.
    Personal Data processed: company name; country; email address; first name; last name.
    Category of personal data collected according to CCPA: identifiers; commercial information.
  • Data transfer outside the EU
    The Owner is allowed to transfer Personal Data collected within the EU to third countries (i.e. any country not part of the EU) only pursuant to a specific legal basis. Any such Data transfer is based on one of the legal bases described below.
    Users can inquire with the Owner to learn which legal basis applies to which specific service.
    Data transfer abroad based on consent (this Application)
    If this is the legal basis, Personal Data of Users shall be transferred from the EU to third countries only if the User has explicitly consented to such transfer, after having been informed of the possible risks due to the absence of an adequacy decision and appropriate safeguards.
    In such cases, the Owner shall inform Users appropriately and collect their explicit consent via this Application.
    Personal Data processed: various types of Data.
    Category of personal data collected according to CCPA: internet information.
  • Remarketing and behavioral targeting
    This type of service allows this Application and its partners to inform, optimize and serve advertising based on past use of this Application by the User.
    This activity is facilitated by tracking Usage Data and by using Cookies and other Identifiers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity.
    Some services offer a remarketing option based on email address lists.
    In addition to any opt-out feature provided by any of the services below, Users may opt out by visiting the Network Advertising Initiative opt-out page.
    Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.
    Google Ad Manager Audience Extension (Google Ireland Limited)
    Google Ad Manager Audience Extension is a remarketing and behavioral targeting service provided by Google Ireland Limited that tracks the visitors of this Application and allows selected advertising partners to display targeted ads across the web to them.
    Personal Data processed: Cookies; Usage Data.
    Place of processing: Ireland – Privacy PolicyOpt Out. Privacy Shield participant.
    Category of personal data collected according to CCPA: internet information.
    This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.
    Google Ads Remarketing
    Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google LLC or by Google Ireland Limited, depending on the location this Application is accessed from, that connects the activity of this Application with the Google Ads advertising network and the DoubleClick Cookie. Users can opt out of Google’s use of cookies for ads personalization by visiting Google’s Ads Settings.
    Personal Data processed: Cookies; Usage Data.
    Place of processing: United States – Privacy PolicyOpt Out; Ireland – Privacy PolicyOpt Out. Privacy Shield participant.
    Category of personal data collected according to CCPA: internet information.
    This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

 

How do we store your data ?

The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located, .
Or in alternative:
All personal data is hosted by the company ………………. ., to be considered Data Processor for said activity carried out for the Owner.
Personal Data is stored, hashed, and anonymized by said company, in using their module ………………….. . The Owner requires from ……………., as Data Processor, full compliance with the GDPR.

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the data.

The data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the data may be accessible to certain types of persons in charge, involved with the operation of this website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner.

Due to its activity covering a number of countries, the Owner may be led to transfer your Personal Data to foreign countries, including countries which are considered to be “non-adequate” by European Union bodies. In this case, the Owner ensures that the necessary guarantees are put in place to maintain a level of protection that is equivalent to that of the European Union.

Retention time: Personal Data shall be processed and stored for as long as required by the purpose they have been collected for. In particular Personal Data collected for purposes related to the performance of a contract between the Owner and the user shall be retained until such contract has been fully performed.

The Owner may be allowed to retain Personal Data for a longer period whenever the user has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

What are your Personal Data protecting rights?

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following:

  • Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
  • Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
  • Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
  • Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
  • Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
  • Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
  • Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
  • Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

What are cookies?

Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. When you visit our website, the Owners will collect information from you automatically through cookies or similar technology.

For further information, visit www.allaboutcookies.org

How do we use cookies?

The owner uses cookies in a range of ways to improve your experience on our website, including:

  • Keeping you signed in
  • Understanding how you use our website

What kind of cookies do we use?

There are a number of different types of cookies, however our website uses:

  • Functionality: the Owner uses these cookies so that we recognize you on your website and remember your previously selected preferences. These could include what language you prefer and location you are in. A mix of first-party and third-party cookies are used.
  • Advertising: the Owner uses these cookies to collect information about your visit to our website, the content you viewed, the links you followed, and information about your browser, device, and your IP address. The Owner sometimes shares some limited aspects of this data with third parties for advertising purposes. The Owner may also share online data collected through cookies with the Owner’s advertising partners. This means that when you visit another website, you may be shown advertising based on your browsing patterns on our website.

How to manage cookies

You can set your browser not to accept cookies, and our website tells you how to remove cookies from your browser. However, in a few cases, some of our websites features may not function as a result.

Privacy policies of other websites

Our website contains links to other websites. Our privacy policy applies only to our website, so if you click on a link to another website, you should read their privacy policy.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Application and/or – as far as technically and legally feasible – sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

Information for Californian consumers

This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).

The provisions contained in this section apply to all Users who are consumers residing in the state of California, United States of America, according to “The California Consumer Privacy Act of 2018” (Users are referred to below, simply as “you”, “your”, “yours”), and, for such consumers, these provisions supersede any other possibly divergent or conflicting provisions contained in the privacy policy.

This part of the document uses the term “personal information“ as it is defined in The California Consumer Privacy Act (CCPA).

Categories of personal information collected, disclosed or sold

In this section we summarize the categories of personal information that we’ve collected, disclosed or sold and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Personal Data” within this document.

Information we collect: the categories of personal information we collect

We have collected the following categories of personal information about you: identifiers, commercial information and internet information.

We will not collect additional categories of personal information without notifying you.

How we collect information: what are the sources of the personal information we collect?

We collect the above mentioned categories of personal information, either directly or indirectly, from you when you use this Application.

For example, you directly provide your personal information when you submit requests via any forms on this Application. You also provide personal information indirectly when you navigate this Application, as personal information about you is automatically observed and collected. Finally, we may collect your personal information from third parties that work with us in connection with the Service or with the functioning of this Application and features thereof.

How we use the information we collect: sharing and disclosing of your personal information with third parties for a business purpose

We may disclose the personal information we collect about you to a third party for business purposes. In this case, we enter a written agreement with such third party that requires the recipient to both keep the personal information confidential and not use it for any purpose(s) other than those necessary for the performance of the agreement.

We may also disclose your personal information to third parties when you explicitly ask or authorize us to do so, in order to provide you with our Service.

To find out more about the purposes of processing, please refer to the relevant section of this document.

Sale of your personal information

For our purposes, the word “sale” means any “selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating orally, in writing, or by electronic means, a consumer’s personal information by the business to another business or a third party, for monetary or other valuable consideration”.

This means that, for example, a sale can happen whenever an application runs ads, or makes statistical analyses on the traffic or views, or simply because it uses tools such as social network plugins and the like.

Your right to opt out of the sale of personal information

You have the right to opt out of the sale of your personal information. This means that whenever you request us to stop selling your data, we will abide by your request.

Such requests can be made freely, at any time, without submitting any verifiable request, simply by following the instructions below.

Instructions to opt out of the sale of personal information

If you’d like to know more, or exercise your right to opt out in regard to all the sales carried out by this Application, both online and offline, you can contact us for further information using the contact details provided in this document.

What are the purposes for which we use your personal information?

We may use your personal information to allow the operational functioning of this Application and features thereof (“business purposes”). In such cases, your personal information will be processed in a fashion necessary and proportionate to the business purpose for which it was collected, and strictly within the limits of compatible operational purposes.

We may also use your personal information for other reasons such as for commercial purposes (as indicated within the section “Detailed information on the processing of Personal Data” within this document), as well as for complying with the law and defending our rights before the competent authorities where our rights and interests are threatened or we suffer an actual damage.

We will not use your personal information for different, unrelated, or incompatible purposes without notifying you.

Your California privacy rights and how to exercise them

The right to know and to portability

You have the right to request that we disclose to you:

  • the categories and sources of the personal information that we collect about you, the purposes for which we use your information and with whom such information is shared;
  • in case of sale of personal information or disclosure for a business purpose, two separate lists where we disclose:
    • for sales, the personal information categories purchased by each category of recipient; and
    • for disclosures for a business purpose, the personal information categories obtained by each category of recipient.

The disclosure described above will be limited to the personal information collected or used over the past 12 months.

If we deliver our response electronically, the information enclosed will be “portable”, i.e. delivered in an easily usable format to enable you to transmit the information to another entity without hindrance – provided that this is technically feasible.

The right to request the deletion of your personal information

You have the right to request that we delete any of your personal information, subject to exceptions set forth by the law (such as, including but not limited to, where the information is used to identify and repair errors on this Application, to detect security incidents and protect against fraudulent or illegal activities, to exercise certain rights etc.).

If no legal exception applies, as a result of exercising your right, we will delete your personal information and direct any of our service providers to do so.

How to exercise your rights

To exercise the rights described above, you need to submit your verifiable request to us by contacting us via the details provided in this document.
For us to respond to your request, it’s necessary that we know who you are. Therefore, you can only exercise the above rights by making a verifiable request which must:

  • provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative;
  • describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We will not respond to any request if we are unable to verify your identity and therefore confirm the personal information in our possession actually relates to you.

If you cannot personally submit a verifiable request, you can authorize a person registered with the California Secretary of State to act on your behalf.
If you are an adult, you can make a verifiable request on behalf of a minor under your parental authority.
You can submit a maximum number of 2 requests over a period of 12 months.

How and when we are expected to handle your request

We will confirm receipt of your verifiable request within 10 days and provide information about how we will process your request.

We will respond to your request within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.

Our disclosure(s) will cover the preceding 12 month period.

Should we deny your request, we will explain you the reasons behind our denial.

We do not charge a fee to process or respond to your verifiable request unless such request is manifestly unfounded or excessive. In such cases, we may charge a reasonable fee, or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind it.

How to contact us

If you have any questions about the Owner’s privacy policy, the data we hold on you, or you would like to exercise one or more of your data protection rights, please do not hesitate to contact us:

Email us at: graphiteandcarbon.ch@imerys.com
Call us: +41 91 873 20 10
Or write to us at: Strada Industriale 12, 6743 Bodio, Switzerland

How to contact the appropriate authority

Should you wish to report a complaint or if you feel that the Owner has not addressed your concern in a satisfactory manner, you have the right to contact the supervisory authority (which, for instance, for France is the CNIL – www.cnil.fr ; for Italy the Garante per la protezione dei dati – www.garanteprivacy.it ; in Germany – Der Bundesbeaufratgte für den Datenschutz und die Informationsfreiheit – www.bfdi.bund.de ) to bring a complaint procedure concerning practices connected with the Owner management of Personal Data. In the above websites, in particular in that of CNIL, you will find also the competent supervisory authorities of your EU member state of residence, if different from France, Italy or Germany.

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