Privacy
RPM International Inc.
Privacy Notice
Last updated: January 1, 2025
QUICK LINKS
Personal information we collect
Cookies and tracking
How we use your information
Sharing your information
Retaining your information
Transferring your information
Securing your information
Product reviews
Your responsibilities
Unsubscribing from email marketing
Biometric information
Reward programmes
Events and teleconferences
Changes to this Privacy Policy
How to contact us
JURISDICTIONAL RIGHTS TO DATA PRIVACY
Canadian data privacy rights
EU, Swiss and UK privacy rights
California privacy rights
U.S. State (General) Privacy Rights
RPM International Inc. and its affiliates, subsidiaries and operating companies (the "Company", "we", "us", "our") understand the importance of protecting your privacy, and this Privacy Policy sets out how we handle personal information. It describes, among other things, the types of personal information we collect, the purposes for which we use it, the types of third parties with whom we share it, and the rights and responsibilities you may have with respect to it.
This Privacy Policy applies to personal information you provide to us when you (i) visit a website or interact with software that we own, license or otherwise operate and that references this Privacy Policy (each, a "Site"), (ii) purchase or receive products, goods or services through the Site, or (iii) visit our offices or otherwise contact or engage with us. For purposes of this Privacy Policy, the Site and all products, goods and services sold or provided by the Company through a Site will be collectively referred to as the "Services".
PLEASE READ THIS PRIVACY POLICY CAREFULLY AS IT DESCRIBES YOUR RIGHTS, RESPONSIBILITIES AND LIABILITIES. BY ACCESSING OR USING THE SERVICES, OR OTHERWISE PROVIDING US WITH PERSONAL INFORMATION, YOU CONSENT TO THE TERMS OF THIS PRIVACY POLICY, THE COMPANY'S TERMS OF USE AND ANY APPLICABLE COOKIE POLICY ON A SITE.
You must be at least eighteen (18) years of age to access the Services. RPM International Inc. is headquartered in the United States, and the personal information you provide to the Company may be processed and stored in the United States and other jurisdictions. For more information about our data transfer practices, please see Section 10 (Data Transfers).
1. Scope
In most cases, this Privacy Policy will apply to personal information that the Company receives in the course of its business activities as a "data controller". This means that we determine the purpose and means of processing such personal information. For the purposes of this Privacy Policy, the term "personal information" means any information which, alone or in conjunction with other information or data, identifies or relates to a natural person and which is subject to, or otherwise protected by, data protection law, statute or regulation. The term "personal information" does not include anonymised or de-identified data which is not attributable to a specific person, household or device and which is not otherwise subject to data protection law, statute or regulation. The Company may anonymise or de-identify personal information, and such data is not subject to this Privacy Policy, and the Company may use such data for any purpose. In some cases, the Company may receive your personal information as a "processor". This means that another party determines the purpose and means of processing such personal information. In such cases, the Company will process your Personal Information only on the written instructions of the data controller and to the extent reasonably necessary or appropriate for the performance of the services it is engaged to provide, including the transfer of personal data to third countries, unless otherwise provided by the Personal Data Protection Laws to which the Company is subject.
2. Types and categories of personal information we collect
The Company collects personal information in order to provide our Services, to comply with our legal obligations, to promote our business interests and for the other purposes set out in this Privacy Policy. Where you do not provide personal information to the Company, we may not be able to provide you with the Services or carry out a transaction you have requested. In general, we collect the following types and categories of personal information in the course of our business operations:
Category | Description/Examples |
Personal identifiers | Identifiers, such as your name, alias, delivery address, e-mail address, account name, telephone number, customer identification number. |
Registration data | Information provided when you create an account to use the Site, including user names and passwords. |
Online identifiers (for more information, see "Technical data" below) | Persistent identifiers that may be used to recognise you or your device over time and across different Services, including a device identifier, Internet Protocol (IP) address, cookies, beacons, web beacons, mobile advertising identifiers and similar technology. |
Commercial information | Records of Services you have purchased, obtained or considered, or your other purchase or usage history or patterns with respect to our Services. |
Business Contact Information | Information about the employees, owners, directors, officers or contractors of a third party organization (e.g., business, corporation, partnership, sole proprietorship, non-profit organization or government agency) with whom we conduct, or may conduct, business activities. |
Product Training Data | Information relating to training sessions, performance records and completion history of training, courses or similar events attended and offered by the Company. |
Health Data | You may provide us with, or we may otherwise collect, your health information in the event that you, or a third party, sustain an injury or illness while visiting our sites or physical premises, or while using our Services. |
Biometric data | We may, in limited circumstances, collect and store biometric data. Please see section 17 for more information. |
Marketing and communication data | Information about your marketing preferences and your subscriptions to our publications and alerts. |
Internet and electronic network data | Data relating to your access to or use of the Site, including browsing history, search history and information about your interaction with the Site or advertisements on the Site or other third party websites, and information derived from any device that connects to our Wi-Fi services. |
Your comments | Information you provide about our Services, which may include data collected from surveys or Company notices you submit. |
Visitor information | Information that an individual provides when visiting any of our physical locations or premises, including visitor logs and records, vehicle and parking information. |
Audio, video and images | In certain circumstances, you may provide us with images (for example, your use of a Service) or we may record your audio/voice and image via a video camera (for example, on-site security systems), a telephone or video conferencing helpdesk, or a virtual assistant or chatbot on the Site. Where we provide, and you use, a virtual assistant or chatbot feature on the Site, we may collect, record and store your image, voice and conversations captured therein. See section 21 for more information. |
Geolocation data | Information about the city, state or region in which a user of the Site resides. |
Professional or employment data | If you apply for a job with the Company, we collect information set forth in a resume, curriculum vitae, cover letter and similar documents, including contact information, employment history, skills or qualifications, educational background, professional compensation and benefit preferences, criminal record, credit history and similar data, as well as information provided on or by your references. |
Inferences | Inferences drawn from some of the categories of personal information identified herein and used to create a consumer profile reflecting your preferences, characteristics and purchasing and marketing behaviour. |
3. Technical data
When you access the Site, we automatically collect certain data using technical means and tools. From time to time, the Company or its service providers may publish aggregated and anonymised reports derived from this technical and usage information (for example, by publishing a report on usage trends of our Site or our service provider's platforms). This data relates to your device and your experience on the Site and other websites, including the following:
Device usage and data. When you access and use the Site, we automatically collect information about your access to and use of the Site, including traffic data, usage logs and other communications data, and the resources you access and use on or through the Site (e.g., browsing history, search history). We may also collect information about your device and Internet connection, including the device's unique identifier (e.g., device type, IMEI, MAC Wi-Fi, IP address), operating system, browser type and mobile network information. The Site may collect "diagnostic" data related to your use of the Site, such as crash data and logs, performance data (e.g., launch time, hang rate or power consumption) and any other data collected for the purpose of measuring technical diagnostics.
Cookies and tracking data. We use "cookies" and other tracking technologies on the Site. A cookie is a small file placed on your smartphone or other device. You can refuse to accept certain cookies by activating the appropriate setting on your smartphone or device or by changing your cookie preferences on a Site. However, if you deactivate certain cookies, certain parts of the Site may become inaccessible or may not function properly. In addition, the Site may contain small electronic files called web beacons (also known as single-pixel GIFs, single-pixel GIFs and web beacons) which allow us to analyse data about your use of the Site (e.g. to record the popularity of certain content and to check the integrity of the system and server). The Site may collect data on the advertisements you have seen or engaged with. For more information, see our Cookie Policy. From time to time, we may use on our Site certain third party cookies and pixels provided by our marketing partners, including social networking companies. To the extent that we use such third party cookies and pixels, you hereby agree to the terms and conditions set forth by such third parties, which may include Meta, X (formerly Twitter), TikToket and LinkedIn, among others.
Site monitoring. We also use cookies and other tracking technologies within the Site to monitor and record all activities and communications to, from and on the Site in order to protect, improve and analyze the use of the Site, and for the other purposes listed in this Privacy Policy. For the avoidance of doubt, you hereby acknowledge, accept and consent to such monitoring and recording.
Technologies other than cookies. We may deploy on our Site certain types of "Non-Cookie Technologies" provided by our service providers to support our digital advertising programs. These technologies often include browser caching, locally stored objects, or the creation of a statistical identifier in which an identifier, much like a cookie identifier, is calculated based on characteristics of a browser or device that distinguish it from other browsers or devices. These identifiers are calculated from data that your browser or device automatically shares or with additional data specifically requested from your browser or device. For more information, see [here].
4. Sources of information
First part / Direct collection. We collect personal information directly from you when you use our Services (e.g., register for an account, make purchases, sign up for a subscription), when you provide a Product Review (as defined below), or whenever you interact directly with us, such as when you visit our offices or premises or otherwise contact us.
Automated Collection. We may collect information and data, such as usage data and cookies, by automated means when you use the Site (see "Technical Data" above).
Third party sources. In accordance with applicable law, the Company may collect personal information about you from third parties, such as publicly available databases, advertising companies, social networking websites and applications, and combine it with information we already hold about you to help us improve and personalise our Services and for other purposes set out in this Privacy Policy. In addition, we may collect personal information from third party service providers so that we can assess whether to continue a business relationship with you and for " context", " credit check" or due diligence processes. We may also collect your contact details from your employer or other third parties in order to facilitate or engage you in traditional business activities and similar administrative matters.
5. How we use your information/Purpose of collection
We may use the personal information we collect about you to perform our Services, to comply with our legal obligations and to promote our business interests.
For the avoidance of doubt, you hereby agree that the Company may contact you by any means, including SMS/text messaging and e-mail and the use of automatic dialling systems and services, to provide you with information regarding a product order, shipping status, warranty information, and similar data and information relating to a business transaction.
6. Information sharing / Third party disclosures
We may share your personal information with certain organisations and third parties in accordance with applicable law, including as set out below .
Intra-group. The Company is comprised of affiliates and operating companies around the world, and we may disclose your personal information to these affiliates and operating companies to facilitate the purposes for which the personal information was collected, including to provide, operate, maintain, improve and promote our Services. For a list of the Company's affiliates and operating companies that may collect, process and share your personal information, please visit https://www.rpminc.com/leading-brands/.
Service Providers. We may share your personal information with companies that provide services on our behalf, such as hosting and analyzing the Site, conducting surveys, benchmarking and marketing on our behalf , processing transactions (including order fulfillment, discounts and returns), tracking and responding to consumer questions or complaints, and performing analysis to improve the quality of our Services.
Payment card transactions. Online payments for purchases made via the Site may be made using the online payment systems of third-party suppliers. In this case, the Company will not have access to your credit card information. Any personal or financial information you provide to our third party online payment systems is subject to the third party's privacy policy and terms of use, and we recommend that you review these documents before providing any personal or financial information. The Company may, from time to time, facilitate payment card transactions outside of the Site, including (but not limited to) transactions conducted by telephone.
Distributors and business partners. We may share your personal information with third parties who distribute our goods, products and marketing materials.
Marketing Partners. The Company has partnered with third party service providers with whom we share online Identifiers about your use of the Site, which are derived from the cookies, pixels and beacons we use on our Site. If you wish to unsubscribe from this information sharing, please click on the cookie management tool to set your preferences. See the Cookie Policy, if any, on each Site for a list of our service providers who provide us with cookies, pixels and tags .
Business restructuring. Circumstances may arise where, for strategic or other business reasons, the Company decides to sell, buy, dispose of, merge or otherwise reorganise our business. We may disclose your personal information to the extent reasonably necessary to negotiate or complete a merger, acquisition, transfer or sale of all or part of the Company's assets.
Legal; Compliance; Legitimate Interest. We may disclose personal information to a third party (i) if required to do so by law or governmental order, or in connection with legal proceedings, (ii) where necessary to defend or protect our legal, regulatory or commercial interests, (iii) to protect and defend our rights or property, or (iv) in urgent circumstances, to protect the health and personal safety of any individual.
Consent. In addition to the purposes for disclosure set out above, we may also disclose your personal information where you consent to the disclosure.
In the event that you facilitate a transaction with the Company, or request information from us or otherwise engage us, and these activities require the Company to share your personal information with a service provider or other third party, you hereby consent to such disclosure and/or direct the Company to intentionally disclose your personal information to the service provider or third party.
We may contact you on various social networking platforms (e.g. Facebook, Twitter, YouTube, Pinterest, Instagram). If you contact us on a social networking platform for customer support or other reasons, we may contact you via the social networks' direct messaging tools. Your use of a social networking platform is subject to the policies and conditions of the relevant social networking platform. Some social networking platforms may also automatically provide us with your personal information, and the information we receive will depend on the terms governing your use of the social networking platform(s) and any privacy settings you have set.
The Site may, from time to time, include social networking features and widgets (e.g., the "Facebook Like" button, the "Share" button) or interactive mini-programs that run on the Site. These features may collect your IP address and the page of the Site you access, and may set a cookie to enable the feature to function properly. Social network features and widgets are hosted by a third party or directly on the Site. Your interactions with these features are governed by the privacy statement of the relevant social network platform that provides them.
In accordance with the terms and conditions governing certain social network platforms, you may request that information, data or other content we obtain from or through the social network platform ("Platform Data") be deleted or modified. If you wish to have Platform Data about you deleted or modified, please contact us in accordance with the "Contact Us" section below and (i) identify the social network platform in question and (ii) the Platform Data you wish to delete and/or modify, and if modified, the modification to such Platform Data. We may also delete Platform Data at the request of the social networking platform.
8. Links to other websites; your direct disclosures from third parties
This Privacy Policy governs your use of our Services (as defined above) only, and the Company is not responsible for the content or privacy practices employed by any third party . As a resource to you, the Site may include links to third party websites or give you the opportunity to disclose information directly to third parties (e.g. credit card processors). Please note that third party websites may include a Company logo, be linked to the Site or appear to be affiliated with the Company . Our Privacy Policy does not apply to these third party websites or organisations. You assume all privacy, security and other risks associated with providing data, including personal information, to third parties via the Services. For a description of the privacy protections associated with the provision of information to third parties, you should consult the privacy statements, if any, provided by such third parties.
The length of time we retain your personal information varies depending on the purpose for which it was collected. We retain personal information to provide you with our Services, to facilitate transactions you have requested, or to engage in marketing activities, and for as long as necessary to defend our legal or commercial interests. For example, where you have made a purchase from us, we will keep a record of your purchase for the period necessary for billing, tax and warranty, and liability purposes. We may also keep a record of correspondence with you (e.g. if you have made a complaint about a product) for as long as is necessary to protect us from a legal claim. Please note that when you unsubscribe from our marketing communications, we will keep a record of your email address to ensure that we do not send you marketing emails in the future.
RPM International Inc. is headquartered in the United States, and personal information that the Company collects and processes may be maintained and stored in the United States. The Company uses service providers that store personal information on our behalf in the United States and other third countries. Please note that the United States, and these other third countries, may not provide the same level of protection for personal information as in your country, state, or other jurisdiction of residence or nationality, and when transferred to the United States or elsewhere, your personal information may be accessed by, or otherwise made available to, local governmental authorities and officials pursuant to judicial and/or administrative orders, decrees, and requests, and/or other national laws, statutes, and regulations. By continuing to provide us with such information, you hereby acknowledge and agree that your personal information will be transferred to and stored in the United States and other third countries.
We use a variety of security technologies and procedures to protect your personal information from unauthorised access, use or disclosure. HOWEVER, NO INFORMATION SYSTEM CAN BE COMPLETELY SECURE, AND WE CANNOT GUARANTEE THE ABSOLUTE SECURITY OF YOUR PERSONAL INFORMATION. FURTHERMORE, WE ARE NOT RESPONSIBLE FOR THE SECURITY OF ANY PERSONAL INFORMATION YOU TRANSMIT TO THE SITE AND/OR SERVICES OVER NETWORKS NOT UNDER OUR CONTROL, INCLUDING THE INTERNET AND WIRELESS NETWORKS, AND YOU PROVIDE ANY PERSONAL INFORMATION AND DATA TO US AT YOUR OWN RISK. TO THE EXTENT PERMITTED BY LAW, WE WILL NOT BE RESPONSIBLE FOR ANY DATA INCIDENT OR EVENT CAUSED BY A THIRD PARTY THAT COMPROMISES THE CONFIDENTIALITY, INTEGRITY OR SECURITY OF YOUR PERSONAL INFORMATION. The safety and security of your personal information also depends on you. Where we have given you (or where you have chosen) a user name and password to access our Services, you are responsible for maintaining the security and confidentiality of that identifying information and for not revealing it to any other person. You must contact us immediately if you have reason to believe that your user name or password for our Services has been compromised. You acknowledge and agree that we may contact you by e-mail or other electronic communications in the event that we are legally required to notify you of a data security incident or event relating to your personal information.
12. No data collected from children
The Site is not intended for children and is not intended to be used by children. Consequently, if you are under the age of eighteen (18) , you are prohibited from accessing or using the Services (including the Site) or from providing us with your personal information. If the parent or guardian of a child under the age of eighteen (18) believes that the child has, or you are under the age of eighteen (18) and believe that you have, provided us with information, the parent or guardian of that child should contact us if they would like that information deleted from our records, and we will use commercially reasonable efforts to comply with the request.
13. Publicly available information; product notices
You may, from time to time, have the opportunity to submit via the Site a comment, provide an opinion, rate or otherwise discuss our Services (a "Product Review"). In other circumstances, you may provide comments directly to us about our business, our industry or the Services ("Comments"). Any information or content you post in a Product Review or in your Feedback may be made available to other users of the Site (and our social networking platforms) and may be picked up by third party search engines, and third parties may also be able to upload or share your Product Review and Feedback on social networking sites or elsewhere. We recommend that you protect your privacy and anonymity and not upload any information to your Product Reviews and Feedback that you wish to keep confidential. Any third party who has access to your information via the Site will be entitled to use the information in the same way as if you had submitted the information directly to that third party. The public posting of any information on the Site is entirely voluntary on your part, and we recommend that you carefully consider what information you choose to make public. As between you and the Company, all Product Reviews and Comments will be considered confidential and proprietary information of the Company. In order for the Company to use such Product Reviews and Feedback, you grant the Company a perpetual, irrevocable, worldwide, royalty-free license, with the right to sublicense, under all relevant intellectual property rights, to use, publish, and disclose such Product Notices and Comments in any manner we choose and display, perform, copy, make, have made, use of, sell, and otherwise dispose of the Company's and our sublicensees' products or services embodying such Product Notices and Comments in any manner and by any means we choose, without reference to the source. The Company shall be entitled to use the Product Reviews for any purpose whatsoever without restriction or compensation of any kind to you and/or your representatives.
You are authorized, and hereby agree, to provide personal information to the Company only if such personal information is accurate, reliable and relevant to our relationship and only to the extent that such disclosure will not violate any applicable law, statute or regulation or infringe the privacy rights or privileges of any person. IF YOU PROVIDE PERSONAL INFORMATION (INCLUDING THIRD PARTY PERSONAL INFORMATION) TO THE COMPANY, YOU EXPRESSLY REPRESENT AND WARRANT TO THE COMPANY THAT YOU HAVE THE FULL RIGHT AND AUTHORITY TO PROVIDE THE COMPANY WITH SUCH PERSONAL INFORMATION (INCLUDING THIRD PARTY PERSONAL INFORMATION) AND THAT THE COMPANY'S USE AND PROCESSING OF SUCH PERSONAL INFORMATION AS DESCRIBED HEREIN WILL NOT VIOLATE THE RIGHTS OR PRIVILEGES OF ANY INDIVIDUAL, INCLUDING RIGHTS OF PRIVACY. YOU HEREBY AGREE TO FULLY INDEMNIFY THE COMPANY FOR ANY CLAIMS, LOSSES OR DAMAGES THAT MAY ARISE FROM YOUR PROVISION OF PERSONAL INFORMATION (INCLUDING THIRD PARTY PERSONAL INFORMATION) TO THE COMPANY.
It is important that the personal information you provide to us is accurate and reliable. In certain circumstances, you may have the opportunity to amend your online account with the Company directly to update and amend your personal information (e.g. name, telephone number, e-mail, delivery address), and you should do so where such changes are warranted. If your account does not contain such an editing facility, you must notify the Company directly of any changes or updates to your personal information in accordance with the "Contact Us" section below.
16. Unsubscribing from e-mail marketing
You have the right to opt-out of receiving e-mail marketing communications and direct marketing from us. Where required by law, e-mail marketing communications you receive from us will give you the opportunity to "unsubscribe" from receiving future e-mail marketing communications from us. You may also unsubscribe from e-mails and direct marketing by contacting us in accordance with the "Contact Us" section below. Due to production, dispatch and system delays, it may take some time to process your request. Until the change you have requested takes effect, you may still receive communications from us. If you send us your request by post, please allow additional time for us to receive your notification. Please note: Although you have chosen not to receive communications, you may still receive business communications such as order confirmations, product recall notices, membership information or other communications necessary to complete your transaction. You hereby agree to immediately notify the Company, in writing, if you no longer own, license or use an e-mail address to which you have subscribed to receive marketing e-mails from us.
Where permitted by law and in certain limited circumstances, the Company may collect biometric data and biometric identifiers relating to our customers, suppliers, service providers, employees, temporary workers, sub-contractors or agents. For example, the Company may use cameras, kiosks and similar devices and technologies to collect, store and use information derived from the analysis of a person's facial geometry or thermal temperature in order to facilitate the Company's health and safety monitoring programmes and for other safety-related purposes. In other circumstances, the Company may collect biometric data or biometric identifiers from individuals who access sensitive areas of the Company's facilities or for other administrative (e.g., time management) or security purposes. The Company will not retain such biometric identifiers longer than permitted by law, but in no event longer than (a) one (1) year after the data subject's last interaction with the Company, or (b) to the extent necessary to fulfill its collection purpose. The Company will maintain protocols for the security and destruction, or disposal, of biometric identifiers in a manner that complies with applicable data protection law and makes such data and identifiers unreadable in order to eliminate any potential for re-use or re-identification. Except as otherwise provided by any applicable law, the Company may disclose and disseminate biometric identifiers to third parties in the same manner as it may disclose and disseminate personal information to third parties in accordance with this Privacy Policy, and such disclosures of biometric identifiers may include third party service providers and law enforcement or regulatory agencies, where permitted by law.
Some web browsers may transmit "do not track" signals to the Site with which the user is communicating. Due to differences in the way web browsers integrate and activate this functionality, it is not always clear whether users intend for these signals to be transmitted, or whether they are even aware of them. Unless otherwise provided by law, we do not currently take any action in response to these signals.
The Company endeavours to ensure that everyone has access to information relating to our Services, including this Privacy Policy. Please contact us in accordance with the "Contact Us" section below if you would like this Privacy Policy provided in an alternative format, and we will endeavour to accommodate your needs.
20. Reward programmes and financial incentives
We collect and use personal information, including personal information provided by a third party, to administer and maintain our financial incentive, rewards and loyalty programs ("Rewards Programs"). We use the personal information you provide in these programs to verify your identity, offer unique rewards, track the status of your program and facilitate the redemption of program points for products, promotional materials, training workshops and other items. If you consent to participate in one of our Rewards Programs, you may withdraw that consent at any time by contacting us in accordance with the "Contact Us" section below or in accordance with the instructions set out in the terms and conditions of the applicable Rewards Program. The Company may use personal information collected from or relating to participants in our Reward Programmes for any other purpose or in any other manner set out in this Privacy Policy.
21. Events and video conferencing
Conferencing platforms. The Company uses web conferencing platforms and applications (each, a "Conferencing Platform") for the purpose of organizing or conducting video and audio meetings and conferences, webinars and similar training exercises, social events and other types of video and audio meetings (collectively, "Conferences"). The type of personal data processed by the Company via a Conference Platform depends on the scope and nature of the Conference, and may include your identity data, registration data, transaction data, technical data and other information provided to the Company during the Conferences. Please note that the Company, as well as our third party service providers and partners, may record our Conferences, including the content of the communications and activities that take place there, and the Company may use and disclose such content, information and data for our own business purposes. By attending a Conference, you hereby consent to such recording, use and disclosure. You may, depending on the jurisdiction in which you reside, have the legal right to withdraw your consent at any time by (i) providing written (acceptable e-mail) or verbal notice to the Company prior to the start of the Conference, (ii) providing verbal notice to the Company's meeting host during the Conference, or (iii) activating, where technically possible, the "do not record" features on the Conference Platform. You must implement measures designed to ensure data protection and privacy in the background of your Conference (e.g. by notifying Conference viewers using the background masking feature). You may not provide any Company-provided access code or link to a Conference without this notice and all other appropriate disclaimers attached thereto. Please see the Microsoft Teams Privacy Statement for a description of its conferencing platform privacy practices. You may, depending on the jurisdiction in which you reside, request access to a conference recording or transcript at any time. The Company prohibits third-party recording devices or processes, including chat/recording bots, on a Conference Platform without the express prior written consent of the Company's IT department.
Content and recordings of communications. When you send an e-mail, call, or otherwise communicate or interact with us or with other users of the Company, including if you subscribe to our mailing lists, fill out forms on our websites, interact with our social networking pages, post a product review or testimonial, submit content to any online discussion groups, participate in a conference, or otherwise enter information into public comment fields, blogs, or community forums sponsored by or affiliated with the Company, we may collect and retain records of your contact information, communications and interactions, your postings or submissions, and our responses, if any. We, and our third party service providers and partners, may also collect and store any information you submit through our websites and online services, for example during one of our conferencing platforms, chat functions or virtual assistants, and we may also keep records of communications relating to information provided to us in connection with any customer support request.
Personal data (as defined in Canada's Personal Information Protection and Electronic Documents Act ("PIPEDA")) will be synonymous with personal information, where permitted, and will be collected, stored, used and/or processed by the Company in accordance with this Privacy Policy and the Company's obligations under PIPEDA and other applicable Canadian provincial laws. Under these Canadian laws, you have the right to request access to your personal information and to request that inaccurate personal information be corrected. If you have submitted personal information to us and would like to access or correct it, please contact us in accordance with the "Contact Us" section below. When you request access to or correction of your personal information, we will ask you to verify our request by e-mail, and we will ask you for specific data to enable us to confirm the authenticity of the request and your identity, and to enable us to search our records and databases. We may charge you a fee for access to your personal information, provided that we inform you of this fee in advance. Your right of access to personal information is not absolute, and we may not be able to provide you with access to certain personal information in certain circumstances (e.g., if the information contains the personal information of others or is subject to legal privilege). In the event that we are unable to provide you with access to or the ability to correct your personal information, we will use reasonable means to inform you of the reasons why, subject to any legal or regulatory restrictions. To remove your name from our electronic contact lists (text or email), please follow the applicable unsubscribe instructions listed above (see "Email marketing and your rights") or contact us in accordance with the "Contact Us" section below. If you have any concerns about our data processing, you may file a complaint with the Office of the Privacy Commissioner of Canada. Please consult the Office of the Privacy Commissioner of Canada for more information.
23. European Union (EU), Switzerland and United Kingdom (UK)
Data protection rights. If you are located in the EU, Switzerland or the United Kingdom, you have the following data protection rights:
· Right to know. The right to know what personal information the Company collects and processes about you, including the types and categories of personal information we collect and process, the sources of that personal information, our retention criteria, with whom we share your personal information, cross-border data transfers, and how to make complaints and requests. This information is set out in this Privacy Policy.
· Automated Decision Making. The Company does not engage in any activity that subjects our customers, Site users, survey participants or others to a decision based solely on automated processing, including profiling, that produces legal effects, or significant similar results, affecting them.
· Access rights. You may ask us whether we are processing your personal information and, if so, whether we have access to it. Where we comply with a request for access, we will also provide you with additional information, such as the purposes of the processing, the categories of personal information concerned and any other information necessary for you to exercise the substance of that right.
· Rectification. You have the right to have your personal information corrected if it is inaccurate or incomplete. Upon request, we will correct inaccurate personal information about you and, taking into account the purposes of the processing, update any incomplete personal information, which may include providing a supplementary statement.
· Deletion. You have the right to have your personal information erased, which means that we and, where possible, any other data controller to whom your data has previously been disclosed, will delete it. However, your right to erasure is subject to legal limitations and preconditions (e.g. where your personal information is no longer necessary for the original purposes for which it was processed, your personal information has been processed unlawfully).
· Restriction of processing. You have the right to have the processing of your personal information restricted, which means that we suspend the processing of your personal information for a certain period of time. Circumstances that may give rise to this right include situations where the accuracy of your personal information is disputed, but we need time to verify the inaccuracy (if any) of your personal information.
· Data portability. You have the right to ask us to provide you with your personal information in a structured, commonly used and machine-readable format and to have that data transmitted directly to another data controller, where technically possible.
· Right to object. You have the right to object to the processing of your personal information, which means that you can ask us to stop processing your personal information. This only applies if the "legitimate interests" ground (including profiling) is the legal basis for the processing (see "Legal basis for processing" below). However, at any time (and free of charge), you may object to the processing of your personal information for direct marketing purposes.
· Withdrawal of consent. You may also withdraw your consent at any time if we rely solely on your consent to process your personal information. However, this will not affect our legal basis for processing that personal information prior to the withdrawal of your consent.
To exercise any of these data privacy rights, please contact us or ask your nominated agent to contact us in accordance with the "Contact Us" section below. To the extent permitted by law, we will need to verify your identity (or the identity of your agent) and ensure the authenticity of your request.
Legal basis for processing. We process your personal information in accordance with the legal bases set out in the law. For example, our processing of personal information (as described herein) is justified on the following legal grounds:
· Consent. Processing is based on your consent (e.g. you sign up to receive our marketing materials, you contact us voluntarily).
· Legitimate interests. Processing is necessary for our legitimate interests as set out herein (e.g., monitoring your use of the Site and your compliance with the terms and conditions governing it, improving our Services).
· Contractual commitment. Processing is necessary for the performance of a contract to which you are a party (e.g. you are purchasing or considering purchasing our Services).
· Legal compliance. Processing is required to comply with a legal or statutory obligation (e.g. tax disclosures).
Complaints. If you have any concerns about our data processing, you have the right to lodge a complaint with your data protection authority. For data protection authorities in the EU, please consult https://edpb.europa.eu/about-edpb/about-edpb/members_en. For the data protection authority in Switzerland, please contact the Federal Data Protection and Information Commissioner (https://www.edoeb.admin.ch/edoeb/en/home.html). For the data protection authority in the UK, please contact the Information Commissioner's Office (www.ico.org.uk). However, we would be grateful if you could address any concerns you may have before approaching a data protection authority with a complaint, and we invite you to contact us in the first instance.
24. Privacy rights in California
Data privacy rights. If you reside in California, you have the following data privacy rights:
· Right to Know (Specific Pieces of Personal Information). You have the right to know what specific pieces of Personal Information we have collected about you.
· Right to know (categories of personal information). You have the right to know (i) the categories of Personal Information that we have collected from you; (ii) the categories of sources from which Personal Information is collected; (iii) the categories of your Personal Information that we have sold or disclosed for commercial purposes; (iv) the categories of third parties to whom your Personal Information has been sold or disclosed for commercial purposes; and (v) the commercial purpose for collecting or selling your Personal Information.
· Right of deletion. You have the right to ask us to delete personal information that we have collected and retained.
· Right of correction. You have the right to ask us to correct inaccurate personal information that we have collected and stored.
· Non-discrimination. You have the right not to be discriminated against for exercising your rights under the CCPA.
Submitting a request for confidentiality. To submit a privacy request, you may contact us by any of the following means: (e-mail)dataprotection@rpminc.com , (web form) https://www.rpminc.com/contact-rpm/, (telephone) 1 (800) 776-4488, or (mail) RPM International Inc, ATTN: Privacy Request, 2628 Pearl Road, Medina, OH 44256, USA. If you prefer, you may designate an authorized agent to submit a CCPA Privacy Claim on your behalf. An authorized agent must be registered with the California Secretary of State to do business in California.
Privacy Request Verification Process. If you (or your authorised agent) make a request relating to your personal information, the Company will verify your identity (and the identity of the authorised agent, to the extent applicable) to the extent of certainty required or permitted by law before processing your request. In particular, the Company will, to the extent required or permitted by law, ask you (or your authorised agent) to verify your request by e-mail, request certain contact details or government identifiers, and we will match at least two pieces of such personal information with data we have previously collected from you before granting access, erasure or correction of specific items or categories of personal information, or otherwise responding to your request. We may require written documentation demonstrating that a third party is authorized to act as our agent for purposes of submitting the requests set forth herein, unless you have provided the authorized agent with a power of attorney pursuant to California Probate Code §§ 4121 through 4130. None of the CCPA's rights, as modified by the CPRA, are absolute, and such rights are subject to statutory and regulatory exceptions and exemptions. For more information on the CCPA or CPRA, please visit: https://oag.ca.gov/privacy/ccpa.
Unsubscribe rights / Do not sell my personal information. California residents have the right to opt-out of the "sale" of their personal information. However, the Company does not sell your personal information to third parties for profit or monetary or other consideration, and therefore we do not provide an opt-out process for the sale of personal information (as we do not engage in such activities).
Unsubscribe rights / Do not share my personal information. California residents have the right to opt-out of having their personal information "shared. The Company uses third-party analytics and targeted advertising features on our Site and similar web-based tools provided by our marketing partners, and these marketing features, tools and relationships involve the disclosure of your personal information to third parties and may constitute the "sharing" of your personal information. To opt-out of this sharing of your personal information in these circumstances, please click on the cookie management/adjustment tool (sometimes visible as a "Cookie Settings" link) in the footer of the Site to set your cookie preferences. You, or your authorised agent, may also contact us in accordance with the "Contact Us" section below.
Children. The Site is not intended for and should not be used by minors under the age of eighteen (18). Accordingly, the Company does not knowingly sell or share personal information of minors under the age of eighteen (18).
Limiting the use of sensitive personal information. The Company does not use or disclose sensitive personal information for purposes other than those set forth in the CCPA, and therefore we do not provide individuals with the ability to limit the manner in which we use or disclose such sensitive personal information.
25. U.S. State Privacy Rights (General)
Data privacy rights. Under certain U.S. state privacy laws, you may have the following privacy rights with respect to your personal information:
· To confirm whether or not we are processing your personal information and to access that personal information.
· To correct inaccuracies in your personal information, taking into account the nature of the personal information and the purposes for which we process your personal information.
· To delete personal information provided by you or obtained about you.
· To obtain a copy of your personal information processed by us, in a portable and, as far as technically possible, readily usable format, which allows you to pass the data to another entity without hindrance.
· To obtain a list of the categories of third parties to whom we have disclosed your personal data.
Submitting a request for confidentiality. To submit a request for privacy, you may contact us by one of the following means: (e-mail)dataprotection@rpminc.com , (web form) https://rpminc.com/contact/, (telephone) 1 (800) 776-4488, or (mail) RPM International Inc, ATTN: Request for Privacy, 2628 Pearl Road, Medina, OH 44256, USA. Where permitted by U.S. state law, you may designate an authorized agent to submit a privacy claim on your behalf.
Privacy Request Verification Process. If you make a request for your personal information, the Company will verify your identity (and the identity of the authorized agent, to the extent applicable) to the extent of certainty required or permitted by law before processing your request . In particular, before granting you access to, erasure or correction of specific parts or categories of personal information or otherwise responding to your request, the Company will, to the extent required or permitted by law, (i) ask you (or require your authorised agent) to verify your request by e-mail, (ii) request certain contact details or government identifiers, and (iii) match at least two parts of that personal information with data we have previously collected from you. None of your privacy rights are absolute, and these rights are subject to exceptions and exemptions.
Appeal process for privacy requests. If you wish to appeal a decision made by the Company regarding your privacy request, please send us an e-mail in accordance with the "Contact Us" section below with the subject line "PENDING: Privacy Appeals" and describe the nature of your request and the reason for the appeal review request.
Unsubscribe rights / Sale of personal information. You may have the right to refuse the "sale" of their personal information. However, the Company does not sell your personal information to third parties for monetary or other valuable consideration, and therefore we do not provide an opt-out request process for the sale of personal information (as we do not engage in such activities). Nevada residents may submit a request that we not sell the personal information we maintain about them to third parties who will sell or license their personal information to third parties. If you wish to exercise this right (even though we do not sell or license personal information), please contact us in accordance with the "Contact Us" section below .
Unsubscribe rights / Targeted advertising. You may have the right to refuse to have your personal information used for targeted advertising purposes. The Company uses third-party analytics and targeted advertising features on our Site and similar web-based tools provided by our marketing partners. To opt-out of this sharing of your personal information in these circumstances, please click on the cookie management tool (sometimes visible as a "Cookie Settings" link) in the footer of the Site to set your cookie preferences.
Unsubscribe/profile rights. You may have the right to refuse to have your personal information used for profiling in connection with decisions that have legal or other significant effects. However, the Company does not engage in such activities.
Complaints. You may file a complaint about our data processing activities with your local authorities, which may include the following:
· The Attorney General of Colorado
· The Attorney General of Connecticut
· The Attorney General of Delaware
· Attorney General of Iowa
· Attorney General of Montana
· The Attorney General of Nebraska
· The Attorney General of Nevada
· The Attorney General of New Hampshire
· New Jersey Consumer Division
· The Attorney General of Oregon
· The Attorney General of Tennessee
· The Attorney General of Texas
· The Attorney General of Virginia
26. Changes to the Policy
We reserve the right to change this Privacy Policy at any time. The "Last Updated" date shown above will identify the date this Privacy Policy was last modified. It is your responsibility to periodically review the Privacy Policy to determine if any changes have been made since your last interaction. Your use of the Services and your continued use of the Services following any changes to this Privacy Policy signifies your assent to this Privacy Policy and any changes reflected in the most current version. We may, in our sole discretion, provide you with communications, including by e-mail or SMS, regarding changes to our Privacy Policy; however, such communications do not remove or otherwise limit your responsibility to periodically review the Privacy Policy to determine whether any changes have been made.
If you have any questions or concerns regarding this Privacy Policy, or if you would like to submit a privacy request, please contact us by one of the following means: (e-mail)dataprotection@rpminc.com , (web form) https://rpminc.com/contact/, (telephone) 1 (800) 776-4488, or (mail) RPM International Inc, ATTN: Privacy Request, 2628 Pearl Road, Medina, OH 44256, USA.
