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ECC Privacy Notice

I. PRIVACY NOTICE

This privacy notice (“Privacy Notice”) explains how we collect, use and share personal data in the operation of www.ecc.net ("Website") and in the course of our business activities.

This Website is owned and operated by Environmental Chemical Corp. of 1240 Bayshore Highway, Burlingame, CA 94010 ("ECC", "we", "us", "our"). ECC is the data controller of any personal information that you submit to this Website or that is otherwise covered by this Privacy Notice. For questions about this privacy notice, or our data processing activities more generally, please contact: webmaster@ecc.net.

In certain circumstances, your personal data may be shared with, or processed by one of our subsidiaries: ECCO GmbH in Germany, and ECC Italy Srl in Italy. This may occur, for example, where the purpose for processing relates to the geographic area relevant to one of our subsidiaries. In such cases, the relevant subsidiary will be the data controller and references in this Privacy Notice to ECC should be read as references to that subsidiary company in relation to that processing.

This Privacy Notice may be updated from time to time. We therefore advise you to consult it on a regular basis. The last line of this Privacy Notice below indicates when the Privacy Notice was last updated.

PERSONAL DATA WE MAY COLLECT FROM YOU

The nature and purpose of our personal data processing will depend on the specific circumstances of our relationship with you.

You are not obliged to provide us with any personal data, however if you fail to provide certain information, we may be unable to communicate with you and respond to your messages or job application. We will also require certain personal data to enable us to enter into a contract with you, where relevant.

We may collect person data in a number of ways, including:

Through your interactions with the Website

In line with the principle of data minimization, we limit the personal data that we collect via our operation of the Website. However, we may collect personal data in certain circumstances, for example when you contact us using the form on the "Contact ECC" section of the Website. The information we may collect in this form includes:

• Basic personal details – your title, name, associated company, etc.
• Contact details - phone number, facsimile number, address, email address, company website, etc.
• Your reason for contacting ECC – the subject, how you heard about ECC, information you include in the free text "Comments" box, etc.

We may also collect some information automatically through your interactions with the Website. For example, we may collect information about your device, your IP address, pages that you visit on the Website, and other such automatically collected information.

Job applicants

You may submit personal data when applying for jobs or to be a subcontractor on the "Opportunities" section of the Website. The information we will collect in relation to this might include:

• Basic personal details – your name, address, how you heard about the job, etc.
• Contact information – your email address and phone number, etc.
• Employment information – your past employment history, desired salary, right to work, etc.
• Any additional information – your social media profiles and additional files that you choose to provide us with.

Suppliers, service providers and other third parties

If we engage with you, or your employer, for you to provide us with products and services, we may collect and process personal data about you (either in your own capacity, or as a representative of your employer) such as:

• Basic personal details - name, job title, email address, contact telephone number, address, etc.
• Details about the products or services being provided and the contract that has been entered into.

Most of the personal data is obtained directly from you or another member of your employer.

Special category data

Some special categories of personal data are given additional protection under global data protection legislation. Examples of this might be information about your health (such as any disabilities), information about your racial or ethnic origin, and information about your sex life or sexual orientation. We do not anticipate routinely processing special category personal data, although we may in some circumstances. For example, if you include special category personal data in any communications that you send to us or if you alert us about any disabilities when applying for a job.

Where we process special category personal data, we generally do so either on the basis that you have explicitly consented to this processing, by freely providing us with the information, or where it is necessary for us to comply with specific obligations in the field of employment law.

USES MADE OF YOUR PERSONAL DATA AND THE LEGAL BASIS FOR THIS

We use personal data held about you in a number of ways during the course of our business operations. We will only collect, use and share your personal data where we are satisfied that we have an appropriate legal basis to do this.

This may be because the processing is necessary:

• For our legitimate business interests (or those of a third party) provided that such interests are not outweighed by your fundamental rights and freedoms. For example: (i) to liaise with customers and suppliers about our business operations; (ii) to ensure that content from our Website is presented in the most effective manner for you and for your computer; and (iii) to comply with lawful requests made by authorities, and to otherwise voluntarily co-operate with regulatory bodies at our discretion.

• To perform a contract entered into between you and us, or to take steps at your request before entering into such a contract. For example to consider your application to enter into an employment contract with us;

• To comply with a legal obligation to which we are subject. For example where we are obligated to provide information, or assistance, to courts, government authorities, or other regulatory bodies; or

• Where you have consented to our processing. If we are processing your personal data (including special category personal data) on the basis of your consent, this can be withdrawn at any time.

If you would like to find out more about the legal basis for which we process your personal data please contact us using the contact details provided above.

HOW WE SHARE PERSONAL DATA

As noted above, we may share your personal data with ECC group companies as necessary.

We may also share your personal data with third parties, for example:

• Service providers who help to manage our business and deliver services. These third parties have agreed to confidentiality restrictions and use any personal data we share with them or which they collect on our behalf solely for the purpose of providing the contracted service to us. For example, we use Jobvite to assist us with the job application process.

• Our legal, financial, or other advisors in order to obtain professional services.

• In order to prevent fraud, investigate crimes (or potential crimes), and ensure security.

ECC is based in California in the USA. Any personal data that we collect from you may therefore be transferred to the USA. We may also further transfer your personal data to other parties located in the USA and abroad. If required by applicable data protection legislation to do so, before transferring any such data we first ensure that an appropriate safeguard has been implemented to protect any transferred data, such as the Standard Contractual Clauses. The Standard Contractual Clauses have been approved by the European Commission for transfers of personal data to third countries.

You have a right to contact us for more information about the safeguards we have put in place (including a copy of relevant contractual commitments).

HOW WE PROTECT YOUR PERSONAL DATA

We’ll take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Notice.

Unfortunately, sending information using the internet isn’t completely secure. Although we’ll do our best to protect your personal data, we can’t guarantee the security of the data you send to our Website. Once we’ve received your information, we’ll try our best to keep it securely. This includes using strict procedures and security features to try to prevent unauthorized access.

HOW LONG WE STORE YOUR PERSONAL DATA FOR

We will store your personal data for as long as is reasonably necessary for the purposes for which it was collected, as explained in this Privacy Notice. In some circumstances, we may store your personal data for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax or accounting requirements.

We store personal data relating to unsuccessful job applications for six (6) months from the date of receipt of your application. If you are successful in your application, you will be provided with a copy of our employee privacy notice which explains how your data will be used and retained while you are an ECC employee and when you leave us.

In specific circumstances we may store your personal data for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal data or relationship with us.

Once your personal data is no longer needed, it is securely destroyed.

YOUR RIGHTS

In certain circumstances and depending on the jurisdiction in which you are located, you may have rights in relation to personal data we hold about you – specifically, where our processing of your personal data is subject to European data protection legislation, you may have the right to:

• request access to your personal data;
• request correction of your personal data;
• request erasure of your personal data;
• object to the processing of your personal data;
• request restriction of processing your personal data;
• request transfer of your personal data to a third party; and
• make a complaint to the appropriate EU Data Protection Authority.

To inquire about your rights, and exercise them where applicable, please contact us using the contact details provided above.

We aim to respond to requests made by you within one month but may extend that period by two further months where necessary. Please note that the above rights are not absolute and certain exemptions may apply.

We will not ordinarily charge a fee for you to exercise any of the rights listed above, but reserve our right to charge a reasonable fee, or to refuse to act on requests which are manifestly unfounded or excessive.


DATE

This Privacy Policy was last updated on June 21, 2021.

     
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