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Tremco CPG, and its affiliates, subsidiaries, and operating companies (the “Company," "us," "we") understands the importance of protecting your privacy, and this Privacy Policy sets out how we process personal information. It describes, among other things, the types of personal information that 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 the personal information you provide us when you (i) visit any website or interact with software that we own, license, or otherwise operate and that links to 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 furnished by the Company through a Site shall be referred to collectively 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 ARE CONSENTING TO THE TERMS OF THIS PRIVACY POLICY AND 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 on our data transfer practices, please see Section 9 (Data Retention and Localization).
1. ScopeIn most instances this Privacy Policy will apply to personal information that the Company receives during its business operations as a “data controller”. This means we determine the purpose and means of processing such personal information. For purposes of this Privacy Policy, the term “personal information” means any information that, alone or in conjunction with other information or data, identifies or is linked to a natural person and that is subject to, or otherwise afforded protection under, a data protection law, statute, or regulation. The term “personal information” does not include anonymized or de-identified data that is not attributable to a particular individual, household, or device and that is not otherwise subject to a data protection law, statute, or regulation. The Company may anonymize 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 instances, the Company may receive your personal information as a “data 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 to which it is engaged, including the transfer of personal data to third countries, unless provided otherwise by Personal Data Protection Laws to which the Company is subject.
2. The Types and Categories of Personal Information We CollectThe Company collects personal information in order to provide our Services, comply with our legal obligations, promote our business interests, and for the other reasons set forth in this Privacy Policy. When you do not provide personal information to the Company, we may not be able to provide you the Services or to complete a transaction you requested. Generally, we collect the following types and categories of personal information during our business operations:
Personal Information | |
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Category | Description/Examples |
Personal Identifiers | Identifiers, such as your name, alias, shipping address, email address, account name, telephone number, customer identification number. |
Registration Data | Information provided when you register for an account to use the Site, including usernames and passwords. |
Online Identifiers (For more information, see “Technical Data” below) | Persistent identifiers that can be used to recognize you or your device over time and across different Services, including a device identifier, an Internet Protocol (IP) address, cookies, beacons, pixel tags, mobile ad identifiers, and similar technology. |
Commercial Information | Records of the Services you purchased, obtained, or considered, or your other purchasing or consuming histories or tendencies with respect to our Services. |
Business Contact Data | Information related to employees, owners, directors, officers, or contractors of a third-party organization (e.g., business, company, partnership, sole proprietorship, nonprofit, or government agency) with whom we conduct, or possibly conduct, business activities. |
Health Data | You may furnish us with health-related information in the event you, or a third party, suffers an injury or illness while visiting our physical locations or premises, or when using our Services. |
Marketing and Communications Data | Information with respect to your marketing preferences and your subscriptions to our publications and alerts. |
Internet and Electronic Network Data | Data pertaining to your access to or use of the Site, including browsing history, search history, and information regarding your interaction with the Site or advertisements embedded on the Site or other third-party websites, and information derived from any device that connects to our Wi-Fi services. |
Your Feedback | Information you provide about our Services, which may include data gathered from any Company surveys or reviews submitted by you. |
Visitor Information | Information an individual provides when visiting any of our physical locations or premises, including visitor logs and registries, vehicle and parking information. |
Video and Images | In some circumstances, you may provide us images (e.g., your use of a Service) or we may record you via a video camera (e.g., on-premises security systems) or through video teleconferencing. |
Geolocation Data | Information about the general 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 resumé, curriculum vitae, cover letter, and similar documentation, including contact details, employment history, skills, or qualifications, education level, job compensation and benefit preferences, criminal record, credit history and similar data, and information provided about or by your references. |
Inferences | Inferences drawn from some of the personal information categories identified herein and used to create a consumer profile reflecting your purchasing and marketing preferences, characteristics, and behavior. |
3. Technical Data
When you access the Site, we collect certain data automatically using technical means and tools. From time to time, the Company or its service providers may release aggregate and de-identified reports derived from this technical and usage information (for example, by publishing a report on trends in the usage of our Site or service provider’s platforms). This data relates to your device, and your experience on the Site and other websites, including the following:
Usage and Device Data - When you access and use the Site, we automatically collect details of your access to and use of the Site, including traffic data, usage logs and other communication data, and the resources that 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, Wi-Fi MAC, 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 energy use), and any other data collected for the purposes of measuring technical diagnostics.
Site Monitoring - We also use cookies and other tracking technologies within the Site to monitor and record any and all activities and communications to, from, and on, the Site in order to safeguard, improve, and analyze usage of, the Site, and for the other purposes listed in this Privacy Policy. For the avoidance of doubt, you hereby acknowledge, agree, and consent to, such monitoring and recording.
4. Sources of InformationThe Site is not directed at, nor intended for use by, children. As a result, if you are under the age of eighteen (18), you are prohibited from accessing or using the Services (including the Site) or 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 if you are under the age of 18 and believe that you have, provided us with any information, the parent or guardian of that child should contact us if they want this information deleted from our files, and we will undertake commercially reasonable efforts to comply with the request.
13. Publicly Posted Information; Product ReviewsYou may, from time to time, have the ability to submit via the Site a comment on, provide an opinion about, rate, or otherwise discuss our Services (a “Product Review”). In other circumstances, you may directly provide us feedback on our business, our business sector, or the Services (“Feedback”). Any information or content you post in a Product Review or in your Feedback may be available to other users of the Site (and our social media platforms) and may be retrievable by third-party search engines, and third parties may also be able to download or share your Product Review and Feedback to social media websites or elsewhere. We recommend that you guard your privacy and anonymity and not upload any information in your Product Review and Feedback that you wish to remain confidential. Any third party with access to your information via the Site will be permitted to use the information in the same manner as if you submitted the information directly to that third party. Publicly posting any information on the Site is entirely voluntary on your part, and we recommend you carefully consider the information you choose to make publicly available. As between you and the Company, any and all Product Reviews and Feedback shall be considered the Company’s confidential and proprietary information. In order for the Company to utilize such Product Reviews and Feedback, you grant to the Company a non-exclusive, perpetual, irrevocable, worldwide, royalty-free license, with the right to sublicense, under all relevant intellectual property rights, to use, publish, and disclose such Product Reviews and Feedback in any manner we choose and to display, perform, copy, make, have made, use, sell, and otherwise dispose of the Company’s and our sub-licensees’ products or services embodying such Product Reviews and Feedback in any manner and via any media we choose, without reference to the source. The Company shall be entitled to use Product Reviews and Feedback for any purpose without restriction or remuneration of any kind with respect to you and/or your representatives.
14. Your ResponsibilitiesIt is important that the personal information that you provide to us is accurate and reliable. In certain circumstances, you may have the ability to directly edit your online account with the Company to update and change your personal information (e.g., name, telephone number, email, shipping address), and you must do so when such changes are warranted. If your account does not contain such an editing feature, then you must notify the Company directly of any changes or updates to your personal information in accordance with the “Contact Us” section listed below.
16. Email Marketing Opt-OutYou have the right to opt out of receiving email marketing communications and direct-mail marketing from us. Where required by law, the email marketing communications that you receive from us will provide you an option to “unsubscribe” from receiving future email marketing communications from us. You may also unsubscribe from email and direct-mail marketing by contacting us in accordance with the “Contact Us” section listed below. Due to production, mailing and system timelines, it may take some time to process your request. Until your requested change takes effect, you may still receive communications from us. If you send us your request by regular mail, please allow extra time for us to receive your notice. Please note: Although you may have opted not to receive communications, you may still receive business-related communications such as order confirmations, product recall notices, membership information, or other communications that are necessary to complete your transaction. You hereby agree to immediately notify the Company, in writing, in the event you no longer own, license, or use an email address to which you subscribed to receive email marketing from us.
17. Biometric Data
Where permitted by law and in certain limited circumstances, the Company may collect biometric data and biometric identifiers related to our customers, suppliers, service providers, employees, temporary workers, contractors, or agents. For example, the Company may use cameras, kiosks, and similar devices and technology to collect, retain, and use information derived from the scanning of a person’s facial geometry or thermal temperature in order to facilitate the Company’s health and safety screening programs, and for other security-related purposes. In other circumstances, the Company may collect biometric data or biometric identifiers from individuals that are accessing sensitive areas of the Company’s facilities or for other administrative (e.g., timekeeping) or security functions and purposes. The Company will retain such biometric identifiers for no longer than as is permitted by law, but in no event longer than a) one (1) year after the applicable individual’s last interaction with the Company, or b) as is 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 renders such data and identifiers unreadable so as to remove any potential for its reuse or re-identification. Barring any applicable law to the contrary, 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 to third party service providers and law enforcement or regulatory agencies, where permitted by law.
18. Do-Not-Track Signals
Some web browsers may transmit “do-not-track” signals to the Site with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they are even aware of them. Unless otherwise required by law, we currently do not take action in response to these signals.
19. Persons with Disabilities
The Company strives to ensure that every person has access to information related to our Services, including this Privacy Policy. Please contact us in accordance with the “Contact Us” section listed below if you would like this Privacy Policy provided in an alternative format, and we will seek to meet your needs.
20. Rewards Programs 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 your program status, and facilitate the exchange of program points for products, promotional materials, training workshops, and other items. If you consent to participate in any of our Rewards Programs, you may withdraw that consent at any time by contacting us in accordance with the “Contact Us” section listed below or in accordance with the instructions set forth in the applicable Rewards Program’s terms and conditions. The Company may use personal information gathered from, or related to, participants in our Rewards Programs for any other purpose or in any other manner set forth in this Privacy Policy.
21. Events and Video Teleconferencing
The Company hosts and uses video teleconferencing platforms to facilitate conferences, meetings, training events, and other programs. We often use online platforms that are owned and administered by a third-party service provider (e.g., Google, Zoom, WebEx, Skype for Business). Please be aware that our video teleconferencing may record the content, conversations, and discussions thereon, and such records may be stored or retained by our third-party service providers. By participating in our events and video teleconferencing, you hereby consent to the collection and retention of any information provided therein, and you hereby consent to the recording of such activities.
22. Canada Privacy Rights
Personal data (as the term is defined in the Personal Data Protection and Electronic Documents Act of Canada (“PIPEDA”)) shall 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. Pursuant to these Canadian laws, you have a 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 have access to it, or have it corrected, please contact us in accordance with the “Contact Us” section listed below. When requesting access to, or correction of, your personal information, we will require that you verify our request via email, and we will request specific data from you 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 to access your personal information, provided that we advise you of any such fee in advance. Your right to access personal information is not absolute, and we may not be able to allow you to access certain personal information in certain circumstances (e.g., if the information contains personal information of other persons or it is subject to legal privilege). In the event that we cannot 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 delete your name from our electronic contact lists (text or email), please follow the applicable opt-out instructions listed above (see “Email Marketing and Your Rights”) or contact us in accordance with the “Contact Us” section listed below. If you have concerns with our data processing, you may file a complaint with the Office of the Privacy Commissioner of Canada. Please refer to 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 UK, you have the following data protection rights:
To exercise any of these data privacy rights, please contact us, or have your designated agent contact us, in accordance with the “Contact Us” section listed 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 forth in law. For example, our processing of personal information (as described herein) is justified based on the following legal grounds:
Privacy Request Verification Process - If you (or your authorized agent) make any request related to your personal information, the Company will ascertain your identity (and the identity of the authorized agent, to the extent applicable) to the degree of certainty required or permitted under the law before addressing your request. In particular, the Company will, to the extent required or permitted by law, require you (or your authorized agent) to verify your request via email, request certain contact information or government identifiers, and we will match at least two pieces of such personal information with data that we have previously collected from you before granting you access to, erasing, or correcting, specific pieces or categories of personal information, or otherwise responding to your request. We may require written documentation that demonstrates a third party is authorized to serve as your agent for the purposes of submitting the requests set forth herein, unless you have provided the authorized agent with power of attorney pursuant to California Probate Code §§ 4121 to 4130. None of the CCPA’s rights, as amended by the CPRA, are absolute, and such rights are subject to legal and regulatory exceptions and exemptions. For more information about the CCPA or the CPRA, please see: https://oag.ca.gov/privacy/ccpa.
Opt-Out 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 valuable consideration, and therefore we do not provide opt-out request processes for the sale of personal information (because we do not undertake such activities).Opt-Out Rights / Do Not Share My Personal Information - California residents have the right to opt out of the “sharing” of their personal information. The Company uses third-party analytical and targeted advertising features on our Site and similar web tools provided by our marketing partners, and such features, tools and marketing 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 tool (sometimes visible as a “Your Privacy Choices” or as a “Do Not Sell/Share My Personal Information” link on the footer of the Site) to set your cookie preferences. You, or your authorized agent, may also contact us in accordance with the “Contact Us” section listed below.
Children - The Site is not directed at, and should not be used by, minors under the age of eighteen (18), and therefore the Company does not knowingly sell or share the personal information of minors under eighteen (18) years of age.
Limit Use of Sensitive Personal Information - The Company does not use or disclose sensitive personal information for reasons other than those set forth in the CCPA, and therefore we do not provide individuals with the ability to limit how we use or disclose such sensitive personal information.
25. Nevada Privacy RightsSubmit a Privacy Request - To submit a privacy request, you may contact us using any of the following means: (email) dataprotection@rpminc.com, (webform) https://rpminc.com/contact/, (telephone) 1 (800) 776-4488, or (mail) RPM International Inc., ATTN: Privacy Request, 2628 Pearl Road, Medina, OH 44256.
Privacy Request Verification Process - If you (or your authorized agent) make any request related to your personal information, the Company will ascertain your identity (and the identity of the authorized agent, to the extent applicable) to the degree of certainty required or permitted under the law before addressing your request. In particular, the Company will, to the extent required or permitted by law, require you (or your authorized agent) to verify your request via email, request certain contact information or government identifiers, and we will match at least two pieces of such personal information with data that we have previously collected from you before granting you access to, erasing, or correcting, specific pieces or categories of personal information, or otherwise responding to your request. None of Virginia’s privacy rights are absolute, and such rights are subject to legal and regulatory exceptions and exemptions. For more information about the Virginia Consumer Protection Act, please see: https://lis.virginia.gov/cgi-bin/legp604.exe?211+ful+SB1392ES1.
Privacy Requests Appeals Process - If you would like to appeal a decision the Company has made with respect to your privacy request, please email dataprotection@rpminc.com, with the subject line “PRIVACY REQUEST: APPEALS” and describe the nature of your request, and the reason requesting an appellate review. Virginia residents may file privacy complaints with the Virginia Attorney General (https://www.oag.state.va.us/contact-us/contact-info).
Opt-Out Rights / The Sale of Personal Information - Virginia 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 or monetary consideration, and therefore we do not provide opt-out request processes for the sale of personal information (because we do not undertake such activities).Opt-Out Rights / Targeted Advertising - Virginia residents have the right to opt out of having their personal information used for targeted advertising purposes. The Company uses third-party analytical and targeted advertising features on our Site and similar web 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 “Your Privacy Choices” or as a “Do Not Sell/Share My Personal Information” link on the footer of the Site) to set your cookie preferences.
27. Changes to the Policy
We reserve the right to amend this Privacy Policy at any time. The “Last Updated” date listed above will identify when this Privacy Policy was last amended. It is your responsibility to periodically review the Privacy Policy to determine whether any amendments have been made since your last interaction. Your use of the Services and continued use of the Services after any amendments are made to this Privacy Policy, signifies your consent to this Privacy Policy and any amendments reflected in the most recent version. We may, in our sole discretion, provide you communications, including via email or text messages, about changes to our Privacy Policy; however, such communications do not abrogate or otherwise limit your responsibility to periodically review the Privacy Policy to determine whether any amendments have been made.
If you have any questions or concerns about this Privacy Policy, or would like to submit a privacy request, contact us using any of the following means: (email) dataprotection@rpminc.com, (webform) https://rpminc.com/contact/, (telephone) 1 (800) 776-4488, or (mail) RPM International Inc., ATTN: Privacy Request, 2628 Pearl Road, Medina, OH 44256.