Privacy Statement

Click to view the Privacy Statement in Chinese, Dutch, French, German, Polish or Spanish.

Victaulic and each of its global subsidiaries and affiliates (collectively, “Victaulic”, “we”, “us” or “our”) respect your privacy and are committed to processing your personal data in accordance with the law.  Full details of each of our global subsidiaries and affiliates can be found here: https://www.victaulic.com/find-location/.This Privacy Statement (hereinafter the “Statement” or “Privacy Statement”) applies to all mobile applications, websites and domains owned by Victaulic or our wholly owned subsidiaries linking to or posting this Statement ("Website” or “Websites").  This Privacy Statement describes how we use, store, disclose and process personal data that we obtain through or in connection with a purchase of our products and services, in connection with the use of our Websites including the Victaulic candidate pool (“Candidate Pool”), or when you otherwise contact us and/or we collect your personal data.

Victaulic reserves the right to change, modify and update this Privacy Statement from time to time by posting a revised version on our Websites and the Candidate Pool homepage or, if considered necessary, we will notify you directly.  Therefore, we recommend you regularly consult this Statement, to make sure that you are aware of any changes.  The most recent version of this Statement is reflected by the version date located at the bottom of this Statement.    

 

1. GENERAL

1.1. The term “personal data” as used in this Statement shall mean any information (including “personal information” as that term may be defined) that actually enables, or is capable of enabling us to identify you, directly or indirectly, by reference to an identifier such as your name, identification number, location data, online identifier or one or more factors specific to you.

1.2. For the purposes of the General Data Protection Regulation 2016/679 (the “GDPR”) and other laws globally, the Victaulic entity that is responsible for your personal data (“data controller”) is the Victaulic entity in the jurisdiction where your personal data is collected. For more information about your data controller ask your Victaulic business contact, consult our list of locations on the Victaulic public website found here www.victaulic.com, or contact our Privacy Team at privacy@victaulic.com.

Should there be no Victaulic entity in the jurisdiction where your personal data is collected, Victaulic Company located at 4901 Kesslersville Road, Easton, PA 18040-6714, USA is deemed to be the data controller responsible for your personal data.

1.3. If you have questions about this Privacy Statement, or the manner in which Victaulic collects, uses or otherwise processes your personal data, including the transfer of your personal data outside your jurisdiction of residence, please contact us by sending an email to our Privacy Team (known as Grievance Officers in some jurisdictions) at the following e-mail address: privacy@victaulic.com, or write to us at the following address:

Victaulic
Privacy Team
4901 Kesslersville Road
Easton, PA 18040-6714 USA

2. LINKS TO NON-VICTAULIC WEBSITES

2.1. The Websites may, from time to time, contain links to and from the websites of our partner networks, advertisers, affiliates and other third parties. If you follow a link to any of these websites, please note that these websites may have their own privacy statements and that we do not accept any responsibility or liability for these statements.  Please check these statements before you submit any personal data to these websites.

2.2. We may also provide social media features on our Websites that enable you to share Victaulic information with your social networks and to interact with Victaulic on various social media sites. Your use of these features may result in the collection or sharing of information about you, depending on the feature.  We encourage you to review the privacy policies and settings on the social media sites with which you interact to make sure you understand the information that could be shared by those sites.  We do not accept responsibility or liability for these policies.  You may elect to not use Victaulic’s social media features and/or adjust your personal settings and preferences to protect your privacy.

3. CANDIDATE POOL

3.1. Victaulic’s Candidate Pool (https://www.victaulic.com/careers/) forms the basis of any application for a specific job at Victaulic. Moreover, it offers you the opportunity, without application to a particular position, to submit information that will allow Victaulic to contact you if suitable openings arise in the future (provided you have given your consent to be contacted in such an event).

3.2. Registering for the Candidate Pool requires you to submit certain personal data. You are under an obligation to provide only personal data which is accurate, complete and up to date at the time at which you submit it to the Candidate Pool.

3.3. If you are using the Candidate Pool, the third party that provides the Candidate Pool runs an ‘eSignature’ function that allows us to keep a record that you have agreed to this Privacy Statement. Our third party service provider will collect your IP address, email address, name, initials and the date and time you agreed to the Privacy Statement for this purpose.

3.4. If you are under 18 years of age (or the age of consent under applicable law in the jurisdiction in which you reside), you must talk to your parents / legal guardian prior to submitting a job application. Depending upon the country in which you are applying for a job with Victaulic, we will need proof of a parent's / legal guardian's consent prior to any employment.

3.5. The open career opportunities published on our Websites do not constitute an offer or promise of employment and Victaulic may eliminate, modify or change without notice any aspect(s) of the employment positions, compensation, and benefit plans described therein. Our Websites provide descriptions of possible positions within Victaulic, and do not provide binding offers, terms or conditions of employment. Any employment offer that may follow as a result of the identification of a potential opportunity by a user or submission of information to Victaulic is in accordance with the specific terms of that offer.

3.6. Please note, by clicking on “I accept” when you create a Candidate Pool profile, you provide your consent that your personal data will be processed in order to process your application in accordance with this Statement. If your application is unsuccessful, we will store your personal data for up to six (6) months in the Candidate Pool following the conclusion of the unsuccessful application, this is in order to respond to any questions you might have about your application and in order to protect ourselves from legal claims.  Should you consent to us retaining your personal data for the purposes of identifying and contacting you about other suitable recruitment opportunities within Victaulic globally, we will store your personal data for a further five (5) year period, unless you withdraw your consent or deactivate your profile, which you may do at any time.  Deactivating your profile will withdraw all your applications from all the positions you have applied to within Victaulic and will remove your profile from the Candidate Pool.  However, if you have applied for a position within Victaulic, your personal data may be retained for a temporary period of time in an "inactive" status as required by applicable law and may not be deleted immediately.  While you may request that we delete your personal data, we will not be able to process your job application as a result.

3.7. If you click "I decline", you will not be able to use the Candidate Pool to apply for global career opportunities with Victaulic. You will then have to apply directly by email to hrm@victaulic.com, stating that you wish to apply directly for a specific position.

4. CATEGORIES OF PERSONAL DATA VICTAULIC COLLECTS

4.1. We may collect and process the following categories of personal data:

  • Personal data provided to us.
    Job applicants, suppliers, vendors, customers, resellers, partners and Website visitors provide personal data to us in many ways, for example by filling in forms, requesting information, requesting/using goods/services, subscribing to materials, entering contests, signing up for the Candidate Pool, corresponding with us by post, phone, email or otherwise.  Such personal data include:

    • Contact Information” including:
      • Name;
      • User name and password;
      • Log-in details; and
      • Contact details.
    • Financial Data” including:
      • Invoicing data;
      • Credit card number data;
      • Bank account details; and
      • Billing and transaction information.
    • Job Application Information” including:
      • Cover letter;
      • Job role and Victaulic office location interested in;
      • Preferred job conditions;
      • Professional history;
      • Academic history;
      • Answers to questions about suitability for a position;
      • Extracurricular activities;
      • Professional references; and
      • Professional and personal competences.
    • Pictures of customers, business partners or supplier’s staff (“Pictures”) in order to create seller profiles.
  • Personal data we collect.
    We collect personal data from job applicants, suppliers, vendors, customers, resellers, partners and Website visitors, which include:
    • Surveillance Images” collected by our CCTV systems.
      • If you visit a Victaulic office, factory or site, you may be caught on CCTV. If security cameras are in use, you may be made aware by way of a clearly visible notice at the entrance of any premises at which CCTV is in operation.
    • Electronic Identification Data” collected automatically by our services when you visit our Websites, including:
      • Internet protocol (IP) address;
      • Web browser type and version;
      • The operating system used and the domain name of your internet service provider; and
      • Information about your visit, including pages you viewed or searched for; page response times; download errors; length of visits to certain pages; page interaction information (such as scrolling, clicks, and mouse-overs); methods used to browse away from the page; and any phone number used to call our customer service number, etc.

Such Electronic Identification Data are collected by cookies and similar technologies. When you first access our Websites from certain jurisdictions, you will receive a message advising you that cookies and similar technologies are in use. By clicking “accept cookies”, closing the message, or continuing to browse the Website, you signify that you understand and agree to the use of these technologies, as described in our Cookie Notice.  For more information about our practices in this area for a particular Website, please see our Cookie Notice linked in the footer of such Website.

We may also allow select third parties to collect information about our Website visitors to provide us with better insights into the use of the Website or user demographics or to provide relevant advertising to you.  These third parties may collect information about a consumer’s online activities over time and across different websites when he or she uses our Website.  Again, please see our Cookie Notice for further details.

  • Special category data.
    We collect:

    • Special category data, with respect to job applicants only, and only where applicable law requires such collection, such as personal data revealing:
      • Racial or ethnic origin;
      • Health;
      • Political opinions;
      • Religious or philosophical beliefs;
      • Trade-union membership; and
      • Sexual orientation.

In particular, if you are applying for a specific job within Victaulic in the U.S. or indicating the U.S. as a preferred location when registering your Candidate Pool profile, you will have the opportunity to provide information about your ethnic origin in order for us to conduct equal opportunities monitoring.  The provision of this information is entirely voluntary and if you choose not to provide it your application(s) will not be affected in any way. If you do choose to provide this information, it will be held separately and anonymously in the Candidate Pool.

    • Health and Safety Incident Data”, with respect to any injuries suffered by suppliers, vendors, customers or resellers on Victaulic premises or in relation to Victaulic products.
    • In certain jurisdictions (e.g. India), Financial Data is considered to be special category data.

4.2. You are not obligated to provide us with your personal data, however, the performance of several services may not be possible if you choose not to provide your personal data.

4.3. We do not knowingly collect personal data from children under the age of eighteen (18) and do not target our Websites to children under 18 (or the age of consent to data processing under applicable law). We encourage parents and guardians to take an active role in their children's online activities and interests.

4.4. We will not sell, hire or rent out your personal data to third parties unless you (or your parent or guardian, if you are under the age of consent under applicable law) have affirmatively authorized the sale of such data, if such authorization is required by applicable law.

5. HOW WE USE YOUR INFORMATION

 

5.1. If you visit us from certain jurisdictions, we may only process your personal data on the basis of consent. If you are visiting from one of these jurisdictions, we will always rely on your consent to collect and process your data.

5.2. Where your consent is not mandatory, we may process personal data on the following lawful bases:

  • For the performance of a contract between you and us or to answer questions or take steps at your request prior to entering into a contract.
  • As necessary in our legitimate business interests, provided such interests are not overridden by your interests or fundamental rights.

5.3. We will process personal data for the following purposes as is necessary for the performance of a contract between you and us or to answer questions or take steps at your request prior to entering into a contract, where you are a:

  • Supplier, vendor, customer, reseller, partner or Website visitor:
    • To administer or otherwise carry out our obligations in relation to any agreement to which we are a party;
    • To assist you in completing a transaction or order;
    • To allow tracking of shipments;
    • To prepare and process invoices;
    • To respond to queries or requests and to provide services and support;
    • To provide aftersales customer relationship management;
    • To create and manage our customer accounts;
    • To notify you about changes to our services; and
    • To administer any promotion or competition.
  • Job applicant only:
    • To facilitate, manage and to allow you to register a profile on the Candidate Pool;
    • To assess your qualifications with respect to your application for a position within Victaulic, and to decide whether to enter into an employment relationship with you; and
    • To facilitate candidate onboarding processes.

5.4. We will process personal data for the following purposes as necessary for certain legitimate interests, or where you have given your informed consent to such processing if required by applicable law (such consent can be withdrawn at any time), where you are a:

  • Supplier, vendor, customer, reseller, partner or Website visitor:
    • To offer our services to you in a personalized way, for example, we may provide suggestions based on your previous requests to enable you to identify suitable products and services more quickly;
    • To send you personalized marketing communications, in order to keep you informed of our and our selected partner’s products and services, which we consider may be of interest to you;
    • To allow you to download Victaulic software or content;
    • To provide you, or allow selected third parties to provide you, with information about products or services, that may interest you;
    • To create image profiles for our suppliers, resellers or partners; and
    • To allow you to participate in contests and surveys and benefit from personalized promotional offers.
  • Job applicant only:
    • To assess your qualifications with respect to available positions within Victaulic, to identify positions for which you may be eligible, to provide you with global employment opportunities, to review references and facilitate background screening and to decide whether to enter into an employment relationship with you;
    • To reimburse you for certain costs incurred related to your application for a position with Victaulic, for instance travel costs associated with travelling to and from your interview; and
    • To contact and correspond with you regarding job applications and to contact you if your profile and preferences match a vacant position globally within Victaulic, as long as your profile is active in the Candidate Pool.

5.5. We will process personal data for the following purposes as is reasonably necessary in our legitimate business interests, provided such interests are not overridden by your interests or fundamental rights, where you are a:

  • Job applicant, supplier, vendor, customer, reseller, partner or a Website visitor:
    • To monitor quality control and ensure compliance with any and all applicable laws, regulations, codes and ordinances, for example, in response to a request from a court or regulatory body, where such request is made in accordance with the law;
    • To resolve any disputes;
    • As part of our efforts to keep our Websites and the Candidate Pool safe and secure;
    • To ensure the physical security of Victaulic premises through the monitoring of Surveillance Images;
    • To ensure the security of your account and our business, preventing or detecting fraud, malicious activity or abuses of our Websites and the Candidate Pool, for example, by requesting verification information in order to reset your account password (if applicable);
    • To administer our Websites and the Candidate Pool and for internal business administration and operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
    • To create products or services that may meet your needs;
    • To develop and improve our products and services, for example, by reviewing visits to the Candidate Pool, our Websites and various subpages, demand for specific products and services and user comments; and
    • To measure performance of marketing initiatives, ads, and websites “powered by” another company on Victaulic’s behalf.
  • Job applicant only:
    • To transfer candidate data from the Candidate Pool to our internal HR systems in the event of a successful application.

5.6. We may collect and process special category data for the following purposes in order to comply with a legal obligation under applicable law, where you are a:

  • Supplier, vendor, customer, reseller or partner:
    • To ensure compliance with any and all applicable laws, regulations, codes, guidelines and ordinances; and
    • To track health and safety incidents which may occur on Victaulic premises or in relation to Victaulic products.

5.7. We may collect and process special category data for the following purpose, only with your prior explicit consent (which may be withdrawn at any time), where you are a:

  • Job applicant only:
    • To conduct equal opportunities monitoring in the U.S. in operation of the Candidate Pool.

5.8. Subject to applicable laws, we may process your personal data in order to protect your vital interests or the vital interests of another person, for example in order to lessen or prevent a serious threat to the life, health or safety of any individual, or to public health or safety.

5.9. We support “do not track” signals (“DNT”).  If you have DNT enabled in your web browser, we will not receive browser-related information from our advertising partners for tailoring advertisements.

5.10. In certain jurisdictions (e.g. India), Financial Data is considered to be special category data and may only be processed on the basis of explicit consent. If you are visiting from one of these jurisdictions, we will always seek your consent to collect and process this type of data.

6. HOW LONG WILL WE HOLD YOUR PERSONAL DATA?

6.1. We process your personal data for as long as necessary.  This means that we do keep a record of your personal data for as long as it is required or justified by the law or by another legal obligation, or for a specific period consented to by you (where relevant), or for the period for which this would be necessary for the aforementioned purposes. Based on the categories of personal data described in Section 4 and unless longer storage would be required to fulfil the purposes (e.g. in the event the personal data would be used as evidence in a judicial procedure), it will be stored until the procedure concerned has come to an end, we generally hold your personal data as follows:

Electronic Identification Data No longer than 1 year
Contact Information No longer than 10 years
Job Application Information (including relevant special category data) No longer than 5 years
Pictures No longer than 1 year
Surveillance Images No longer than 3 months
Financial Data No longer than 10 years
Health and Safety Incident Data No longer than 10 years

6.2. At the end of the retention period, we will use appropriate measures to delete or anonymize your personal data. To the extent that we hold hard copies of your personal data, such records, print-outs or hard copy documents etc. will be permanently destroyed.

7. HOW WE SHARE YOUR INFORMATION

7.1. We will not sell, hire out, disclose, transfer or pass on your personal data to third parties, except in the situations provided for in this Statement or unless you provide prior consent, (which may be required under applicable law). We may share personal data in the following ways:

  • Our Affiliates. We are headquartered in the U.S.  Your personal data may be accessed by us or transferred to us in the U.S. or to our affiliates who are located worldwide (please see our Website for our locations) and in order to process your personal data, including in order to identify positions for which you may be eligible, including in territories other than your preferred employment location.  Full details of the companies within our group can be found here: https://www.victaulic.com/find-location/.
  • Third-party service providers. We may share personal data with service providers and suppliers retained to deliver complete products, services and customer solutions and to assist us with marketing and communication initiatives. These service providers and suppliers include, for example, providers of customer support and live-help, IT and network vendors, marketing, email service providers, automated data processors, and shipping agents.  When we share your personal data with third parties that we engage to process data on our behalf, including our affiliates, we will ensure that those third parties are contractually bound to guarantee the same levels of privacy protection and confidentiality observed by Victaulic when handling your personal data.
  • Candidate Pool. For the purposes of operating the Candidate Pool, Victaulic shares personal data with certain third parties hired to perform specific employment-related services, such as recruitment services, pre-employment checks and tests needed to assess CV, resumes, qualifications and skills submitted to the Candidate Pool.
  • Marketing partners. From time to time, we participate in marketing initiatives with other companies, including websites “powered by” another company on behalf of Victaulic.  As part of these initiatives, certain Victaulic services and marketing communications may be delivered at the same time as those from other companies.  Some of these services and communications offer you the option to share personal data with both Victaulic and the other companies participating in these initiatives. For example, you may receive marketing communications from Victaulic and other companies or have the opportunity to register online for software products from multiple companies.  If you choose to provide personal data only to Victaulic, Victaulic will not share this information with the other companies participating in that marketing initiative.  If you choose to provide personal data to the other companies, that personal data will be handled according to the privacy statement of those companies which may differ from Victaulic’s policies and practices.
  • Third party involved in a business transaction. We may share personal data with one or more third parties in connection with or during negotiation of any merger, financing, acquisition or dissolution, transition, or proceeding involving the sale, transfer, divestiture, or disclosure of all or a portion of our business or assets.  In the event of an insolvency, bankruptcy or receivership, such personal data may also be transferred as a business asset.  To the extent required by applicable law, you will be notified if your personal data has been shared in these ways.  If another company acquires any of our companies, businesses or assets, that acquiring company may acquire your personal data, we will inform you of the new controller responsible for the protection of your personal data, to the extent required by applicable law.  Except to the extent required by applicable law, we do not guarantee that any entity receiving such data in connection with one of these transactions will comply with all of the terms of this Statement following such transaction.  However, it is our practice to seek reasonable protection for personal data in these types of transactions.
  • Our advisors. We may also share personal data with our auditors, legal advisors, and similar third parties in connection with our receiving their professional services, subject to standard confidentiality obligations.
  • Law enforcement. We may disclose personal data to the government or to third parties under certain circumstances when legally obligated to do so, such as in connection with suspected illegal activity in connection with our Websites, products or services, or to respond to a subpoena, court order or other legal process, or that we believe may aid a law enforcement investigation.  In accordance with applicable law, we reserve the right to release Personal Data to law enforcement or other government officials, as we, in our sole discretion, deem necessary or appropriate.
  • Legal processes. We may share all types of personal data with others as required by, or permitted by, applicable law. This may include sharing personal data with governmental entities, or third parties in response to subpoenas, court orders, other legal process, or as we believe is necessary to exercise our legal rights, to defend against legal claims that have been brought against us, to defend against possible legal claims that we determine in our sole discretion might be brought against us, to investigate and help prevent security threats, fraud or other malicious activity and to protect the rights or personal safety of Victaulic employees and third parties.
  • Other Third Parties. We may share personal data with other third parties that are not described above. When we do so we will either aggregate or de-identify the data so that a third party would not be likely to link data to you, your computer, or your device. Aggregation means that we combine the information of numerous people together so that the data does not relate to any one person. De-identify means that we remove or change certain pieces of information that might be used to link data to a particular person

7.2. International transfers and storage of personal data

  • If you are visiting our Websites or accessing our products and services from outside the U.S., be aware that your personal data may be transferred to, stored, and processed in the United States where our servers are located, and our central database is operated.   Where required by applicable law, personal data may be stored locally before onward transfer.
  • Where required by applicable laws, we will take appropriate measures to ensure adequate protection of your personal data when transferred internationally and, if necessary, seek your prior consent. Such measures may include use of data transfer agreements and / or official transfer mechanisms such as data authority approved contractual clauses. For instance, if you are located in the European Economic Area (“EEA”), we may store your personal data as described in this policy outside the EEA.  Where we transfer EEA personal data to a third party located in a country not recognized by the European Commission, or another relevant body, as ensuring an adequate level of protection, we will take appropriate steps, such as implementing Standard Contractual Clauses recognized by the EU Commission, to safeguard such personal data.
  • If you are visiting our Websites or accessing our products and services from Korea in particular, applicable data protection law requires that we provide you with certain information relating to the transfer of such data, including the name of the recipient, the purpose of transfer and the categories of personal data transferred. For further information, please contact privacy@victaulic.com.

8. YOUR RIGHTS AS A DATA SUBJECT

8.1. General right of access to and accuracy of your personal data in the Candidate Pool

  • Where you are a Candidate Pool profile holder, you can access, check, change and update your personal data at any time by logging into your profile. However, the right of access referred to above does not entitle you to inspect any internal notes made by the competent staff members or employees within Victaulic.
  • Should you wish to delete your profile from the Candidate Pool, sign in using your username and password, select "My Account Options" at the top of the page, and then "Deactivate". Please ensure that you confirm the deactivation when asked by the system.  Deactivating your profile will withdraw all your applications from all the positions you have applied to within Victaulic and will remove your profile from the Candidate Pool. However, if you have applied for a position within Victaulic, your personal data may be retained for a temporary period of time in an "inactive" status as required by applicable law and may not be deleted immediately.

8.2. Right to withdraw consent to marketing and job vacancy communications

We may give you the opportunity to choose your privacy preferences regarding the communications we send.  Such communications include email newsletters, software updates, etc. that may be expressly requested by you or which you consented to receive. General communications provide information about products, services, vacant job positions globally within Victaulic, and/or support.  This may include new product information, special offers, or invitations to participate in market research.  You may opt-out of receiving them by using one of the following methods:

  • Select the email "opt-out" or "unsubscribe" link, or follow the opt-out instructions included in each email communication.
  • To unsubscribe from messages delivered to mobile devices, reply to the message with the words “STOP” or “END”.
  • Contact us at privacy@victaulic.com. Be sure to provide your name, relevant contact information, and specific relevant information about the Victaulic communications that you no longer wish to receive.
  • When you register with the Candidate Pool, Victaulic may contact you if your profile and preferences match a vacant position globally within Victaulic as long as your profile is active in the Candidate Pool. You may also choose to receive automated emails about positions within Victaulic at the e-mail address you provided during registration informing you of positions that may fit your registered profile.  To stop receiving job position communications, you can click the "unsubscribe" link at the bottom of these emails.  You may also choose to stop receiving these emails (or to begin receiving them if you had previously elected not to) by signing in to the Candidate Pool using your username and password, selecting "My Account Options" at the top of the page, and then editing your preferences in the “Correspondence” section of the "My Account" page.

Please be aware that when you opt-out of receiving certain subscription communications, it may affect the services you have chosen to receive from Victaulic where accepting the communications is necessary for Victaulic to provide the services to you.

8.3. Data subject rights

In certain circumstances, and subject to applicable laws, for example if you are an EU resident, you may have the following rights in relation to your personal data:

  • Request access to your personal data. You may have the right to request confirmation from us as to whether we process your personal data and to request access to any personal data we hold about you as well as related data, including the purposes for processing the personal data, the recipients or categories of recipients with whom the personal data has been shared, where possible, the period for which the personal data will be stored, the source of the personal data, and the existence of any automated decision making.
  • Request correction of your personal data. You may have the right to obtain without undue delay the rectification of any inaccurate personal data we hold about you.  To the extent required by applicable laws, any correction requests will be communicated to each recipient of your personal data.
  • Request erasure of your personal data. You may have the right to request that personal data held about you is deleted.  To the extent required by applicable laws, any erasure requests will be communicated to each recipient of your personal data.
  • Request restriction of processing your personal data. You may have the right to prevent or restrict processing of your personal data.  To the extent required by applicable laws, any restriction of processing requests will be communicated to each recipient of your personal data.
  • Request transfer of your personal data. You may have the right to request transfer of your personal data directly to a third party where this is technically feasible.
  • Right to object. You may have the right to object to the processing of your personal data when you have legitimate reasons to do so.
  • Right to withdraw consent.  Where processing is based on consent, you may have the right to withdraw such consent.  In some cases, if you withdraw your consent to use of your personal data, we may not be in a position to continue to provide our services or products to you.

8.4. Specific country rights

Further to the rights outlined above, if you are a resident of the following jurisdictions, you may have the following rights:

  • Ukraine, you may have the right to make a “reservation”. When providing your consent for data processing, you may specify limitations as regards to restriction of Victaulic’s right to process your data.
  • Brazil, you may have the right to request information from us on the consequences of not providing consent to processing.

8.5. Exercising your rights

To exercise the above-mentioned rights, or to raise a question, comment or complaint, send an e-mail with an enclosed copy of the frontside of your identity card to our Privacy Team by email to privacy@victaulic.com, or to exercise rights in relation to the Candidate Pool send an email to privacy@victaulic.com or log into your Candidate Pool profile where relevant.  We reserve the right to request the provision of additional information necessary to confirm the identity of the enquirer.

Subject to applicable laws, you may exercise the above data subject rights through a legal representative or delegated person, in which case we will verify whether the requesting party is a duly authorized representative.  We may reject such request if there is justifiable reason for rejection under applicable laws.

8.6. Responding to your requests

We will respond to your requests without undue delay and in accordance with applicable laws.

8.7. Right to complain

If you have any complaints about the way Victaulic collects, uses, stores and/or processes your personal data, you may have the right to file a complaint with an authority responsible for data protection in your country.  For example, if you are a resident of:

  • The EU, you have the right to file a complaint with the Belgian Data Protection Authority, which has been nominated as Victaulic’s Lead Supervisory Authority. However, you may also choose to lodge a complaint with the Supervisory Authority of the EU Member State in which you live or work, or where the alleged infringement took place should you prefer.
  • Australia, we suggest you contact the Office of the Australian Information Commissioner for guidance on alternative courses of action which may be available to you. We will provide our full cooperation in the event that you elect to pursue this course of action.
  • The Ukraine, you may file a claim with the Ukrainian court or the Ukrainian Parliament Commissioner for Human Rights (Ombudsman).
  • Colombia, you have the right to file a complaint with the Colombian Data Protection Authority.
-

8.8. Privacy rights for residents of California only

Shine the Light

Under California law, a California customer with whom we have an established relationship has the right to request certain information with respect to the types of personal data that we have shared with third parties for their direct marketing purposes and the identities of those third parties during the prior calendar year. All requests for such information must be in writing and sent to us at privacy@vicatulic.com.

California Consumer Privacy Act Rights

The California Consumer Privacy Act of 2018 (“CCPA”) provides “consumers” (California residents) with specific rights regarding their “personal information”.  This section describes your CCPA rights and explains how to exercise those rights.

During the past twelve (12) months, we have collected the following categories of personal information from the listed sources, used it for the listed business purposes and shared it with the listed categories of third parties.  The categories of information include information we collect from our job applicants, suppliers, vendors, customers, resellers, partners and Website visitors, and any other person that interacts with us either online or offline.  Not all information is collected about all individuals.

Identifiers (name, alias, postal address, email address and phone number) Individuals submitting information to us.
Information we may receive from third-party marketing and data partners.
Performing services for you.
Advertising customization.
Auditing relating to transactions. Internal research and development. Security detection, protection and enforcement. Functionality debugging, error and repair. Quality control.
Service providers (such as those listed in Section 7). Affiliated companies. Government regulators. Law enforcement. Strategically aligned businesses.
Sensitive information (invoicing data, credit card number data, bank account detail, billing details, log-in details, health data and trade-union membership) Individuals submitting information to us. Performing services for you. Advertising customization. Auditing relating to transactions. Internal research and development. Security detection, protection and enforcement. Functionality debugging, error and repair. Quality control. Service providers (such as those listed in Section 7). Affiliated companies. Government regulators. Law enforcement. Strategically aligned businesses.
Commercial information (transaction history, products/services purchased, obtained or considered and product preferences) Individuals submitting information to us. Information we automatically collect from website visitors. Performing services for you. Advertising customization. Auditing relating to transactions. Internal research and development. Security detection, protection and enforcement. Functionality debugging, error and repair. Quality control. Functionality debugging, error and repair. Quality control. Service providers (such as those listed in Section 7). Affiliated companies. Government regulators. Law enforcement. Strategically aligned businesses.
Protected classification information (racial or ethnic origin, religious or philosophical beliefs and sexual orientation) Individuals submitting information to us. Performing services for you. Auditing relating to transactions. Internal research and development. Security detection, protection and enforcement. Service providers (such as those listed in Section 7). Affiliated companies. Government regulators. Law enforcement. Strategically aligned businesses.
Professional or employment-related information (cover letter, job role and Victaulic office location interested in, preferred job conditions, professional history, academic history, answers to questions about suitability for a position, extracurricular activities, professional references, and professional and personal competencies) Individuals submitting information to us. Performing services for you. Auditing relating to transactions. Internal research and development. Security detection, protection and enforcement. Service providers (such as those listed in Section 7). Affiliated companies. Government regulators. Law enforcement. Strategically aligned businesses.
Internet or other electronic network activity (IP address, web browser type and version, the operating system used and the domain name of your internet service provider, information about your visit, including pages you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page) Information we automatically collect from website visitors. Advertising customization. Auditing relating to transactions. Internal research and development. Security detection, protection and enforcement. Functionality debugging, error and repair. Quality control. Service providers (such as those listed in Section 7). Affiliated companies. Government regulators. Law enforcement. Strategically aligned businesses.
Geolocation Information we automatically collect from website visitors. Advertising customization. Auditing relating to transactions. Internal research and development. Security detection, protection and enforcement. Functionality debugging, error and repair. Quality control. Service providers (such as those listed in Section 7). Affiliated companies. Government regulators. Law enforcement. Strategically aligned businesses.
Inferences from the above (preferences, characteristics, behaviour, attitudes and abilities, etc.) Internal analytics Advertising customization. Auditing relating to transactions. Internal research and development. Security detection, protection and enforcement. Functionality debugging, error and repair. Quality control. Service providers (such as those listed in Section 7). Affiliated companies. Government regulators. Law enforcement. Strategically aligned businesses.

*The business purposes also include those listed at Section 5 of this Statement.

Sale of personal information

In the preceding twelve (12) months, Victaulic may have sold the following categories of personal information:

  • Identifiers;
  • Sensitive information;
  • Commercial information;
  • Protected classification information;
  • Professional or employment-related information;
  • Internet or other electronic network activity;
  • Geolocation; and
  • Inferences from the above.

Your rights and choices

As of January 1, 2020, if you are a verified California resident, you have the right to obtain certain information about our collection and use of personal information over the past twelve (12) months, including:

  • The categories of personal information we collect;
  • The categories of sources of personal information we collect;
  • Our business purpose for collecting or sharing that personal information;
  • The categories of third parties with whom we share that personal information;
  • The specific personal information we have collected about you over the past twelve (12) months;
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
    • the categories of personal information sold and the category of third party recipients; and
    • list of the categories of personal information that we disclosed for a business purpose.

You have the right to request that we do not sell personal information about you, and to request that we delete (and direct our service providers to delete) your personal information subject to certain exceptions.

Personal information sales opt-out and opt-in rights

If you are sixteen (16) years of age or older, you have the right to direct us to not sell your personal information at any time (the "right to opt-out"). We do not sell the personal information of individuals we actually know are less than eighteen (18) years of age.  To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following page: https://www.victaulic.com/california-consumer-privacy-act/.

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales.

Exercising your rights

You can exercise any of these rights by contacting us using the contact details set out above or you may submit a request to us by visiting the following page https://www.victaulic.com/request-submission-page/.  You may make a request up to twice within a twelve (12) month period.  You may also call us on the following toll free telephone number:  1-866-842-2927.

We will ask you for information that allows us to reasonably verify your identity (that you are the person about whom we collected personal information) and we will use that information only for that purpose. We cannot respond to your request or provide you with personal information if we cannot verify your identity and confirm that the personal information relates to you.

Response timing and format

We will endeavour to respond within forty-five days of receipt of your request, but if we require more time (up to an additional forty-five days) we will notify you of the reason and extension period in writing.

Where you request a copy of your personal information, we will endeavour to provide the information in a format that is readily useable, including by mailing you a paper copy or providing an electronic copy.  Any disclosures we provide will only cover the twelve (12) month period preceding the receipt of you verified request.

We do not charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

We will not discriminate against you as a result of your exercise of any of these rights.

9. SAFETY AND CONFIDENTIALITY

9.1. Victaulic undertakes reasonable efforts as required by applicable law to keep your personal data accurate, complete and up-to-date and to prevent: (i) unauthorized access to, collection, use, disclosure or modification of, your personal data; and (ii) loss, abuse or alteration of your personal data, by using physical, administrative and technological measures to protect the personal data maintained, such as use of:

  • Access controls;
  • Strong passwords and log-in credentials;
  • Strong configuration standards;
  • Encryption;
  • Firewalls and anti-malware software; and
  • Advanced security software.

9.2. You shall be solely responsible for your own user content, such as content you upload to the Websites or services, or Candidate Pool and the consequences of posting submitting and/or publishing it. Victaulic is not responsible or liable to you or any third party for the content or accuracy of any user content posted by you or any other user of the Websites or services, and Victaulic expressly disclaims any and all liability in connection with user content to the fullest extent permitted by applicable law.

9.3. Once the personal data you submit to the Candidate Pool is stored with Victaulic, only the following persons are authorized to access your personal data for the purposes specified in this Privacy Statement:

  • Authorized staff working with recruitment in the Victaulic HR departments;
  • Victaulic's shared services centers which co-ordinate recruitment in the regions in which Victaulic operates;
  • Authorized suppliers that we contract to process your personal data on our behalf; and
  • The people involved in the individual recruitment process at Victaulic companies.
Effective Date: January 10, 2020