We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“Personal Information”). In particular, we have collected the following categories of personal information from consumers, also referred to as customers, contacts and prospects, within the last twelve (12) months:

Additionally, as part of our business operational requirements we may collect or process various information that you voluntarily provide to us, including personal contact details, and information related to your purchases, employment or demographic as well as information that we have received about you from third parties. In particular, we may collect the following information:

• Personal contact details including names, business addresses, telephone numbers, or e-mail addresses such as when you provide them to us during online registration or when doing business with us or providing services to us; some websites allow you to establish a user name and password to set up an account or subscribe to our newsletters.
• Purchase-related information including data regarding purchases you make via our Sales Teams or ERP systems, payment card or bank detail information and shipping details.
• Employment-related information including your indicated job preferences, work history and information provided on applications submitted to us electronically.
• Demographic information that you voluntarily provide to us including data such as age, gender, ethnicity, hobby or activity information, taste or other preference information, and the like.

We may collect information from other sources, including contact lists and demographic information from third parties and other sources. This data may be combined with other information that we collect and use for the business purposes described in this Privacy Statement.

All of this information is collected directly from you, as well as through third parties that you have authorized to provide such personal information, and where permitted by local law, through publicly available sources, including without limitation, social media. We also collect certain types of information automatically, including your Internet Protocol (IP) address or device identifier, your device’s operating system, browser type, websites visited before or after you visit our website, pages viewed and activities at our website, as well as your interaction with advertisements. Third-party service and advertising partners may also collect information automatically.

Personal information does not include:

• Publicly available information from government records.
• De-identified or aggregated consumer information.
• Information excluded from the CCPA's scope, like:
• Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
• Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from our customers, contacts, prospects or associates. For example, from documents that our clients provide to us related to the products and services for which they engage us or purchase from us.
• Directly from our customers, contacts, prospects or associates. For example, through information we collect from them in the course of offering products or providing services to them.
• Directly and indirectly from activity on our website (www.nch.com and other websites used by our subsidiaries). For example, from submissions through our website portal or website usage details collected automatically.
• From third parties that interact with us in connection with the services we perform. For example, from submissions relative to product sales, supply chain and transportation.

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[1] NCH collects personal information (PI) on its employees as part of the human resources function pursuant to employment with the company. This includes PI of contractors, job applicants, independent contractors and employees, who are generally referred to as (“Associates”).

We may use, share or disclose the personal information we collect for one or more of the following business purposes:

• To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information in order for us to send you products or materials about our products, or for us to service a water treatment contract, we will use that information only for the purpose of that contract, and possibly marketing to you additional services similar to what you already have.
• To provide you with information, products or services that you request from us.
• To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
• To improve our website and present its contents to you.
• For testing, research, analysis and product development.
• As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
• As part of human resources we will collect personal information as it relates to employment with the company.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

We retain and store your personal information only for as long as is necessary for the purposes set out in this Privacy Statement. We retain and use your information to the extent necessary to comply with our legal obligations (e.g. tax laws), resolve a legal dispute, pursue a legal right and/or enforce contracts and agreements, to pursue our legitimate business interest and/or in accordance with your consent. We only collect and retain PI which is reasonable, necessary and proportionate to achieve our business purpose.

Any data that we collect will be retained in accordance with our Record Retention Policy – which sets out specific retention periods as required by applicable local regulations and NCH policy. A copy of said policy may be obtained by contacting our Data Protection Officer at NorthAmericaDataPrivacy@NCH.com.

We may disclose your personal information to our affiliates or a third party for a business purpose. These third parties include vendors, suppliers, agents and other service providers we have hired such as banking institutions, payroll services, credit card processors, insurance and health care providers. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we have not sold any personal information to outside third parties for commercial purposes.

The CCPA provides consumers, customers, contacts and prospects who are California residents, with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing such information would be required:
  • sales, identifying the personal information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
  • WE NOTE THAT NCH DOES NOT SELL YOUR PERSONAL INFORMATION.

Because NCH does not sell the personal information of our customers, contacts and prospects, it is not necessary for NCH, or our subsidiary companies to have a clear and conspicuous “Do Not Sell My Personal Information” link to any of our business Internet home pages.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code ยง 1546 seq.).
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request using the following Data Subject Rights Request form by calling us, emailing us or mailing your request to the address below:

NCH Corporation

Attention: Data Protection Officer

2727 Chemsearch Boulevard, Irving, Texas, 75062

United States of America

Toll Free: 1-800-527-9919

Email: NorthAmericaDataPrivacy@NCH.com

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

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

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer 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.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

We may offer chat rooms, message, bulletin boards, or interactive areas where visitors may post comments or information, including personal information. In any such case, be sure to check posted rules before entering, as you will be bound by them as well as our General Terms and Conditions. Rules for participation in interactive features may establish age and other restrictions on participation. Anything you post online is public information, and we are not responsible for anything you voluntarily post online. Users should exercise caution when disclosing personal information online as that information can be read, collected and used by other users of these services and may result in unsolicited messages, both commercial and otherwise.

California’s “Shine the Light” Law (Civil Code Section § 1798.83) permits users of our website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to the address above.

We reserve the right to amend this Privacy Statement at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage. This Privacy Statement is effective as of December 15, 2019 and was revised on March 20, 2023.

If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at: