This Privacy Statement sets out guiding principles to be applied to the collection, use, processing, retention, and disclosure of Personal Data, including those relating to NCH’s customers, suppliers, vendors, contractors, business partners, website visitors, job candidates and, if applicable, former and/or current employees. This includes all storing and processing of files in an electronic or paper form, including electronic mail and transmittal of documents as well as information shared with third parties.

This Privacy Statement applies to any personal information collected or processed through the websites (including this website), internal sites, mobile applications, webinars and other services and products that collect or process data. It also applies to data collected in connection with marketing or sales activities, prospective or current employment or other engagement with NCH.

This Privacy Statement applies to your personal information, which is any information or combination of information that could reasonably be used to identify you.

We adapt our privacy practices and comply with the regional and country-specific data protection laws like for example the General Data Protection Regulations (GDPR) 2016 as well as laws (CCPA, PIPEDA, KVKK etc) and if required cooperate with the country Data Protection Authorities.

We recognize that certain laws may provide stricter standards than those described in this Privacy Statement, in which case the stricter standards shall apply. NCH will handle Personal Data in accordance with local law of the place where the Personal Data is collected and/or processed.

If you are in the European Union, in Switzerland, Uk or Turkey , the respective NCH subsidiary or affiliate you have a business relationship with will be the data controller or data processor responsible for the collection, processing and use of your personal information.

In Europe your data is also processed by NCH Corporation and NCH UK Ltd which serves as NCH Europe’s main and regional headquarters. In this case many local regulations require that a representative in the respective country or region is nominated.

If you are a California resident, California Consumer Privacy Act (CCPA) may provide you with additional rights regarding NCH’s use of your personal information. To learn more about your California privacy rights please refer to https://www.nch.com/Privacy-Policy/California-Residents-Privacy-Statement

In other countries (and states) where NCH does business, you must refer to the local Data Protection Authority in the country/state where the data subject resides.

As part 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 purchase, employment or demographic information, 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.
• Images recorded via CCTV whenever you visited our sites where this equipment is installed.

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:

• 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.

We may use your information only for a purpose for which you provided the information to us.

If you or the company you represent are a Customer or a Vendor - We may use the information to (i) fulfill a contractual obligation such as providing or receiving products or services to or from you, (ii) because you have provided consent or explicit permission, or (iii) for other legitimate business interests explained as follows:

• To engage with you and explore business opportunities;
• To communicate and respond to your questions and comments about features, products and services you may be interested in;
• To register and facilitate contests and promotions as well as features, products and services in line with your chosen marketing preferences;
• To provide you with personalized content, information, and to send you brochures, product discounts, samples, offers, newsletter and other information on our products or our group of companies; We may ask you to indicate if you would like further information or updates from us or our website and only if requested, you will receive follow-up communications from us. We may also ask if you would like to receive information about other products available from members of our group of companies. After opting in to receiving communications from NCH, should you change your mind we also offer visitors an “opt-out” option at any time they wish to cease receiving e-mails or other information from us;
• To deliver to you relevant advertising. We may purchase and use opt-in e-mail lists to contact potential customers who we believe may be interested in products or services from the NCH group of companies. We will honour opt-out requests and ask those providing lists to give us assurances that e-mail contact information is provided only for individuals who have expressed a desire to receive offers and information by e-mail. We also may use demographic and preference information to allow advertising related to NCH products and services to be targeted to the users for whom they are most pertinent. This is designed so that users will see advertising that is most likely to interest them, and advertisers can display their ads to people who are most likely to be receptive.
• To provide you with other offers, including catalogues, available to you through the mail. We may also use lists we have received from third parties or public sources to send you this information. You may “opt-out” of receiving offline communications from any of our companies at any time.
• To improve our websites, features, products and services;
• To improve efficiency and effectiveness of service to our customers.

If you or the company you represent, are a Website Visitor - We may use your information after you have provided consent or explicit permission , to administer promotions (sweepstakes, contests and offers); to communicate with you; to deliver advertising; to improve our websites, products and services; and for other legitimate business interests explained as follows:

• To enter you in contests and/or promotions to notify you of results and to register you for certain features, products and services in line with your chosen marketing preferences.
• To communicate with you, to respond to your questions or comments.
• To provide you with personalized content, information, and to send you brochures, products discounts, samples, offers and other information on our products or our group of companies. We ask visitors providing e-mail addresses to indicate if they would like further information or updates from us or our website and only those who request it will receive follow-up communications from us. We may also ask if you would like to receive information about other products available from members of our group of companies. After opting in to receiving communications from NCH, should you change your mind we also offer visitors an “opt-out” option at any time they wish to cease receiving e-mails or other information from us.
• To deliver to you relevant advertising;
• We may purchase and use opt-in e-mail lists to contact potential customers who we believe may be interested in products or services from the NCH group of companies. We will honour opt-out requests and ask those providing lists to give us assurances that e-mail contact information is provided only for individuals who have expressed a desire to receive offers and information by e-mail. We also may use demographic and preference information to allow advertising related to NCH products and services to be targeted to the users for whom they are most pertinent. This is designed so that users will see advertising that is most likely to interest them, and advertisers can display their ads to people who are most likely to be receptive.
• To provide you with other offers, including catalogues, available to you through the mail. We may also use lists we have received from third parties or public sources to send you this information. You may “opt-out” of receiving offline communications from any of our companies at any time.
• To improve our websites, features, products and services.
• We use Cookie technology to collect additional information about visitors to our website. For more information, see NCH Cookies Policy.

If you are a Job Candidate and/or interested in employment with NCH we may use your information after you have provided consent, to facilitate the recruitment process and your job application, communicate with you, to respond to your questions or comments, to provide you with updates and news and to alert you when job vacancies that fit your profile arise (in the event that you submit your resume). We also may use your information to provide you with personalized content and other information about our group of companies. You may “opt-out” of receiving communications from any of our companies at any time.

We will never share your personal data with any third party that intends to use it for their own purpose, other than if required by law, nor would be ever sell your personal data. NCH is a business to business entity and as part of a worldwide conglomerate group of businesses, may transfer or disclose your personal data to another entity/subsidiary within the NCH group, based either in the European Economic Area (EEA), in the United Kingdom (UK), or in the United States.

We may share your personal data with vendors, suppliers, agents or other providers whom we have hired to provide services on our behalf. When we share information with these other companies to provide services for us, they are not allowed to use it for any other purpose and must keep it confidential unless you otherwise consent or provide explicit permission.

We may share or disclose your personal data to third parties along with other business assets in the event of a sale of the business, reorganization of the business or as otherwise required or permitted by applicable laws. In the event that all or part of our assets are sold or acquired by another party, or in the event of a merger, you grant us the right to assign the personal information we have collected from you.

We also may share or disclose personal information, including the content of your communications:

• To comply with the law or respond to legal process or lawful requests, including from law enforcement and government agencies.
• To conduct investigations of customer complaints or possible breaches of law, to protect the integrity of the website, to fulfil your requests, or to cooperate in any legal investigation.
• To protect the rights or property of the NCH group of companies or our customers, including enforcing the terms governing your use of the services.
• To act on a good faith belief that access or disclosure is necessary to protect the safety of our associates, customers or the public.

Our websites and/or business services are primarily designed and intended for business purposes and therefore intended for adults and teens (age 16 and older) only, and not directed to children under age 16. In accordance with the applicable children privacy regulation, such as for example Children’s Online Privacy Protection Act (COPPA) and the General Data Protection Regulations (GDPR), we do not knowingly collect or store any personal information about children under age 16, and our business websites are not designed to collect personal information from children under age 16. Where local law imposes higher age thresholds, we will comply with such requirements. If we become aware that information has been collected, we are committed to taking appropriate steps to remove the information.

Personal information collected on our websites and through our services, or received by NCH from you or third parties in connection with NCH’s business, may be stored and processed in the EEA, UK, United States or any other country where we or our service providers maintain facilities.

The servers and databases in which information may be stored may be located outside the country from which you accessed this website, other sites or services, and in a country that does not have the same privacy laws as your country of residence. The personal information you provide us may be transmitted abroad, but we will collect, process and use personal information only in accordance with this Privacy Statement. Any and all providers of services to us which maintain those servers and databases are bound by a contract that ensures your data is being managed in accordance with this Privacy Statement, that the provider acts only on NCH’s instructions and implements all technical and organizational measures to ensure that your personal data remains secure at all times.

Employment-related queries may also be transferred to any member of the NCH group of companies. By visiting this website and submitting information, you consent to such collection, processing, transfer and/or storage of your personal information. Please note: our policies may differ by country, region, or state, so if you visit one of our websites in a different region, please check to see if there is a statement specific to that location.

NCH is a global company in 56 countries and your personal data may be transferred to our affiliates and subsidiaries or to other third parties, across borders, and from your country or jurisdiction to other countries or jurisdictions around the world in accordance with legal regulations. NCH has, where local data protection regulations so require, put in place security measures for the export of personal data from that jurisdiction. In the event data is transferred from within the EEA UK or Switzerland to a jurisdiction outside of the EEA, UK or Switzerland, it is done so under a Data Transfer Agreement, which incorporates standard data protection contract clauses adopted and promulgated by the European Commission. These standard data protection clauses, also called Model Clauses, provide adequate safeguards for personal information being transferred outside of the EEA UK or Switzerland. For more information about international transfer of your personal data, you may contact our Data Protection Officer at DataPrivacy@nch.com.

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 legitmate business interest and/or in accordance with your consent. Any data that we collect is being retained in accordance with our Record Retention Policy – which sets out specific retention periods as required by applicable local regulations. A copy of said policy may be obtained by contacting our Data Protection Officer at DataPrivacy@nch.com.

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.

We do not endorse and are not responsible for the content or practices of web sites operated by companies outside of NCH that may be linked to any of our websites or services. If you submit personal information to any of those websites, your information is governed by the privacy policies on those websites. We encourage you to review the privacy policy of any website you visit.

We have implemented organizational, physical and technical safeguards designed to protect your information. We protect personal data under our control by implementing industry standard security practices and measures in order to prevent misuse, unauthorized access, disclosure or alteration of the information. We limit access to personal information to those who have a business need for such information. No security measures can be 100% secure, however, we recommend that you take additional measures to protect yourself and your information, for example, by installing up to date anti-virus software, closing browsers after use, keeping confidential your log-in credentials and passwords, and making sure that you regularly update software and applications you have downloaded to ensure you have enabled the latest security features on your devices.

We take steps to keep your personal information accurate. You can view, correct or update the personal contact information you provide to NCH. For example the General Data Protection Regulations (GDPR) 2016 as well as laws (CCPA, PIPEDA, KVKK etc) in other local countries provide you with the right to access the data we hold about you or to authorise someone to act on your behalf. You can ask what data we are holding about you, ask us to modify or correct data that is incorrect, ask for restricting the use of or removing the data we hold, provided that there are no legal reasons for us to process and/or retain the data. For data processed by automated means, you can request to have it provided in a structured, commonly used and machine-readable format to be transferred to another data controller. Your request will be processed within 30 calendar days upon receipt of a fully completed form and proof of identity. Request should be made by completing the attached Data Subject Rights Request form and submitting it by email to:

(*) European DPO also supports NCH subsidiaries in Switzerland, Turkey and United Kingdom

You can also send your questions via normal post to the local NCH subsidiary, as per the contact section on https://www.nch.com/Global-Presence/Global-Directory.

Reasonable access to your personal data will be provided at no cost to you. If access cannot be provided within a reasonable time frame, we will provide you with a date when the information will be provided. If for some reason access is denied, we will provide a written explanation as to why access has been denied.

If you would like to access, update, change, delete, transfer, restrict or object to the processing of the information we have about you in our database (subject to any applicable legal exceptions), opt-out of receiving further communications from us, or have questions about our Privacy Statement, please contact our Data Privacy Officer at DataPrivacy@nch.com

Where our processing of your information is based on your consent, you may have the right to withdraw your consent by contacting us by e-mail at DataPrivacy@nch.com. Note that your withdrawal of consent will not affect the lawfulness of our processing of your information based on your consent provided prior to your withdrawal. Where appropriate, you may also have the right to lodge a complaint with your local data protection authority. We are intent on resolving any issues relating to our handling of your information, and you may contact us at any time regarding any questions or concerns.

You have the right to file a complaint concerning our processing of your personal data. We are committed to working with you to resolve any complaints you may have regarding this Privacy Statement or the treatment of your personal information. We have appointed internal Data Protection Officers whom you can contact if you have a concern or questions regarding this Privacy Statement. Their contact information are as follows:

(*) European DPO also supports NCH subsidiaries in Switzerland, Turkey and United Kingdom

You may also lodge a complaint with the data protection authority in your country of residence or with the Data Protection Commission (DPC) in Ireland which is NCH’s nominated Leading Supervisory Authority in the EEA.

We may update this Privacy Statement from time to time, so please visit this page periodically and review this statement for changes. We will notify you of material changes to this privacy statement by posting a notice on our home page for a reasonable period of time and changing the “Last Updated” date below. Your continued use of our websites, applications or services following the posting of changes will mean that you accept the changed terms.

This Privacy Statement was drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of NCH’s collection and use of your personal information.

You can also send your questions via normal post to the local NCH subsidiary, as per the contact section on https://www.nch.com/Global-Presence/Global-Directory.

We do not support “Do Not Track” browser settings and do not currently participate in any Do Not Track frameworks that would allow us to respond to signals or other mechanisms from you regarding the collection of your personal information.

If there is any conflict between the English version of our Privacy Statement and a version translated in another language, the English version controls (to the extent that local regulation allows).

This Privacy Statement has been reviewed and Last Updated: 15 December 2020.