Transcontinental Advanced Coatings – Privacy Policy

Last Updated : 15 October 2018

We respect the privacy of every person who visits or registers with Transcontinentaladvancedcoatings.com  (the “Site”) and who uses the services that we make available from the Site or who engages with us to purchase products or services (be it through the Site or not) (our “Services”) and we are committed to ensuring a safe online experience.

1. Purpose of this Policy

This privacy policy (“Privacy Policy”) explains our approach to any personal information that we might collect from you or which we have obtained about you from a third party and the purposes for which we process your personal information. This Privacy Policy also sets out how we process personal data in relation to any third party who assists us in providing the Site or the Services. This Privacy Policy also sets out your rights in respect of our processing of your personal information.  

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2. Who are we and what do we do?

The Site and our Services are operated by Transcontinental Holding Corp. (“we”, “us” or “our”).  

Transcontinental Holding Corp. is the data controller responsible for your personal information processed via the Site. Transcontinental Holding Corp. is a corporation organized under the laws of the State of Delaware, U.S.A., and has a registered address at 1209 Orange Street, Wilmington, Delaware, 19801 USA; its registered Delaware corporation number is 3380441.

Please note that depending on from which country you access the Site or with which Transcontinental entity you contract in relation to the Services the following entities may also be data controllers responsible for your personal information processed in relation to the Services:

Transcontinental Holding Corp.

Transcontinental US LLC

Transcontinental AC UK Ltd.

Transcontinental AC US LLC

Transcontinental Matthews LLC

Transcontinental Ontario Inc.

Transcontinental TVL LLC

Transcontinental Michigan Inc.

Transcontinental Packaging Whitby ULC

McNeel International Corp.

Petrochem Corp.

Olefinas S.A.

Olefinas C.R.S.A.

Olefinas Panama S.A.

Olefinas S.L.P, S.A. de C.V.

Tyrachem, LLC

Surpaplast S.A.

Transcontinental New Zealand Limited

Transcontinental Australasia Pty Limited

 

How to contact us?

If you have any questions about this Privacy Policy or want to exercise your rights set out in this Privacy Policy, please contact us by sending an e-mail to ISO.Coatings@tc.tc

3. What personal information do we collect and how do we use it?

Our primary goal in collecting personal information from you is to: (i) verify your identity; (ii) help us improve our products and services and develop and market new products and services; (iii) carry out requests made by you on the Site; (iv) investigate or settle inquiries or disputes; (v) comply with any applicable law, court order, other judicial process, or the requirements of a regulator; (vi) enforce our agreements with you or third parties; (vii) protect the rights, property or safety of us or third parties, including our other customers and users of the Site; (viii) provide support for the provision of our Services; and (ix) use it as otherwise required or permitted by law.

To undertake these goals we normally process the following personal information:

• Name, job title and company name.
• Contact information including email address.
• Demographic information such as postcode, preferences and interests.
• Other information relevant to provision of services.

In particular, we use your personal information for the following purposes:

• Fulfilment of products and services.

We collect and maintain personal information that you voluntarily submit to us during your use of the Site and/or in relation to provision of the Services. We use the contact details you have provided to us so that we can respond to requests for information, fulfil the supply of products and services you have ordered from us, or when providing Services.

What is our legal basis?

It is in our legitimate interest to use your personal information in such a way to ensure that we can undertake any Services administration necessary.

• Customer services.

Our Site uses various user interfaces to allow you to request information about our products and services, including printed and electronic enquiry forms. Contact information may be requested in each case, together with details of other personal information that is relevant to your customer service enquiry. This information is used in order to enable us to respond to your requests.

Who do we share your personal information with for this purpose?

We do not share your personal information for this purpose.

• Your feedback about our products and services.

From time to we will contact you to invite you to provide feedback about our products and services in the form of online or postal surveys. We use this information to help us improve the quality of service provided by our staff. We also use your feedback to monitor the quality of our products and services and to assist with the selection of future product and service lines.

Who do we share your personal information with for these purposes?

We use third party service providers to assist us with customer surveys and feedback requests. Our third party providers are located in Canada and the USA, and their use of your information is governed by EU Model Contracts.

What is our legal basis?

It is in our legitimate business interests to use the information you provide to us in your feedback for the purposes described above.

• Business administration and legal compliance.

We use your personal information for the following business administration and legal compliance purposes:

• to comply with our legal obligations (including any Know Your Client or Anti-Money Laundering or Anti-Bribery obligations or Export Control and Trade Sanctions restrictions);

• to enforce our legal rights;

• to undertake any administrative tasks in relation to any third parties who help us provide the Site or the Services to customers (and similar);

• to protect rights of third parties; and
• in connection with a business transition such as a supply deal with a third party company or a merger, or acquisition by another company, or sale of all or a portion of our assets.

Who do we share your personal information with for these purposes?

We will share your personal information with professional advisers such as lawyers and accountants and/or governmental or regulatory authorities. We also share your data with one or more third party software providers, each of which hosts a data base of entities and individuals restricted under trade sanctions laws of the countries in which we operate.  These providers are located in Canada and the USA and their  use of your personal information is governed by EU Model Contracts.

What is our legal basis?

Where we use your personal information in connection with a business transition, enforce our legal rights, or to protect the rights of third parties it is in our legitimate interest to do so. For all other purposes described in this section, it is our legal obligation to use your personal information to comply with any legal obligations imposed upon us such as a court order.

Where we share your sensitive personal information, we shall obtain your consent to do so.

• Customer insight and analysis.

We analyse your contact details with other personal information that we observe about you from your interactions with our Site, our email communications to you and/or with our products and services such as the products and services you have purchased or viewed.

Where you have given your consent (where lawfully required), we use cookies, log files and other technologies to collect personal information from the computer hardware and software you use to access the Site, or from your mobile. This includes the following:

• an IP address to monitor Site traffic and volume;

• a session ID to track usage statistics on our Site;

• information regarding your personal or professional interests, demographics, buying habits, experiences with our products and contact preferences.

Our web pages and e-mails contain “cookies” “web beacons” or “pixel tags.” (“Tags”). Tags allow us to track receipt of an e-mail to you, to count users that have visited a web page or opened an e-mail and collect other types of aggregate information. Once you click on an e-mail that contains a Tag, your contact information may subsequently be cross-referenced to the source e-mail and the relevant Tag.

In some of our e-mail messages, we use a “click-through URL” linked to certain websites administered by us or on our behalf.

Please see our cookie policy for further .

This information is used to create profiles and insights about your shopping habits and the shopping habits of our other customers. Where we have your consent to do so, we will also use your location data for customer insight purposes. 

By using this information, we are able to measure the effectiveness of our content and how visitors use our Site and our Services. This allows us to learn what pages of our Site are most attractive to our visitors, which parts of our Site are the most interesting and what kind of offers our registered users like to see.

We also use this information to help us with the selection of future product and service lines, and website design and to remember your shopping preferences.

We also use this information for marketing purposes (see the marketing section below for further details).

Who do we share your personal information with for these purposes?

We share your personal information with a variety of third party service providers to assist us with customer insight analytics. These providers include Thrivehive, Parker Design  and  TOMO 360.  Other providers are described in our Cookie Policy.

Some of our third party providers are located in Canada and/or the USA and their use of your personal information is governed by EU Model Contracts.

What is our legal basis?

Where your personal information is completely anonymised, we do not require a legal basis to use it as the information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Please see our Cookie Policy for further details.

Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best products and services to you and our other customers.

We will only use your location data for customer insight purposes where we have your consent to do so.

• Marketing communications.

We carry out the following marketing activities using your personal information:

• Postal marketing.

We use information that we observe about you from your interactions with our Site, our email communications to you and/or with our products and services (see the Customer Insight and Analysis section above for more details of the information collected and how it is collected) and/or your address details, to send you marketing communications by post.

Who do we share your personal information with for these purposes?

We share your personal information with a variety of third party postal providers who assist us in delivering our postal marketing campaigns to you, including the post office.

What is our legal basis?

Where your personal information is completely anonymised, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised information may be subject to other laws where your consent is required. Please see our Cookie Policy for further details.

Where your personal information is not in an anonymous form, such as your postal address, it is in our legitimate interest to use your personal information for postal marketing.

We will only use your location data where we have your consent to do so.

• Email marketing.

We use information that we observe about you from your interactions with our Site, our email communications to you and/or with our Services (see the Customer Insight and Analysis section above for more details of the information collected and how it is collected) and/or your email address, to send you marketing communications by email, where you have consented to receive such marketing communications, or where we have another lawful basis to do so.

Who do we share your personal information with for these purposes?

We share your personal information with a variety of third party email marketing providers who assist us in delivering our email marketing campaigns to you.

What is our legal basis?

Where your personal information is completely anonymised, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Please see our Cookie Policy for further details.

Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes.

We will only send you marketing communications via email where you have consented to receive such marketing communications, or where we have a lawful right to do so.

• Social media remarketing.

We may use information that we observe about you from your interactions with our Site, our email communications to you and/or with Services (see the Customer Insight and Analysis section above for more details of the information collected and how it is collected) to provide you with personalised advertising on social media channels operated by LinkedIn, Twitter, YouTube, Facebook and/or Google where you are a registered user of such services.

We may do this using Facebook Customer Audiences and/or Google Customer Match respectively. Please note that any such activity is also subject to the privacy choices you have elected to make on such services.

Who do we share your personal information with for these purposes?

We share your email address with third party service providers who assist us with social media remarketing campaigns.

Your encrypted email address is also shared by us or our third party service providers with Facebook and/or Google under the terms of their Facebook Customer Audiences and/or Google Customer Match services respectively.

What is our legal basis?

Where your personal information is completely anonymised, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Please see our Cookie Policy for further details.

Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes.

We will only engage in social media remarketing where you have consented to us using your email address for marketing purposes.

• Social media insight.

Where you are a registered user of Facebook, or of a Google service, we may use your email address in an encrypted format to enable Facebook and Google to find other registered users of their services that share similar interests to you based on:

• information that we observe about you from your interactions with our Site, our email communications to you and/or Services (see the Customer Insight and Analysis section above for more details of the information collected and how it is collected); and

• the information Facebook and/or Google hold about you.

We may do this using Facebook Lookalike Audiences and/or Google Similar Audience respectively. Please note that such activity is subject to the privacy choices you have elected to make on such services.

Who do we share your personal information with for these purposes?

We may share your email address with third party service providers who assist us with social media remarketing campaigns.

Your encrypted email address also may be shared by us or our third party marketing consultancies with Facebook and/or Google under the terms of their Facebook Customer Audiences and/or Google Customer Match respectively.

What is our legal basis?

Where your personal information is completely anonymised, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Please see our Cookie Policy for further details.

Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes.

• Any other purposes for which we wish to use your personal information that are not listed above, or any other changes we propose to make to the existing purposes will be notified to you using your contact details.

4. How do we obtain your consent?

Where our use of your personal information requires your consent, you can provide such consent:

• at the time we collect your personal information following the instructions provided; or
• by informing us by e-mail, post or phone using the contact details set out in this Privacy.

5. Our use of cookies and similar technologies

Our Site use certain cookies, pixels, beacons, log files and other technologies of which you should be aware. Please see our Cookie Policy to find out more about the cookies we use and how to manage and delete cookies.

6. Third Party contractors

, such as, without limitation, website developers, hosting companies and advertising agencies who will process personal information on our behalf and at our direction.  We conduct an appropriate level of due diligence and put in place necessary contractual documentation in relation to any sub-contractor to ensure that they process personal information appropriately and according to our legal and regulatory obligations.

7. Extra-EEA Transfers

If you are based within the EEA, please note that where necessary to deliver the Services we will transfer personal information to countries outside the EEA (including to other entities that are part of (i.e. Transcontinental Holding Corp. and its affiliates listed in Section 2 above). When doing so we will comply with our legal and regulatory obligations in relation to the personal information including but without limitation putting appropriate safeguards in place to ensure an adequate level of protection for the personal information.

8. Third Party Links and Services

Our Site contain links to third party websites and services. Please remember that when you use a link to go from our Site to another website or you request a service from a third party, this Privacy Policy no longer applies.  

Your browsing and interaction on any other website, or your dealings with any other third party service provider, is subject to that website’s or third party service provider’s own rules and policies. 

We do not monitor, control, or endorse the privacy practices of any third parties.

We encourage you to become familiar with the privacy practices of every website you visit or third party service provider that you deal with and to contact them if you have any questions about their respective privacy policies and practices.

This Privacy Policy applies solely to personal information collected by us through our Service and does not apply to these third party website and third party service providers.

9. How long do we keep your personal information for?

We will retain your personal information for up to and in compliance with our obligations under the EU General Data Protection Regulation (or similar legislation around the world) (or for longer as we are required to do so according to our regulatory obligations). We may then destroy such files without further notice or liability to you. If you request your files and documents we may charge you for the costs of copying a duplicate.

If your information is only useful for a short period, e.g. for specific marketing campaigns, we may delete it.

10. Confidentiality and security of your personal information

We are committed to keeping the personal information you provide to us secure and we will take reasonable precautions to protect your personal information from loss, misuse or alteration.

We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from:

• unauthorised access;

• improper use or disclosure;

• unauthorised modification; and

• unlawful destruction or accidental loss.

All of our employees and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of the personal information of all users of our Services.

11. How to access your information and your other rights?

You have the following rights in relation to the personal information we hold about you:

• Your right of access.

If you ask us, we’ll confirm whether we’re processing your personal information and, if so, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.

• Your right to rectification.

If the personal information we hold about you is inaccurate or incomplete, you’re entitled to have it rectified. If we’ve shared your personal information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

• Your right to erasure.

You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable). If we’ve shared your personal information with others, we’ll let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

• Your right to restrict processing.

You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or you object to us processing it. It won’t stop us from storing your personal information though. We’ll tell you before we lift any restriction. If we’ve shared your personal information with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

• Your right to data portability.

With effect from 25 May 2018, you have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.

• Your right to object.

You can ask us to stop processing your personal information, and we will do so, if we are:

• relying on our own or someone else’s legitimate interests to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or
• processing your personal information for direct marketing.
• Your rights in relation to automated decision-making and profiling. You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us.
• Your right to withdraw consent. If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.
• Your right to lodge a complaint with the supervisory authority. If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you can report it to the UK Information Commissioner’s Office (ICO). You can find details about how to do this on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.

12 Children’s Privacy

We do not knowingly collect personal data from children. We do not take specific steps to protect the privacy of children who disclose their personal data to us. We do not provide information about our personal data practices in relation to children on our homepage, or at those sites on our website where we collect personal data.

13. Changes to this Privacy Policy

We may make changes to this Privacy Policy from time to time.

To ensure that you are always aware of how we use your personal information we will update this Privacy Policy from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements. We will notify you by e-mail of any significant changes. However, we encourage you to review this Privacy Policy periodically to be informed of how we use your personal information.