Privacy Statement

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or where you have given your informed consent to such processing if required by applicable law (such consent can be withdrawn at any time), where you are a: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.

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 [email protected]. 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 the 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 the 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 the processing is based on consent, you may have the right to withdraw such consent.  In some cases, if you withdraw your consent to the 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 [email protected], or to exercise rights in relation to the Candidate Pool send an email to [email protected] 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 a 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.