We are committed to protecting your privacy when you use our online services or when you purchase goods or products from us.
Please read our Global Privacy Notice carefully as it contains important information to help you understand our practices regarding the use of your personal information by Element.
Introduction
EM Topco Limited and all its subsidiaries (“Element” or “the Group”) are committed to complying with internationally recognized standards of privacy protection and applicable data privacy and security laws in the countries in which we operate. Element’s head office is at 3rd Floor Davidson Building, 5 Southampton Street, London, United Kingdom, WC2E 7HA. In this notice, references to “we”, “us” or “our” are references to Element.
This Global Privacy Notice applies to all personal information we collect, use and process about you when you purchase products from us or use our services.
California Residents
If you are a California resident, please read our California Privacy Notice.
Who is collecting Personal Information?
The Group comprises of multiple legal entities acting as separate data controllers, responsible for processing personal information in connection with our business. Please see our ‘Element Legal Entities Processing Personal Information’ PDF for further details on the companies within the group processing personal information.
What Personal Information we may collect
We may collect and process your personal information in connection with our products or services at the start of, and for the duration of, your relationship with us and beyond. We will limit the collection and processing of your personal information to information necessary to achieve one or more legitimate purposes, as identified in this notice.
We will only process sensitive personal information where we’ve obtained your explicit consent or are otherwise lawfully permitted to do so. Where you have provided consent for us to process your sensitive persona information, you can withdraw that consent at any time by contacting us.
We may collect the following categories of personal information about you:
Personal Information Category |
Personal Information Collected |
Identity information |
First name, middle name, last name, alias, username or similar identifier, marital status, title, date of birth, gender, state or national identification number (such as a driver license, national insurance number or social security number), passport number, internet protocol (IP) address, signature |
Sensitive information |
Racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, health data, sex life or sexual orientation, Social Security number, driver’s license or state ID number, passport number |
Demographic information |
Age, gender, race, nationality, ethnicity, ethnic origin, citizenship, marital status, income, education, religion, citizenship, physical or mental disability, veteran or military status |
Contact information |
Home, delivery, or billing address (including street address, city, state, town, postal code / zip code), telephone numbers, email address |
Contractual information |
Personal information (as outlined in the other categories) collected as part of the products and services we provide to you. |
Commercial information |
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. |
Financial information |
Bank account, payment card details, invoice amounts, payment amount, outstanding balances. |
Internet or another similar network activity information |
Internet Protocol (IP) address, smart device information, location coordinates, site visits, browsing history, search history, information on an individual’s interaction with our websites, time zone setting and location, browser plug-in types and versions, operating system and platform, other unique personal identifier, online identifier, account name, other technology on the devices you use to access our websites and comments or other content you send to us over the internet |
Information that we gather through cookies or similar tracking tools when you use our websites |
Browser cookies, advertising cookies, targeting cookies, web beacon, pixel tag, mobile ad identifier, or similar technologies may also be used to track your responses to adverts, messages or forms, which helps us to ensure we present you with the most relevant content in the future. When running email campaigns, we may track delivery and monitor when emails are opened. For example, when you open the email a small image file may be downloaded to your web browser or email programme. You can restrict or block this type of technology through your web browser or email programme settings by preventing automatic downloading. Cookies may also be set if you click on a link within the email. |
Geolocation Data |
Physical location or movements |
Sensory Data |
Audio, electronic, visual, thermal, olfactory, call recordings, passport copies, identification document copies, CCTV images or similar information |
Professional or employment related information |
Education, current employment, employment history. |
Inferences drawn from other personal information |
Profile reflecting a person's household, individuals associated with your account(s),information regarding your relationship with these individuals, or information about your business relations with us. |
Criminal offence data
We may collect and process information about criminal convictions where such processing is necessary to act in accordance with regulatory or other legal obligations or where the processing is necessary to protect the interests of our customers or the public.
How we collect your Personal Information
We collect your personal information in a variety of ways, such as:
• Through interactions with you when you enquired about or purchased products or services from us, requested information or assistance from us, registered to attend or attended one of our events, used our website or client portal or applied for a job with us, or when you participate in product reviews, pilots, feedback sessions or similar
• Through activity on our website such as submissions from you via our website or website usage details collected automatically
• Through interactions with our clients due to your role in your organisation
• Through interactions with third parties such as industry, trade or regulatory bodies
• From third party service providers acting on our behalf in connection with the products and services we provide
• From publicly available sources including social media (LinkedIn, Facebook, Twitter), your organisation's website, the press, the electoral register, company registers and online search engines
• From automated technologies or interactions that collect technical data about your equipment, browsing actions and patterns such as cookies, server logs or other similar technologies
Purpose of processing your Personal Information
We will only use and share your personal information where it is necessary for us to carry out our lawful business activities. Your personal information may be shared with and processed by other Element group companies. Element collects and processes your personal information for purposes detailed below:
Reason for Processing Personal Information |
Purpose of Processing Personal Information |
To fulfil our contractual obligations |
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For our legitimate interest, as a commercial organisation, provided our use is proportionate and respects your privacy rights |
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To comply with a legal obligation |
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You have provided your consent to the processing |
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If you do not provide us with your personal information when requested, it may prevent us from being able to carry out the tasks listed above.
Cookies and online tracking
Our websites use cookies to distinguish you from other users and to remember your preferences when you visit our website. Cookies are small files stored on a computer that are designed to hold small amounts of data specific to a user and the websites or applications to help tailor that user’s experience. Our Cookies policy provides you with further detail about the cookies we use and the purposes for using these cookies. This policy also provides details on how you can change your settings to block or delete cookies, although some features of our website may not function as a result. Please note our websites do not recognise 'Do Not Track' signals sent by your browser. You can personalise your cookies preferences using on-site tools.
How we share your Personal Information
To help us provide our products and services to you and to run our website we may share your personal information when necessary for us to lawfully carry out our business activities. We may share your information with the following categories of third parties:
• Other group companies where it is necessary to do so, and where we have a legal basis to share the information.
• Our third-party service providers and advisors with whom we have contracted to perform services on our behalf and who process information on our behalf to provide our Services or run internal business operations including email distribution, IT services, business support and customer services.
• Independent debt recovery agencies, service providers, solicitors, or other agents in the event of non-payment for Products or Services and where a debt remains outstanding after a specified timeframe for payment, no payment plan is in place or an agreed payment plan is not being adhered to, we may initiate formal proceedings to recover the full amount of the unpaid debt. We may share your information with litigation and recovery specialists to undertake recovery action through the courts.
• Law enforcement authorities, regulatory bodies or government agencies as in some circumstances we are legally obliged to share information with law enforcement bodies, for example to comply with a court order or legal obligation. We will satisfy ourselves that we have a lawful basis on which to share the information and document our decision making.
• With a successor entity in the event of a merger, acquisition, or similar transaction.
No Sale of Personal Information
We do not sell any personal information.
How we transfer your Personal Information
We operate globally and we may transfer your personal information between Element group companies to help us operate our business efficiently and to provide you with our products and services. Third party service providers may process your personal information in connection with a service, they provide to us. When we share your personal information between Element group companies or with third parties, they may be located outside of the jurisdiction in which your personal information was collected. This means personal information collected in one jurisdiction may be transferred, stored, and processed outside the country of origin and where privacy laws differ. We only make these arrangements or transfers where we are satisfied that adequate levels of protection are in place to protect your personal information. For these transfers, we have the relevant legal safeguards in place, including (1) an Adequacy Decision in favour of the country of destination, (2) contractual arrangements based on Standard Contractual Clauses (“SCC”) pre-approved by the European Commission (or otherwise consistent with the requirements of the relevant jurisdiction) or Binding Corporate Rules (“BCR”) binding on the exporter and importer, plus a corresponding “transfer impact assessment” (“TIA”) and supplementary measures, or (3) an Article 49 exemption to the rules such as explicit consent that allows us to perform these transfers.
Following the EU’s Adequacy Decision granted on 10 July 2023, the EU-US Data Privacy Framework (“DPF”), allows self-certified US businesses to freely receive personal data from the EEA without further measures. This means that for some transfers to the US, SCCs, TIAs and supplementary measures will no longer be required.
How we protect your Personal Information
We place great importance on the security of all information associated with our customers. We invest appropriate resources and use reasonable technical and organization measures, in compliance with applicable laws, to protect your personal information from unauthorized access, unlawful processing and against accidental loss, destruction or damage. Our security and privacy policies are periodically reviewed and enhanced as necessary and only authorized personnel have access to your personal information.
Our website uses secure server software (SSL) to encrypt financial information you input before it is sent to us. We will do our best to protect your personal information, however we cannot guarantee the security of your data sent over the internet or by email. We cannot be held responsible for unauthorized or unintended access that is beyond our control.
Retention of your Personal Information
We will retain your personal information for as long as necessary to fulfil the purpose for which it was collected, such as providing our products or services, or as required by applicable laws or regulations. Our retention periods are driven by legislation and / or business need. If there is no legally defined retention period for personal information, we will determine an appropriate retention period. We will take reasonable steps to destroy personal information we hold if it is no longer needed. Retention may extend beyond the termination of our relationship with you.
CCTV
Links to other websites
You may not create a link to any of our websites from another website or document without our prior written permission.
Changes to this Privacy Notice
Marketing
Your Rights
Your Rights |
Description of Rights |
Right to know |
You may have the right to know what personal information we process about you including:
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Right to access |
You may have the right to access categories and specific pieces of personal information that we collect, use, and disclose about you |
Right of rectification |
You may have the right to ask us to rectify information you think is inaccurate or incomplete |
Right to erasure |
You may have the right to ask us to erase your personal information in certain circumstance |
Right to restriction of processing |
You may have the right to restrict the processing of your personal information in certain circumstances |
Right to object to processing |
You may have the right to object to the processing of your personal information in certain circumstances |
Right to data portability |
You may have the right to ask that we transfer any personal information you gave us from one organisation to another or give it to you. We will provide the personal information in a structured, commonly used or in machine-readable format, and transmit it directly you or the required entity |
Your right to opt out of sale of personal information |
This right does not apply as Element does not sell personal information |
Your right to non-discrimination |
You may have the right to non-discriminationfor exercising your rights. We cannot deny goods or services, charge you a different price, or provide a different level or quality of goods or services just because you exercised your rights |
How to exercise your rights
Please contact privacy@ghibligroup.com to exercise a right in relation to your personal information. Subject to legal considerations and some exemptions, we may not always be able to action your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way. Please note that we cannot facilitate the exercise of your rights without proper verification of your identity.
How to complain
If you would like to complain about how we have handled your personal information, please contact us at privacy@ghibligroup.com. If you are unhappy with our response, you have the right to lodge a complaint with the relevant data protection supervisory authority:
• In the UK the supervisory authority is The Information Commissioners Office (ICO). To raise a complaint please visit their website http://ico.org.uk/make-a-complaint/
• In the EU details of the national data protection supervisory authorities can be found on the European Data Protection Board website at http://edpb.europa.eu/about-edpb/about-edpb/members_en. Contact information for the supervisory authorities may be found here: EU Data Protection Authorities
• In the United States the Federal Trade Commission (FTC) has authority to enforce privacy laws and take actions to protect consumers. You can report fraud, scams, and bad business practice on the federal government's website at http://reportfraud.ftc.gov/. Many US states also have their own data privacy and security laws, and state attorney general offices are responsible for overseeing these laws. State attorney general office contact details can be found at http://www.usa.gov/state-attorney-general.
Contact us
If you would like to speak to us about data protection you can do so by post or email using the details below:
Email: privacy@ghibligroup.com
Postal address: FAO Privacy Manager
Element Materials Technology, Roswell House, 2A (1F) Harvest Drive, Newbridge, Midlothian, UK, EH28 8QJ
For general queries please contact us via the ‘contact us’ section of our website.
Contact us – United States
If you are based in the United States, we also have a toll-free number you can call on 1-866-843-1820.
Contact us - Germany
If you are based in Germany and would like to speak to our German Data Protection Officer, you can do so by post, email, phone, web, and video conferencing, using the details below. The German version of Element's privacy statement can be found here.
Postal address:
Datenbeschützerin Regina Stoiber GmbH
Unterer Sand 9, 94209 Regen, Germany
Email: regina@datenbeschuetzerin.de
Phone: +49 9921 9062719
Web: www.datenbeschuetzerin.de
Video call: conf.datenbeschuetzerin.de