Document Purpose

Smith-N-Smith Chemicals Limited., including its subsidiaries and its affiliates (“Smith-N-Smith Chemicals,” the “Company” or “we”) believe that the responsible use of personal information is critical to our business objectives and reputation. As part of our commitment to privacy, we have adopted this Privacy Policy (“Policy”). The extent and type of information we receive from you depends on the information provided to us. The purpose of this Policy is to ensure that all individuals whose Personally Identifiable Information is collected by Smith-N-Smith Chemicals are well informed about how and why Smith-N-Smith Chemicals collects Personally Identifiable Information and what rights are available to them, including under the General Data Protection Regulation (“GDPR”), California Consumer Privacy Act (‘CCPA’) and any other applicable data protection legislation, hereinafter referred as data protection laws.

Document Scope

This Policy is intended to provide website users, customers, employees, job applicants, business partners/ vendors and other service providers with information on how Smith-N-Smith Chemicals collects, protects and uses Personally Identifiable Information.

This Policy applies to all business units, processes and systems in all countries in which Smith-N-Smith Chemicals conducts business and has dealings or other business relationships.

This Policy applies to all employees, directors, contractors, consultants, advisors or service providers that may collect, process, or have access to Personally Identifiable Information of individual data subjects.

I Introduction & notice

a) Introduction

Smith-N-Smith Chemicals respects individual privacy and values the confidence of its customers, employees, job applicants, business partners/ vendors. The Company collects, uses and discloses Personally Identifiable Information in a manner consistent with the laws of the countries in which it does business. The Company has a tradition of upholding the highest ethical standards in its business practices.

We have implemented industry-standard security safeguards designed to protect the Personally Identifiable Information that you may provide. We also periodically monitor our system for possible vulnerabilities and attacks, consistent with industry standards.

Your privacy is important to us. We believe it is pertinent for you to know how we treat the Personally Identifiable Information that we receive from you. This privacy policy explains what Personal Data we collect from you through our interactions with you on our website, and how we use that data.

IF YOU DO NOT AGREE WITH THE TERMS IN THIS PRIVACY POLICY, DO NOT USE THE SERVICES AND SITES OF Smith-N-Smith CHEMICALS. CONTINUED USE OF THE SERVICES AND SITES OF Smith-N-Smith CHEMICALS CONSTITUTES YOUR FREELY GIVEN, SPECIFIC AND INFORMED CONSENT AND AGREEMENT TO YOUR PERSONAL DATA BEING PROCESSED PURSUANT TO THIS POLICY.

b) Definitions

“Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

“Data Subject” means an identifiable natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

“Joint Controller” means two or more controllers jointly determining the purposes and means of processing Personal Data.

“Personal Data” and “Personal Information” means any information relating to an individual that can be used to identify that individual either on its own or in combination with other readily available data.

“Pixels” means small, graphic images on web pages, web-based documents, or in email messages that allow us or third parties to monitor who is visiting our Sites (or other third-party sites) or if an email has been read.

“Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

“Special Categories of Data” means Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.

“We”, “our”, and “us” in this Privacy Policy refer to Smith-N-Smith Chemicals Digital Inc., its affiliates and any legally empaneled sub-processor or contractor delivering the services and products herein.

“You” means the individual to whom any given Personal Data covered by this Privacy Policy refers.

II Collection of Personal Identifiable Information

a) Authorized Users

The Sites are not intended for children under the age of 18. If you are under 18 years old, please do not provide information of any kind whatsoever on the Sites. If you are the parent of a child under 18 and believe your child has provided us with personal information, please contact us via Section XI below and we will remove that information.

b) Information you actively submit

Any Personal Information we collect is used only to respond to your inquiry, consider your application, process an order or allow you to access specific account information, and is not shared with third parties except as described in this Policy. We do not collect or otherwise process Personal Information about race, religion, sexual orientation, health or any other information that is deemed to be sensitive in the ordinary course of business with the exception of employees and job applicants.

Careers. If you decide that you wish to apply for a job with us, you may submit your contact information and your resume through Smith-N-Smith Chemicals Sites. We will collect the information you choose to provide with your application. We will use information provided by you in connection with your application for employment to assess your qualifications and we may share this information with clients and affiliates of Smith-N-Smith Chemicals solely in connection with our efforts to evaluate you for a position at Smith-N-Smith Chemicals or for assignment to one or more Smith-N-Smith Chemicals clients. We may retain application information provided by you for consideration in connection with the position that you actively apply for and other positions at Smith-N-Smith Chemicals, its affiliates and its clients that may become available in the future. Applicant information may be retained for these purposes for time period specified in Data Retention Policy.

We do not seek to collect or otherwise process any Personally Identifiable Information for any other purpose other than what is legitimate; and we do so in accordance with applicable law

C) Modes of collection of data

Personal Information collected either electronically or physically, including but not limited to emails, cold calls, resumes, social media networking sites, subscription to databases, prospective candidate search engines and online identifiers, etc.

Policy statement

Smith-N-Smith Chemicals shall protect its customers, employees and job applicants’, website user’s information / data deemed as ‘Personal’ and / or ‘Private’. We will not sell or disclose the records to any third party except as may be required by law.

Any information that is provided to us in the course of interacting with our project staff or support departments shall be held in confidence. This includes information (including, but not limited to email addresses, phone numbers, postal addresses, bank account details, credit card numbers and medical history), as well as any data that is supplied to us in the course of business engagement.

You can visit most of our sites without registering or actively submitting Personal Data to us. If you do not register, general technical user data, including but not limited to, your device’s Internet Protocol (IP) address, operating system and browser type, and the date and time of your visit, may be automatically collected through the use of “cookies”.

d) Combination & synchronization

We may combine and synchronize information that your device transmits, information that you actively submit and information that we obtain from third party sources (including web publishers, advertisers, data brokers and online service providers that may have obtained information from you or your devices via cookies, pixels, and other tracking technologies for the purpose of analytics and ecommerce).

e) Information tracking technologies

A technology called cookies may be used to provide you with tailored information. A cookie is a tiny element of data that a web site can send to your browser, which may then be stored on your hard drive, so we can recognize you when you return.

If you prefer to not receive cookies while browsing the website, you can set your browser to warn you before accepting them and refuse the cookie(s) when your browser warns you, or you can set your browser to refuse all cookies from the website (or certain parts of the website), and/or you can delete cookies received from the website using your browser, for instance. Cookie handling instructions vary depending on the particular browser being used, and Smith-N-Smith Chemicals does not assume responsibility for any undesired results arising from altering your browser's cookie handling settings.

We may use, and allow third parties to use, pixels (sometimes called web beacons) on our Sites (or other third-party sites). Pixels may be linked to your Personal Information, and they collect the IP address of the device to which the web beacon is sent (for geolocation lookup), the URL of the page the web beacon comes from, the user agent string (for device lookup), and the time it was viewed. Smith-N-Smith Chemicals may use a Pixel or cookie to examine what is happening on third-party websites, including programs and sites with marketing and advertising partners, to improve the understanding of site traffic at a granular level and other services provided.

f) Business information

We do collect Personal Data of our employees, including job candidates and contact names, addresses, phone numbers and email addresses of our business partners, including buyers, suppliers and vendors, for the administration of our business relationships. If you feel that your Personal Data or personally identifiable information is being collected inappropriately, please notify us at info@smithnsmith.net.

III Purpose & use of collected Personal Identifiable Information

Smith-N-Smith Chemicals uses the data collected for three main purposes, described in detail below.

1. Operations. To operate our business including the official website, we use data collected to assess queries, requirements, and process requests for services, to assess website usage and to deliver our services to clients and potential clients.

2. Communications: We use data collected to communicate with you and personalize our communications with you. Additionally, you can sign up for email subscriptions and choose whether you wish to receive promotional communications from Smith-N-Smith Chemicals by email, SMS, post and telephone or other means of communication. We may process your Personal Information to contact you via email, telephone, SMS or other methods of communication to provide you with information regarding our offerings that may be of interest to you.

3. Careers. We may use information provided by you in connection with your application for employment to assess your qualifications for employment and we may share this information with clients and affiliates of Smith-N-Smith Chemicals solely in connection with our efforts to evaluate you for current and future positions at Smith-N-Smith Chemicals and for assignment to one or more Smith-N-Smith Chemicals clients.

IV Data protection rights – Data Protection Laws (Including GDPR & CCPA)

When we process Personal Data about you, we do so with your consent and/ or as necessary to provide the website you use, operate our business, meet our contractual and legal obligations, protect the security of our systems and our customers, or fulfil other legitimate interests of Smith-N-Smith Chemicals as described in this privacy policy.

Below, you will find additional privacy information that you may find important. Smith-N-Smith Chemicals adheres to applicable data protection laws including the GDPR in the European Union, which if applicable, includes the following rights:

If the processing of Personal Data is based on your consent, you have a right to withdraw consent at any time for future processing;
You have a right to request us to rectify or correct your Personal Data. Please inform us of any data which you would like rectified, and we usually respond within a month of the request. We will pass on the changes to any third parties who need to change their records and let you know this has been done;
You have a right to access your Personal Data. Please contact us if you would like confirmation that your data is being processed and access to your personal data. There is no charge for providing you with this data and it will usually be provided within a month of the request;
You have a right to request that your Personal Data be erased, subject to certain exceptions. You may exercise your right to have your personal data erased in a number of circumstances (e.g. if the data is no longer necessary in relation to the purpose for which it was created or you withdraw your consent). Wherever possible, we will comply with all such requests, though some details are part of Smith-N-Smith Chemical’s permanent records (e.g., your name, accounting records) which cannot reasonably be deleted;
You have a right to restrict processing of your Personal Data. You can tell us that we can keep your data but must stop processing it, including preventing future mailings and communications. If possible, we will inform any third parties to whom your data has been disclosed, of your requirement.
You have a right to object to the processing of your Personal Data. We will stop processing your data if you object to processing based on legitimate interests or the performance of a task in the public interest / exercise of official authority;
You have a right to request data portability. Your data is stored across manual records and electronic database. We will do our best to provide information in a portable format;
You have a right to not to be subject to automated decision-making including profiling; and
You have a right to lodge a complaint with a data protection authority.

Do Not Sell My Information

While Smith-N-Smith Chemicals does not sell your Personal Information in exchange for any monetary consideration, we do share your information for other purposes, including analysis and ecommerce with third party channels and ad words, that could be deemed a “sale” as defined by the CCPA. We support the CCPA and wish to provide you with control over how your personal information is collected and shared. This section has been provided to make it easy for you to understand and exercise your rights.

V Information retention & accuracy

We take reasonable steps to ensure that Personal Information we receive, process, or maintain is accurate, complete, and reliable for its intended use. We rely on the accuracy of the information provided directly to us but accept responsibility for the management and confidentiality of the Personal Information collected.

In general, we keep Personal Information only as long as we need it to provide you the services you requested, to consider your application for current and future positions or for the purpose for which the information was provided. We may also process data on behalf of third parties who have engaged us. We keep Personal Information processed on behalf of third parties for as long as needed to provide services to third party in question. However, we reserve the right to retain Personal Information for any period required by law or to comply with our legal obligations, resolve disputes, and enforce our agreements.

VI Data Minimization

We take every reasonable step to ensure that your Personal Information that we process is limited to the purposes set out in this policy or as required to provide you services or access to the services.

VII Sharing of Personal Information and Accountability for Onward Transfer

a) Information associated with your name is shared in accordance with the procedures stated as follows:

With your consent;
We use affiliated and unaffiliated service providers all over the world that help us deliver our service and run our business subject to confidentiality agreements;
We will disclose data as required by law including to meet national security requirements or to protect you, other users, us or third parties from harm, including fraud, data security breaches or where someone’s physical safety seems at risk; and
In a reorganization or sale of our company or assets, your data may be transferred, subject to the acquirer accepting the commitments made in this Privacy Policy and in compliance with applicable law.

When Smith-N-Smith Chemicals does share your Personal Information with third party service providers and/or sub-processors, Smith-N-Smith Chemicals will:

transfer such data only for limited and specified purposes;
ascertain that the sub-processor is obligated to provide at least the same level of privacy protection as is required by this Policy;
take reasonable and appropriate steps to ensure that the sub-processor effectively processes the Personal Information transferred in a manner consistent with our obligations under this Policy;
require the sub-processor to notify Smith-N-Smith Chemicals if it makes a determination that it can no longer meet its obligation to provide the same level of protection as is required by this Policy;
upon notice, take reasonable and appropriate steps to stop and remediate unauthorized processing; and
provide a summary or a representative copy of the relevant privacy provisions of its contract with that sub-processor to authorized regulators upon request.

b) International transfers

If you are visiting this website from a country other than the country in which our servers are located, your communications with us will result in the transfer of information across international boundaries. By visiting this website and communicating electronically with us, you consent to such cross-border transfers.

VIII Security of Personal Data

Smith-N-Smith Chemicals is committed to protecting the security of your Personal Data. We use a variety of security technologies and procedures to help protect your Personal Data from unauthorized access, use or disclosure.

IX Protection of Personal Data

Smith-N-Smith Chemicals uses reasonable security measures in an effort to prevent loss, misuse and alteration of information under our control. However, we cannot guarantee the security of information on or transmitted via the Internet. We rely on various security procedures and systems to ensure the secure storage and transmission of data, including encryption and authentication technology licensed from third parties, to effect secure transmission of confidential information. We have no control over the security of other sites you might visit, interact with or do business with.

If we learn of a security systems breach, then we may attempt to notify you electronically so that you can take appropriate protective steps. Smith-N-Smith Chemicals may post a notice on the Smith-N-Smith Chemicals Site if a security breach occurs. We may also send an email to you at the email address you have provided to us in these circumstances. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive a free written notice of a security breach (or to withdraw your consent from receiving electronic notice) you should notify us.

X Limits to Your Privacy

Our Sites may contain links to external websites, and areas where you can provide information to third-parties. These are provided for your convenience only, and we do not have control over the content or privacy and security practices and policies of such third parties or third-party sites. Any Personal Information you provide in such areas, and on such linked pages is provided directly to that third party and is subject to that third party’s privacy policy. Please learn about the privacy and security practices and policies of external websites and third-parties before providing them with Personal Information.

XI Choice Regarding Collection, Use & Distribution of Personal Information

You can choose to opt-out whenever your Personal Information is (i) to be disclosed to a third party or (ii) to be used for a purpose that is materially different from the purpose(s) for which it was originally collected or subsequently authorized by you.

If you choose to opt-out, please contact us via email at info@smithnsmith.net. In such an event, you will be only able to access public areas of the Sites and may be limited in the use of Smith-N-Smith Chemical’s Sites. In certain cases, limiting the use and disclosure of your personal data may impact functionality or prevent the use of Smith-N-Smith Chemicals products or services.

XII Changes to Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we decide to change our Privacy Policy, we will prominently post those changes here and any other place we deem appropriate, so you are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If we make any material changes, we will notify you by means of a notice on this site prior to the change becoming effective. We will use information in accordance with the privacy policy under which the information was collected.

We use a self-assessment approach to address compliance with this Privacy Policy, verifying periodically that the policy is accurate, comprehensive, and addresses the privacy requirements applicable to the markets we serve.

Periodically, our operations and business practices are reviewed for compliance with corporate policies and procedures governing the confidentiality of information.

XIII How to contact us

If you have any comments, questions or concerns about any of the information in this Policy, or any other issues relating to the processing of user information carried out by us, or on our behalf, please contact us by email at info@smithnsmith.net.