Lynne Kemp, VP of HR & Legal Affairs
31 August 2020
1 July 2022 (including Australia Addendum)
- How we collect your personal data
a) Personal data collected on our Site and use of “cookies”
ARLON collects the following types of personal data through our Site:
- Information You Voluntarily Provide
ARLON collects personaldata that you voluntarily provide ARLON, which may include: (i) contact information, such as your name, company name, job title, address, e-mail address, phone number, and social media profiles; (ii) additional information about you or your business to help us get to know you or your business better, such as professional association, information about how you use our products, and demographic information; (iii) comments, questions, requests and orders you may make; (iv) financial information needed to process payments if you make purchases, such as a credit card or account information or tax identification number; (v)information about your preferences, such as your preferred methods of communication and product types in which you are interested. This information is used for the purposes of targeted advertising, delivering relevant email content, event and product promotions, and to understand user patterns and behavior.
- Information Automatically Collected from Your Device
ARLON collects technical information about your device, such as device type, browser type, IP address, operating system, and device identifier that may qualify as personal data. ARLON collects this information automatically from your device and web browser through cookies and similar technologies. ARLON may collect technical data about your usage of ARLON Internet Sites and how you interact with our digital advertisements and promotions, such as content viewed or downloaded, features used, links clicked, ARLON promotional emails opened, and dates and times of interactions.
- Australia/New Zealand – English: https://www.arlon.com/anz_en/legal/cookie-policy-anz-en
- Europe – English: https://www.arlon.com/eu_en/legal/cookie-policy-eu-en
- Europe – French: https://www.arlon.com/eu_fr/legal/cookie-policy-eu-fr
- Europe – Italian: https://www.arlon.com/eu_it/legal/cookie-policy-eu-it
- Europe – German: https://www.arlon.com/eu_de/legal/cookie-policy-eu-de
- Europe – Polish: https://www.arlon.com/eu_pl/legal/cookie-policy-eu-pl
- Latin America – English: https://www.arlon.com/la_en/legal/cookie-policy-la-en
- Latin America – Spanish: https://www.arlon.com/la_es/legal/cookie-policy-la-es
- North America – English: https://www.arlon.com/na_en/legal/cookie-policy-na-en
b) Other websites
c) New product offerings / promotional emails
We will not send you unrelated promotional e-mails unless you have specifically asked to receive them. If you choose to receive promotional e-mails from ARLON, we will ask you to provide ARLON with your e-mail address. If at any time after you subscribe to receive e-mail promotions, you may unsubscribe by replying to ARLON with the word "unsubscribe" in the subject heading of your e-mail (opt-out). You can also send us an email to [email protected] at any time with your request to unsubscribe.
d) Customer inquiries
We also collect customer personal data from customers who contact our customer service with inquiries via telephone or email. These personal data are also stored in the third-party lead management system and in a Survey Software that is hosted by a third party as ARLON's service provider but will not be disclosed or otherwise made available to any other party.
2. Disclosure of your personal data
a) Sharing with third parties
We do not sell your personal data to third parties for their marketing purposes without your express consent. However, your personal data may be disclosed by us in the normal course of business of providing goods and services to customers, including but not limited to, third party service providers. We do not grant our advertisers access to your personal data.
b) Sharing with employees, contractors, service providers, etc.
In addition, Arlon Graphics and its contractors and service providers may process your personal data to:
- customize, analyze, adjust and improve the Site and our services to better meet your needs;
- respond to your inquiries;
- protect or defend Arlon Graphics’ rights or property, even without a subpoena, warrant or other court order. All personal data will be treated and processed based in the principles of legality, consent, Information, quality, purpose, loyalty proportionality and responsibility, as set forth in applicable law.
c) Data sharing with law enforcement and regulators, restructuring etc.
3) Protection against unauthorized access
ARLON takes appropriate measures to safeguard your personal data and to prevent unauthorized access to that information in its internal procedures and technology. However, we do not promise, and you should not expect, that your personal data are always safe against cyber-attacks, involuntary data loss or hacking, as such activities are common. ARLON has implemented physical, electronic and procedural safeguards to protect your personal data from unauthorized access and use. While ARLON strives to protect your personal data, no data transmission over the Internet is 100% secure and, consequently, we cannot guarantee the security of any information, nor should you expect that your personal data, searches or other communications with ARLON will always remain secure. You should also be aware that ARLON has no control over the security of other sites on the Internet that you might visit or interact with even when a link to any such third-party site appears on our site.
In the event of a breach of the confidentiality or security of your personal data, ARLON may notify you directly as necessary so you can take appropriate protective steps. ARLON may notify you under such circumstances using the e-mail address(es) that we have on record for you.
4) No Marketing to Children
This Site is a general audience site and does not target or intend to collect personal data from children. ARLON is concerned about the privacy and safety of children when they use the Internet. We will never knowingly request or collect personal data online from minors without prior verifiable parental consent. To use the Site or any of service, you must be the age of legal majority in your place of residence. By using the Site or any of our services, you hereby represent that you are at least the age of legal majority in your place of residence or have otherwise provided us with parental consent. All information provided to ARLON will be treated as if it was provided by an adult. In accordance with the US Children's Online Privacy Protection Act of 1998 and similar non-US laws and regulations, if we discover that a child under 13 has provided us with personal data, we will remove it from our systems.
5) Removal / update of your personal data, revocation of consent for data processing
If you would like to (A) access, rectify, modify or delete your personal data (including, without limitation, your User Login, email address, contact information, user preferences) or (B) revoke your consent for the processing and treatment of your personal data, you can do this on our Site using our online form. Alternatively, you can also send an email to [email protected] with clear instructions about the personal data that you would like to have accessed, rectified, modified or deleted. You must promptly update your personal data if it changes or is inaccurate.
7) California residents
California residents have a right to knowledge, access, and deletion of their personal information under the California Consumer Privacy Act (CCPA). California residents also have a right not to be discriminated against for exercising one of their California privacy rights. ARLON does not sell the personal information of California consumers and does not discriminate in response to privacy rights requests.
California residents are entitled once a year, free of charge, to request and obtain certain information regarding our disclosure, if any, of their personal data to third parties for their direct marketing purposes in the preceding calendar year. We give these users the ability to tell us not to share their personal information with third parties for their direct marketing purposes. To make such a request, please send us an email to [email protected]. We may need additional personal information to process your request. If you make such request, ARLON will provide it to you in a structured, commonly used, and machine-readable format.
8) How to contact us
Arlon Graphics LLC
200 Boysenberry Lane
Placentia, CA 92870
Email: [email protected]
GDPR Data Protection Notice
ARLON GRAPHICS LLC and its European Union ("EU") affiliates (identified below) (hereinafter collectively, "ARLON", "we" or "us") collect and process personal information provided to us from, or that we obtain on behalf of, our suppliers/customers/outside contacts in the course of providing services to them.
The ARLON affiliates in the EU are located at:
ARLON GRAPHICS LLC
Dr. Lelykade 22B
2583CM, Den Haag
This Data Protection Notice ("Notice") is provided in accordance with applicable privacy laws including, but not limited to, laws implementing the General Data Protection Regulation 2016/679 ("GDPR") and its national laws referring to it (the "Data Privacy Laws"). It applies only to former, current and prospective suppliers/customers/outside contacts ("third parties") whose EU personal data we process on their behalf or on behalf ARLON. It identifies the personal data we receive and how ARLON uses this information to serve the third parties and do business with the third parties.
ARLON provides various commercial services to our customers. In this respect, we are likely deemed a data controller under applicable Data Privacy Laws with respect to the personal data we obtain from third parties about their personnel and other individuals with whom we work. To the extent that ARLON is deemed a data controller under applicable Data Privacy Laws, this Notice fulfils our obligation to provide information to the third parties whose personal data we process in this capacity.
The EU personal data ARLON processes primarily include contact details for the third parties and their employees and their other personnel, along with any other data relating to such individuals in which they are identified or from which they are identifiable. Only to the extent provided to us by a third party or its employees or other personnel, this includes each individual's name and contact information, and information about where the individual works.
ARLON collects various types of personal data from different sources, including from:
- directly from the third parties;
- public sources, such as the internet sites; and
- from any vendor engaged by us or by the third parties to provide services on our customer's behalf.
What we do with this personal data
The personal data ARLON collects is used in connection with and to provide its commercial services to its customers, notably to facilitate our provision of such services, to respond to queries, and for other professional dealings with third parties. Where and to the extent required by a court order or a request from a governmental or regulatory authority, ARLON may also disclose this personal data to the court or governmental or regulatory authority.
Where personnel employed or engaged by a third party and contacts consent to ARLON's using their personal data for marketing purposes we use their data to newsletters, new product introductions or promotions, notices of product changes or discontinuations, any legal updates and to invite them to events hosted or sponsored by ARLON. Individuals can unsubscribe from these marketing communications at any time after initially providing consent.
ARLON will not use this EU personal data for any additional purposes without express consent to do so, unless we have another lawful ground on which to use this information under the Data Privacy Laws. Any such consent is revocable at any time. ARLON is not using EU personal data for automated decision making, including profiling.
We are also permitted to process this personal data to comply with our legal and regulatory obligations and/or our contractual obligations to the third parties to provide the services to them and our own legitimate interests.
Some of this personal data is processed by us outside Europe, including in the United States, and is held on secured servers. ARLON'S European affiliates take steps to safeguard the privacy and security of all categories of personal data as required under the Data Privacy Laws. ARLON uses the EU Standard Contractual Clauses that the European Commission has approved and can be obtained through the contacts mentioned in this Notice. ARLON shares the personal data for the purposes mentioned in this Notice only to the extent that this is necessary to provide the services
to our customers and other third parties. Our security measures to protect the personal data are described below in this Notice.
There may be instances when we disclose this personal data to other parties to:
- Comply with the law or respond to compulsory legal processes (such as a search warrant or court order) or in response to a request for information from a regulator or governmental authority, or in the course of actual or anticipated litigation or otherwise for legal purposes; and/or
- Protect the rights, property or safety of ARLON, or any of our respective affiliates, business partners, or other third parties, or otherwise in the legitimate business interests of ARLON and/or our affiliates and in accordance with Data Privacy Laws.
- We may share this personal data with other business entities in connection with the sale, assignment, merger or other transfer of all or a portion of ARLON's business to that business entity. We will require that such recipients undertake to protect this personal information as required by the Data Privacy Laws.
How ARLON protects personal data
We are regularly audited for adherence to the ISO 9001 standard and are currently certified. We backup data every day to a secure offsite location which is GDPR compliant. Firewalls in our facilities are updated by the company IT department. Hard drives on PCs and laptops are protected by industry-standard encryption software. A stock of encrypted pen drives is maintained should staff require to transport personal data off site.
ARLON understands that storing personal data in a secure manner is an essential requirement of the Data Privacy Laws and, therefore, employs reasonable physical, technical and administrative safeguards to secure such data against foreseeable risks, including unauthorized use, access, disclosure, destruction, or modification. You also have the right to transmit your personal data to another company etc. (data portability). More specifically, our information security team has developed policies, standards and procedures to support and enforce preventive and detective operational controls to ensure the confidentiality, integrity, and availability of ARLON's data. We utilize preventive and detective controls such as Log Collection Analysis and Event Correlation, Perimeter Protection, Account Security, Physical Security, User Access, Encryption, Data Loss Prevention, and Vulnerability Management to safeguard the data of third parties. In addition, ARLON personnel are required to read ARLON's code of business conduct and confidentiality and data security policies which are available to them online via the company internal network.
Although we make good-faith efforts to store the information we receive from and on behalf of the third parties in a secure operating environment that is not available to the public, ARLON cannot guarantee complete security. Further, while we work to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent third-party "hackers" from illegally obtaining this information.
How long we keep it
We retain the personal data for the duration of the business relationship with the third party and, depending on the applicable jurisdiction in which a third party is located, after the end of the engagement, unless the information is needed longer for legal, regulatory, audit, and tax requirements.
Data protection rights under the GDPR
Individuals in the EU have the right to access their personal data and to ensure that it is accurate, and to request that we delete and/or restrict the processing of their personal data in accordance with, and subject to, the Data Privacy Laws. To enforce any of these rights, or for any further privacy-related question or concern you may have, you can contact us by email at [email protected] If you are not satisfied with our response, you can complain to the data protection authority in your country of residence or in the ARLON affiliate's place of residence (the Dutch Data Protection Authority - Autoriteit Persoonsgegevens (AP) at https://autoriteitpersoonsgegevens.nl/nl/contact-met-de-autoriteit-persoonsgegevens/informatie-en-meldpunt-privacy ).
1. Comply with Chinese legal requirements
ARLON shall take all necessary measures to protect your personal data collected from the People’s Republic of China, and comply with P.R.C Personal Privacy Protection Law and Cyber Security Law.
2. Data Sharing with Third Party
We do not sell your personal data to third parties for their marketing purposes without your express consent. However, your personal data may be disclosed by us in the normal course of business of providing goods and services to customers, including but not limited to, third party service providers. While the information is disclosed to the third party, we shall restrict further process of the personal data by it and require protection measures to be taken properly.
3. Sensitive Personal Information and No Marketing to Children
ARLON would not collect or process any sensitive personal information, including but not limited to biometrics, religious belief, special identity, medical health, financial account information, traveling records and other important information relate to the personality and property of you. if any sensitive personal information is obtained without advance consent from you, we will remove it from our systems. For particular purposes if sensitive personal information is collected from you, we will surely obtain your express consent on each personal information collected and processed in advance. Alternatively, all information provided to ARLON will be treated as if it was provided by an adult. In accordance with the P.R.C Personal Privacy Protection Law, if we discover that a child under 14 has provided us with personal data, we will remove it from our systems unless consent from parents or other guardians.
4. Retention Period
We retain the personal data for the duration of completing the purpose as designated and shall be kept as short as possible and legally required.
5. Other Rights
ARLON shall provide you the way to transmit the personal data you provided to us to any designated personal information controller upon request to use the right to data portability, on the basis of complying with the regulations of P.R.C. cyberspace administration bureau.
We have adopted the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (the Privacy Act). The APPs govern the way in which we collect, use, disclose, store, secure and dispose of your Personal Information.
A copy of the Australian Privacy Principles may be obtained from the website of The Office of the Australian Information Commissioner at www.aoic.gov.au.
Sensitive information is defined in the Privacy Act as information or opinion about an individual's racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information. ARLON does not collect sensitive information through the Website, about Website visitors, or otherwise about actual or potential customers or end consumers.
Access and Deletion Rights
You have the right to access the Personal Information we hold about you and to update and/or correct it, subject to certain exceptions. If you wish to make a request to access, update or correct your Personal Information, please contact us in writing at [email protected]. There is no fee for your access request. We may require identification from you before releasing the requested information.