Date of last update: June 15, 2023

CONFIDENTIALITY AND PERSONAL INFORMATION PROTECTION POLICY 

At Groupe Swagelok Québec, we are committed to respecting and protecting the privacy of our customers and visitors to our website. We are aware of the importance of preserving the confidentiality of personal information and we comply with Law 25 on the protection of personal information in Quebec as well as any other applicable law. This privacy policy explains how Swagelok Quebec Group and Swagelok Company have access to personal information. Details in this policy indicate how we collect, use, disclose and protect the personal information you provide to us. We ask that you also read our General Conditions of Use, which govern the use of the sites as well as any content you transmit through them, swagelok.com.fr ^®  General Conditions | Swagelok , if you have any questions, please contact the Swagelok Quebec Group Privacy Officer. Swagelok Companyand Swagelok Quebec Group are operated independently, however these two entities can access the personal data of the people covered by this policy. This personal information protection policy describes the personal information protection practices applied by Swagelok Quebec Group.

Definition of personal information:

According to Law 25, personal information means any information concerning a natural person which allows them to be identified, directly or indirectly. This may include, but is not limited to, information such as name, address, telephone number, email address, payment data, demographic information, personal preferences, etc.

Collection of personal information:

We only collect personal information necessary to fulfill the specific and legitimate purposes of our business. We do not collect personal information in excessive or irrelevant ways. When we collect personal information, we inform you of the purpose of this collection and we obtain your consent, except as required by law. By choosing to use our website and/or provide us with your personal information in the course of your dealings and activities with our company, you consent to the collection, use and disclosure of your personal information in accordance with this personal information protection policy and applicable data protection laws. The personal information requested may include, but is not limited to, your name, address, email address, location, company name, telephone number, job title, industry and billing information (including payment information) or shipping.

• Personal Data We Collect Automatically

When you visit the Sites, we collect information about your activity on the internet or other electronic networks using cookies and other trackers. Depending on the tracking settings you have set, the information we collect includes, but is not limited to, the IP address of your device, the website from which you came, the type of browser used, the pages visited from your device and the time our Site was accessed from your device. We may use various technologies to know your geographic location, including collecting your IP address or other information about your device, which may depend on your device's location services settings. We may also use tools such as a firewall to protect against spam and other security risks associated with the use of abusive automated software. You can configure your choices regarding the use of cookies and other trackers by going to the preferences center on our Sites. For more information on the types of cookies and other trackers used on our Sites, see our Cookie Notice . If you have any questions regarding cookies, please contact the Swagelok Group Privacy Officer by referring to the last section of this policy. In addition, we may receive information transmitted by third parties – technical, advertising or marketing partners, public databases, social media platforms – in order to complete the Personal Data that you may choose to send to us and confirm the accuracy of this data. If we collect such data, our use of it is governed by this policy.

Use of personal information:

We use the personal information you provide to us only for the purposes for which it was collected. These purposes may include, for example, managing orders, providing services, personalizing your experience, communicating with you, responding to your requests, etc. We do not use your personal information for purposes that are unauthorized or inconsistent with these purposes.

The personal information we collect may be used for the following purposes:

• To respond to your various requests
• When necessary to fulfill our obligations or exercise our contractual rights
• When necessary to comply with applicable laws or regulations
• For legitimate interests, such as: managing and promoting the Swagelok brand; sell products and process payments; improve the products we sell; administer the products we sell; administer the sites and events that we organize; to carry out our activity; for internal activities – problem solving, data analysis, testing, statistics, surveys, etc.
• To communicate with you regarding products and information about our products
• To improve our Sites to ensure that their content is presented in the best possible way

To use your Personal Data for marketing purposes, where we have your consent to do so (as may be required by applicable law). When your consent is necessary and you have given it to us, you can withdraw it at any time by contacting us.

Without being limiting, here are situations in which we may obtain, transfer or share information about individuals, including personal information, in the following situations:

• Where we have your consent to do so;
• Between Swagelok Quebec Group and Swagelok Company to achieve the objectives set out in this policy;
• Between Swagelok Quebec Group, Swagelok Company and service providers, to perform tasks on our behalf. Our service providers provide the following services: payment processing; web traffic analysis; cybersecurity and fraud prevention; support services; customer relationship management ; email ; archiving of technical drawings;
• When you participate in events, certifications or training, we may share personal information with your employer to verify your Swagelok certifications;
• To enforce our legal rights and respond to valid requests from public authorities where permitted by law and based on our legitimate interests or legal obligations

Disclosure of personal information:

We only disclose your personal information to third parties where required by law or where we have obtained your consent. We take necessary steps to ensure that third parties with whom we share your personal information also respect the confidentiality and security of that information.

Protection of personal information:

We take appropriate security measures to protect your personal information from unauthorized access, disclosure, misuse, alteration or destruction. We use technical, administrative and physical security measures to ensure the confidentiality and integrity of your personal information. Please note that Swagelok Quebec Group is committed to applying security measures in order to protect your personal information and reduce the risk of breach or unauthorized access. Despite the measures taken, Swagelok Quebec Group cannot guarantee that your personal information will not be subject to a breach of confidentiality or integrity in the event of a breach. If you have any concerns or concerns that personal information may have been compromised or subject to unauthorized access, please contact our Privacy Officer at the following email address: prp@swagelok.com

Access and correction of personal information:

You have the right to access the personal information we hold about you and to request its correction or deletion, in accordance with Law 25. When we receive a request from you to exercise any of your rights, we will do so. we respond without delay, within the deadlines set by current legislation. The deadlines for receiving a response may be extended in certain situations. As a general rule, we provide the requested information free of charge, except when the requests are manifestly unfounded or excessive. In such situations, we may charge a reasonable fee or we may refuse to comply with the request. We will notify you of the fees associated with a request before acting on it. We may ask you for additional information to verify your identity before processing a request. Please note that we may still use aggregated and anonymized Personal Data – which does not identify individuals – and that we may also retain and use your Personal Data if this is necessary to comply with our legal obligations, resolve disputes or enforce our agreements.

If you would like to exercise these rights and/or file a complaint, please contact us at prp@swagelok.com

If you send us a request by email, please indicate “  Privacy Rights Request  ” in the subject line of the email and provide us with the following information: the nature of your request, your full name, your email address and a mailing address valid. Please note that it will be possible to make only one request per email sent. We may also contact you to request additional information in relation to your request. We ask that you please respond promptly to any requests for additional information so that we can verify your identity.

However, please understand that it will generally not be possible to withdraw your consent to the use of your personal information without terminating your contract. However, certain personal information is required to purchase Swagelok products and/or as part of related business activities with Swagelok Quebec Group.

Please note that you can also control certain information that we collect and use in the different ways below:

• Location Data:  You can disable location services on your mobile device or web browser by adjusting your device or browser settings. This will prevent our Site from accessing data allowing you to be located. Note that some services may not be available if you turn off location services.
• Emails:  You can unsubscribe from our marketing emails by following the instructions in any email communication you receive or by using the contact details provided in the “Contact Us” section below to get in touch with us.
• Social Networks:  This Policy does not cover the privacy and security practices of the social networks on which we operate. If you have any questions about how these networks collect and use your data, please review the terms of use, policies and settings of these platforms.
• Online Advertising:  For more information on how to opt out of receiving third party advertisements, visit the  NAI Opt-Out  or  DAA sites . You will leave this Site to another, separately managed site where you can indicate your preferences. You can also click on the icon that may appear on some of our advertisements served using this technology. We may use the services of several companies to place these advertisements. You will therefore have to carry out the unsubscription procedure for each of them.
• Google Analytics  :  You can opt out of Google Analytics on any website you use. To do this, go to  this site .
• Postal Marketing:  To opt out of receiving other forms of marketing materials (e.g. by post), please contact us using the contact details provided in the “Contact Us” section below.

Portability of personal information: Please note that as of September 2024, you will be able to obtain, upon request and in the absence of serious practical difficulties, a copy of the personal information that has been collected about you, in a technological format appropriate, structured and commonly used. This technological format will be determined by Swagelok Quebec Group.

Retention of personal information:

We retain your personal information only for as long as necessary for the purposes for which it was collected, unless otherwise required by law. We take appropriate steps to delete, anonymize and/or adequately protect your personal information when it is no longer necessary. We may retain your personal information for as long as necessary where permitted by law. Please note that your personal information is generally stored in Quebec. However, it is possible that Swagelok Company, located in the United States, may access and/or even retain certain personal information. However, Swagelok Quebec Group has ensured that Swagelok Company uses safeguards to protect access and use of personal information.

 

 

Changes to the privacy policy:

We may update our Privacy Policy from time to time to reflect changes in our practices and legal obligations. We encourage you to periodically review this policy to stay informed about our privacy practices.

To contact the person responsible for the protection of personal information:

The person responsible for the protection of personal information is responsible for ensuring the protection of personal information at Swagelok Quebec Group. The contact details of the person responsible for the protection of personal information are as follows:

• 2425, rue Halpern

  Saint-Laurent (Quebec) H4S 1S3

   

• lrntnprp@swagelok.com

If you have any questions, concerns or requests regarding our privacy policy, please contact us by email using the contact details provided above.