PRIVACY NOTICE FOR BUSINESS PARTNERS IN ACCORDANCE WITH U.S. LAW
Standard
Steel, LLC (“SS”), its Head Office located at 500 North Walnut Street, Burnham,
PA, 17009 provides information on the processing of personal data in connection
with its relationship with existing and potential customers, trading companies,
end users, goods and service suppliers, agents, advisors, outside auditors,
research institutions, industrial organizations and other persons with whom SS
maintains or is considering to create a business relationship (each a “Business
Partner”) to the extent U.S. law applies. This Privacy Notice also applies to
users of SS (website standardsteel.com).
If a Business
Partner who is an individual or a Business Partner Contact (as defined below)
is a California “consumer” within the meaning of the
California Consumer Privacy Act of 2018 (“CCPA”), the “ADDENDUM FOR CALIFORNIA CONSUMERS” below applies to them.
SS may process the following personal data:
·
Profile and contact information, such as
full name, signature, work position, work experience, work address, work
telephone number, work mobile phone number, work fax number, work e-mail
address, physical characteristics or description, work position, and
preferences of a Business Partner who is an individual, or a person working for
or on behalf of a Business Partner (each shall be referred to as a “Business
Partner Contact”);
·
Further information processed in connection
with the relationship between SS and a Business Partner or provided by a
Business Partner Contact.
·
Information SS or third parties it
authorizes collect from users that navigate its website, such as IP addresses, browsers,
and other information related to how a user interacts with SS’s website.
SS processes the personal data indicated above for the following purposes:
·
Communicating with Business Partner
Contacts about products and services of SS, e.g. by responding to inquiries or
requests, entering into or executing transactions for products or services,
providing technical support;
·
Communicating with Business Partner
Contacts about the products and services of Business Partners;
·
Planning, performing and managing the
business relationship with Business Partners;
·
Improving its websites;
·
Solving disputes, enforcing agreements
and/or to establish, exercise or defend legal claims;
·
Complying with applicable laws and
regulations, including cooperating with relevant authorities and regulators.
For the purposes of processing indicated above, SS may disclose personal data
to the following recipients or categories of recipients:
·
Directors, supervisory board members,
senior advisors, advisors, executive officers, fellows, executive counsellors,
employees (including employees undergoing their probationary employment
period), temporary employees, and any persons who correspond to such positions
(“Staff”) of SS;
·
External advisors such as attorneys,
accountants and tax advisors (“Advisors”) of SS;
·
Parent companies of SS and their Staff and
Advisors with whom SS needs to share the data;
·
Other Business Partners and their Staff and
Advisors with whom SS needs to share the data;
·
Governmental agencies, boards, commissions,
officers, officials or entities exercising legislative, judicial, regulatory or
administrative functions.
SS does not knowingly collect personal
information from minors under the age of 16.
Unless indicated otherwise, SS will retain
personal data for as long as is necessary for the purpose for which they were
collected or otherwise processed (including as required by applicable law or
regulation or for the exercise or defense of legal claims).
If a
Business Partner Contact has a question with regard to processing of his/her
personal data, he/she may contact SS at: privacy_info@standardsteel.com
SS may
modify this Privacy Notice from time to time. SS will inform of any substantial
changes to this Privacy Notice by posting the amended notice on the website of Standard
Steel.
This amended
privacy notice is effective as of January 1, 2020.
ADDENDUM
FOR BUSINESS PARTNERS WHO ARE CALIFORNIA CONSUMERS
Date last
updated: January 1, 2020
This
Addendum for Business Partners Who Are California Consumers (this “Addendum”)
intends to inform Business Partners and Business Partner Contacts who are
California residents (collectively, “you” or “your”) about how SS collects and
uses your Personal Information (as defined below) under the CCPA and what your
rights and SS’s obligations are in relation to the processing of your Personal
Information in accordance with the CCPA. This Addendum supplements
the “PRIVACY NOTICE FOR BUSINESS PARTNERS IN ACCORDANCE WITH U.S. LAW” above (“Privacy Notice”) and
prevails over any conflicting provisions in the Privacy Notice. Capitalized
terms used but not otherwise defined herein have the meanings ascribed thereto
in the Privacy Notice.
For the purpose of this Addendum, “Personal Information” means information that
identifies, relates to, describes, is reasonably capable of being associated
with, or could reasonably be linked, directly or indirectly, with a particular
California resident or household.
Unless otherwise required by California law , Personal Information does not include information reflecting a written or verbal communication or a transaction between SS and the consumer, where the consumer is a natural person who is acting as an employee, owner, director, officer, or contractor of a company, partnership, sole proprietorship, nonprofit, or government agency and whose communications or transaction with SS occur solely within the context of SS conducting due diligence regarding, or providing or receiving a product or service to or from such company, partnership, sole proprietorship, nonprofit or government agency. This exemption does not remove an individual’s right to pursue a private right of action if their information is compromised in a breach.
1. Categories
and Purposes of Collected Personal Information
The following is a list of categories
of Personal Information as listed in the CCPA which SS has collected within the
preceding 12 months, and the business or commercial purposes for which such
Personal Information was collected:
|
Personal Information Collected |
Business/Commercial
Purposes |
|
A. Identifiers, such as full name, signature, work
address, work telephone number, work mobile phone number, work fax number or
work e-mail address of a Business Partner Contact |
Communicating
with Business Partner Contacts |
|
B. Personal information, as defined in the California customer records law, such as full name, signature, work position, work experience, work
address, work telephone number, work mobile phone number, work fax number,
work e-mail address or physical characteristics or description |
Communicating
with and building relationships with Business Partner Contacts |
|
C. Characteristics of protected classifications
under California or federal law |
Communicating
with and building relationships with Business Partner Contacts |
|
D. Internet or network activity information,
such as IP addresses and browsers |
Conducting
analytics for the purpose of improving SS’s website |
|
E. Professional or employment-related
information, such as work position, work
experience and preferences |
Communicating
with and building relationships with Business Partner Contacts |
|
Inferences
drawn from any Personal Information listed above to create a profile or
summary about you; for example, your individual preferences and
characteristics, |
To
arrange proper accommodations with Business Partners and Business Partner
Contacts |
2. Sources
of Personal Information
For each of
these categories, SS may collect Personal Information from
I. The Business Partner or Business Partner
Contact
○
Identifiers
○
Personal
information categories listed in the California Customer Records statute (Cal.
Civ. Code § 1798.80(e))
○
Characteristics of protected
classifications under California or federal law
○
Professional
or employment-related information
II. Group companies (affiliates and parent
companies) of SS
○
Identifiers
○
Personal
information categories listed in the California Customer Records statute (Cal.
Civ. Code § 1798.80(e))
○
Characteristics
of protected classifications under California or federal law
○
Professional
or employment-related information
3. Disclosure
of Personal Information
SS has
disclosed the following categories of Personal Information as listed in the
CCPA to third parties for SS’s operational business purposes within the
preceding 12 months:
·
Identifiers,
such as full name, work address, and work email
·
Personal information, as defined in the California customer
records law, such as full name, work position, work address, work telephone
number, work mobile phone number, and work fax number
·
Inferences drawn from any Personal Information listed above to
create a profile or summary about you
SS has
disclosed these categories of Personal Information to
·
Advisors
of SS, group companies of SS and their Staff and Advisors
·
Other
Business Partners and their Staff and Advisors
·
governmental
agencies, boards, commissions, officers, officials or entities exercising
legislative, judicial, regulatory or administrative functions
·
Third-party
service providers that assist us with improving our website
We have not
sold your personal information over the past 12 Months, as “sale” is defined in
the CCPA. We also do not knowingly collect, disclose, use, or sell personal
information of minors under the age of 16.
4. Your Rights and Requests
Under the
CCPA, you may:
1.
Request
that SS disclose to you the following information that it has collected, used
or disclosed over the past 12 months:
a. The categories of Personal Information
SS has collected about you;
b. The categories of sources from which SS
has collected such Personal Information;
c. The business or commercial purpose(s)
for collecting such Personal Information;
d. The categories of third parties with
whom SS shares such Personal Information; and
e. The specific pieces of Personal
Information SS has collected about you; and
2.
Request
to delete Personal Information SS has collected from or about you.
SS will not discriminate against you for exercising any
of your rights under the CCPA.
To make a
request for the disclosure or deletion described above, please contact NIPPON STEEL
NORTH AMERICA, INC. (“NSNA”), Standard Steel’s parent company located in the
United States, by using the following phone number, or SS, through the below
email:
Calling the following toll-free number: [+1 844 202 2755]
Sending
an e-mail message to the following e-mail address: privacy_info@standardsteel.com
Upon
receiving a request from you, SS will first verify your identity by requiring
to submit your name, email address, phone number and other information we
require to verify your identity and by matching the information you provide
with what SS already has on file.
If you wish
to use an authorized agent to submit a request to know or a request to delete,
you may do so by providing SS or NSNA with a written document that is signed by
both you and the agent that allows the agent to submit a request on your behalf
(including a power of attorney).
5. Contact SS
If you have
any questions or concerns regarding this Addendum or SS’s privacy practices,
please contact SS, or NSNA at:
NIPPON STEEL NORTH AMERICA, INC.
1251 Avenue of the Americas, Suite 2320, New York, NY
10020, U.S.A.
STANDARD STEEL, LLC
500 N. Walnut Street
Burhnam, PA 17009
privacy_info@Standardsteel.com