Privacy policy - GDPR

SSAB SWEDISH STEEL LTD

- privacy statement, last updated 01-August 2019


This Privacy Statement informs about processing of personal data by SSAB Swedish Steel Ltd.
It answers the questions what personal data SSAB Swedish Steel Ltd collects, uses or shares, for what purposes the data is collected and what rights Users have. The Users can be SSAB Swedish Steel Ltd’s customers, representatives of customer companies, potential customers or internet users visiting the website ("Users"). This aluzinc.co.uk website may contain links to websites and services of third parties. These websites or services are subject to their own privacy statements. SSAB Swedish Steel Ltd does not take any responsibility of third parties’ privacy statements or processing of personal data in third parties’ operations. Please pay attention to their respective privacy statements and subsequent changes to them.

1. DATA CONTROLLER
The data controller in accordance with the applicable data protection law is SSAB Swedish Steel Ltd (registration number: 00710624, address: Unit 17 Narrowboat Way, Brierley Hill, West Midlands. DY5 1UF) for all data processing, the primary contact for privacy matters is: e-mail: data.privacy@aluzinc.co.uk

SSAB Swedish Steel Ltd is responsible for ensuring that personal data is processed in compliance with this Statement and applicable data protection laws.

2. LEGAL BASIS AND PURPOSE OF PROCESSING PERSONAL DATA
SSAB Swedish Steel Ltd processes personal data of the Users for various purposes, which are explained below.
2.1 Service provision
The main purpose of processing personal data is to provide the website and deliver SSAB Swedish Steel Ltd's products and services. This processing of personal data is primarily based on contract with the User, including processing needed prior to entering into the customer relationship.
2.2 Marketing and communications
Users' personal data will be used to manage communication with Users and for marketing purposes. In this respect, the processing is based on SSAB Swedish Steel Ltd’s legitimate interest to provide Users with relevant and up-to-date information as part of the website. It is also based on SSAB Swedish Steel Ltd's legitimate interest to promote SSAB Swedish Steel Ltd's latest products and services as well as to personalize the User experience.
To some extent, marketing via electronic means is based on Users' prior consent, for example for sending marketing messages. Users should refer to section 6 below for further information about marketing communications and Users' rights in this respect.
2.3 Product and services development purposes
SSAB Swedish Steel Ltd's goal is to provide high quality services and give Users relevant information about those services. Therefore, SSAB Swedish Steel Ltd may use personal data to analyze the market, User groups, use of websites for the purpose of developing and improving the quality of the website and SSAB Swedish Steel Ltd's products and services. This processing is based on SSAB Swedish Steel Ltd's legitimate interest to grow and develop.
SSAB Swedish Steel Ltd uses cookies and other similar techniques for statistical purposes, to compile anonymous, aggregated statistics that allows SSAB Swedish Steel Ltd to understand how Users use the website and increase user-friendliness. Please see Swedish Steel Ltd's Cookie Statement for further information.
2.4 Information security
SSAB Swedish Steel Ltd may process technical data, including some personal data for information security purposes and fraud prevention. SSAB Swedish Steel Ltd maintains information security measures to safeguard business information and business assets, to protect personal data, to avoid criminal activities and to ensure the availability of the websites and services. This processing is based on SSAB Swedish Steel Ltd's legitimate interest to ensure an appropriate level of network and information security.
2.5 Processing of personal data internally within SSAB group
Users' personal data may be processed in other SSAB group companies. In this case, the processing of personal data is based on SSAB Swedish Steel Ltd's legitimate interest to organize and manage customer relationships, marketing as well as information security measures within the group in an appropriate and practical way.

3. COLLECTION OF DATA
SSAB Swedish Steel Ltd may collect personal data through different means, which are explained below.
3.1 Customer relationship
SSAB Swedish Steel Ltd processes personal data for the purpose of maintaining a good customer relationship, for example when providing and delivering products or services and maintaining customer communications. This personal data is collected directly from the Users.
Depending on the Users' interaction, SSAB Swedish Steel Ltd may collect the following personal data:
• Basic information about the User, such as name, email address and phone number;
• Basic information about the User's employer , company name, address, email address and phone number;
• Information relating to customer relationship, such as products and services ordered, starting and end time of customer relationship;
• Billing information, such as account numbers, payments made and outstanding and bills delivered; and
• Customer communications.

3.2 User's interaction with SSAB on website or otherwise
SSAB may collect personal data when Users contact SSAB's customer service, use website chat, contact SSAB otherwise, order SSAB's newsletter or participate in surveys or competitions on websites or elsewhere. This personal data is collected directly from the Users.
SSAB may collect personal data that the User has shared with SSAB, such as
• Basic information about the User, such as name, email address and phone number;
• Basic information about the User's employer, company name, address, email address and phone number;
• Reasons for contacting SSAB Swedish Steel Ltd and details related to contact; and
• Surveys and competitions participated in.

3.3 Automatically collected data of the use of website and services
SSAB Swedish Steel Ltd automatically collects and processes the following technical data about the User and the use of website, products and services provided by SSAB Swedish Steel Ltd:
• IP address, device ID, device type, operating system used and application settings;
• User activity such as pages viewed and items ‘clicked’ on;
• timestamps and log data relating to the use of the service; and
• location/country of origin.
This technical data is collected automatically through the use of website and services.
3.4 Data collected from other sources
SSAB Swedish Steel Ltd may, from time to time, also collect information from publicly available sources and third parties, such as social networks and marketing companies. For example, SSAB Swedish Steel Ltd may receive basic information about the User's social network profile, if the User login to SSAB Swedish Steel Ltd's website or services using social network account.

4. SHARING OF DATA
SSAB Swedish Steel Ltd may disclose Users' personal data to the following third parties:
• other SSAB group companies for the purposes listed above;
• trusted services providers, such as distributors and marketing service providers for the purposes listed above. However, at all times, these trusted service providers act on SSAB Swedish Steel Ltd's behalf and SSAB Swedish Steel Ltd is responsible for the use of Users' personal data;
• when permitted or required by law to comply with requests by competent public authorities such as subpoenas or similarly binding acts;
• if SSAB Swedish Steel Ltd is involved in a merger, acquisition, or sale of all or a portion of its assets; and
• when SSAB Swedish Steel Ltd believes in good faith that disclosure is necessary to protect SSAB Swedish Steel Ltd's rights, protect Users' safety or the safety of others, investigate fraud, or respond to a government request.

5. TRANSFER OF PERSONAL DATA OUTSIDE OF EU/EEA
5.1 Intra-group transfers
As some of the SSAB group companies are located outside of the EU/EEA, User's personal data may be transferred outside of EU/EEA, such as to the United States. In this case SSAB Swedish Steel Ltd will use the required established mechanisms that allow the transfer outside of EU/EEA, such as the Standard Contractual Clauses approved by the European Commission.
5.2 Service providers located outside of EU/EEA
SSAB Swedish Steel Ltd may use subcontractors when providing the website or services. When necessary and to the extent required for the purpose of the website and the provision of the services, personal data may be transferred to a country outside of the EU/EEA. In this case SSAB Swedish Steel Ltd will use the required established mechanisms that allow the transfer to subcontractors in those thirds countries, such as the Standard Contractual Clauses approved by the European Commission. SSAB Swedish Steel Ltd will rely on the so-called Privacy Shield for those service providers located in the U.S that are Privacy Shield-certified. For more information about the Privacy Shield framework developed by the U.S. Department of Commerce and the EU Commission and the related principles concerning processing of personal data, please see here.

6. MARKETING COMMUNICATIONS
When a User provides SSAB Swedish Steel Ltd with contact details, for example, in connection with a sale of product or service, contact SSAB Swedish Steel Ltd's customer service, order a handbook or other materials on the website or participate in competitions, SSAB Swedish Steel Ltd may use User's personal data for marketing purposes and to promote SSAB Swedish Steel Ltd's latest products and services as well as to personalize the User experience. Users are given the opportunity to give their prior consent or in where applicable laws allow the opportunity to opt-out of receiving marketing communications from SSAB or other group companies.
6.1 eMarketing
SSAB Swedish Steel Ltd may provide a User with product and service updates, newsletters and other communications about existing or new products and services by email and text message (SMS), if the User has given a prior consent or if SSAB Swedish Steel Ltd has otherwise permitted to do so under applicable law.
A User may unsubscribe from marketing communications at any time by clicking on the "unsubscribe" link located on the bottom of emails.
6.2 Statistics and segregation
SSAB Swedish Steel Ltd may create User group profiles or segment data for the purpose of creating anonymous, aggregated statistics about the use of the aluzinc.co.uk website, products and services, such as to estimate number of Users, viewed pages, email reads and detect which parts of the website the Users find most useful, to identify features that could be improved and to provide context based advertising to User groups. Data collected for these purposes is not used to identify a particular User but to analyse how the Users in general or User groups use the website or services.


7. RETENTION OF PERSONAL DATA
The personal data will be retained only for as long as necessary to fulfill the purposes defined in this Privacy Statement. After that personal data will be removed except when personal data retention is required by law or rights or obligations by either party.
Here are the main rules for the retention periods:
• Personal data regarding customers will be retained during the customer relationship and after that as long as necessary or required by law or rights or obligations by either party, for example for billing purposes;
• Data collected in connection with customer service, other interaction with SSAB Swedish Steel Ltd, surveys and competitions will be retained as long as necessary to manage and handle the matter in question.
• SSAB will delete or anonymise data used for marketing purposes after a reasonable period of time has lapsed from last contact between the User and SSAB, unless data retention is required by law or rights or obligations by either party.
• Should a User have a concern about data retention for marketing purposes, User should refer to section 8 below for further information about Users' rights in this respect.

8. PRIVACY RIGHTS
A User has the right to access personal data that SSAB Swedish Steel Ltd holds about him or her.

A user has the right to request to correct, update or remove their personal data at any time. However, please note that certain information is strictly necessary in order to fulfil the purposes defined in this Statement and may also be required by law. Therefore, the deletion of such data may not be allowed by applicable law, which prescribes mandatory retention periods.

A user has a right to object to processing, that is based on legitimate interest of SSAB Swedish Steel Ltd on grounds relating to their particular situation at any time. To the extent required by applicable data protection law, Users have a right to restrict data processing.

A user has a right to data portability, i.e. the right to receive the personal data in a structured, commonly used machine-readable format and transmit the personal data to another data controller, to the extent required by applicable law. This applies only for personal data provided by the User based on customer contract or the User's consent.

Please send any requests regarding the above-mentioned rights to SSAB Swedish Steel Ltd at [data.privacy@aluzinc.co.uk].

If a User thinks there is a problem with the way SSAB Swedish Steel Ltd is processing User's personal data, User has a right to file in a complaint to the national data protection authority in the EU/EEA.

9. SECURITY
SSAB Swedish Steel Ltd maintains reasonable security measures, including physical, electronic and procedural measures, to protect personal data from loss, destruction, misuse, and unauthorized access or disclosure. For example, SSAB Swedish Steel Ltd limits the access to this information to authorized employees and contractors who need to know that information in the course of their job description and third party service providers who may only process data in accordance with SSAB Swedish Steel Ltd's provided instructions.

Please be aware that, although SSAB Swedish Steel Ltd endeavours to provide reasonable security measures for personal data, no security system can prevent all potential security breaches.

10. CHANGES TO THIS PRIVACY STATEMENT
SSAB Swedish Steel Ltd may amend this Privacy Statement and the related information. SSAB Swedish Steel Ltd recommends that the Users regularly access the Privacy Statement to obtain knowledge of any possible changes to it. SSAB Swedish Steel Ltd will always provide the date of the Privacy Statement to allow the Users to see changes. Please note that this Privacy Statement is for information purposes only.

SSAB Swedish Steel Ltd will inform Users of possible changes by using reasonable and available channels.

11. CONTACT SSAB SWEDISH STEEL LTD
For requests regarding SSAB Swedish Steel Ltd's Privacy Statement or personal data SSAB Swedish Steel Ltd holds about the User in question, please contact SSAB by email at [data.privacy@aluzinc.co.uk].