Third-Party Personal Data Protection Notice

1. Introduction

The Lubrizol Corporation, its subsidiaries and majority-owned joint ventures (“Lubrizol”, “we”, “us” and “our”) operates in several different countries. We are committed to protecting your privacy. This Notice explains how we collect, use and disclose the personal data in our possession relating to our customers, vendors, suppliers, distributors, sales representatives, consultants, and other third parties including persons visiting our websites (referred to collectively in this Notice as a “Third Party”). This Notice does not apply to individuals who provide services for Lubrizol as interims, temporary workers, (independent) contractors, students and apprentices.

This Notice may change from time to time. You are advised to review this Notice periodically.

If you have any questions, feel free to get in touch via one of the methods set out in section 11. Contact us below.

2. What personal data do we collect about you?

Lubrizol may collect and generate personal data about you. This personal data includes:

• Your basic information – such as your name (including name prefix or title); your maiden name and surname; your gender and your position (including a description of your current position, your title, your unit/department), and year of birth
• Contact information – office address, professional email address; and professional  phone number(s)
• Additional information: additional information may be obtained during the course of any background checks that are conducted in compliance with applicable law

3. How do we obtain your personal data?

We collect your personal data:

• during the course of your relationship with Lubrizol, for example personal data that is included in materials submitted during networking events or sales calls, or on invoices
• when you order a product or a service, make a request, or register for subscriptions or other communications through our websites
• when you participate in  a marketing event such as a survey, promotion, forum  or trade show, whether organized by Lubrizol or not
• as part of market research
• when you provide it to us, for example when you contact us or in response to our notice that a check of your background is needed. We combine personal data that we have about you from various sources, including the personal data that you have provided to us

4. How do we use your personal data?

We use your personal data for the following purposes:

• Entering into a business relationship with your employer, and generating data during the performance of the business relationship
• Developing and maintaining professional relationships as required to conduct Lubrizol business
• Responding to any queries or requests you may have
• Facilitating communication (including marketing communications) with you and your employer and organizing marketing and networking events
• Complying with legal, regulatory and other requirements such as those imposed by the Foreign Corrupt Practices Act or UK Bribery Act;, or record-keeping or reporting obligations; conducting audits; complying with government inspections and other requests from government or other public authorities; responding to legal process such as subpoenas; pursuing legal rights and remedies; defending litigation and managing internal complaints or claims; complying with internal policies and procedures; or complying with local employment law obligations

5. On what basis do we use your personal data?

We use your personal data on the following basis:

• in order to enter into a business relationship with you, and for the purposes of performing all obligations associated with the business relationship
• for the legitimate interests of Lubrizol, including those described in section 4. How do we use your personal data above
• to comply with certain legal and regulatory obligations of Lubrizol

6. With whom do we share your personal data?

Due to the global nature of our operations, and as we grow globally, Lubrizol needs to be able to move Third Parties’ personal data across our organization. We share certain of your personal data with:

• members of the Lubrizol group of companies
• Lubrizol employees, including those who work in Lubrizol’s Legal, Security, Accounting and Internal Audit, Marketing, Sales, and Customer Service groups

From time to time, we may also need to make your personal data available to other parties, such as:

• legal and regulatory authorities
• auditors, lawyers, consultants and other outside professional advisors to Lubrizol
• authorized intermediaries of Lubrizol (such as distributors and sales representatives)
• companies that provide products and services to Lubrizol (such as background check providers or translation services)

7. Transfers of your personal data outside of your home country

Your personal data may be processed by Lubrizol and those other parties described in section 6. With whom do we share your personal data above, anywhere in the world, including in countries where data privacy laws may not be equivalent to, or as protective as, the laws in your home country. We have implemented appropriate safeguards to ensure that your personal data remains protected and secure when it is transferred outside of your home country, in accordance with applicable data protection and privacy laws. You may obtain information regarding the available safeguards, including any adequacy decisions, by contacting Lubrizol’s European Data Privacy Compliance Team: GDPR-EU@lubrizol.com.

8. Protecting your personal data

Consistent with applicable privacy and data security laws, we use a variety of technological and organizational security measures to help protect your personal data from unauthorized access, use, disclosure, alteration or destruction,. Personal data will generally be maintained in secure and centralized databases. The databases are protected via standard back-up and recovery processes.

9. How long will we keep your personal data?

We will keep your personal data for the period required by law. We will also keep your personal data for as long as necessary in connection with a legal action or an investigation involving Lubrizol. Otherwise, we keep your personal data for the period necessary to fulfill the purposes outlined in section 4. How do we use your personal data above.

10. Your rights

You are entitled to:

• request information about the processing of your personal data
• request a copy of your personal data
• request the correction and/or deletion of your personal data
• request the restriction of, or object to, the processing of your personal data
• withdraw your consent to the processing of your personal data (where Lubrizol is processing your personal data based on your consent)
• request receipt or transmission to another organization, in a machine-readable form, of the personal data that you have provided to Lubrizol
• complain to your local supervisory authority if your privacy rights are violated, or if you have suffered as a result of unlawful processing of your personal data

Please note that your rights may vary depending on the jurisdiction in which your personal data is processed. If you would like more information about your rights, or have any concerns about Lubrizol’s processing of your personal data, please let us know by getting in touch with Lubrizol’s European Data Privacy Compliance Team: GDPR-EU@lubrizol.com. 
 
Where you are given the option to share your personal data with us, you can always choose not to do so. If you object to the processing of your personal data, Lubrizol will respect that choice in accordance with its legal obligations. However, this could mean that we are unable to perform the actions necessary to achieve the purposes of processing described in section 4. How do we use your personal data above.

11. Contact us

If you have questions or requests about the processing of your personal data, or need additional information, you can find the relevant contact details here: Lubrizol’s European Data Privacy Compliance Team: GDPR-EU@lubrizol.com.

12. Data controller

 Lubrizol is the controller of your personal data that you provide to Lubrizol or that Lubrizol otherwise acquires as described above.