WEBSITE PRIVACY STATEMENT


INTRODUCTION  

Afton Chemical Corporation and its subsidiary and affiliated companies (together the “Afton Group”) respect your privacy and is committed to protecting your Personal Data (as defined below).

Afton Group is made up of different legal entities, details of which can be found here: https://www.aftonchemical.com/Contact. This privacy statement is issued on behalf of the Afton Group so when we mention "Afton", "we", "us" or "our" in this privacy statement, we are referring to the relevant company in the Afton Group responsible for processing your Personal Data. The Afton Group is the controller and is responsible for this website and any Personal Data that is provided via this website.

"Personal Data", or personal information, means any information about an individual from which that person can be identified. This privacy statement describes how Afton collects, uses, and discloses your Personal Data that we receive from you when you visit this website (https://www.aftonchemical.com/), or which we otherwise receive or collect from you in the course of, or in connection with, our business operations.

"Europe" means the UK, the European Economic Area and Switzerland.

This privacy statement is provided in a layered format so you can click through to the specific areas set out below.

 
1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS AS A RESIDENT OF EUROPE

10. YOUR LEGAL RIGHTS AS A CALIFORNIA RESIDENT UNDER THE CALIFORNIA CONSUMER PRIVACY ACT (“CCPA”)

1.  IMPORTANT INFORMATION AND WHO WE ARE  

PURPOSE OF THIS PRIVACY STATEMENT

This privacy statement aims to give you information on how Afton collects and processes your Personal Data, including any data you may provide through this website.

This privacy statement is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy statement together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing Personal Data about you so that you are fully aware of how and why we are using your Personal Data. This privacy statement supplements the other notices and is not intended to override them.

CONTACT DETAILS  

Afton Chemical Corporation is a company based in the United States. Its subsidiary Afton Chemical Limited is located in England and Wales. We have appointed a data compliance officer who is responsible for overseeing questions in relation to this privacy statement in Europe, and we have also appointed a representative to field questions in North America (each a “Data Compliance Representative”). If you have any questions about this privacy statement, including any requests to exercise your legal rights, please contact the appropriate Data Compliance Representative using the details set out below.

Afton Chemical Limited
Data Compliance Officer
[email protected]
London Road, Bracknell, Berkshire RG12 2UW

Afton Chemical Corporation
Legal Counsel
[email protected]
330 S. 4th Street
Richmond, VA 23219

Afton Chemical Corporation has appointed Afton Chemical Limited (a company incorporated in England and Wales, with company number 01213092) to be its representative regarding data privacy matters in Europe. Its contact details are email: .

You can direct any questions or complaints about the use or disclosure of your Personal Data to us by contacting us as set out above. We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of your Personal Data. If you are located in Europe and are dissatisfied with the resolution of your complaint, you may contact the applicable data protection authority in your jurisdiction in Europe using the contact details provided at
http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm for further information and assistance. California residents have special rights with respect to California based privacy requests. These are described here.

CHANGES TO THE PRIVACY STATEMENT AND YOUR DUTY TO INFORM US OF CHANGES  

This version was last updated on May 1, 2020.

It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us.

THIRD-PARTY LINKS  
 

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy statement of every website you visit.

2.  THE DATA WE COLLECT ABOUT YOU  

We may receive, use and store the following categories of Personal Data which we have grouped together as follows:

  • Identity Data includes first name, last name, username or similar identifier.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  • Profile Data includes your username and password, purchases or orders made by you, your preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
  • Recruitment Data includes:
    • Contact details (including names, postal addresses, email addresses and telephone numbers)
    • The information you have provided on our application form, including name, title, address, telephone number, personal email address, date of birth, gender, employment history, qualifications, and previous salary and benefits (if provided).
    • Details of your references, and medical records.
  • Personal Data includes Identity Data and Contact Data of employees of our customers and suppliers who we deal with in connection with our business operations.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this privacy statement.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, and genetic and biometric data, with exception of pre-employment medical checks in relation to recruitment or health information in order to comport with our legal obligations). Nor do we collect any information about criminal convictions and offences.

IF YOU FAIL TO PROVIDE PERSONAL DATA  

Where we need to collect Personal Data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services or process your job application). In this case, we may have to cancel a product or service you have with us, or not progress your job application. We will notify you if this is the case at the time. California residents have certain rights with respect to non-discrimination. These are described here.

3.  HOW IS YOUR PERSONAL DATA COLLECTED?  

We use different methods to collect your Personal Data from and about you including through: 

  • Direct interactions. You may give us your Identity, Contact, Financial and Recruitment Data by filling in forms or by corresponding with us by post, phone, email, through our website or otherwise. This includes Personal Data you provide when you: 
    • purchase or enquire about our products or services;
    • subscribe to our service or publications;
    • request marketing to be sent to you; 
    • give us some feedback; 
    • apply for a job or respond to a recruitment drive; or
    • interact with company representatives at industry conferences, events or meetings. 
  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy https://www.aftonchemical.com/Generic/Cookie-Policy for further details.

  • Third parties or publicly available sources. We may receive Personal Data about you from various third parties as set out below:
    • Technical Data from the following parties: (a)  analytics providers such as Google, based outside Europe.
    • Identity and Contact Data from publicly availably sources such as Companies House and the electoral register based inside Europe.
    • Recruitment data from recruitment agencies, background check providers  based inside and outside Europe.

4.  HOW WE USE YOUR PERSONAL DATA  

We will only use your Personal Data when the law allows us to.  Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract we are about to enter into or have entered into with you, or to take steps at your request prior to entering into a contract with you;

  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA 

We have set out below, in a table format, a description of all the ways we plan to use your Personal Data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using that data. Please contact us using the details set out above if you need details about the specific legal ground we are relying on to process your Personal Data where more than one ground has been set out in the table below.
 

Purpose / Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new or prospective customer          (a) Identity
(b) Contact   
Performance of a contract with you
To process and deliver your order including:
 
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us and promote our products and services)
To manage our relationship with you which will include:
 
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products / services)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise or sale of business or assets)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical
(b) Usage
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
Necessary for our legitimate interests (to develop our products/services and grow our business)
To make decisions about your selection and recruitment for a job (a) Recruitment (a) To take steps prior to entering into a contract with you
(b) Necessary for our legitimate interests (to ensure that we can make recruitment decisions)

 

 

MARKETING  

We strive to provide you with choices regarding certain uses of your Personal Data, particularly around marketing. 

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us, purchased goods or services from us, consented to receiving such communications or where we are pursuing a legitimate interest and have a lawful right to do so and, in each case, you have not opted out of receiving that marketing.
We will obtain your express opt-in consent before we share your Personal Data with any third party outside the Afton Group for marketing purposes.

For guidance on special rights for California residents, please click here.

OPTING OUT  

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at [email protected] at any time.
Where you opt out of receiving these marketing messages, this will not apply to your Personal Data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions. For guidance on specific rights for California residents, please click here.

COOKIES 

You can set your browser settings, our use the check boxes in our Cookie Policy, to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see http://www.aftonchemical.com/Generic/Cookie-Policy.

CHANGE OF PURPOSE  

Afton will only process your Personal Data in ways that are compatible with the purpose that we collected it for, or for purposes you later authorize. 
Before we use your Personal Data for a purpose that is materially different than the purpose we collected it for or that you later authorize, we will notify you, explain the legal basis which allows us to do so, and provide you with the opportunity to opt out. 

Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.


5.  DISCLOSURES OF YOUR PERSONAL DATA  

To provide services and effectively run our business, we may need to share your Personal Data as permitted by law. We may share your Personal Data with the following categories of recipients:

  • Other companies within the Afton Group;
  • Service providers (which may include “service providers” as that term is defined under the California Consumer Privacy Act), including IT and system administration services and recruitment agencies.
  • Professional advisers including  lawyers, bankers, auditors and insurers.
  • Regulators and other authorities where required by law.
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners are permitted to use your Personal Data in the same way as set out in this privacy statement.

We require all group companies and third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions. 

We do not sell the Personal Data we collect about you. We may, however, share your Personal Data with service providers or third parties in accordance with the business purposes set out in this privacy statement.

6.  INTERNATIONAL TRANSFERS 

Afton is headquartered in the United States. As a result, if you are located in Europe, your Personal Data may be transferred outside Europe.
 
This website is hosted in the United States. Personal Data that is voluntarily provided on or via this website may be maintained or accessed in servers or files located in the United States, which Europe has not deemed to provide "adequate" privacy safeguards. If you do not consent to having your Personal Data processed and stored in the United States, please do not provide it to Afton. By voluntarily providing your Personal Data on or via this website, you acknowledge and accept that your Personal Data will be transferred, processed and stored in the United States.

Afton complies with the EU-US Privacy Shield program as set forth by the US Department of Commerce, regarding the collection, use and retention of Personal Data from Europe. This requires us to comply with similar data protection standards to Personal Data to those required under European law.

For more information about the Privacy Shield, see the US Department of Commerce’s Privacy Shield website located at: https://www.privacyshield.gov and our Privacy Shield policy: https://www.aftonchemical.com/Generic/EU-–-US-Privacy-Shield-Policy.

To review Afton’s representation on the Privacy Shield list, see the US Department of Commerce’s Privacy Shield self-certification list located at: https://www.privacyshield.gov/list

Some of our third party service providers are based outside Europe so their processing of your Personal Data will involve a transfer of data outside Europe.

Whenever we transfer your Personal Data out of Europe, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

7.  DATA SECURITY  

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8.  DATA RETENTION  

Afton maintains reasonable procedures to help ensure that your Personal Data is reliable for its intended use, accurate, complete, and current.

We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Where it is no longer necessary to retain your Personal Data, we will securely delete, or in some circumstances, anonymize your Personal Data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further statement to you. Any such anonymization would be performed in accordance with, and where allowed by, applicable law.

To determine the appropriate retention period for your Personal Data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements We have a record of retention policy. This can be provided upon request.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

California residents have special right with respect to our retention of Personal Data. There are described here.

9.  YOUR LEGAL RIGHTS AS A RESIDENT OF EUROPE  

If you are located in Europe, under certain circumstances, you have rights under data protection laws in relation to your Personal Data. These rights include:

  • Request access to your Personal Data (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
  • Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. 
  • Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.  
  • Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.  
  • Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. 
  • Request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.  
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact the appropriate Data Compliance Representative.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.


 

10.  YOUR RIGHTS AS A CALIFORNIA RESIDENT UNDER THE CALIFORNIA CONSUMER PRIVACY ACT (“CCPA”) 

California Privacy Rights

Beginning January 1, 2020, California residents may exercise certain privacy rights pursuant to the California Consumer Privacy Act of 2018 (“CCPA”). Your right to submit certain requests as a California resident are described below. Please note that when submitting a request, you will be asked to provide information to verify your identity before action is taken. You may designate an authorized agent to make the requests below on your behalf. An authorized agent must submit proof to us that he or she has been authorized by you to act on your behalf, and you will need to verify your identity directly with us.

More Information
 

Right To Request More Information

As a California resident, you have the right to request more information regarding the following, to the extent applicable:
 

(1) The categories of Personal Data we have collected about you.

(2) The categories of sources from which we have collected your Personal Data.

(3) The business or commercial purpose why we collected or, if applicable, sold your Personal Data.

(4) The categories of third parties with whom we shared your Personal Data in the past 12 months.

(5) The specific pieces of Personal Data we have collected about you.

(6) The categories of Personal Data that we have shared with third parties about you for a business purpose.

You may submit a request for the information above by calling us at 1-800-259-7766, or emailing us at [email protected] The Afton Group will evaluate all requests for information under all applicable laws and confidentiality protections or restrictions that apply to the company, its clients, its employees, or to other third parties whose data the company collects. The Afton Group will not provide any information if it would otherwise violate governing law or legal protections that apply to such data, including without limitation any applicable privileges. In connection with submission of your request, we will take steps to verify your identity, and you will need to verify your identity before action is taken.
 

Right to Request Deletion of Your Personal Data

You also have the right to request that we delete your Personal Data collected or maintained by us. Once we receive your request, we will let you know what, if any, Personal Data we can delete from our records, and we will direct any service providers with whom we shared your Personal Data also to delete your Personal Data from their records. There may be circumstances where we cannot delete your Personal Data or direct service providers to delete your Personal Data from their records. For example, if we need to: (1) retain your Personal Data to complete a transaction or provide goods or services; (2) detect security incidents; (3) protect against unlawful activities; (4) identify, debug or repair errors; or (5) comply with a legal obligation. You may submit a request to delete your Personal Data by calling us at 1-800-259-7766, emailing us at [email protected] The Afton Group will not delete any information if it would otherwise violate law or legal protections that apply to such data, including any applicable privileges. In connection with submission of your request, we will take steps to verify your identity and you will need to verify your identity as required under California law before action is taken.

Verification of Requests Upon submission of a request for information or a request to delete information, we will take reasonable steps to confirm that the person submitting the request to know or request to delete is the person to whom the information relates, and to prevent unauthorized access or deletion of information. The specific steps taken to verify the identity of the requesting person may vary based on the nature of the request, including the type, sensitivity and value of the information requested, the risk of harm posed by unauthorized access or deletion, the likelihood that fraudulent or malicious actors may seek the information, the robustness of Personal Data provided to verify your identity, the nature of our business relationship with you, and available technology for verification.

We will generally try to avoid requesting additional information from you for the purpose of verification. However, we may need to do so if we cannot verify your identity based on the information already maintained by us. If we request additional information to verify your identity, it will be for that purpose only, and will be deleted as soon as practical after processing the request, except as otherwise provided by law.

The following generally describes the verification processes we use:
 
  • Password Protected Accounts. If you have a password-protected account with us, we may use existing authentication practices to verify your identity, but will require re-authentication before disclosing or deleting data. If we suspect fraudulent or malicious activity relating to your account, we will require further verification (as described below) before complying with a request to know or delete.
  • Verification for Non-Accountholders. If you do not have, or cannot access, a password-protected account with us, we will generally verify your identity as follows:
    • For requests to know categories of Personal Data, we will verify your identity to a reasonable degree of certainty by matching at least two data points provided by you with reliable data points maintained by us.
    • For requests to know specific pieces of Personal Data, we will verify your identity to a reasonably high degree of certainty by matching at least three data points provided by you with reliable data points maintained by us. We will also require a declaration, signed under penalty of perjury, that the person requesting the information is the person whose information is the subject of the request. We will maintain all signed declarations as part of our records.
    • For requests to delete Personal Data, we will verify your identity to a reasonable degree or a reasonably high degree of certainty depending on the sensitivity of the Personal Data and the risk of harm posed by unauthorized deletion. We will act in good faith when determining the appropriate standard to apply.
If there is no reasonable method by which we can verify your identity, we will state so in response to a request to know or delete Personal Data, including an explanation of why we have no reasonable method to verify your identity. As indicated above, the Afton Group will not delete any information if it would otherwise violate law or legal protections that apply to such data, including any applicable privileges.
 

Right to Non-Discrimination for the Exercise of California Resident’s Privacy Rights

By exercising any of the above listed privacy rights conferred by the California Consumer Privacy Act of 2018, you have the right not to receive discriminatory treatment by us. This means that, consistent with California law, we will not deny providing goods or services to you, charge you different prices or provide a different level or quality of goods and services to you unless those differences are related to the value of your information.
 
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