Swagelok Privacy and Data Protection Policy

Last updated September 12, 2018

SWAGELOK’S COMMITMENT TO PRIVACY

Swagelok Company, its subsidiaries and its authorized sales and service centers (collectively, “Swagelok” or “we,” “us,” or “our”) respect your right to privacy and are committed to protecting your information and/or data. This policy (the “Policy”) summarizes what information we may collect through Swagelok.com® and any authorized sales and service center website (collectively, the “Sites”), how the information may be used, with whom it may be shared, and other important topics relating to your privacy and data protection.

Please read this Policy carefully, because by using the Sites, you are acknowledging that you understand and agree to the terms of this Policy. In addition, please review the Terms and Conditions of Use, which govern your use of the Sites and any content you submit to the Sites.

1.    USE AND COLLECTION OF INFORMATION

Use of Cookies and Similar Technologies

Like most companies, Swagelok uses cookies and similar tools (“cookies”) on the Sites to facilitate and improve your online experience. Please review the Swagelok.com® Cookie Notice and Disclosure, which explains how we do that.

Information You Provide To Us

Generally you can visit the Sites without providing personal data, unless otherwise mentioned in the Sites themselves. For instance, at Swagelok.com, you may register with an authorized sales and service center, which enables you to place orders electronically with your selected authorized sales and service center. If you choose to register and place an order, you will be asked to provide certain personal data, including your name, e-mail address, company name, telephone number, job title, market, billing and shipping information (“Personal Information”). 

The collection, processing and the use of Personal Information collected during registration with your authorized sales and service center requires your consent. The consent may be declared electronically. You may withdraw your consent at any time by sending an e-mail to 资讯sec@swagelok.com or write to us at Swagelok Company, Data Privacy Officer, 6262 Cochran Road, Solon, Ohio 44139 USA.

In addition, if you choose to communicate with us by e-mail or otherwise complete on-line forms or other documents, this 资讯rmation may also be collected in your profile. 更多over, if you choose to use the “forward to a friend” function, or link to referenced documents or sources, this 资讯rmation is used to analyze site usage metrics.

Information We Collect Automatically

We (and third party service providers acting on our behalf) use cookies and other tools (such as web analytic tools and pixel tags) to automatically collect 资讯rmation 关于 you when you use the Sites, subject to the terms of this Policy and applicable data laws and regulations. The types of 资讯rmation collected automatically may include:

• information about the type of browser you use;
• details of the web pages you have viewed;
• your IP address; and
• the hyperlinks you have clicked.

We use this data to determine the general physical location of your computer or device and understand what regions of the world our visitors to the Sites are coming from. We also may use this Personal Data to enhance the Sites.

Use and Collection of Personal Information

The following persons or entities may have access to the Personal 资讯rmation that you provide to Swagelok: Swagelok, and its employees, and Swagelok authorized sales and service centers and their respective employees. We will take reasonable care to protect data and limit access only to Swagelok employees or Swagelok authorized sales and service center employees who have a legitimate business reason to view the Personal 资讯rmation. All parties who have access to your Personal 资讯rmation are required to keep it confidential and may not use it for any purpose other than to provide you 服务 within the normal business activities of Swagelok and its authorized sales and service centers. Such normal business activities may include, for example:

• communicating with you about your account, products, services, events, surveys and promotions by Swagelok (including by sending you marketing communications);
• sending you samples, products and information;
• processing payment for products or services purchased by you;
• processing payment for products or services sold by you to Swagelok;
• providing you with access to certain areas and features of the Sites;
• verifying your identity to ensure security for the other purposes listed here;
• processing, evaluating and responding to your requests, inquiries and applications; and
• for purposes disclosed at the time you provide your Personal Information or otherwise with your consent.

2.    SHARING AND TRANSFERRING OF YOUR PERSONAL INFORMATION

We will keep your Personal 资讯rmation private and will not disclose it to other parties, unless such disclosure is necessary to: (a) comply with any federal or state law, a court order or other legal process; (b) prevent physical harm or financial loss, or in connection with an investigation of suspected or actual illegal activity; (c) enforce any of our Terms and Conditions of Use; (d) enable service providers we may have retained to perform 服务 on our behalf; or (e) enable other Swagelok group companies performing 服务 on our behalf. We also reserve the right to transfer Personal 资讯rmation in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution or liquidation). However, we may share non-Personal 资讯rmation, such as aggregate user statistics, demographic data, and usage data with third parties. When sharing any Personal 资讯rmation with a third party, Swagelok will require that party to use and protect your Personal 资讯rmation in a manner that is consistent with this Policy.

In the event that we transfer the Personal 资讯rmation collected to other countries where we do business, we will do so only for the purposes described herein. When any Personal 资讯rmation is transferred, it will be protected as stated in this Policy.

3.    CHOICE AND ACCESS

We will give notice to you regarding the types of third parties to which we disclose any Personal Information, and provide choice regarding the types of Personal Information we disclose. You can choose to opt-out of having Personal Information stored in our systems at any time by sending an e-mail to 资讯sec@swagelok.com or by writing us at Swagelok Company, Data Privacy Officer, 6262 Cochran Road, Solon, Ohio 44139 USA. Except as may be provided otherwise in this Policy, unless otherwise authorized by the individual, Swagelok will not disclose Personal Information to a third party. For sensitive Personal information, we will provide an affirmative or explicit (opt in) choice if: (i) the personal information is to be disclosed to a third party; (ii) used for a purpose other than those for which it was originally collected; or (iii) subsequently authorized by the individual through the exercise of opt in choice. You can request a copy of the Personal Information that Swagelok has collected about you at any time by sending an e-mail to 资讯sec@swagelok.com or by writing us at Swagelok Company, Data Privacy Officer, 6262 Cochran Road, Solon, Ohio 44139 USA. You can also have factual inaccuracies in this information corrected, or request that your Personal Information be removed, by contacting us. We are under no obligation to store Personal Information indefinitely and disclaim any liability arising out of, or related to, the destruction of Personal Information.

4.    HOW WE PROTECT YOUR PERSONAL INFORMATION

Security

Swagelok takes reasonable and appropriate precautions to protect Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction.

Data Integrity

Swagelok uses Personal 资讯rmation only for the purposes for which it was collected or subsequently authorized by the individual. Swagelok takes reasonable steps to ensure that the Personal 资讯rmation the company processes are (i) relevant for the purposes for which they are to be used, (ii) reliable for their intended use, and (iii) accurate, complete and current.

Verification

Swagelok uses a self-assessment approach to ensure compliance with this Policy. This includes a periodic assessment to verify the Policy is accurate and being adhered to. If you have concerns, please 联系 us and Swagelok will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of personal 资讯rmation.

5.    CHILDREN’S PRIVACY

The Sites are not directed to children under the age of thirteen (13) and we do not knowingly collect Personal 资讯rmation from children under the age of thirteen (13) on the Sites. If we become aware that we have inadvertently received Personal 资讯rmation from a visitor under the age of 13 on the Sites, we will delete the 资讯rmation from our records.

6.    CHANGES TO THE PRIVACY, DATA PROTECTION AND COOKIES POLICY

This Policy may be updated periodically and without prior notice to you to reflect changes in our information practices. We will post a prominent notice on Swagelok.com to notify you of any significant changes to our Policy and indicate at the top of the Policy when it was most recently updated.

7.    LINKS TO OTHER SITES

The Sites may contain links to other websites for your convenience and 资讯rmation. We are not responsible for the privacy practices or the content of linked websites. Please refer to the privacy policies of those third-party websites.

8.    HOW TO CONTACT US

If you have any questions or comments 关于 this Policy, please 联系 us by:

Writing to:

Data Privacy Officer

Swagelok Company

6262 Cochran Road Solon, Ohio 44139 USA

or

Via e-mail to: 资讯sec@swagelok.com

1. TERMS

The terms (the “Terms”) set forth herein govern the provision of the training 服务 (the “Training 服务”) provided by Swagelok Company or its subsidiaries and any Swagelok Authorized Distributor (collectively, “Swagelok”) to the user or recipient of the Training 服务 (individually and collectively the “User”). Any User response to, or confirmation of, these Terms which states different or additional terms is specifically rejected unless specifically agreed to in writing by Swagelok. Swagelok’s failure to object to provisions contained in any communication from User will not be deemed a waiver of the Terms contained herein.

2. WARRANTY

(a) The Training 服务 shall be performed in a professional and workmanlike manner. The User’s remedies shall be limited to a refund of the fees paid for such Training 服务.

(b) IT IS EXPRESSLY AGREED THAT THIS WARRANTY IS IN LIEU OF ANY AND ALL OTHER WARRANTIES AND LIABILITIES, EXPRESSED OR IMPLIED, INCLUDING BUT NOT LIMITED TO ANY WARRANTY OF MERCHANTABILITY OR FITNESS FOR ANY PURPOSE.

3. LIMITATION OF LIABILITY

IN NO EVENT, REGARDLESS OF CAUSE, SHALL SWAGELOK ASSUME RESPONSIBILITY OR BE LIABLE FOR: (a) PENALTIES OR PENALTY CLAUSES OF ANY DESCRIPTION, (b) TO THE EXTENT PERMITTED BY LAW, INDEMNIFICATION OF USER OR OTHERS FOR COSTS, DAMAGES, OR EXPENSES EACH ARISING OUT OF OR RELATED TO THE TRAINING 服务 PROVIDED, (c) CERTIFICATION, UNLESS OTHERWISE SPECIFICALLY PROVIDED FOR IN WRITING BY SWAGELOK, OR (d) INDIRECT, SPECIAL OR CONSEQUENTIAL DAMAGES UNDER ANY CIRCUMSTANCE, INCLUDING ANY LOST PROFITS, BUSINESS INTERRUPTION, OR OTHER DAMAGES. IN NO EVENT SHALL SWAGELOK LIABILITY EXCEED THE PURCHASE PRICE FOR THE TRAINING 服务 REGARDLESS OF THE FORM OF ACTION, WHETHER IN CONTRACT OR TORT, INCLUDING NEGLIGENCE. THE FOREGOING WARRANTY AND LIMITATION OF LIABILITY STATES USER’S ENTIRE AND EXCLUSIVE LIABILITY AND SOLE REMEDY.

4. RELEASE OF CLAIMS.

User hereby waives, releases, and relinquishes any and all claims for liability and causes of action, including, but not limited to, personal injury, property damage or wrongful death, arising out of participation in the Training 服务 or activities incidental thereto, whenever or however they occur, regardless of fault. User acknowledges, understands and assumes all risks relating to User’s participation the Training 服务, and understands that the Training 服务 involve risks including, but not limited to, death or bodily injury.

5. INTELLECTUAL PROPERTY.

All intellectual property contained in the training materials delivered to the User as part of the Training 服务 shall remain the exclusive property of Swagelok and may not be disclosed to, or relied upon by any third party unless approved in writing by Swagelok. Swagelok hereby grants User a limited, non-exclusive license to use the training materials solely for User’s internal business use.

6. CHOICE OF LAW AND VENUE.

The laws of the State of Ohio, USA shall govern and be used to construe Terms and any claims or disputes related to these Terms or the Training 服务. Such laws shall exclude conflict of law provisions and the UN Convention on Contracts for the International Sale of Goods. All actions or proceedings under or relating to this agreement shall be resolved in a state, or federal Northern District of Ohio court located in that jurisdiction; provided, however, that in Swagelok’s discretion such an action may be heard in some other place designated by Swagelok if necessary to acquire jurisdiction over third parties to consolidate the dispute into one action. User hereby agrees to appear in any such action, consents to the jurisdiction of such courts, and waives any objections it might have as to venue in any such court.

7. EXCLUSIVE TERMS AND CONDITIONS.

It is expressly agreed that these Terms contain the complete agreement between User and Swagelok, and no agreement or other understanding purporting to modify them shall be binding upon Swagelok without Swagelok’s written consent. Course Cancellations: Swagelok reserves the right to cancel a course in its sole discretion. Registered students will be notified and refunded no later than 30 days prior to course date. Swagelok is not responsible for fees incurred with cancelled travel. Students needing to cancel an enrollment may change enrollment to another course date, send someone in your place, or request a refund. Refund requests must be received 3 weeks prior to the start day of the enrolled training course. Course cancellations, refunds and changes may be requested by contacting your authorized Swagelok sales and service center or by emailing analyticaltraining@swagelok.com.