FERRO CORPORATION PRIVACY NOTICE
 
Last modified: March 2020
 
INTRODUCTION
 
This notice describes the types of personal data that Ferro Corporation (the “Company,” “we,” “our,” or “us”) may collect from you or that you may provide when (i) you visit the website at www.ferro.com ("Website"); or (ii) we collect information from our prospective and existing customers and vendors; or (iii) we collect information from prospective employees and applicants. This notice also describes our practices for collecting, using, maintaining, protecting, and disclosing that personal data. This notice does not apply to personal data collected through any other means, including on any other website operated by the Company or a third party or through any application or content (including advertising) that may link to or be accessible from the Website.

The Company is committed to protecting your privacy in compliance with the GDPR or any other applicable data protection law. We provide this notice to explain the types of personal data we collect and to inform you of the specific practices and guidelines that protect the security and confidentiality of your personal data. Please read this notice carefully. If you are a Website user and any term in this notice is unacceptable to you, please do not use the Website or provide any personal data. This notice may change from time to time (see section entitled “HOW FREQUENTLY IS THIS NOTICE REVISED?”). 

TABLE OF CONTENTS 

WHO IS RESPONSIBLE FOR THE PROCESSING OF YOUR PERSONAL DATA?
WHAT TYPES OF PERSONAL DATA DOES FERRO PROCESS?
FOR WHICH PURPOSES DOES FERRO PROCESS YOUR PERSONAL DATA?
HOW DOES FERRO DISCLOSE YOUR PERSONAL DATA?
HOW DOES FERRO DEAL WITH INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA?
HOW LONG DOES FERRO RETAIN YOUR PERSONAL DATA?
WHAT ARE YOUR DATA PROTECTION RIGHTS? 
WHAT SECURITY MEASURES HAS FERRO IMPLEMENTED?
HOW IS YOUR PERSONAL DATA PROCESSED BY THIRD-PARTY WEBSITES?
WHAT HAPPENS IF A CHILD UNDER THE AGE OF 16 USES OUR WEBSITE?
HOW DOES FERRO ENSURE COMPLIANCE WITH THIS NOTICE? 
HOW FREQUENTLY IS THIS NOTICE REVISED?
CCPA

WHO IS RESPONSIBLE FOR THE PROCESSING OF YOUR PERSONAL DATA?

Website data collection
The data controller for the purposes of processing personal data in the context of this Website is Ferro Corporation, with a registered office at 6060 Parkland Boulevard, Mayfield Height, Ohio 44124 USA.

Questions, comments, and requests regarding our Privacy Notice may be addressed to the Director, Risk & Compliance at FerroCompliance@Ferro.com or you may contact our EU Data Protection Coordinator at the following email address: DataProtectionEU@Ferro.com.
Contact information for our global locations is listed here.

Customer and vendor data collection
The data controllers for the purposes of processing personal data in the context of Ferro’s business relationship with customers, vendors and contractors is available here

WHAT TYPES OF PERSONAL DATA DOES FERRO PROCESS? 

We collect several types of personal data from and about (i) users of our Website; and (ii) existing and prospective customers and vendors, which may include information defined as “personal data” under the GDPR or “personally identifiable information” under applicable data protection laws. 

Ferro collects personal data relating to prospective customers and vendors, for instance when an individual submits a request through our Website or is identified through prospecting efforts.

Ferro also collects personal data relating to existing customers and vendors, such as personal data related to employees of our customers and vendors. 

Ferro will not collect personal data if such collection is prohibited under the applicable data protection laws. In any case, no personal data revealing racial or ethnic origin, political opinions, philosophical beliefs, or concerning sex life will be processed.

Ferro will maintain personal data in a manner that ensures it is accurate, complete and up-to-date.

We collect information such as your name, e-mail address, telephone number, country, job function, company/organization name, industry, current customer status, product interests, and information related to your inquiries and requests. We also collect information about your Internet connection and the equipment you use to access our Website. As you navigate through the Website, we automatically collect information such as your usage details, IP addresses, and information collected through cookies.  

Information You Give to Us. The information we collect on or through our Website includes:

• Information that you provide by filling in forms on our Website. This includes information provided when you sign up for e-alerts; when we process and respond to your inquiries related to products, technical and/or safety data sheets, technical support, R&D requests, media, and customer service; and when you provide feedback on our Website.
• Records and copies of your correspondence with us (including email addresses). 

The information you provide to us in the context of your existing or prospective business relationship with Ferro includes: 

• Business information necessary to render services or products to you (such as name of organization, phone number, email address, department and job title, bank details, personal identifiers, user account information);
• Contractual information (such as date of agreement, type of commercial relationship). 

Information We Automatically Collect About You. As with many other websites, as you navigate through and interact with our Website, we use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Website, including resources that you access and use on our Website, traffic data, location data, logs, date and time of access, frequency, and other communication data.
• Information about your computer and Internet connection, including your IP address, operating system, host domain, and browser type.
• Details of referring websites (URL).  

The information we collect automatically is statistical data that helps us improve our Website and deliver a better and more personalized service, including by enabling us to:

• Determine web site traffic patterns.
• Count web visits.
• Determine traffic sources so we can measure and improve the performance of our site.
• Help us to know which pages and content are the most and least popular.
• Observe site search patterns to provide more intuitive navigation cues.
• Determine user frequency and time between user visits.

FOR WHICH PURPOSES DOES FERRO PROCESS YOUR PERSONAL DATA? 

Ferro processes personal data in accordance with applicable data protection laws and only for limited, explicit and legitimate purposes.

Ferro will not use personal data for any purpose that is incompatible with the purpose for which it was initially collected unless you provide your prior explicit consent for further use.

Ferro processes your personal data for the following purposes and corresponding legal basis: 

For questions or additional information regarding the purpose and legal basis for processing personal data, please contact either the Director, Risk & Compliance, Ferro Corporation or the Ferro EU Data Protection Coordinator.

Ferro ensures that our internal governance procedures clearly specify the reasons behind decisions to use personal data for further processing purposes. Prior to using your personal data for a purpose other than the one for which it was initially collected, you will be informed about such new purpose.
   

HOW DOES FERRO DISCLOSE YOUR PERSONAL DATA?

Ferro will only grant access to personal data on a need-to-know basis, and such access will be authorized and limited to the personal data that is necessary to perform the function for which such access is granted.

Service providers are legally and contractually required to abide by our instructions when processing personal data and will only receive personal data according to the purposes of the service agreement or any other type of contract entered into with Ferro.

We disclose aggregated information about our Website users’, and information that does not identify any individual, without restriction.

Subject to any applicable laws and regulations, we disclose personal data that we collect or you provide as described in this notice:

Within our organization 

• To authorized staff members employed by Ferro Corporation or our subsidiaries and affiliates

To third parties

• To contractors, service providers, and other third parties we use to support our business or in connection with the administration and support of the activities noted above and who are bound by contractual obligations to keep personal data confidential and use it only for the purposes for which we disclose it to them (e.g., database hosting providers, managed services providers, or consultants); 
• To insolvency administrators in the event of bankruptcy;
• To tax authorities and/or other governmental agencies as required by law. 

To other third parties

• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by the Company is among the assets transferred.
• To fulfill the purpose for which you provide it. For example, if you request us to contact a third-party we may transmit the content of your request to the recipient. 
• For other purposes only with your consent when required by applicable law and regulations.
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements, including for billing and collection purposes; or to protect the rights, property, or safety of Ferro, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

HOW DOES FERRO DEAL WITH INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA?

International data transfers refers to transfers of personal data outside of the EU.

The international footprint of Ferro involves a large number of transfers of personal data between different corporate entities, as well as to third parties located in various countries. This includes the transfer of personal data from EU Member States to countries outside of the EU considered as not providing adequate legal protection for the processing of personal data.

Ferro ensures that appropriate safeguards are implemented to secure such data transfers in compliance with applicable data protection laws. We have implemented international data transfer agreements based on EU Standard Contractual Clauses to cover our international data transfers and a copy of these clauses can be obtained by contacting the EU Data Protection Coordinator.

HOW LONG DOES FERRO RETAIN YOUR PERSONAL DATA?

We will not retain your personal data processed longer than allowed under the applicable data protection laws. In any case, we will not retain it longer than such personal data is necessary for the purpose for which it was collected or otherwise processed, subject to applicable local retention requirements.

WHAT ARE YOUR DATA PROTECTION RIGHTS? 

You may at any time exercise certain rights you may have under applicable law and regulation. 

Under the GDPR, you may benefit from the rights listed in this section. These rights can be exercised by you at any time by contacting the Ferro EU Data Protection Coordinator. 

Right to access
You are entitled to obtain confirmation from Ferro as to whether or not any personal data concerning you is processed by Ferro.
In the affirmative, you have the right to access such personal data, to obtain a copy of it free of charge (except for repetitive or excessive requests) and to be provided with the following information:

(i) purposes of such processing, (ii) categories of personal data concerned, (iii) recipients or categories of recipients of personal data, in particular recipients in third countries outside the EU, (iv) the envisaged retention period or, if not possible, the criteria used to determine it, (v) existence of the right to request rectification or erasure of personal data, as well as the right to object to or request restriction of processing, (vi) the right to lodge a complaint with a supervisory authority, (vii) information relating to any third party source of personal data if the data were not collected from you, and (viii) the existence, the logic involved, the significance and the consequences of any automated decisions, including profiling.

Where personal data is transferred outside of the EU, you will be informed of the appropriate safeguards relating to such transfer.

Right to rectification
You have the right to obtain without undue delay the rectification of inaccurate, incomplete or outdated personal data concerning you.

Right to erasure
You have the right to obtain without undue delay the erasure of your personal data in one of the following cases:

• The personal data is no longer necessary in relation to the purpose(s) for which it was collected or otherwise processed;
• You withdraw the consent on which the processing was based, and there are no other legal grounds for the processing;
• You object to the processing, as provided in the “Right to object” section below;
• Your personal data has been unlawfully processed;
• Your personal data has to be erased for compliance with a legal obligation in EU or EU Member State law.

However, Ferro may refuse the erasure of personal data if the processing of such data is necessary for (i) exercising the right of freedom of expression and information, (ii) compliance with a legal obligation which requires processing by EU or EU Member State law or for the performance of a task carried out in the public interest, (iii) reasons of public interest in the area of public health, scientific or historical research purposes or statistical purposes, or (iv) establishment, exercise or defense of legal claims.

Right to restriction
You have the right to obtain restriction of processing in the following cases:

• Where you claim inaccuracy of your personal data processed by us (the restriction being provided for a period enabling Ferro to verify the accuracy);
• Where the processing appears unlawful, and you oppose the erasure and request the restriction of use of your personal data instead;
• Where Ferro does not need your personal data for the purposes of processing, but the personal data is required by you for the establishment, exercise or defense of legal claims; and
• Where an objection is raised by you in relation to the processing, pending the verification whether the legitimate grounds of Ferro override those of you.
  
   

When you have obtained a restriction of processing of your personal data, you will be informed prior to lifting of such restriction.

Right to object
As a general rule, you have the right to object, at any time and on legitimate grounds relating to your particular situation, to the processing of your personal data.
Provided that such objection is justified, Ferro will no longer process the personal data concerned unless we can demonstrate compelling legitimate grounds for the processing which override your interests.

Right to data portability
In cases where the data processing is based on your consent or on your contract, and where such processing is carried out by automated means, you can request us (i) to communicate to you the personal data concerning you, in a structured, commonly used and machine-readable format, in order to be able to further transmit such personal data to another data controller, or (ii) to directly transmit such personal data to such other data controller, if technically feasible.

However, Ferro can refuse such request if the processing concerned is necessary for the performance of a task carried out in the public interest or if responding to such request risks to adversely affect the rights and freedoms of others.

Right to withdraw consent
Where the processing of your personal data is based on consent, you have the right to withdraw such consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.

Right to lodge a complaint
You also have the right to lodge a complaint with the competent supervisory authority.
 

WHAT SECURITY MEASURES HAS FERRO IMPLEMENTED? 

We have implemented measures designed to secure your personal data from accidental loss and from unauthorized access, use, alteration, and disclosure. Personal data provided to us through our Website (e.g., when you fill out and submit a web form to us) will be encrypted in transit.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Website. 

HOW IS YOUR PERSONAL DATA PROCESSED BY THIRD-PARTY WEBSITES?

Our Website may contain links or references to other websites outside of our control. Please be aware that this notice does not apply to these websites. The Company encourages you to read the privacy statements and terms and conditions of linked or referenced websites you enter. These third-party websites may send their own cookies and other tracking devices to you, log your IP address, and otherwise collect data or solicit personal data. THE COMPANY DOES NOT CONTROL AND IS NOT RESPONSIBLE FOR WHAT THIRD PARTIES DO IN CONNECTION WITH THEIR WEBSITES, OR HOW THEY HANDLE YOUR PERSONAL DATA. PLEASE EXERCISE CAUTION AND CONSULT THE PRIVACY POLICIES POSTED ON EACH THIRD-PARTY WEBSITE FOR FURTHER INFORMATION. 

WHAT HAPPENS IF A CHILD UNDER THE AGE OF 16 USES OUR WEBSITE?
 
Our Website is not intended for children under 16 years of age, and the Company does not knowingly collect or use any personal data from children under the age of 16. No one under the age of 16 may provide any information to or on the Website. If we learn we have collected or received personal data from a child under the age of 16, we will delete that information. If you believe we might have any information from or about a child under the age of 16, please contact either the Director, Risk & Compliance, Ferro Corporation or our EU Data Protection Coordinator.
 

HOW DOES FERRO ENSURE COMPLIANCE WITH THIS NOTICE?

Monitoring and ensuring compliance of the personal data processing within Ferro with this notice and applicable data protection laws is the responsibility of the EU Data Protection Coordinator.

As mentioned above, you may contact the EU Data Protection Coordinator with regard to any issue related to processing of your personal data and to exercise your rights as mentioned in the section entitled “WHAT ARE YOUR DATA PROTECTION RIGHTS?” above.

CAN THIS NOTICE BE REVISED?

We reserve the right to change this notice at any time. Any changes we make will be posted on this page. If we make material changes to how we treat your personal data, we will notify you through a notice on the Website home page via a separate banner related to this Website privacy notice. The date this notice was last revised is identified at the top of the page. You are responsible for ensuring we have a deliverable email address for you, and for periodically monitoring and reviewing any updates to this notice. Your continued use of our Website after such amendments will be deemed your acknowledgement of these changes to this notice.

YOUR CALIFORNIA PRIVACY RIGHTS
 
The California Consumer Privacy Act (“CCPA”) provides eligible California residents with specific rights with respect to our collection and use of personal information. Please see our California Privacy Rights Notice that supplements this Privacy Notice and applies solely to eligible residents of California as of January 1, 2020.