PRIVACY POLICY

Last Modified: 11 March 2021

EJ Group, Inc. (“EJ”) (“us”, “we” or “our”) is committed to following the standards set by national and international law in addition to EJ's policies and ethics.

This Privacy Policy, together with Terms of Use of the Website (the “Website”), Cookie Policy and the documents referred to in them, sets out the basis on which any personal data we collect from you or that you provide to us will be processed.

We will use your personal data (or “personal information” under the meaning of the Australian Privacy Act of 1988 (Cth) as amended from time to time) only for the purposes and in the manner set forth below.

In broad terms, “Personal Data” is any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier that we collect through this Website. Information is not Personal Data where the information cannot be linked to an identifiable individual.

Our commitment to securing your Personal Data is demonstrated in this Privacy Policy which has been developed to ensure that your Personal Data is handled appropriately. It describes the kinds of Personal Data that EJ, as a data controller, collects from Website users, how EJ holds, processes and uses it, with whom it is shared, and how you can contact EJ for any queries regarding your privacy.

Please read this Privacy Policy carefully to understand our treatment and use of Personal Data.

IDENTITY OF THE CONTROLLER OF PERSONAL DATA

For the purposes of Data Protection legislation, the Data Controller of the Site is EJ, having its registered office at EMEA - Zone Industrielle de Marivaux – BP 50409 – 60149 Saint Crépin Ibouvillers. In this document personal data and personal information are referred to as “Personal Data”.

CONTACT DETAILS

Questions, comments and requests regarding this Privacy Policy and the information we hold are welcome and should be addressed to dpo@ejco.com (in Europe, the Middle East and Africa) or customersupport@ejco.com (for all other global regions) or alternatively you can write to us at: EMEA - Zone Industrielle de Marivaux – BP 50409 – 60149 Saint Crépin Ibouvillers.

CHANGES IN PROCESSING

If at any time we decide to use your personal data in a manner significantly different from that stated in this Privacy Policy, or otherwise disclosed to you at the time it was collected, we will notify you by email, and you will have a choice as to whether or not we use your information in the new manner.

WHAT PERSONAL DATA IS COLLECTED ABOUT VISITORS TO THE WEBSITE

When you visit or use the Website in any way, we may collect and process different types of information about you. If a Website user creates a Website profile, for example, to use the “Contact us” page or to request literature, the user becomes a “registered user”. The following Personal Data may be collected from Website users seeking to become registered users:

• Contact details (including first name, last name, company, address (including street name, city, state/province/county, country and post code), email address, and phone number) as mandatory fields;
• Issue details and comments as mandatory fields on the “Contact Us” form only;
• Title, job function, type of business, area of interest, interests and comments as optional fields on the “Literature Request” page; and
• Preferred language and preferred unit of measure as optional fields on the “Register” and “Create a User Profile” pages.
• IP Address and activity on the www.ejco.com website, for example, drawing downloads, videos watched, pages viewed and time on website.

If you want to use a pseudonym or remain anonymous when dealing with us, you should notify us by email message to dpo@ejco.com (in Europe, the Middle East and Africa) or customersupport@ejco.com (for all other global regions) and we will try to accommodate your request, subject to our ability to provide this service.

An unregistered user of the Website will not be required to provide any Personal Data, but cookies may be created and used as indicated and defined in the Cookie Policy.

HOW PERSONAL DATA IS COLLECTED

We collect Personal Data via the www.ejco.com Website in three primary ways:

1. Navigation habits are collected via cookies and other similar technologies during navigation of our web site;
2. Personal Data is collected via the Website registration, Contact Us, or Literature Request forms; and
3. User Surveys.

WHY WE COLLECT, HOLD, USE OR DISCLOSE PERSONAL DATA

We generally collect and use Personal Data from Website users for the following purposes:

• To evaluate and grant rights to access information posted on the Website (registered users have access to certain Website features not available to unregistered users);
• To communicate with registered users concerning their use of the Website and any other queries expressed;
• To supply requested services;
• To monitor for misuse of EJ's proprietary information;
• To gather feedback from registered users about EJ services;
• To send email communications containing direct marketing materials when you have indicated your consent to receive such emails. You can withdraw your consent to receive any such marketing emails at any time by opting-out through the registered user Website profile page, by selecting to unsubscribe in any email marketing campaign or by sending an email message to emea.sales@ejco.com (in Europe, the Middle East and Africa) or customersupport@ejco.com (for all other global regions) to request to be unsubscribed from future email marketing campaigns; and
• To provide support and notification of new services and to notify registered users about important changes or developments to the Website or EJ services.

We may also use the Personal Data provided by you in user surveys regarding the experience you had, to help us better understand and respond to our customers' needs and interests and to take into account our customers’ feedback.

We may also use aggregate information and statistics for the purposes of monitoring Website usage in order to help us develop and improve the Website.

We take reasonable steps to use and disclose personal information for the primary purpose for which we collect it, however, the Personal Data we collect may also be used or disclosed by us for other secondary purposes that are within your reasonable expectations and that are related to our primary purposes of collection.

OUR LEGAL BASIS FOR PROCESSING YOUR INFORMATION

The basis for our processing of your Personal Data vary depending on the different purposes set out above. For example, where we provide you with email communications containing direct marketing materials from us the basis of our processing is your consent, which we will ask for and can be withdrawn at any time. When we use your Personal Data to fulfill an order you placed from our Website, respond to your inquiries, and provide our Website, we do so on the basis of fulfilling our contract with you. For all other purposes noted above, we will only process your Personal Data for our business’ legitimate interests, such as to improve our website and/or our services and products made available to you, or to comply with our legal obligations.

WHO WE SHARE YOUR PERSONAL DATA WITH

We may sometimes disclose your Personal Data to agents or service providers appointed by us and/or to regulatory bodies, who work for us in connection with the provision of our services. We will have written contracts with them which provide assurances regarding the protections that they will give to your personal data and their compliance with our data security standards and international transfer restrictions. The following is a non-exhaustive list of these agents and service providers:

• EJ corporate affiliates, or joint venture partners to assure that EJ is more responsive to the needs of its customers on a need to know basis only;
• Third party service providers acting on EJ’s behalf and under its instructions, These third parties are providing their support to EJ as data processors:
  • Salesforce as a SaaS CRM service provider
  • Infor as an ERP managed service provider
  • AWS as a hosted service provider

We may access and/or disclose your Personal Data if required to do so by law or in good faith and belief that such action is necessary to: (a) conform with the law or comply with legal process served on us; (b) protect and defend our rights or property including, without limitation the security and integrity of our network and systems; or (c) act under exigent circumstances to protect the personal safety of users of our services or members of the public.

We may also provide non-personal data to third parties, where such information is combined with similar information of other users of our Website. For example, we might inform third parties regarding the number of unique users who visit our Website, the demographic breakdown of our community users of our Website, or the activities that visitors to our Website engage in while on our Website. The third parties to whom we may provide this information may include our Website design, development and hosting contractors.

INTERNATIONAL TRANSFERS

Personal Data collected on this Website may be stored or processed in the United States and other countries that may not guarantee the same level of protection of personal information as the one in which you reside. For example, all Personal Data collected from this Website is stored on secure servers in the United States of America (“USA”) owned by EJ USA, Inc. However, we will handle your Personal Data in accordance with this Policy regardless of where your personal information is kept. Your Personal Data will only be stored or transferred using safeguards that have been approved by the relevant regulatory body. Please contact us as described in this Privacy Policy for more details about the suitable mechanisms we have in place.

HOW WE HOLD AND SECURE PERSONAL DATA

We may hold Personal Data physically at our premises and electronically on secure servers.

All Personal Data we collect is kept confidential and protected from unauthorized use by non-authorized third parties, dissemination, alteration, damage or publication, in strict accordance with international privacy laws and our internal policies.

We secure the Personal Data we hold in numerous ways, including by using passwords and firewalls, storing Personal Data on secure servers and implementing physical security systems to ensure that only our authorized personnel are permitted to access your Personal Data.

As effective as modern security practices are, no physical or electronic security system is entirely secure. 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 Personal Data transmitted to our Website. Any transmission of Personal Data is at your own risk. Once we receive your Personal Data, we will use appropriate security measures to seek to prevent unauthorized access. We will continue to revise policies and implement additional security features as new technologies become available.

FOR HOW LONG WE WILL USE YOUR DATA

We keep your personal data for as long as it is necessary to do so to fulfil the purposes for which it was collected as described above, including for the purposes of satisfying any legal, accounting, or reporting requirements.

YOUR RIGHTS AND OPTIONS

For registered users, you can either change your Personal Data from the Personal Information page found on the My Account page or send an email to dpo@ejco.com (in Europe, the Middle East and Africa) or customersupport@ejco.com (for all other global regions) to request that the account be canceled and the personal data be removed from the system.

In addition, European data protection laws gives you the following rights in some circumstances related to your Personal Data:

Access – You may ask us to provide you with information about our processing of your Personal Data and give you access to your Personal Data.

Correct – You may ask us to update or correct inaccuracies in your Personal Data.

Delete – You may ask us to delete your Personal Data.

Transfer – You may ask us to transfer a machine-readable copy of your Personal Data to you or a third party of your choice

Restrict– You may ask us to restrict the processing of your Personal Data.

Object – You have the right to object to our processing your data where we are relying on a legitimate interest in order to process it.

To exercise any of your rights, please contact us using the “Contact Details” above.

LINKS TO OTHER WEBSITES

Our Website may, from time to time, contain links to and from other Websites and web platforms. In addition, third party Websites may also provide links to our Website. If you follow a link to any of those Websites or web platforms, please note that those Websites and web platforms have their own privacy policies and that we do not accept any responsibility or liability for those policies. Please check those policies before you submit any personal data to those Websites.

We do not accept, and we disclaim, any responsibility for the privacy policies and information protection practices of any third party Website (whether or not such Website is linked on or to our Website). These links are provided to you for convenience purposes only, and you access them at your own risk. It is your responsibility to check the third party Website's privacy policies before you submit any personal data to their Websites.

SOFTWARE QUALITY

The security and confidentiality of your personal data is extremely important to us. As no data transmission over the Internet can be guaranteed as 100% secure, we cannot ensure or warrant the security of any information that you transmit to us and you transfer the personal data at your own risk. We endeavor to use and keep under review appropriate technical and organizational measures (including staff training and awareness) in order to protect against unauthorized or unlawful processing of your personal data, including unauthorized destruction, alteration or disclosure or access. We shall only hold personal data for as long as is necessary or as required by law.

CHANGES TO OUR PRIVACY POLICY

We reserve the right to change this Privacy Policy at any time in our sole discretion. If we make changes, we will post these changes in the Change Log at the bottom of this policy so that you can see what information we gather, how we might use that information and in what circumstances we may disclose it. In some cases, we may provide additional notice (like adding a statement to our homepage or sending an email notification).

COMPLAINTS

If you are unhappy about any aspect of the way we collect, share or use your personal data, please let us know using the “Contact Details” above.

You also have the right to lodge a complaint with the Supervisory Authority in your jurisdiction.

Change Log

11 March 2021: Updated to remove language about tacit agreement to any changes to the policy.

25 May 2018: Updated for GDPR compliance and clarification.