Privacy

PRIVACY POLICY

Introduction

Welcome to the Armstrong Privacy Policy.At Armstrong we understand the sensitivity with which your personal information should be handled. We are committed to safeguarding your privacy in order to earn and maintain your trust. This Privacy Policy will inform you as to how we look after your personal data when you visit our website, telephone, or write to us (including e-mail) or where you otherwise have dealings with us.

Armstrong may amend this Privacy Policy from time to time without notice. Please visit www.armstrongfluidtechnology.com ("Site") for the most recent version.

Children

The Site is not intended for access by children, including children under 13 years of age, and we do not knowingly collect data relating to children from any source. If you are a child, do not use or provide any information on this Site or on or through any of its features. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us using the details set out below.

1. IMPORTANT INFORMATION AND WHO WE ARE
   
   Purpose of this Privacy Policy

   This Privacy Policy tells you about your privacy rights and how the law protects you. Where you are a party dealing with us, it also sets out your obligations in dealing with personal data which we may provide to you or which you may obtain in the course of our dealings with you.

   It is important that you read this Privacy Policy together with any other privacy notice or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you, or providing personal data about us, so that you are fully aware of how and why we are using your data and the basis on which you may use our data.

   This Privacy Policy supplements other notices and privacy policies and is not intended to override them.

   Controller
   Armstrong is made up of different legal entities (collectively, the “Armstrong Group”) of which S. A. Armstrong Limited, registered in Ontario, Canada, is the parent company. This Privacy Policy is issued on behalf of the Armstrong Group so when we mention “Armstrong”, "we", "us" or "our" in this Privacy Policy, we are referring to the relevant company in the Armstrong Group responsible for processing your data. This will usually be the Armstrong company with which you have dealings.

   If you are unsure as to which Armstrong company is the controller of your personal data, or you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us using the details set out below.

   Contact details
   Our full details are:

   S.A. Armstrong Limited
   Privacy Manager: Chief Financial Officer
   Email address: gdpr@armstrongfluidtechnology.com
   Postal address: 23 Bertrand Avenue, Toronto, Ontario  M1L 2P3
   Telephone: 416-755-2291
   

   Depending upon the state or country in which you are situate, you may have the right to make a complaint to the statutory body or supervisory authority for data protection issues set up within your state or country to deal with personal data issues.

   In Canada, you may contact the Privacy Commissioner of Canada: https://www.priv.gc.ca/en

   In the United Kingdom, you may contact the Information Commissioner’s Office: www.ico.org.uk

   We would, however, appreciate the chance to deal with your concerns before you approach any particular regulatory body so please contact us in the first instance.

   Your duty to inform us of changes
   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
   The Site 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 Site, we encourage you to read the privacy policy of every website you visit.



2. THE DATA WE COLLECT ABOUT YOU

   Personal data, or personal information, means any information about an individual from which that person can be identified. It does not apply to any company, corporation or other legal entity and nor does it include data where the identity has been removed and cannot be identified (anonymised data).

   As supplier to or customer of your business, we have access to certain personal information of individuals within your business which may be necessary for our business relationship. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together. Your relationship and dealings with us will dictate the amount and type of information we collect and hold about you and so not all of the below list will necessarily apply to you, for example if we deal with you as a contact within the accounts team of one of our suppliers or customers, we will hold your name, role, business email address and business contact telephone number only:

   • Identity Data includes first name, last name, username or similar identifier, your role in the company in which you work and your title.
   • Contact Data includes business address, home address, email address and telephone numbers.
   • Financial Data includes in relation to our suppliers and customers, bank account and payment card details together with background financial information available through public registers which may include personal data.
   • Transaction Data includes details about payments to and from you.
   • Technical Data includes internet protocol (IP) address, 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 our Site.
   • Profile Data includes if you are purchasing from us, your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
   • Usage Data if you are visiting our Site includes information about how you use our Site.
   • Marketing and Communications Data includes your preferences in receiving marketing from us and our selected third parties and your communication preferences.

   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. 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 Policy.

   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, information about your health and genetic and biometric data). 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). In this case, we may have to refuse to provide a product or service to you.



3. HOW IS YOUR PERSONAL DATA COLLECTED?

   We use different methods to collect data from and about you including through:

   • Direct interactions. You may give us your Identity, Contact and Financial Data by providing a business card, filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
     • Apply for our products or services;
     • Offer to supply to us;
     • Have contact with us through a company which has dealings with us;
     • Create an account on our website;
     • Subscribe to our service or publications;
     • Request marketing to be sent to you;
     • Enter a competition, promotion or survey; or
     • Give us some feedback.
   • Automated technologies or interactions. As you interact with our Site and systems, 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.
   • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources including those set out below:
     • Financial searches;
     • Technical Data from the following parties:
       1. Analytics providers such as Google;and
       2. search engine information providers;
     • Identity and Contact Data from publicly availably sources such as a registrar of companies.

   Any of the above sources may be outside of the state or jurisdiction in which you reside.



4. WHEN 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 the business you represent).
   • 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.

   Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or other medium.

   Promotional offers from us
   You will receive marketing communications from us if you have requested such communications from us and you have not opted out of receiving those marketing communications.

   Third-party marketing
   We will obtain your express consent before we share your personal data with any company outside Armstrong for marketing purposes.

   Opting out
   You can ask us to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time.

   Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

   Cookies
   You can set your browser 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 our Site may become inaccessible or not function properly.

   Change of purpose
   We will only use your personal data for the purposes for which we collected it If we wish to use your personal data for a new purpose, we shall seek your consent.

   If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

   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. OUR USE OF YOUR PERSONAL DATA

   In agreeing to allow us process your personal data (and that of your employees and officers referred to above), we confirm in each instance that:

   • We limit access to that data to those who have a genuine business need to access it;
   • We have appropriate security measures to prevent personal information from being accidentally lost, or used or accessed unlawfully;
   • We will only process that data for the purpose, and for the period strictly required in our transactions with you and that we will review and cleanse such data from time to time as appropriate;
   • Through our employment contracts and policies we require our personnel to comply with this Privacy Policy when accessing, using, processing or sharing your personnel data.; and
   • If applicable, we have enforceable provisions within our contracts and terms of business in place with our suppliers, which may have access to such personal data through the services which they provide.

   These points are dealt with in more detail elsewhere within the Privacy Policy.

   International transfers
   We share your personal data within the Armstrong Group. This will involve transferring your data outside the state in which you may be situate. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data. Where we are based in the European Union and we use providers based in the United States of America, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.



6. YOUR USE OF OUR PERSONAL DATA

   Where we are your customer or your supplier, you have access to certain personal information of individuals within our business which may be necessary for our business relationship. This information will include (but is not limited to) names and personal data of individual persons such as the persons listed in 2 above.

   In providing and agreeing to allow you to process personal data, whether within your business or to other persons whose details we provide, you confirm in each instance that you will comply with the provisions of all applicable data protection laws and that as a bare minimum, you have policies in place which reflect those to those referred to in the Privacy Policy which we ourselves apply.

   Where a party contracts with us, this provision places a contractual obligation on that other party which could have legal and financial consequences should they not comply.



7. HOW LONG WE USE YOUR PERSONAL DATA FOR?

   We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period where we believe there is an ongoing need to do so, but only in accordance with applicable law.

   To determine the appropriate retention period for personal data, in addition to the points above, 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.

   In some circumstances we will 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.



8. DATA SECURITY

   We have put in place appropriate security measures designed 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.
   For the purposes of above, “third parties” include professional advisers (including lawyers, bankers, auditors, insurers and IT providers) who provide services to us together with regulators and other statutory authorities which require reporting of processing activities in certain circumstances.



9. YOUR RIGHTS

   Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights are to:

   • 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 that you feel impacts on your fundamental rights and freedoms, you may object to our processing on this basis. You also have the right to object where we are processing your personal data for marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information that 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 This may be 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.

   In this section, "Legitimate Interest" means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

   If you wish to exercise any of the rights set out above, please contact us.

   No fee usually required
   You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

   What we may need from you
   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.

   Time limit to respond
   We will respond to all legitimate requests within the time period required by applicable law, which is usually one month from the date we receive your request. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

   Your California Privacy Rights
   California Civil Code Section § 1798.83 permits users of our Site that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us as detailed above.