1. Key Terms. It would be helpful to start by explaining some key terms used in this policy:
We, us, our
Oilfield Steel Supply, LLC dba OSS Metals and Oilfield Steel Supply Canada, Ltd.
Martin Marini, CEO and President firstname.lastname@example.org
Any information relating to an identified or identifiable individual
2. Personal Information We Collect About You. We may collect and use the following personal information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:
Categories of Personal Information
Specific Types of Personal Information Collected
Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers)
Name, address, and email address
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health
Name, address, email address, telephone number, any information included in a submitted resume or message on our Careers page
Professional or employment-related information
Any information included in a submitted resume or message on our Careers page
Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA)
Any information included in a submitted resume or message on our Careers page
This personal information is required to provide products and/or services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing products and/or services to you.
3. How Your Personal Information is Collected. We collect most of this personal information directly from you—in person, by telephone, text or email, and/or via our website. However,
we may also collect information:
• From publicly accessible sources (e.g., property records);
• Directly from a third party (e.g., sanctions screening providers, credit reporting agencies, or customer due diligence providers);
• From a third party with your consent (e.g., your bank);
• From cookies on our website; and
• Via our IT systems, including:
o Door entry systems and reception logs;
o Automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems; and
4. How and Why We Use Your Personal Information. We only use your personal information if we have a proper reason for doing so, including in the following cases:
• To comply with our legal and regulatory obligations;
• For the performance of our contract with you or to take steps at your request before entering into a contract;
• For our legitimate interests or those of a third party; or
• Where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your
information, so long as this is not overridden by your own rights and interests.
The table below explains what we use your personal information for and our reasons for
What we use your personal information for
To provide products, services or
information to you
For the performance of our contract with you or to take steps at your request before entering into a contract
To prevent and detect fraud against you or
For our legitimate interests or those of a third party, i.e., to minimize fraud that could be damaging for us and for you
Conducting checks to identify our customers and verify their identity Screening for financial and other sanctions or embargoes Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g. under health and safety regulation or rules issued by our professional regulator
To comply with our legal and regulatory obligations
Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies
To comply with our legal and regulatory obligations
Ensuring business policies are adhered to, e.g. policies covering security and internet use
For our legitimate interests or those of a third party, i.e., to make sure we are following our own internal procedures so we can deliver the best service to you
Operational reasons, such as improving efficiency, training and quality control
For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at
the best price
Ensuring the confidentiality of
commercially sensitive information
For our legitimate interests or those of a third party, i.e., to protect trade secrets and other commercially valuable information To comply with our legal and regulatory obligations
Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures
For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price
Preventing unauthorized access and modifications to systems
For our legitimate interests or those of a third party, i.e., to prevent and detect criminal activity that could be damaging for us and for you To comply with our legal and regulatory obligations
Updating and enhancing customer records
For the performance of our contract with you or to take steps at your request before entering into a contract To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g., making sure that we can keep in touch with our customers about existing orders and new products
To comply with our legal and regulatory obligations
Ensuring safe working practices, staff administration and assessments
To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
Marketing our products and services to:
– existing and former customers;
– third parties who have previously expressed an interest in our services;
– third parties with whom we have had no previous dealings
For our legitimate interests or those of a third party, i.e., to promote our business to existing and former customers
Credit reference checks via external credit reference agencies
For our legitimate interests or those of a third party, i.e., to ensure our customers are likely to be able to pay for our products and services
External audits and quality checks
For our legitimate interests or a those of a third party, i.e., to maintain our accreditations so we can demonstrate we operate at the highest standards To comply with our legal and regulatory obligations
The above table does not apply to special category personal information, which we will only
the process with your explicit consent.
5. Promotional Communications. We may use your personal information to send you updates (by email, text message, telephone or post) about our products and/or services, including exclusive offers, promotions or new products and/or services. We have a legitimate interest in using and processing your personal information for promotional purposes (see above “How and Why We Use Your Personal Information”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly. We will always treat your personal information with the utmost respect and never sell or share it with other organizations for marketing purposes. You have the right to opt out of receiving promotional communications at any time by contacting us at email@example.com. We may ask you to confirm or update your marketing preferences if you instruct us to provide further products and/or services in the future, or if there are changes in the law regulation, or the structure of our business.
6. Who We Share Your Personal Information With. We routinely share personal
• Our affiliates, including companies within the OSS Metals group;
• Service providers we use to help deliver our products and/or services to you, such as payment service providers, warehouses and delivery companies;
• Other third parties we use to help us run our business, such as marketing agencies or website hosts;
• Third parties approved by you, including social media sites you choose to link your account to or third-party payment providers;
• Credit reporting agencies;
• Our insurers and brokers;
• Our banks.
We only allow our service providers to handle your personal information if we are satisfied that they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors in relation to ISO accreditation and the audit of our accounts.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
7. Personal Information We Sold or Disclosed for a Business Purpose. We do not sell your personal information to third parties.
In the preceding 12 months, we have disclosed for a business purpose to one or more third parties the following categories of personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:
• Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers);
• Information that identifies, relates to, describes, or is capable of being associated
with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information;
• Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies);
• Professional or employment-related information; and
• Education information, defined as information that is not publicly available
personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA).
8. Where Your Personal Information is Held. Information may be held at our offices and those of our affiliates, third party agencies, service providers, representatives and agents as described above (see above: “Who We Share Your Personal Information with”). Some of these third parties are based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: “Transferring Your Personal Information Out of the EEA”.
9. How Long Your Personal Information Will Be Kept. We will keep your personal information while you have an account with us or while we are providing products and/or services to you. Thereafter, we will keep your personal information for as long as is necessary:
• To respond to any questions, complaints or claims made by you or on your behalf;
• To show that we treated you fairly; or
• To keep records required by law or acceptable business practice.
We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information. When it is no longer necessary to retain your personal information, we will delete or anonymize it.
10. Transferring Your Personal Information Out of the EEA. To deliver services to you, it is necessary for us to share and store your personal information outside the European Economic Area (EEA), e.g.:
• Our businesses and information systems are located in the United States and Canada;
• Our service providers are usually located outside the EEA;
These transfers are subject to special rules under European and UK data protection law. The following countries to which we may transfer personal information have been assessed by the European Commission as providing an adequate level of protection for personal information: Canada.
Except for the countries listed above, these non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure. Our practice is to use standard data protection contract clauses that have been approved by the European Commission.
If you would like further information, please contact us (see “How To Contact Us” below).
11. Your Rights Under the GDPR if you are in the EEA.
Right to Access
The right to be provided with a copy of your
personal information (the right of access)
Right to Rectification
The right to require us to correct any mistakes in your personal information
Right to be Forgotten
The right to require us to delete your personal information—in certain situations
Right to Restriction of Processing
The right to require us to restrict processing of your personal information—in certain circumstances, e.g., if you contest the accuracy of the data
Right to Data Portability
The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
Right to Object
The right to object:
• at any time to your personal
information being processed for direct marketing (including profiling);
• in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests
Right Not to be Subject to Automated
The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.
For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner’s Office (ICO) on individual rights under the General Data Protection Regulation.
12. Your Rights Under the CCPA. You may have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to exercise free of charge:
Disclosure of Personal Information We Collect About You
You have the right to know:
The categories of personal information we have collected about you;
The categories of sources from which the personal information is collected;
Our business or commercial purpose for collecting or selling personal information;
The categories of third parties with whom we share personal information, if any; and
The specific pieces of personal information we have collected about you
Please note that we are not required to:
• Retain any personal information about
you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;• Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or
• Provide the personal information to you more than twice in a 12-month period
Personal Information Sold or Used for a Business Purpose
In connection with any personal information we may sell or disclose to a third party for a business purpose, you have the right to know:
• The categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; and
• The categories of personal information that we disclosed about you for a business purpose.
• You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to opt-out of the sale or disclosure of your personal information. If you exercise your right to opt-out of the sale or disclosure of your personal information, we will refrain from selling your personal information, unless you subsequently provide express authorization for the sale of your personal information
Right to Deletion
Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:
Delete your personal information from our records; and
Direct any service providers to delete your personal information from their records Please note that we may not delete your personal information if it is necessary to:
• Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
• Debug to identify and repair errors that impair existing intended functionality;
• Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
• Comply with the California Electronic Communications Privacy Act;
• Engage in public or peer-reviewed scientific, historical, or statisticalresearch in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
• Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
• Comply with an existing legal obligation; or
• Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information
Protection Against Discrimination
You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things:
• Deny goods or services to you;
• Charge different prices or rates for goods or services, including through
the use of discounts or other benefits or imposing penalties;
• Provide a different level or quality of goods or services to you; or
• Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services
Please note that we may charge a different price or rate or provide a different level or quality of goods and/or services to you, if that difference is reasonably related to the value provided to our business by your personal information.
13. Keeping Your Personal Information Secure. We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable
regulator of a suspected data security breach where we are legally required to do so.
• Email us at firstname.lastname@example.org.
Please note that you may only make a CCPA-related data access or data portability disclosure request twice within a 12-month period.
If you choose to contact directly by email, you will need to provide us with:
• Enough information to identify you (e.g., your full name, address and customer number);
• Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and
• A description of what right you want to exercise and the information to which your request relates.
We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.
Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.
15. How to File a GDPR Complaint. We hope that we can resolve any query or concern you raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.
16. Changes to This Privacy Notice. This privacy notice is dated November 1, 2022. We may change this privacy notice from time to time–when we do, we will inform you via our website or other means of contact such as email.
18. Do You Need Extra Help? If you would like this notice in another format (for example: audio, large print, braille) please contact us (see “How to contact us” below).