1. Our approach
This Privacy Notice (the “Notice”) sets out how we, the Ingevity Corporation group of companies, headquartered at North Charleston, South Carolina 29405 USA, (further referred to as “Ingevity”, “we”, “our”, “us”), process information of our website visitors, customers and other individuals whose information we collect (each a “User”, “you”, “your”). The information we collect includes personally identifiable information as defined under US law ("PII") and personal data as defined under EU data protection laws, including but not limited to the general data protection regulation and the UK data protection act 2018 ("Personal Data"). In this Notice, PII and Personal Data are together referred to as: Personal Information.
When collecting information about our customers or visitors of our website, we are, under EU data protection laws, qualified as "data controller". This means that we are responsible for deciding how we hold and use personal data about you.
For further details of the members of the Ingevity Corporation that are acting as data controllers, please see Ingevity Group Details:
To contact Ingevity’s Privacy Office in relation to any enquiries about this notice, please use:
Email: [email protected]
Post: Ingevity - Information Privacy Office
c/o Law Department
4920 O'Hear Avenue, Suite 400, North Charleston, S.C. 29405, USA
We may change this Notice from time to time. We will let you know about any changes we make to this Notice, including by posting them on our website. Your continued use of our website after any such changes have been made will amount to your acknowledgement of the amended Notice.
This version of our Notice was uploaded on April 15, 2019. Any previous versions of this Notice can be obtained by contacting Ingevity’s Privacy Office.
2. What is Personal Information?
Personal Information means any information relating to an identified or identifiable natural person, known as ‘Data Subject’, who can be identified directly or indirectly; it may include name, address, email address, phone number, IP address, location data.
We collect Personal Information from you when you provide it to us or through your use of our website or services. This will include:
a. information you, or your employer, chooses to give us when registering on our website, filling in forms on our website or when corresponding with us by phone, e-mail or otherwise;
c. any other information collected or obtained about you.
You are under no obligation to provide this information, but without it, we may not be able to provide you with some of the content or services or the information you request
3. Purposes for which we process Personal Information
We will only process your Personal Information, in accordance with the applicable data protection laws in which our Group Companies operate, under the following legal grounds:
3.1 Where you have consented to our processing of your personal data for the following purposes:
a. creating and maintaining your User account on our website or platforms.
b. responding to your queries and requests;
c. receiving and considering any job application that you may make to us (for further information on how we process personal data provided to us as part of the job application process, please see our Applicant Fair Processing Notice;
d. sending you personalized marketing communications and alerts;
3.2 Where the processing is necessary for the pursuit of our legitimate interests:
a. enabling our suppliers and service providers to carry out certain functions on our behalf, including the hosting of our platforms, verification, technical, logistical or other functions, as may be required, in order to make available our website and services;
b. ensuring the security of your User account and our business, preventing or detecting fraud or abuses of our website, for example, by requesting verification information in order to reset your account password;
c. to allow us to establish, exercise and/or defend our legal rights, including to evidence our compliance with the law, investigating claims made against us or to allow us to commence legal proceedings where required.
d. sending you personalized marketing communications and alerts requested by you in a business to business context;
e. serving personalized advertising to your devices; delivering ads based on your interests ascertained from your past searches, visits of subpages and purchases on our websites, and other data obtained through the use of "cookies" placed on your devices. For further information, please see our Cookie Notice;
f. ensuring the security of your User account and our business, preventing or detecting fraud or abuses of our website, for example, by requesting verification information in order to reset your account password;
g. developing and improving our products and services, for example, by reviewing visits to our website and its various subpages, demand for services and User comments or other contributions;
h. to make voluntary disclosures to third parties, where permitted by Law, such as to report an alleged criminal incident, or where we are subject to a request to disclose information as part of a litigation case, and we consider that the disclosure is necessary for the purposes of bringing or defending a litigation claim.
3.3 Where necessary for the performance of a contract that you are a party to, or to take steps at your request prior to entering into a contract:
a. To process payments, to receive and respond to purchase orders or delivery notes, processor orders, arrange delivery or acknowledge receipt of deliveries and liaise with and respond to our suppliers’ and customers’ designated contract managers.
3.4 To allow us to comply with our legal obligation:
a. to comply with applicable law, for example, in response to a request from a court or regulatory body, where such request is made in accordance with the law, or where we are required by law to process personal data
4. Disclosure of customer information
There are circumstances where we may disclose or be compelled to disclose your Personal Information to third parties. This will only take place in accordance with the applicable Data Protection laws and for the purposes listed above. These scenarios include disclosure, where necessary:
a. to our subsidiaries, branches or associated offices;
b. to our suppliers and service providers to facilitate the provision of our website, services or goods to our Users, for example, the disclosure to our data centre provider for the safekeeping of your Personal Information, web hosting provider through which your Personal Information may be collected, identity verification partners in order to verify your identity against public databases;
c. to our advertising partners who enable us to deliver personalized ads to your devices or similar advertising, but only where you have explicitly consented to allow their cookies to be installed on your devices;
d. subject to your consent, to our marketing partners, who may contact you by post, email, telephone, SMS or by other means. If you do not wish to be contacted by our marketing partners, please unsubscribe, through the link provided at the bottom of the relevant email, but if you need additional assistance please contact Ingevity’s Privacy Office;
e. to another legal entity, on a temporary or permanent basis, where it is necessary for the purposes of an actual or proposed joint venture, collaboration, financing, sale, merger, reorganization, change of legal form, dissolution or similar event. In the case of a merger or sale, your Personal Information will be permanently transferred to a successor company;
f. to public authorities where we are required by law to do so;
g. to any other third party where you have provided your prior explicit consent; or
h. to any other recipient, where permitted under the applicable Data Protection Laws, including where we may a voluntary disclosure of information to Law Enforcement bodies or where the disclosure is necessary for the purposes of exercising, establishing or defending legal rights.
5. International Transfer of Personal Information
We may transfer your Personally Information to recipients located in countries outside the country in which it was originally collected for further processing in accordance with the purposes set out in paragraph 3 above. In particular, your Personally Information may be transferred to other members of the Ingevity Group and to our outsourced service providers located abroad. In these circumstances, we will, as required by applicable law, ensure that your privacy rights are adequately protected by implementing appropriate technical, organization, contractual measures to keep your personal data secure. In addition, we will implement, where required by law, appropriate or suitable safeguards to facilitate the lawful international transfer of Personal Information. If you are located in the UK and/or the EEA, you are entitled to request details of the safeguards which we put in place. To do so, please contact Ingevity’s Privacy Office.
6. Retention of Personal Information
Your Personally Information will be retained for as long is reasonably necessary for the purposes listed in paragraph 3 above or as required by applicable laws. Please contact the Ingevity’s Privacy Office for further details of applicable retention periods.
We may keep an anonymized form of your Personally Information, which will no longer refer to you, for statistical purposes without time limits, to the extent that we have a legitimate and lawful interest in doing so.
7. Your rights
In certain countries data protection law provides individuals with additional rights over their Personal Information, including the right to request access, rectify, erase, the right to request restriction of or to object to the processing your Personal Information. You also have the right to withdraw your consent you previously provided to us to allow us to process and transfer of your Personal Information to another party (right to data portability).
To exercise your rights as Data Subject, make queries or complaints, please contact Ingevity’s Privacy Office.
If you are located in the UK and/or the EEA and are dissatisfied with any aspect of our handling of your Personal Information, you have the right to make a complaint at any time to the relevant data protection authority.
8. Security of your information
We will use procedures and security measures to try to prevent unauthorized access to your information, and we will take reasonable steps to ensure that your information is treated securely and in accordance with this Notice.
Where you have chosen a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Please be aware that the transmission of information via the internet is never completely secure. While we can do our best to keep our own systems secure, we cannot control the whole of the internet and we cannot therefore guarantee the security of your information as it is transmitted to and from our website.
Please note that this website is not intended for children under the age of 13.
10. Linked websites
Please note that any websites that may be linked to our websites are subject to their own legal and privacy notices.
11. Modifications of the Privacy Notice
We reserve the rights to modify this Privacy Notice at any time and will notify you by posting an amendment to the privacy notice on the Site. Such modifications will become effective on the day they are posted. We encourage you to frequently review this Notice for any modifications.
Effective: April 15, 2019