Privacy Policy–Olin Chlorinated Organics

Olin Websites Privacy Policy

If you are having trouble viewing or accessing this Statement or need it made available to you in an alternative format, please contact: dpo@olin.com or +1.314.355.8285.

Olin Corporation, 190 Carondelet Plaza, Suite 1530, Clayton, MO 63105, United States of America (“Olin”), (also referred to as “we” and “us”) is committed to respecting and protecting your privacy. This Websites Privacy Policy (“Policy”) applies to any personal data that we collect from and about you through the use of all of our Olin Websites, namely www.olin.com, www.olinchloralkali.com, www.olinepoxy.com, www.olinchlorinatedorganics.com, www.olinpolycarb.com (the “Websites”). This Policy explains the basis on which any personal data we collect from and about you (“Data”) will be processed, the control you have over your Data and the procedures we have in place to protect it. Please see the following links for more
information:

Responsible Data Controller
Categories of Data Processed
Purpose of Processing
Legal Basis for Processing
Recipients
Retention
Security
Third Party Links
Your EEA Rights
Changes to this Policy
Your California Privacy Rights

Responsible Data Controller. These Websites are operated by Olin. Olin is responsible for the processing of your Data. We have appointed a global Data Protection Officer whose contact details you will find at the end of this Policy. Olin has designated Blue Cube Germany Assets GmbH & Co. KG, Werk Stade, Bützflether Sand 2, D-21683 Stade, Germany, as their European Union (EU) representative with regard to their respective obligations under the General Data Protection Regulation (Regulation 2016/679) (“GDPR”) with effect from May 25, 2018.

Categories of Data Processed. Olin processes the following categories of Data when you use our Websites:

Log data, such as your IP address, including details concerning the access to our Websites, such as date and time, status and data volume transferred, products you viewed or searched for, information on your browser (type of browser and version number) and other technical device information, and details of the websites that you used to access our Websites. Olin saves this data in a log file every time a page is viewed. Olin is unable to assign this data to individual, identifiable persons without additional information, such as information from an Internet provider on the subscriber, which Olin regularly does not have access to without a concrete reason, such as, e.g., in the case of suspicions of a legal infringement.

Cookies in order to broaden the Websites’ range of functions and make it more convenient to use. These are small text files, which are stored on your computer. Most of the cookies that are used by Olin are deleted from your hard drive at the end of your browser session (session cookies). In addition, Olin uses so-called permanent cookies, which remain on your device in order to recognize you the next time you visit the Websites. You can prevent cookies from being stored on your device by changing the settings accordingly in your browser. At this time, however, we do not honor “do not track” signals from website browsers.

Contact form data. If you are contacting Olin through a contact form Olin processes the Data as shown in the contact menu provided on our Websites – in particular email address and your request, as well as first name, last name, salutation and telephone number, or any other data that you choose to submit to Olin.

Investor’s newsletter. If you register for our investor newsletter, we will collect your email address, IP address, and time of registration for the newsletter. We will use your email address to send you the newsletter. If you are subscribing from a country in the EU, we will use a double opt-in method: After you have submitted your email address, we will send you an activation link to your email address to confirm your subscription. When you click on the link, we collect log data as described above. You may revoke your consent to receive our newsletter at any time with future effect by clicking on the link provided in each newsletter email or sending a message to dpo@olin.com.

Purpose of Processing. Olin collects your Data in order to enable you to use the Websites, provide the services you have requested (such as sending email newsletters), and answer your contact requests. You have the option to refrain from affirmatively providing certain Data (such as contact form Data) or you may provide Olin with incomplete information. However, you may not be able to use the Websites in such case at all or to the fullest extent that the Websites provide for. Olin will not use your Data for automated decision-making. We do not create any personalized profiles using your Data.

Google Analytics. Our Website uses Google Analytics, a web analyzing service provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google“). Google Analytics uses cookies. Information generated concerning your usage of the Website (including your IP address) are transmitted to a Google server in the USA and are saved there. You may read about how Google uses your Data here: https://www.google.com/intl/de/policies/privacy/partners/.You can prevent Google Analytics cookies from being stored on your device through your browser software settings. You may object to the processing of your Data at any time with effect for the future.

Legal Basis for Processing. Olin is entitled to process your Data as set out above because you are visiting our Websites. If you subscribe to any service for which Olin is asking you to provide consent, the legal basis of processing your Data will be your consent; you will be provided additional information on the processing in such case. You make revoke your consent at any time with effect for the future by sending an email to the contact information.

If you have subscribed to a newsletter or a service, Olin may send you additional information about similar services or products. You may object to the sending of this additional information at any time with effect for the future. Please send an email in this regard to the contact information at the end of this Policy, or contact us directly using the contact methods provided in any such communication.

Recipients. Olin will grant access to your Data to those employees who are responsible for technical administration, maintenance and the further development of the Websites and the provision of the services you may have subscribed for. In addition, Olin engages external IT service companies to maintain its IT systems, and other service providers who assist Olin to operate the website, to help with Olin’s business functions, or to provide the services you have requested. These third-party service providers may be able to access your Data when performing their services. Olin will contractually obligate these recipients to confidentiality to safeguard your Data from disclosure and utilize an adequate level of data protection. For example, if legally required, Olin will require such third parties to sign the EU or Swiss Model Clauses. To the extent permitted by applicable local law, we share your Data with government authorities or courts in order to comply with any legal obligation, or to protect the rights, property or safety of Olin, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction. Finally, to the extent permitted by applicable local law, Olin may transfer your Data to a third party as part of a merger, acquisition, bankruptcy, transfer, sale, corporate change, or any other transaction involving all or a portion of Olin’s assets.

Retention. Your Log Data that is generated through the usage of our Websites will be deleted within seven days. Data that is collected in connection with contacting us will be deleted one year after your request is answered. In case your data is uploaded into our customer database or stored elsewhere due to a contractual or pre-contractual relationship, it will be stored in accordance with the retention periods of such system. Permanent cookies will be deleted after 6 months. We will follow these retention periods unless otherwise required by law.

Security. We maintain reasonable administrative, technical and physical safeguards to protect your Data against loss, misuse, unauthorized access, disclosure, alteration or destruction.

Third Party Links. Our Websites may, from time to time, contain links to and from the websites of our partner networks, third party organizations and affiliates (including our “careers” website, which is hosted by a third party). If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Your EEA Rights. In the case that the GDPR applies to you because you are located in the EU and you are using the Websites in relation to the offering of goods or services, you have the following rights. These rights can be exercised by contacting us by using the contact information at the end of this Policy:

Obtain information on your Data in order to check and verify such Data,
Receive a copy of your Data,
Correction, deletion or restriction of the processing, which also includes the right to have incomplete or incorrect Data rectified by supplementary information,
Right to object to the processing,
You may receive your provided Data in a structured, common and machine-readable format and transfer this Data to another controller as long as you have consented to the processing or the processing is based on a contract.

In addition, you have the right to file a complaint with the regulatory authorities in connection with the processing of your Data.

Changes to the Policy. Any changes we make to the Policy in the future will be posted on this page. We encourage you to visit this area frequently to stay informed, as your continued use of our Website following the posting of changes to this Policy means that you consent to such changes. If you have signed up to a service that is provided through the Websites, you will be notified by email of any changes to the Policy.

Contact: Olin Data Protection Officer, Megan Rosenberg, dpo@olin.com or +1.314.355.8285

Last Updated: December 16, 2019

Your California Privacy Rights. We primarily provide our services to business customers and generally only collect Data of the employees of those business customers. In limited circumstances when an individual consumer who is a California resident interacts with us directly, such as through our Website, this section applies. If you are a California resident, this section applies. Pursuant to the California Consumer Privacy Act of 2018, below is a summary of the Data we collect from and about consumers, the online and offline sources from which we collect the Data, the business or commercial purpose for which the Data is collected and the categories of third parties with whom we share consumer Data.

The terms in the chart below have the following meanings:

Auditing. Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting and impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
Security. Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
Debugging. Debugging to identify and repair errors that impair existing intended functionality.
Performing Services. Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.
Internal Research. Undertaking internal research for technological development and demonstration.
Quality Assurance. Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.
Legal. As necessary to comply with legal and regulatory requirements, such as to ensure the safety of our property, employees, and users, and to protect our rights including investigating and responding to claims against us, our customers, or employees.
Marketing. For market research and for commercial sales and other marketing activities including but not limited to sending you information about our products and services, promotions, or events.

Personal Data	Sources of Personal Data	Business or Commercial Purpose for Collection	With Whom We Share Personal Data
Identifiers such as real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers	You, Your Authorized Representative, Affiliates, Third Parties, or Service Providers	Auditing, Performing Services, Internal Research, Quality Assurance, Legal, and Marketing.	With other Olin Corporation entities; to service providers that assist us with providing our products and services, including IT, storage, business operations, and marketing service providers; in the event of a merger, transfer of business assets, or bankruptcy may share your Data with buyers, lawyers, or professional advisors; and to third parties when required to do so by law or otherwise to protect our legal rights, property, and safety
Characteristics of protected classifications under California or Federal Law, such as age and gender	You, Your Authorized Representative, Affiliates, Third Parties, or Service Providers	Performing Services, Legal	With other Olin Corporation entities; to service providers that assist us with providing our products and services, including IT, storage, business operations, and marketing service providers; in the event of a merger, transfer of business assets, or bankruptcy may share your Data with buyers, lawyers, or professional advisors; and to third parties when required to do so by law or otherwise to protect our legal rights, property, and safety
Commercial information, including records of personal property, product or services purchased, obtained or considered, or other purchasing or consumer history	You or Service Providers	Performing Services, Internal Research, Legal, and Marketing.	With other Olin Corporation entities; to service providers that assist us with providing our products and services, including IT, storage, business operations, and marketing service providers; in the event of a merger, transfer of business assets, or bankruptcy may share your Data with buyers, lawyers, or professional advisors; and to third parties when required to do so by law or otherwise to protect our legal rights, property, and safety
Internet or other electronic network activity information, including, but not limited to, browsing history, search history and information regarding a consumer’s interaction with an internet website, application or advertisement	You or Service Providers	Auditing, Security, Performing Services, Internal Research, Legal, and Marketing.	With other Olin Corporation entities; to service providers that assist us with providing our products and services, including IT, storage, business operations, and marketing service providers; in the event of a merger, transfer of business assets, or bankruptcy may share your Data with buyers, lawyers, or professional advisors; and to third parties when required to do so by law or otherwise to protect our legal rights, property, and safety
Geolocation data	You or Service Providers	Performing Services	With other Olin Corporation entities; and to service providers that assist us with providing our products and services, including IT, storage, business operations, and marketing service providers
Audio, electronic, visual, or similar information	You, Your Authorized Representative, or Service Providers	Performing Services, Internal Research, Legal, and Marketing.	With other Olin Corporation entities; and to service providers that assist us with providing our products and services, including IT, storage, business operations, and marketing service providers
Professional or employment-related information	You	Auditing, Performing Services, Legal, and Marketing.	With other Olin Corporation entities; and to service providers that assist us with providing our products and services, including IT, storage, business operations, and marketing service providers
Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes	You or Service Providers	Auditing, Security, Performing Services, Internal Research, and Marketing.	With other Olin Corporation entities; and to service providers that assist us with providing our products and services, including IT, storage, business operations, and marketing service providers

We disclosed all of the categories of Data listed above for a business purpose in the past 12
months.

Your Rights
As a California resident, you have certain rights, subject to legal limitations and applicable exceptions, regarding the collection, use, and sharing of your Data. California residents may exercise the following rights via our website at https://www.olin.com/privacy/ccpa/, by emailing us at dpo@olin.com, or by calling 1-800-356-2666.

Right to Know. You have the right to request information about the categories of Data we have collected about you, the categories of sources from which we collected the Data, the purposes for collecting the Data, the categories of third parties with whom we have shared your Data, and the purpose for which we shared your Data (“Categories Report”). You may also request information about the specific pieces of Data we have collected about you (“Specific Pieces Report”).
Right to Delete. You have the right to request that we delete Data that we have collected from you.
Right to Opt Out. We do not sell Data to third parties.

In accordance with applicable law, we will not discriminate against you for exercising these rights.

Verification: In order to exercise your rights, we will need to obtain information to locate you in our records or verify your identity depending on the nature of the request. If you are submitting a request on behalf of a household, we will need to verify each member of the household in the manner set forth in this section. For Specific Pieces Report, we will request your name, email address, phone number or physical address to verify your identity, along with a signed declaration, under penalty of perjury, that you are who you say you are. For a Categories Report, we will request your name, email address, phone number or physical address to verify your identity. For a Right to Delete request, we will request your name, email address, phone number or physical address to verify your identity.

Authorized Agents: You may use an authorized agent to exercise your rights on your behalf. If you are making any of the requests above through an authorized agent, we will request written authorization from you and will seek to verify as described above or we will accept a legal Power of Attorney under the California Probate Code to the authorized agent. To make a request using an authorized agent use the webform at https://www.olin.com/privacy/ccpa/ and upload documentation demonstrating you have authorized the agent to exercise rights on your behalf.

Timing: We will respond to Requests to Delete and Requests to Know within 45 days, unless we need more time in which case we will notify you and may take up to 90 days total to respond to your request.