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 which is collected and/or provided through all of our Olin Websites, namely www.olin.com, www.olinchloralkali.com, www.olinepoxy.com, www.olinchlorinatedorganics.com (the “Websites”) and explains the basis on which any personal data we collect from you through your use of the Websites (“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 Rights
Changes to this Policy

Responsible Data Controller. This Websites is 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 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 European Union, 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 personal 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 Website 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 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 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 pageWe 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