Privacy
Policy

 

 

 

Privacy Notice

Last updated: December, 2021

The Innovative Chemical Products Group (ICP Group, we, us, our) respects privacy and is committed to protecting personal information. This Privacy Notice informs our customers, business partners, suppliers, service providers and other third parties that we interact with in the course of providing our products and services, as well as our visitors to our website (icpgroup.com, referred to as the Site) whose information we collect as a result of navigating or interacting the Site (collectively you, your), about how we collect, use, and share personal information.

Important information about this Notice

While we always aim to provide complete and transparent information about how we process your personal information, we reserve the right to update this Notice from time to time or to create additional policies in order to accurately reflect changed circumstances or new legal requirements. As a result, it is important that you read this Privacy Notice together with any other privacy notice we may provide, so that you are fully aware of how and why we are using your personal information. Please note that this Privacy Notice supplements the other notices and is not intended to override them.

To assist us in ensuring that we can provide the most accurate information possible, we ask that you check this Notice for updates. We also ask that where we have an ongoing relationship with you and any of the data you have provided become are no longer accurate you keep us informed of this so that we can amend our records accordingly. By providing us with personal information or using our Site, you expressly consent to the information handling practices described in this Notice. If you do not agree with this Notice, please do not use our Site or provide us with your information.

Who are we?

ICP Group is an international group of companies that operates in multiple jurisdictions around the world, offering a range of specialty coatings, adhesives, and sealants. This Notice is provided for and on behalf of the companies listed here https://www.icpgroup.com/4496-2/.

Information We Receive

A. Personal Information

For the purposes of this Notice, “personal information” is any information that identifies or can be used to contact a particular individual. As business-to-business companies, the personal information we typically collect personal information is limited to the information that can be found on a business card—name, organization name, position, address, email address, and telephone number. More specifically, the personal information we collect includes the following categories.

  •   Contact information – first name, last name, email address, position, physical address of your organization, billing address, and telephone number.

  •   Marketing information – details regarding informational and promotional materials you may have requested or received from us, the products in which you are interested, your receipt of promotional communications, and information on your marketing or communication preferences.

  •   Customer Account and web portal information – customer account or web portal username and log-in password, customer files and transaction histories, and other information that we may request or that you may provide relating to your account.

  •   Transactional information – details about your organization’s purchases, including method of payment, payments received, payment details, and other information relating to your use of our products.

  •   Communications information – copies of communications and inquiries you have submitted to us, including through email, calls, and features available on our Site.

  •   Device and usage information – details regarding how and when you use our Site and Services, including the device used to connect to our Site or software, your IP address, the frequency and duration of your usage, the pages you view, what websites or search terms referred you to the Site, and information about your interaction with our Site.

    Please note that we may aggregate or anonymize the foregoing types of data such that they are no longer capable of identifying you, in which case they are no longer considered “personal information.” We may also collect information about you from third party sources and information about you that is publicly available.

B. Automatically Collected Usage and Device Information

Like most websites, our Site uses various technologies to automatically collect information about visitors. Those technologies include:

  •   Cookies. Cookies are small text files that a website transfers to a visitor’s device for recordkeeping purposes. We use cookies to personalize visitors’ experiences on our Site, provide content that we believe may be of interest, track visitor trends and patterns, engage in marketing and advertising, and otherwise analyze our Site traffic. For further information about cookies, including how to refuse cookies, please visit www.allaboutcookies.org. Please note that if cookies are disabled, you may not be able to enjoy certain features of our Site.

  •   Log Files and Device Identifiers. We use log files to track actions occurring on the Site and collect data about visitors, including IP address, browser type, Internet service provider, referring/exit pages, date/time stamps, and device identifiers.

  •   Web beacons and other technologies. Our App may use other tracking tools, including web beacons (also known as clear gifs, pixel tags, and single-pixel gifs), which are small electronic images embedded in content and email messages that are not ordinarily visible to users. Web beacons allow us to track pages and content accessed and viewed by users, as well as to monitor email readership.

  •   Analytics. Our Site may also use third-party analytics tools such as Google Analytics. You can find more information about how data is collected and processed in connection with the Google Analytics service here. You can also read Google’s privacy policy here.

The information collected through these technologies may be combined with personal information or aggregated with other information on Site visits. We may share information about your use of our Site with our advertising and analytics partners, who may combine it with other information that you previously provided to them.

C. Information from Other Sources

We may obtain both personal and non-personal information about you from business partners, contractors, suppliers, and other third parties and add it to your account information or other information we have collected. We, and the third parties we engage, may combine information we collect from you over time, and across the Site, with information obtained from other sources. This helps us improve the information’s overall accuracy and completeness, and also helps us better tailor our interactions with you.

D. Social Media

If you interact with us on any social media platform: (a) depending on your social media privacy settings, the personal information that you submit on the social media platform may be read, collected, or used by us as described in this Notice, and (b) where we respond to any interaction with you on social media, your account name/handle may be viewable members or users of our social media accounts. Social media platforms operate independently from the ICP Group and we are not responsible for the personal information that you choose to submit or link on any Social Media. We encourage you to review the privacy policies and settings of any social media platform with which you interact to help you understand their privacy practices.

How We Use Personal Information

We (or service providers acting on our behalf) may use the personal information identified above for the following purposes:

  •   Negotiating, entering into, and managing our business relationship and agreements with your company.

  •   Providing and optimizing your experience on our Site and ensuring that our content is presented to you in the most

    effective manner.

  •   Fulfilling your company’s purchases, processing payments, and managing the purchase and delivery process.

  •   Communicating with you and responding to your inquiries and communicating regarding our products, your

    company’s purchases, and other issues.

  •   Sending you promotional or informational communications and solicitations, tracking your marketing preferences, and

    for our internal marketing purposes.

  •   Managing customer service issues, including issues relating to the quality of products, returns, refunds, and customer

    feedback.

  •   Developing, updating, and improving our products, customer service, and marketing efforts, and otherwise improving

    our knowledge and insights regarding customers.

  •   Preventing and detecting fraud, financial crime, hacking activities, security breaches, and other unlawful activities in

    connection with the Site or the purchase of our products.

  •   Enforcing our agreements with customers, complying with our legal or regulatory obligations, and defending or advancing legal claims.

  •   Notifying you about changes to our Site, products, or material changes to this Policy.

  •   Providing you with surveys or otherwise soliciting feedback from you.

  •   Performing other functions as otherwise described to you at the time of collection or to which you otherwise consent.

    For more information about your options relating to your personal information and your communication

preferences, see “Choices About the Collection and Use of Personal Information” below.

Our Marketing Efforts

We may send you direct marketing communications from time to time including news, updates, offers, and other promotions relating to our products, services, and activities. We will only send marketing messages where the law allows us to do so and, in the event that you no longer wish to receive marketing from us, then you can always unsubscribe using the option provided in the footer of the communication you have received or by contacting us using the information provided below.

Disclosure of Personal Information

When the information we collect about you is aggregated, anonymized, or otherwise does not identify you, we may use that information for any purpose or share it with third parties, to the extent permitted by applicable law.

In addition, we may share your personal information with the following types of trusted third parties:

 Service providers we use to facilitate our business operations and administration. These third parties have access to your personal information only to perform specific tasks on our behalf and are obliged not to disclose or use it for any other purpose. Our service providers include (i) IT and system administration providers (ii) marketing and advertising agencies; (iii) logistics and delivery agents; (iv) data analytics providers and (v) payment institutions that we use to process

payments.

  •   Regulatory and governmental authorities, law enforcement agencies, and courts, as necessary to comply with applicable

    laws and regulations, respond to a subpoena, search warrant, or other lawful request for information, or to otherwise

    protect our rights.

  •   Our professional advisors, such as lawyers, accountants, and other similar advisers.

  •   Other entities within our group of companies.

  •   Buyers or other successors prior to or in the event of a merger, acquisition, divestiture, restructuring, reorganization,

    dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as a part of bankruptcy,

    liquidation, or similar proceeding, where the information is among the assets being transferred.

  •   Other parties for any purpose we disclose at the time you provide the information.

Protection of Personal Information

We have implemented appropriate technical and organizational measures to protect your personal information from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors, and service providers who have a business need to know. They will only process your information on our instructions and are subject to a formal duty of confidentiality. Any third parties involved in handling your personal information will only do so for specific purposes and will be subject to contractual obligations of confidentiality.

In the event that we experience any intrusion of our information systems or otherwise suffer a breach of our data security, then the Group has in place specific procedures designed to deal with such a breach, including protecting the personal information within our control and, where we are legally obliged to do so, notifying you and the relevant authorities.

Please note however that despite our best efforts we cannot guarantee the security of information being exchanged over the internet and any information you provide to us is done at your own risk. Where our Site contains links to other sites plug-ins and applications that are not operated by us, clicking on those links, or enabling those connections may allow third parties to collect or share data about you. Once you leave our Site then we have no control over, and assume no responsibility for, the content, privacy policies or practices of any third-party sites or services.

Choices About the Collection and Use of Personal Information

We strive to provide you with choices regarding your personal information. If we ever send you promotional emails, you can stop receiving those emails by clicking the “unsubscribe” link in the email. We endeavor to promptly process any unsubscribe requests. You can also correct any personal information you have provided us by contacting us using the information provided below. You can also choose not to provide us with information we may request, but that may result in you being unable to use certain features of our Site, request information about our products and services, or initiate transactions with us on behalf of your company.

Data Retention

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or other mandatory reporting requirements. To determine the appropriate retention period we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process it, whether we can achieve those purposes through other means and the applicable legal requirements. To the extent data is held in connection with contractual rights and obligations, then we will also take into account any specific limitation periods under applicable law.

Rights Afforded Certain Individuals

A. EU / UK Residents

With respect to personal information regarding individuals in the European Union and United Kingdom, the ICP Group may act as a “controller” under the General Data Protection Regulation and UK’s version of the same (collectively, the “GDPR”). For information on the rights GDPR affords individuals in the EU and UK, as well as disclosures required by the GDPR, please review our EEA Privacy Notice available here [https://www.icpgroup.com/terms/].

B. California Residents

If you are a California resident, please refer to our “Privacy Notice for California Residents” [https://www.icpgroup.com/terms/] for a description of rights available to you under California law.

International Transfers

The ICP Group is headquartered in the United States and, as a result, the information you provide to us may reside on servers or workstations in the United States. You understand and consent that information you provide may be transferred to and processed in the United States. When we transfer personal information to the United States from other countries, we will implement appropriate and suitable safeguards to protect such information as may be required by applicable data protection laws.

Children’s Privacy

Our Site is a general audience site and is not directed at, or intended for use by, children under the age of 13 years. Accordingly, we do not knowingly collect personal information from children under age 13. Should we discover that a child under the appropriate age provided his or her personal information, we will use that information only to respond to that child and inform him or her that we must have parental consent before receiving such information.

Do-Not-Track Disclosure

Please note that we do not alter our Site’s data collection and use practices when we see a “Do Not Track” signal from your device.

Links to Third-Party Websites

Our Site may contain links to third-party websites. Such websites have separate privacy policies that you should review. We cannot take responsibility for the content of linked websites or those companies’ data- handling practices.

Contact Us

If you have any questions about this Privacy Notice or about how we handle your personal information, then please write to us either by email to privacy@icpgroup.com or at the following address:

Attn: HR Director
ICP Group
150 Dascomb Road Andover, MA 01810 United States of America