1. The personal information we collect and why
2. The legal basis for processing personal information
3. Who do we share your personal information with and how
4. Data retention
5. Your data protection rights for personal information held by [Company Name]
6. Will my personal information be transferred abroad?
7. Security measures for your personal information
8. Cookies and Similar Technologies
9. Links to third party websites
10. Changes to our Privacy Notice
11. How to contact us


1. The personal information we collect and why

The personal information that we may collect about you through the Website broadly falls into the following

Information that you provide voluntarily
Certain parts of our Websites may ask you to provide personal information voluntarily, such as through completing
a Web form:
• name, and address of the company for the sample request ;
• personal contact information (phone, email)
• project information, technical information, samples needed, design and production, desired
carrier/shipper, charrier/shipper account # (if applicable), competitor’s name if replacement of product;
• user preferences (e.g., preferred language settings);
• content of any communication sent through the website, including any information posted in social
communities on the website or otherwise shared with ITW CER and/or other users :Transtech, United
Silicone, Morlock;
• any other information that you enter on, or upload to, the website (e.g., content that you fill into an online
form, a photo that you upload).

Information that we collect automatically

When you visit our Website, we may collect certain information automatically from your device. In some countries,
including countries in the European Economic Area, this information may be considered personal information under
applicable data protection laws.
Specifically, the information we collect automatically may include:
• IP address, operating system, browser type, browser version, browser configuration, name of internet
service provider, and other types of computer and connection related information relevant to identifying
your type of device, connecting to the website, enabling data exchange with you and your device, and
ensuring a convenient use of the website;
• URL and IP address of the website from which you accessed, or were directed to, our website, including
date and time;
• subpages visited while on our website, links followed on the website, including date and time;
• the full Uniform Resource Locator (URL) click stream to, through and from the website, including date and
• search terms entered; and
• services/products viewed or searched for on the website.
Collecting this information enables us to better understand the visitors who come to our Website, where they come
from, and what content or products on our Website are of interest to them. We use this information for our internal
analytics purposes and to improve the quality and relevance of our Website to our visitors.
Some of this information may be collected using cookies and similar tracking technologies, as explained further
under the heading “Cookies and similar tracking technology” below.

2. The legal basis for processing personal information

Our legal basis for collecting and using the personal information described above will depend on the personal
information concerned and the specific context in which we collect it.
However, we will normally collect personal information from you only
(i) where the processing is in our legitimate interests and not overridden by your rights,
(ii) where we need the personal information to perform a contract with you, or
(iii) where we have your consent to do so.

We will process your personal information for any of the purposes below:

• administering, operating, maintaining and improving the website;
• contacting you to inform your organisation of new products and services we will be providing;
• evaluating your organisation’s eligibility for certain types of offers, products or services;
• helping us to improve and personalise the website, our marketing, products and services;
• performing analytics and conducting customer research, including general market re- search or surveying
our customers’ needs and opinions on specific issues, generating sales and traffic patterns, and to analyse
advertising effectiveness, both on an anonymous basis (e.g., by aggregating data) or on an individual basis
(if legally permissible);
• answering your questions and responding to your requests;
• providing your organisation with information about our other products and services and regular updates on
issues that may be of interest to your organisation performed through marketing channels such as (but not
limited to): traditional mail, email, telephone, fax, newsletter, text / SMS / MMS messaging, social media
posts, online advertising and search engine advertising, including periodic sending of promotional
materials on products;
• creating statistical data about use of our Website and Social Media Pages, products and services;
• confirming that your organisations’ orders have been received and to process them, to validate your
organisation as a registered customer when using our services and calling our customer services;
• providing the relevant products and services to your organisation, for administration of your organisation’s
account with us and customer services, and for billing purposes;
• our internal purposes such as management, research, analytics, corporate reporting and to improve
business efficiencies;
• ensuring security for your organisation and our staff, and help maintain service quality (calls to our
customer services may be monitored and/or recorded for authentication, security, quality and training
• tracing nuisance or malicious calls;
• complying with applicable laws, regulations, court orders, government and law enforcement agencies’
requests, to operate our systems properly and to protect ourselves, our users and customers and to solve
any customer disputes;
• segmenting our customer base and help us develop offers, products and services to provide your
organisation with the best customer experience;
• complying with legal obligations, prevent unlawful uses of the website, resolve disputes, and enforce our
agreements; and
• other purposes that you have specifically agreed to; and otherwise as permitted by applicable law.

We will seek your consent before collecting, processing and using your personal information for the above-mentioned
purposes, if and to the extent legally required. Likewise, if we wish to use your personal information for a
new or different purpose that is not compatible with the purpose for which we collected or received it, we will notify
you and will only make such other use if it is required or permitted by applicable law or if you have consented to it.
For the purposes mentioned above, only a limited number of individuals within ITW CER (e.g. individuals in sales,
marketing, IT, accounting departments and HR, as well as certain managers with assigned responsibility) will
receive access to your personal information.
If you have questions or need further information concerning the legal basis on which we collect and use your
personal information, please contact us using the contact details provided under the “How to contact us” heading
below (item 11).

3. Who do we share your personal information with and how

For the purposes mentioned above, we may share your personal information with third parties. In order to make
improvements to our website we may gather information that helps us understand how customers use it. For
example, we may research the collected information to determine which areas of the site our customers most
frequently access.
ITW CER may provide aggregate statistics about our customers, sales, traffic patterns, and related site information
to reputable third-party vendors, but these statistics will not include individual identifying information. Personal
information such as your name and email address will not be used in our research.
We do not sell, trade, rent, disclose, transfer or otherwise share your personal information, except as follows:
• Our group companies, third party service providers and partners: We may employ third party service
providers (i.e., companies or individuals engaged by us) to perform certain functions on our behalf and
under our instructions. Examples include database management, maintenance services, web analytics,
handling in- bound inquiries, sending postal mail and email, removing repetitive information from customer
lists, analysing data. Third party service providers may for instance include IT companies. Any third-party
provider who provides data processing services to us, or who otherwise processes personal information for
purposes that are described in this Privacy Notice will have access only to such personal information as it
needs to perform its specific functions, and only for the purpose of performing these functions. We will
ensure that any third-party service provider is aware of and abides by these obligations. We will also ensure
that any third-party service provider processes your personal information as required by applicable data
protection laws and that they adopt adequate technical and organizational security measures.

List of our current group companies:
Transtech / USA – United Silicone / USA –Morlock / Germany

List of our current service providers:
Foremost Media / USA (
Google Analytics (https:/

Courts, competent law enforcement authorities and regulatory, government agency: We may share
personal information when we believe it necessary to comply with applicable law or regulation, to exercise,
establish or protect our legal rights, or to protect your vital interests, the rights or safety of our website,
other users, or third parties (e.g., for fraud protection purposes). Without limitation, this may include cases
in which we are required to share personal information by the law or binding order of courts, law
enforcement authorities or regulators.
Potential or actual buyers (and its or their agents and advisers): As we continue to develop our business,
we might sell all or parts of our website or business. We may disclose your personal information to an
actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase,
merger or acquisition of any part of our business or website, provided that we inform the buyer it must use
your personal information only for the purposes disclosed in this Privacy Notice.
• Any other person: if agreed by you (e.g., where you consent to other types of data transfers in connection
with enrolling for a specific service).

4. Data retention

We retain personal information we collect from you where we have an ongoing legitimate business need to do so
(for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting

When we have no ongoing legitimate business need to process your personal information, we will either delete or
anonymise it or, if this is not possible (for example, because your personal information has been stored in backup
archives), then we will securely store your personal information and isolate it from any further processing until
deletion is possible in accordance with our standard backup deletion/destruction policies.

5. Your data protection rights for personal information held by ITW CER

You have the following data protection rights:

• If you wish to access, correct, update or request deletion of your personal information, you can do so at any
time by contacting us using the contact details provided under the “How to contact us” heading below
(item 11).
• Upon receipt of your written request and enough information to permit us to identify your personal
information, we will disclose to you the personal information we hold about you and to which you are
entitled, for which we may make a charge up to the maximum as allowed by applicable law.
• You may request that we rectify any personal information that is inaccurate or delete any personal
information that you think we no longer have a legitimate purpose for processing, as may be required by
• Requests to delete personal information are subject to any applicable legal and ethical reporting or
document retention obligations imposed on us.
• In addition, you can object to the processing of your personal information in certain situations, including
where your personal information is processed on the basis of legitimate interests

• You can also ask us, in certain situations, to restrict processing of your personal information (i.e. stop
processing but retain the information), or to provide portability of your personal information (i.e. transfer
your personal information to you or another party as you request).
• Again, you can exercise these rights by contacting us using the contact details provided under the “How to
contact us” heading below (item 11).
• You have the right to opt-out of marketing communications we send you at any time. You can exercise this
right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of
other forms of marketing (such as postal marketing or telemarketing), then please contact us using the
contact details provided under the “How to contact us” heading below (item 11).
• Similarly, if we have collected and process your personal information with your consent, then you can
withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any
processing we conducted prior to your withdrawal, nor will it affect processing of your personal information
conducted in reliance on lawful processing grounds other than consent.
• You have the right to complain to a data protection authority about our collection and use of your personal
We respond to all requests we receive from individuals wishing to exercise their data protection rights in
accordance with applicable data protection laws.

6. Will my personal information be transferred abroad?

Our group companies and third-party service providers and partners operate around the world, mainly in Europe,
EEA and USA. Accordingly your personal information may be transferred to, or processed in, in any country other
than the country in which you are resident. This may include countries where applicable data protection laws
provide a lesser degree of protection than your home country. Specifically, our Website servers are located in USA.
This means that when we collect your personal information we may process it in any of these countries.
For instance, if you are located within the EU/EEA or Switzerland, the country where the recipient is located may not
qualify as a safe country within the European Data Protection Directive (95/46/EC), the EU General Data Protection
Regulation (679/2016) or the Federal Data Protection Act of Switzerland. In such cases, ITW CER will nevertheless
ensure an adequate level of protection for your personal information in compliance with applicable data protection
laws. This includes implementing the European Commission’s Standard Contractual Clauses for transfers of
personal information between our group companies; these require all group companies to protect personal
information they process from the EEA in accordance with European Union data protection law.

7. Security measures for your personal information

We are committed to protecting the confidentiality and security of the information that you provide to us and we put
in place appropriate technical, physical and organisational security measures to protect against any unauthorised
access or damage to, or disclosure or loss of, the personal information that we collect and process about you. The
measures we use are designed to provide a level of security appropriate to the risk of processing your personal
You should also be aware that communications over the internet, such as e-mails, are not secure unless they have
been encrypted.


8. Cookies and Similar Technologies

We use cookies, web beacons, unique identifiers and similar technologies to collect and store information (which
may include your personal information) about how you interact with our websites, communications and services
and selected third party websites which belong to our partner advertising networks. We may use these technologies
to show you relevant adverts based upon this information, this is called interest-based advertising.

Cookies are small text files placed on your device which uniquely identify your device. Cookies cannot be used to
run programs or deliver viruses to your device.

Web beacons (also known as “Pixel tags“) are small blocks of code on webpages or in our emails that allow us to
read and set cookies. Web beacons are often used in connection with cookies to help operate our websites, emails
and collect information about online

Some cookies expire when the browsing session ends. Some cookies expire after some number of years. Cookies
can be deleted by clearing them in the user’s browser. Google Analytics stores the data for 26 months.

9. Links to third party websites

This privacy notice does not apply to third party websites which our websites link to or which advertise on our
websites. These third-party websites operate their own privacy notice or policy which we encourage you to read.

10. Changes to our Privacy Notice

We may amend this Privacy Policy from time to time for example, to keep it up to date or to comply with changing
legal, technical or business requirements. When we update our Privacy Notice, we will take appropriate measures
to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material
Privacy Notice changes if and where this is required by applicable data protection laws.

You can see when this Privacy Notice was last updated by checking the “last updated” date displayed at the top of
this Privacy Notice.

11. How to contact us

If you have any questions or concerns about our use of your personal information, please contact us using the following details:

Address: ITW CER SAS – 85 Rue Castellion – 01117 OYONNAX Cedex – France

Contact Number: +33 (0) 4 74 73 26 32