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Safe Harbor Privacy PolicySafe Harbor Privacy Policy
Rockwood recognizes that privacy is very important to our customers, partners, and employees, and as such is committed to protecting the privacy of our employees and other people we do business with. Rockwood developed this Safe Harbor Privacy Policy (hereafter, "Policy") to set forth the privacy principles that Rockwood follows with respect to the transfer of personally identifiable information from the European Union (EU) to the United States. 1.2 Safe Harbor Privacy Statement Rockwood complies with the U.S.-EU Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. Rockwood has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view our certification page, please visit www.export.gov/safeharbor. 1.3 Definitions "Rockwood" means Rockwood Specialties Group, Inc. and Rockwood Specialties Inc. "Personally identifiable information" means information that (1) is transferred from the EU to the United States; (2) is recorded in any form; (3) is about, or pertains to a specific individual; and (4) could be used by Rockwood to distinguish or trace an individual's identity. "Sensitive personal information" means personal information that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, trade union membership or that concerns an individual's health. "Agent" means any third party that collects or uses personally identifiable information under the instructions of, and solely for, Rockwood or to which Rockwood discloses personal information for use on Rockwood's behalf. 1.4 Notice When Rockwood collects personal information directly from individuals in the EU, Rockwood will inform them about the purposes for which it collects and uses their personal information, the types of non-agent third parties, if any, to which Rockwood discloses that information, and the choices and means, if any, that Rockwood offers individuals for limiting the use and disclosure of their personal information. Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to Rockwood, or as soon as practicable thereafter, and in any event before Rockwood uses the information for a purpose other than that for which it was originally collected. 1.5 Choice If Rockwood intends (a) to disclose personal information to a non-agent third party or (b) to permit personal information to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual, Rockwood will offer individuals the opportunity to opt-out or choose whether or not their personal information will be used. For sensitive personal information, Rockwood will give individuals the opportunity to affirmatively and explicitly consent (opt-in) to the disclosure of the information to a non-agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. Rockwood will provide individuals with reasonable methods to exercise their choices. 1.6 Transfer to Agents Rockwood may choose to share personally identifiable or sensitive personal information with its Agents. In such cases where such Agents are not subject to laws based on the EU Data Protection Directive, Rockwood will require its Agents to either: (1) subscribe to the Safe Harbor principles or (2) contractually agree to provide at least the same level of protection for personally identifiable information as is required by the relevant Safe Harbor principles. If the third party does not comply with its privacy obligations, Rockwood may choose to, where appropriate, take reasonable steps to prevent or stop the use or disclosure of personally identifiable or sensitive personal information. 1.7 Security Rockwood will take reasonable precautions to protect personally identifiable information from loss, misuse and unauthorized access, disclosure, alteration and destruction. 1.8 Data Integrity Rockwood will use personally identifiable information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Rockwood will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current. 1.9 Access and Correction Upon request, Rockwood will grant individuals reasonable access to personal information provided by such persons that it possesses about them. In addition, Rockwood will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete. 1.10 Enforcement Rockwood uses a self-assessment approach to assure compliance with this privacy policy and periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, implemented and accessible and in conformity with the Safe Harbor principles. 1.11 Dispute Resolution Any concerns regarding the use or disclosure of personal information should be directed to the Rockwood Privacy Office at the address given below. Rockwood will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information. Rockwood Specialties Inc. participates in the U.S. – E.U. Safe Harbor framework as set forth by the United States Department of Commerce. As part of our participation in the safe harbor, we have agreed to TRUSTe dispute resolution for disputes relating to our compliance with the Safe Harbor Privacy Framework. If you have any complaints regarding our compliance with the Safe Harbor you should first contact the Rockwood Privacy Office at the address given below. If contacting us does not resolve your complaint, you may raise your complaint with TRUSTe by Internet here, fax to 415-520-3420, or mail to TRUSTe Safe Harbor Compliance Dept., click for mailing address. If you are faxing or mailing TRUSTe to lodge a complaint, you must include the following information: the name of company, the alleged privacy violation, your contact information, and whether you would like the particulars of your complaint shared with the company. For information about TRUSTe or the operation of TRUSTe's dispute resolution process, click here or request this information from TRUSTe at any of the addresses listed above. The TRUSTe dispute resolution process shall be conducted in English. For human resources data we have agreed to cooperate with Data Protection Authorities. In the event that complaints cannot be resolved between Rockwood and the complainant, Rockwood has agreed to TRUSTe dispute resolution. Individuals who submit a question or concern to Rockwood and who do not receive acknowledgment from Rockwood of the inquiry or who think their question or concern has not been satisfactorily addressed should then contact the TRUSTe Safe Harbor Dispute Resolution Program on the Internet, by mail or by fax. Inquiries by mail or fax should identify Rockwood as the company to which a concern or question has been submitted, and include a description of the privacy concern, the name of the individual submitting the inquiry, and whether TRUSTe may share the details of the inquiry with Rockwood. TRUSTe will act as a liaison to Rockwood to resolve these disputes. 1.12 How to Contact Us If you have any questions about this Policy, please contact us by email at complianceofficer@rocksp.com or by writing to us at: Rockwood Privacy Policy 1.13 Amendments Rockwood may update this Safe Harbor Policy periodically within the requirements of the Safe Harbor program and principles. If we make changes, we will post the revised version on our websites.
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