December 2020 Privacy Website Privacy Policy We have adopted this Privacy Policy in order to demonstrate our commitment to your privacy. This Privacy Policy states the policies of Lincoln Electric regarding the collection, processing, and transfer of any personal information relating to (1) our customers, vendors, or suppliers, (2) an individual accessing websites maintained by Lincoln Electric, (3) job applicants, or (4) participants in our video conferencing events (referred to as “Personal Data”).
This Privacy Policy provides information on the following:
Lincoln Electric will only process Personal Data consistent with this Privacy Policy and the purposes for which it was collected or authorized by you. To the extent necessary for those purposes, Lincoln Electric will take reasonable steps to ensure that Personal Data is accurate, complete, current as provided, and reliable for its intended use. To the extent possible, before you submit your Personal Data to Lincoln Electric, you will be informed about certain rights you have regarding Personal Data you submit and how that Personal Data will be processed and used by Lincoln Electric. At that time, you may consent to the use of and submit your Personal Data by Lincoln Electric or decline to consent to such use and not submit your Personal Data. What is Personal Data? The term “Personal Data” means “any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.” What Personal Data We Collect and How We Use That Personal Data?
Who Provides Us With Your Personal Data? The Personal Data that we collect and process on our customers, vendors, suppliers and video conferencing events participants, is derived from the individual or from his/her business. For website users, we collect Personal Data that you choose to enter into the Site. Lincoln Electric may also receive Personal Data from distributors to incentivize sales and from third parties who provide services to us, such as trade shows, mailing or other list services. Lincoln Electric may receive the following categories of Personal Data, such as your name, email address, phone number, job title, business or personal address. As for job applicants, Lincoln Electric generally collects Personal Data directly from the job applicants (e.g. via a dedicated, online talent management platform or via email communication). Lincoln Electric may also receive Personal Data about job applicants from third parties who provide services to us, such as a third party staffing or recruiting firm. Why Do We Process Personal Data? Categories of Personal Data collected and purposes for which they are processed are listed below:
Do We Collect Special Categories of Personal Data or Information on Children? Lincoln Electric does not ask for, and does not collect, Special Categories of Personal Data related to our customers, vendors, suppliers, website users, or video teleconferencing events participants. Job Applicants: In some countries such as Italy, companies are required by law to employ a certain number of people with disabilities. For this reason, Lincoln Electric needs to collect certain information on disabilities from job applicants in such countries. Children’s Privacy: The Site is not directed to children under the age of sixteen, unless otherwise provided by applicable laws, and we do not knowingly collect Personal Data from children. We may ask you to confirm that you have not and will not provide such information to us or in postings on the Site when you register. If we become aware that such information has been provided or posted on the Site, we will delete it from our records.
Lincoln Electric does not sell or lease any Personal Data, such as email addresses, collected from customers, vendors, suppliers, Site users, job applicants, or from video teleconferencing participants. The following are the ways we share your information:
How Do We Address Site Privacy and Tracking? We support the Do Not Track (DNT) browser setting. DNT is a preference you can set in your browser’s settings to let the websites you visit know that you do not want the sites collecting your personally identifiable information. How do we comply with the California Consumer Privacy Act (“CCPA”)? If you are a California resident you have certain rights regarding the collection, use, and sharing of your Personal Data.
Please note that your CCPA rights are subject to certain conditions and exceptions and that the law allows for extensions to the mandatory period to respond to your requests in certain cases. Should you have any questions regarding the rights you might have under California law or wish to exercise your CCPA rights, please make such a request by emailing us at Privacy@lincolnelectric.com, or by calling 1-888-935-3877 or by mail to: The Lincoln Electric Company Attn: Privacy Coordinator
How We Protect Your Personal Data? Lincoln Electric will take reasonable steps to protect the Personal Data it collects from loss, misuse, unauthorized access, disclosure, alteration, and destruction. Lincoln Electric has put in place appropriate physical, electronic and managerial procedures to safeguard and secures the Personal Data it collects from loss and misuse and unauthorized access, disclosure, alteration, or destruction. Please note that despite our reasonable efforts, no security measure is ever perfect or impenetrable, so we cannot guarantee the security of your Personal Data. What About Third Party Websites? This Site contains links to other third-party websites. Lincoln Electric does not control and is not responsible for the operation of such websites. Please refer to the privacy policies of those websites if you have questions about their privacy practices. Can I Unsubscribe from Emails? You may choose to stop receiving marketing or promotional emails by unsubscribing here, by clicking on the unsubscribe link at the bottom of the email, or by emailing us your request to unsubscribe. How Can I Update My Personal Data? You may use the link in the “Contacting Us” section of this policy to provide us with your updated or corrected Personal Data or to request that we delete your Personal Data. If you have an account and login with us, the Site provides you the option to update or correct information previously provided by logging into your account and clicking User Admin left and then My Profile to access your Personal Data and correct, amend or delete inaccurate information. What is Our Data Retention Policy? Lincoln Electric retains your Personal Data collected as reasonably necessary to fulfill the purposes for which Personal Data are collected and to comply with legal obligations or for the establishment, exercise or defense of a legal claim. For our customers, vendors, and suppliers, we retain their Personal Data for the duration needed to complete or facilitate our contract, agreement, or engagement, and for a reasonable amount of time thereafter in accordance with our legitimate business needs and functions. We shall retain certain Personal Data of Site visitors for no longer than reasonably necessary to fulfill the purposes for which Personal Data are collected, to comply with legal obligations or for the establishment, exercise or defense of a legal claim. The Personal Data of unsuccessful job applicants will be deleted in accordance with the normal document retention policy at Lincoln Electric. We retain any video or voice recordings of our video teleconferencing events in accordance with the normal retention policy at Lincoln Electric. Is Personal Data Transferred Across Borders/Internationally? Personal Data collected from our customers, vendors, and suppliers, Site users, job applicants or from video teleconferencing events participants is stored on servers located in the United States. In some cases, your Personal Data may also be stored on servers in a country where the Lincoln Electric affiliate is located. Concerns If you have any concerns about the privacy of the Personal Data you have provided to Lincoln Electric, please email us. Lincoln Electric will investigate and attempt to resolve any complaints you have and any disputes regarding the use and disclosure of your Personal Data in accordance with this Privacy Policy. If you have any questions about this privacy statement, the practices of the Site or your dealings with the Site, you can email us or contact us at the following addresses: Webmaster
PRIVACY POLICY UPDATES If we change our Privacy Policy, we will post those changes on this page and update the Privacy Policy modification date above. If we materially change this Privacy Policy in a way that affects how we use or disclose your Personal Data, we will notify you by prominently posting a notice of such changes before making them and by stating the effective date of the changes. EUROPEAN UNION INFORMATION PROCESSING If you are located in a country in the EU, please see the following details about the processing of your Personal Data by Lincoln Electric. Who is responsible for processing of your Personal Data? The entity with which you have a primary relationship with (such as the entity that concluded sales/services/supply contract with you; or a primary entity in the country for which we created a local website; or an entity, representatives of which you have been video teleconferencing with) (“Lincoln Electric”) is the controller of the Personal Data collected from customers, vendors, or suppliers, or submitted on this Site, or recorded in the course of video teleconferencing events from participants. As for the job applicants, the relevant controller for your Personal Data is the Lincoln Electric entity to which you have submitted your job application. You can find the full list of our entities and their respective contact details here. What Personal Data do we process about you? The categories of Personal Data that Lincoln Electric processes about you, for the purposes described below are listed herein. Why are we processing your Personal Data and on which legal bases? Lincoln Electric processes Personal Data for the purposes we have outlined herein and for your convenience, also in this section. Where applicable, we will point out, at the time of the data collection, if the provision of the Personal Data is a statutory or contractual requirement and whether you are obliged to provide the Personal Data and the possible consequences of failure to provide such Personal Data. Information on Our Customers, Vendors, or Suppliers Lincoln Electric may collect and process Personal Data concerning our customers, vendors, and suppliers to facilitate routine and common business practices, such as those related to sales orders and management. Legal Bases: The processing is justified based on statutory provisions that (1) processing is based on the consent; (2) processing is necessary for Lincoln Electric’s legitimate interests as set out herein. (3) processing is necessary for the performance of a contract to which you are a party; and (4) Lincoln Electric is required to comply with a legal or statutory obligation in the EU or a Member State. Information on Lincoln Electric, Distributors and its Products This includes processing Personal Data to: provide information or updates about Lincoln Electric or its products, arc welding, safety data sheets (SDS), safety and corporate investor information; carry out optional online surveys and opinion polls to obtain Site visitor’s input relating to our present or planned products and their use; locate a nearby Lincoln Electric distributor. Legal Bases: The processing is justified based on statutory provisions that (1) processing is based on the consent of the Site visitor; (2) processing is necessary for Lincoln Electric’s legitimate interests as set out herein; (3) processing is necessary for the performance of a contract to which you are a party; and (4) Lincoln Electric is required to comply with a legal or statutory obligation in the EU or a Member State. Site and myLincoln Administration This includes processing Personal Data to: carry out Site and myLincoln Account administration. Legal Bases: The processing is justified based on (1) your consent; (2) processing is necessary for Lincoln Electric’s legitimate interests as set out herein; and (3) processing is necessary for the performance of a contract to which you are a party. Compliance with Law, Internal Regulations and Protection This includes processing Personal Data to: comply with law or legal process, Lincoln Electric’s policies and procedures and to protect the rights, property, or safety of Lincoln Electric, our users, or others. Legal Bases: The processing is justified based on statutory provisions that (1) Lincoln Electric is required to comply with a legal or statutory obligation in the EU or a Member State; (2) to protect the vital interests of the data subject or of another natural person; and (3) processing is necessary for Lincoln Electric’s legitimate interests as set out herein. Communication with Site Visitors This includes processing Personal Data to: enable visitors to submit an inquiry or comment to Lincoln Electric and reply to such inquiries. Legal Bases: The processing is justified based on statutory provisions that processing is necessary for Lincoln Electric’s legitimate interests as set out herein. Corporate Transactions This includes processing Personal Data to: comply with requests of prospective or actual purchasers interested in Lincoln Electric or its assets, or in relation to a purchase of companies or assets by Lincoln Electric. Legal Bases: The processing is justified based on (1) your consent; (2) processing is necessary for Lincoln Electric’s legitimate interests as set out herein. Direct Marketing This includes processing Personal Data to: provide (e-)newsletters and other marketing materials. Legal Bases: The processing is justified based on (1) your consent; (2) processing is necessary for Lincoln Electric’s legitimate interests as set out herein. Warranty and Registration This includes processing Personal Data to: provide product registration and extended warranty orders. Legal Bases: The processing is justified based on statutory provisions that (1) processing is necessary for the performance of a contract to which you are a party; (2) processing is necessary for Lincoln Electric’s legitimate interests as set out herein; and (3) Lincoln Electric is required to comply with a legal or statutory obligation in the EU or a Member State. Recruiting talent This includes processing Personal Data for the purposes of initial screening of applications and further evaluation during interviews or online assessments, and in some countries, for the purposes of complying with the law requiring companies to employ a certain number of people with disabilities. Legal bases: The processing is (1) justified on your consent; or necessary: (2) for the purposes of Lincoln Electric’s legitimate interest to carry out appropriate assessment of applications and to select suitable candidates for the roles available; (3) to comply with a legal obligation of Lincoln Electric to hire individuals with the right to work in the country you have applied to work in; (4) if applicable in the country you have applied to work with, to comply with a legal obligation of Lincoln Electric to employ a certain number of people with disabilities; (5) to take steps as necessary prior to entering into an employment contract; and (6) to comply with a legal obligation or for the establishment, exercise or defense of a legal claim. Video Teleconferencing Events This includes processing Personal Data recorded in the course of training events, meetings, conferences and other events we may organize. Legal Bases: The processing is justified based on (1) your consent; (2) processing is necessary for Lincoln Electric’s legitimate interests as set out herein. With whom do we share your Personal Data? Personal data are shared within the Lincoln Electric (i.e. intra-group) or with third parties. In some cases, external companies collect Personal Data directly from you on our behalf. The categories of recipients of Personal Data are listed herein. Do we disclose your Personal Data internationally? Intra-Group Due to the global nature of our operations, some of the recipients mentioned herein may be located in countries outside the European Economic Area (EEA), which do not provide an adequate level of data protection by law. International transfers will be to countries where Lincoln Electric entities have offices, including the United States of America, United Kingdom (following the end of the Brexit transition period), Canada, Mexico, Argentina, Brazil, Colombia, Venezuela, Russia, Ukraine, Australia, China, India, and Japan. The transfer of your Personal Data outside the EEA takes place on the basis of our Global Intra-Group Data Transfer and Processing Agreement, which is based on standard contractual clauses adopted by the European Commission to protect the Personal Data when transferred outside the EEA and in accordance with applicable law. Third Parties Some of the third parties with whom we share Personal Data are also located outside the EEA. Certain third countries have been officially recognized by the European Commission as providing an adequate level of protection. You can find the list of these countries at the following address: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en. Transfers to third parties located in other third countries outside the EEA take place using an acceptable data transfer mechanism, such as the EU Standard Contractual Clauses, Binding Corporate Rules, approved Codes of Conduct and Certifications or in exceptional circumstances on the basis of permissible statutory derogations. Please contact privacy@lincolnelectric.com, if you want to receive further information or, where available, a copy of the relevant data transfer mechanism. How long does Lincoln Electric keep my Personal Data? To find out more about Lincoln Electric’s retention of your Personal Data, click herein. Rights in relation to your Personal Data Under the conditions set by applicable data protection laws, you may exercise the following rights regarding your Personal Data: Access You have the right to obtain from us confirmation if Personal Data are being processed, the purpose of processing, the categories of data, the legal basis of the processing, information on recipients of the data and the non-EU countries in which they are located, the safeguards put in place for the transfer of data to non-EU countries, the storage period of data or criteria to determine it, further information on your rights, our processing activities, the sources of information and the significant and envisaged consequences of processing. Rectification You have the right to request the rectification of inaccurate Personal Data and to have incomplete data completed. Objection You have the right to object to the processing of your Personal Data for compelling and legitimate reasons relating to your particular situation, except in cases where legal provisions expressly provide for that processing. In addition, you have the right to object at any time where your Personal Data are processed for direct marketing purposes. Portability You may receive your Personal Data that you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit them to other data controllers without hindrance. This right only exists if the processing is based on your consent or a contract and the processing is carried out by automated means. Restriction You may request to restrict processing of your Personal Data if (i) you contest the accuracy of them – for the period we need to verify your request; (ii) the processing is unlawful and you oppose the erasure of them and request restriction instead; (iii) we no longer need them, but you tell us you need them to establish, exercise or defend a legal claim; or (iv) you object to processing based on public or legitimate interest – for the period we need to verify your request. Erasure You may request to erase your Personal Data if they are no longer necessary for the purposes for which we have collected them, you have withdrawn your consent and no other legal ground for the processing exists, you objected and no overriding legitimate grounds for the processing exist, the processing is unlawful, or erasure is required to comply with a legal obligation. Right to lodge a complaint You also have the right to lodge a complaint with a supervisory authority, in particular in the EU Member State of your residence, place of employment, or the location where the issue that is the subject of the complaint occurred. Right to refuse or withdraw consent Please note that in case we ask for your consent to certain processing, you are free to refuse to give consent and you can withdraw your consent at any time without any adverse negative consequences. The lawfulness of any processing of your Personal Data that occurred prior to the withdrawal of your consent will not be affected. Contact Details To find out more about how to contact Lincoln Electric, click here. If you wish to exercise any of the afore-mentioned rights or if you have any questions regarding this Privacy Policy, you may direct your request to privacy@lincolnelectric.com. You may also contact the Data Protection and Privacy Coordinator for Europe: Robert Mayo Protection of Username and Password Some areas of the Website may require that you register and log in. You are responsible for protecting your username and password and all activities on your account. Additionally, we may rely upon any communications we receive on the Website under your login. Notify us immediately if you have reason to believe your login has been or may be used by someone not authorized to do so. |