Privacy Notice

Thank you for your interest in Vantage! This Privacy Notice explains how information about you, that directly identifies you, or that makes you identifiable (“personal information”) is collected, used, disclosed, and otherwise processed by Vantage in connection with our services.

When we use the terms “Vantage”, “Vantage Group”, “we”, “us”, or “our” in this Privacy Notice, we are referring to Vantage Specialty Chemicals, Inc. and its affiliates and subsidiaries. When we use the term “Service,” we are referring to all of the services and product offerings that we offer as a controller, our website https://www.vantagegrp.com/ or any other Vantage Group product or service that posts or links to this Privacy Notice.

Vantage as a Data Controller: For purposes of data protection laws, Vantage is the “data controller” (or similar term under applicable laws) and is generally responsible for and controls the processing of your personal information collected through your use of our Service. This Privacy Notice applies only to instances where Vantage acts as a data controller. Note this Privacy Notice does not address our privacy practices relating to Vantage’s employees and other personnel.

Table of Contents

How We Collect Your Information
How We Use Your Personal Information
How We Share Personal Information
Control Over Your Information
Children
Third Party Websites and Services
Changes to Privacy Notice
Contact Us
Region-Specific Disclosures

Additional Disclosures for California Residents (United States)
Additional Disclosures for Nevada Residents (United States)
Additional Disclosures for the European Economic Area, United Kingdom, and Switzerland
Additional Disclosures for Brazilian Residents
Additional Disclosures for Chinese Residents

1. HOW WE COLLECT YOUR PERSONAL INFORMATION

When you interact with us, we are collecting personal information about you. Sometimes we collect personal information automatically when you interact with our Services and sometimes we collect the personal information directly from you. At times, we may collect personal information about you from third parties.

Personal Information You Provide

We may collect the following personal information you provide in connection with our Service:

Account Creation and Profile Information for a Vantage Account. We may collect personal information that you provide when you register for an account. This information may include your email and password, company name, company URL, office phone number and office address. You may also add or confirm your name, company industry, tax ID, billing address, and time zone.
Contract Data. If your company enters into a contractual relationship with us, we may collect your name, job title, email address, signature (if wet signed or a copy of their autograph is used), customer name and address, and information how you heard about us.
Payment and Transaction Information. When you purchase one of our products (where available), we collect the information provided in connection with such payment. Please note that we use third party payment processors to process payments made to us. As such, all such information is provided directly by you to our third-party processor. The payment processor’s use of your personal information is governed by their privacy notice. We will only receive the last 4 digits of the credit card number along with transaction-related information (i.e., payment date, amount, device type, IP address and card type). If custom billing is arranged, the account contact’s name, email, job title, company and address may be collected as well.
Communications. When you contact us through any method of communications, including through one of our website “Contact Us” or “Support” functions, we may collect your name, email address, mailing address, phone number, company/company URL, account ID, type of inquiry, or any other personal information you choose to provide to us, such as how many contacts you have/your company has, which products interest you, what platform is currently being used, and meeting dates and times.
Newsletter and Marketing Emails. If you sign up to receive news or alerts from us, we may collect your email and applicable interests and communication preferences.
Events, Surveys, Feedback, Promotions, Sweepstakes and Contests (including Webinars, Training Sessions, or Live Events). If you fill out any forms or otherwise provide your information to us in connection with Vantage events, surveys, or other promotional events (including webinars, trainings, conferences, or other live events), as well as when you provide feedback to us, we may collect your contact information (such as your name, email, and phone number), your organization company, your job title, the office address and any other information you provide to us.
Job Application Information: Through our recruitment process, we may collect your full name, email address, phone number, resume, cover letter, immigration status, state/province/territory of residence, gender, race, drug testing, behavioral and other assessments, and any additional information you choose to provide to us. We may also collect background check information including professional and educational history, criminal history that may be relevant for a position with our team, in connection with your job application when permitted by applicable law.

Personal Information Automatically Collected

As is true of most digital platforms, we and our third-party providers and partners collect certain personal information automatically when you visit, interact with, or use our Service:

Log Data: Including your internet protocol (IP) address, operating system, browser details such as type, ID, and configuration, unique identifiers, device type and version, the referring URL, date/time of your visit, the time you spent on our services and any errors that may occur during your visit to our Services.

Analytics Data: Including the electronic path you take to our services, through our services and when exiting our services, UTM source, as well as your usage and activity on our services, such as the time zone, activity information (first and last active date and time), usage history (flows created, campaigns scheduled, emails opened, total log-ins) as well as the pages, links, objects, products and benefits you view, click or otherwise interact with. We may also analyze the interaction between you and your customer using our Services.

Location Data: Including your general geographic location based on the IP address we collect.

We and our third-party providers may use (i) cookies or small data files that are stored on an individual’s computer and (ii) other, related technologies, such as web beacons, pixels, embedded scripts, location-identifying technologies and logging technologies (collectively, “cookies”) to automatically collect this personal information. For more information about these practices and your choices regarding cookies, please see our Cookie Notice.

Personal Information from Other Sources and Third Parties

We may also obtain personal information from third parties, which we may combine with personal information we collect either automatically or directly from an individual.

We may receive personal information from the following third parties:

Vantage Group: We may receive personal information from other companies and brands owned or controlled by Vantage, and other companies owned by or under common ownership as Vantage and that are part of the Vantage Group.

Vantage Business and Marketing Partners. We may also collect personal information from other business and marketing partners with whom we jointly offer products or services, co-market or host events, or who are part of our partner ecosystem. The information we collect may include your name, phone number, email address, company name and address, opportunity/interest details of your company, and information on whether your company is a current client of our partner.

Social Media: When an individual interacts with us through various social media networks, such as when someone follows us or shares our content on LinkedIn, YouTube, Twitter, WeChat or other social networks through, for example, the social media buttons embedded into our website, we may receive some information about individuals that they permit the social network to share with third parties. The data we receive is dependent upon an individual’s privacy settings with the social network, and may include name, username and other details you may provide. Individuals should always review and, if necessary, adjust their privacy settings on third-party websites and social media networks and services before sharing information and/or linking or connecting them to other services.

ServiceProviders: Our service providers that perform services solely on our behalf, such as payout processing, and marketing providers, collect personal information and often share some or all of this information with us.

2. HOW WE USE YOUR PERSONAL INFORMATION

We may use the personal information we collect for the following purposes:

Fulfill our contractual obligations, to deliver the Services you have requested, including facilitating your messages to other users or groups and for account and contract management (including customer support);
Communicate with individuals, including via email, text message, social media and/or telephone and video calls;
Review our business performance;
Market and sales of our Services to individuals, including through email, direct mail, phone, video call or text message;
Send gifts to you;
Administer, improve and personalize our Services, including by recognizing an individual and remembering their information when they return to our Services and analyzing our client-base;
Process payment for our Services;
Conduct market research;
Opportunity tracking, conversion and lead generation;
Test, enhance, update and monitor the Services, or diagnose or fix technology problems;
Help maintain the safety, security and integrity of our property and Services, technology assets and business;
Enforce any terms and conditions, resolve disputes, carry out our obligations and enforce our rights, and protect our business interests and the interests and rights of third parties;
Prevent, investigate or provide notice of fraud or unlawful or criminal activity;
Process and deliver contest and sweepstakes entry and awards;
Comply with legal obligations and regulatory obligations;
Execute a contract or preliminary procedures related to a contract of which you are a party.

3. HOW WE SHARE PERSONAL INFORMATION

We may also share, transmit, disclose, grant access to, make available, and provide personal information with and to third parties, as described below.

Service Providers: We share personal information with third party contractors and service providers, that are subject to reasonable confidentiality terms, and which may include processing payments, providing web hosting and maintenance services, technology support providers, email communications providers, analytics providers, data storage providers, and web and video hosting providers and developers. Any such service providers will be subject to confidentiality provisions and be bound to only process the data on our behalf and under our instructions, unless such service providers act as their own controllers (e.g., in the case we seek advice from lawyers and tax consultants).
Vantage Group: We may share with other companies and brands owned or controlled by Vantage, and other companies owned by or under common ownership as Vantage and which are part of the Vantage Group. These companies will use your personal information in the same way as we can under this Privacy Notice.
Business and Marketing Partners: We may also disclose personal information with other business and marketing partners with whom we jointly offer products or services, co-market or host events, or who are part of our partner ecosystem. We may obtain your consent where required by applicable law. Our business and marketing partners will use your information in accordance with their own privacy notices.
Corporate Transaction: We may transfer any information we collect in the event we sell or transfer all or a portion of our business or assets (including any shares in the company) or any portion or combination of our products, services, businesses and/or assets. Should such a transaction occur (whether a divestiture, merger, acquisition, bankruptcy, dissolution, reorganization, liquidation, change of control or similar transaction or proceeding), we will use reasonable efforts to ensure that any transferred information is treated in a manner consistent with this Privacy Notice.
Legal Obligations and Rights: We may disclose personal information to third parties, such as legal advisors and law enforcement agencies, regulators, other authorities and other third parties for legal reasons if we reasonably believe that such action is necessary:
- in connection with the establishment, exercise, or defense of legal claims;
- to comply with laws or to respond to lawful requests and legal process;
- to protect our rights and property and the rights, personal safety and property of others, including to enforce our agreements and policies;
- to detect, suppress, or prevent fraud;
- as otherwise required by applicable law.
With Your Consent: We may disclose personal information about an individual to certain other third parties or publicly with their consent or direction. For example, with an individual’s consent or direction we may post their testimonial on our website or service-related publications.

4. CONTROL OVER YOUR INFORMATION

Email Communications. From time to time, we may send you emails regarding updates to our Services, products or services, notices about our organization, or information about products/services we offer that we think may be of interest to you. If you wish to unsubscribe from such emails, simply click the “unsubscribe link” provided at the bottom of the email communication. Note that you cannot unsubscribe from certain services-related communications (e.g., account verification, confirmations of transactions, technical or legal notices).
Modifying or Deleting Account Information. If you have a Vantage account with us, you have the ability to modify or delete certain information in your account. Note, however, that not all personal information is maintained in a format that you can access or change. If you would like to request access to, or correction or deletion of personal information, you may send your request to us by legal@vantagegrp.com. We will review your request and may require you to provide additional information to identify yourself, but we do not promise that we will be able to satisfy your request.

5. CHILDREN

Our Services are not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 16. If an individual is under the age of 16, they should not use our Services or otherwise provide us with any personal information either directly or by other means. If a child under the age of 16 has provided personal information to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal information from our systems. If we learn that any personal information we collect has been provided by a child under the age of 16, we will promptly delete that personal information.

6. THIRD PARTY WEBSITES AND SERVICES

The Services may contain integrations or links to third party websites or services, including those of our business partners. By interacting with these third parties, you are providing information directly to the third party and not Vantage. Please note that Vantage is not responsible for the privacy practices of these third parties or any entity that it does not own or control. We encourage you to review the privacy notices and online terms of those third parties to learn more about how they handle your personal information.

7. CHANGES TO PRIVACY NOTICE

We reserve the right to change this Privacy Notice from time to time in our sole discretion. We will notify you about material changes in the way we treat personal information by adequately informing you via your account, by placing a prominent notice on our website, or through other appropriate communication channels. It is your responsibility to review this Privacy Notice periodically. All changes shall be effective from the date of publication unless otherwise provided.

8. CONTACT US

If you have any questions or requests in connection with this Privacy Notice or other privacy-related matters, please send an email to legal@vantagegrp.com.

9. REGION-SPECIFIC DISCLOSURES

This Privacy Notice is designed to apply to our website visitors, users of our Service, and other companies and users on a global basis. Please refer below for additional disclosures that may be applicable to you:

Additional DISCLOSURES for California Residents (UNITED STATES)

These additional disclosures for California residents (“CA Disclosures”) supplement the information contained in our Privacy Notice and apply solely to individual residents of the State of California (“consumers” or “you”).

These CA Disclosures provide additional information about how we collect, use, disclose and otherwise process personal information of individual residents of the State of California, either online or offline, within the scope of the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (collectively, the “CCPA”)

Unless otherwise expressly stated, all terms in these CA Disclosures have the same meaning as defined in our Privacy Notice or as otherwise defined in the CCPA.

When we use the term "personal information" in this CA Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

A. COLLECTION AND USE OF PERSONAL INFORMATION

We collect personal information from and about you for a variety of purposes, as described in the How We Collect Your Personal Information and How We Use Your Personal Information sections of the Privacy Notice.

Categories of Personal Information Collected. In the last 12 months, we have collected the following categories of personal information:

Identifiers, such as your first, middle and last name, email address, username, or other similar identifiers, Social Security Numbers and drivers license numbers;
CA Customer Categories, such as your name, phone number, and postal address;
Commercial Information, such as records of services purchased, obtained or considered;
Internet/Network Information, such as device information, logs and analytics data;
Geolocation Data, such as approximate location data generated based on your IP address or other information;
Sensory Information, such as recordings of any phone calls or video calls (with your permission, as applicable) between you and Vantage;
Professional/Employment Information, such as the business or organization you represent, your title with that business or organization and information relating to your role with the business or organization, job application information and other details contained in your resume;
Inferences about your interests and preferences, generated from your use of our sites; and
Other Personal Information, including information you submit into the feedback form and any communications between you and Vantage, as well as information we receive from social networking sites.

We collect this information from the following sources: directly from you, from our business partners and affiliates, from your browser or device when you visit our website or use our Services, or from third parties that you permit to share information with us. Please see the How We Collect Your Personal Information section of the Privacy Notice for more information about the sources of personal information we collect.

B. DISCLOSURE OF PERSONAL INFORMATION

We share personal information with third parties for business purposes. The categories of third parties to whom we disclose your personal information for a business purpose include: (i) other brands and affiliates in our family of companies; (ii) our service providers and advisors; (iii) analytics providers; (iv) marketing and strategic partners; and (v) social networks.

In the previous 12 months, we have disclosed all of the categories of personal information we collect, explained in the Collection and Use of Personal Information section of these CA Disclosures, to third parties for a business purpose, as describe the How We Share Your Personal Information section of the Privacy Notice.

C. SALE OF PERSONAL INFORMATION

As further described in the How We Share Your Personal Information section of the Privacy Notice, we may“sell” or “share” your personal information (as those terms are defined by the CCPA) to third parties, subject to your right to opt out of those sales or sharing (see Exercise Your Right to Opt-Out below).

In the last 12 months, we have sold or shared the following categories of personal information for the purposes described in our Privacy Notice, subject to your settings and preferences and your Right to Opt-Out: Identifiers, such as your name and email address, CA Customer Categories, such as your name and phone number, and Commercial Information, such as records of services purchased, obtained or considered.

The categories of third parties to whom we may sell or share the personal information include:

Business Partners
Social Networks

We may also disclose personal information to third parties at your direction or upon your request, in connection with a corporate business transaction, or to comply with legal or contractual obligations, as described in our Privacy Notice.

D. YOUR CALIFORNIA PRIVACY RIGHTS

As a California resident, you may be able to exercise the following rights in relation to the personal information that we have collected about you (subject to certain limitations at law):

The Right to Access/Know

You have the right to request any or all of the following information relating to your personal information we have collected and disclosed in the last 12 months, upon verification of your identity:

The specific pieces of personal information we have collected about you;
The categories of personal information we have collected about you;
The categories of sources of the personal information;
The categories of personal information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed;
The categories of personal information we have sold about you (if any), and the categories of third parties to whom the information was sold; and
The business or commercial purposes for collecting or, if applicable, selling the personal information.

The Right to Request Deletion

You have the right to request the deletion of personal information we have collected from you, subject to certain exceptions.

The Right to Correction

You have the right to request that any inaccuracies in your personal information be corrected, taking into account the nature of the personal information and the purposes of the processing of your personal information.

The Right to Opt-Out of Sales or Sharing of Personal Information

You have the right to direct us not to “sell” your personal information to third parties for monetary or other valuable consideration, or “share” your personal information to third parties for cross-context behavioral advertising purposes.

If you are under the age of 16, you have the right to opt in, or to have a parent or guardian opt in on your behalf, to such sales.

The Right to Limit Use and Disclosure of Personal Information

You have the right to direct us to limit the use of your sensitive personal information to certain purposes, subject to certain exceptions.

The Right to Control Over Automated Decision-Making / Profiling

You have the right to direct us not to use automated decision-making or profiling for certain purposes.

The Right to Non-Retaliation

You have the right not to receive retaliatory or discriminatory treatment for exercising these rights.

However, please note that if the exercise of these rights limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products and services or engage with you in the same manner.

“Shine the Light”

California residents that have an established business relationship with us have rights to know how their information is disclosed to third parties for their direct marketing purposes under California’s “Shine the Light” law, or the right to opt out of such practices (Civ. Code §1798.83).

E. HOW TO EXERCISE YOUR CALIFORNIA PRIVACY RIGHTS

To exercise your rights: please submit a request by filling out our Privacy Rights Form.

Before processing your request, we will need to verify your identity and confirm you are a resident of a jurisdiction that offers such right(s). In order to verify your identity, we will generally either require the successful authentication of your account, or the matching of sufficient information you provide us to the information we maintain about you in our systems. This process may require us to request additional personal information from you. In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to verify your identity or locate your information in our systems. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.

To exercise your right to opt-out: please submit a request, as follows:

Opt-out of data "sales": please submit a request by filling out our Privacy Rights Form

Unless you have exercised your right to opt-out, we may disclose or “sell” your personal information to third parties for monetary or other valuable consideration or use your information for all the purposes described in this Privacy Notice, including for targeted advertising. The third parties to whom we sell or disclose personal information may use such information for their own purposes in accordance with their own privacy statements.

You do not need to create an account with us to exercise your right to opt-out. However, we may ask you to provide additional personal information so that we can properly identify you to track compliance with your opt-out request. We will only use personal information provided in an opt-out request to review and comply with the request. If you choose not to provide this information, we may only be able to process your request to the extent we are able to identify you in our data systems. We may not process your request if we, in good faith, believe that the request is fraudulent. In such instances, we will send a notice to the requestor explaining our decision.

Authorized Agents

In certain circumstances, you may permit an authorized agent to submit requests to exercise your California Privacy Rights on your behalf. The authorized agent must provide a letter signed by you confirming the agent has permission to submit a request on your behalf or must provide sufficient evidence to show that the authorized agent has been lawfully vested with power of attorney.

For security purposes, we may need to verify your identity and confirm directly with you that you have provided the authorized agent permission to submit the request, and it may take additional time to fulfil agent-submitted requests. We may deny a request in the event we are not able to verify the authorized agent’s authority to act on your behalf. Please note that for privacy and security reasons, we will direct future communications to the data subject on whose behalf the request was made.

“Shine the Light” Disclosures

The California “Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. To opt out of this type of sharing, please email us at legal@vantagegrp.com.

Notice of Financial Incentives

In addition, we may offer you financial incentives for the collection, sale, retention, and use of your personal information as permitted by the CCPA that can, without limitation, result in reasonably different prices, rates, or quality levels. The material aspects of any financial incentive will be explained and described in its program terms. Please note that participating in incentive programs is entirely optional, you will have to affirmatively opt-in to the program and you can opt-out of each program (i.e., terminate participation and forgo the ongoing incentives) prospectively by following the instructions in the applicable program description and terms. We may add or change incentive programs, and/or their terms by posting notice on the program descriptions and terms linked to above, so check them regularly.

Each financial incentive or price or service difference related to the collection and use of personal information is based upon our reasonable, good-faith determination of the estimated value of such information to our business, taking into consideration the value of the offer itself and the anticipated revenue generation that may be realized by rewarding brand loyalty. We calculate the value of the offer and financial incentive by using the expense related to the offer.

Minors

We do not sell the personal information and do not have actual knowledge that we sell the personal information of minors under 16 years of age. Please contact us at legal@vantagegrp.com to inform us if you, or your minor child, are under the age of 16.

If you are under the age of 18 and you want to remove your name or comments from our website or publicly displayed content, please contact us directly legal@vantagegrp.com. We may not be able to modify or delete your information in all circumstances.

ADDITIONAL DISCLOSURES for NEVADA Residents (UNITED STATES)

If you are a resident of the State of Nevada in the United States, Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. To submit such a request, please contact us at legal@vantagegrp.comwith the subject line "Nevada Opt-out Request."

ADDITIONAL DISCLOSURES for THE European Economic Area, United Kingdom, and Switzerland

Vantage Group maintains operations in Europe and may direct our services to individuals located in the EEA, UK and Switzerland. In these instances, the following additional disclosures apply to our processing of personal data.

When we use the term “personal data” in this section, we mean information relating to an identified or identifiable natural person.

CONTROLLERS

The Vantage Group controller that is responsible for the processing of your personal information depends on how you interact with the Vantage Group. The controllers will be disclosed at the time of data collection, and include the following:

Vantage Specialties Germany GMBH

Vantage Leuna GmbH

Am Haupttor, Gebäude 7302

06237 Leuna, Germany

Vantage Specialties Spain

Vantage Specialties Spain SLU

C/Girona 34/6th Floor

08402 Granollers, Barcelona

Vantage France S.A.S.

Les Fjords

Immeuble Véga, Bât 2

19 av. de Norvège,

ZA de Courtaboeuf

91140 Villebon-sur Yvette

France

In addition, Vantage is jointly responsible to process your personal data for the following reasons: perform our contractual services, as further described below.

A. LEGAL BASES FOR THE PROCESSING

Regularly, we use your personal data based on the following legal grounds according to the Regulation (EU) 2016/679 (the “EU GDPR”) or, where applicable, the “UK GDPR” as it forms \tpart of the law of England and Wales, Scotland and Northern Ireland by virtue of section 3 of the UK European Union (Withdrawal) Act 2018 GDPR:

Perform our contractual services, including prior to entering into a contract with you: If you order Services from us or if you contact us to request our Services, we use your \tpersonal data to provide you with these Services, including for account and contract management, to facilitate user benefits and services, including customer support, and evaluate your \tcandidacy for employment and to facilitate the onboarding process;

Justified by our legitimate interests: The usage of your personal data may also be necessary for our own business interests. For example, we may use some of your personal data to send gifts to you; market our Services to individuals; administer, improve and personalize our Services, including by recognizing an individual and remembering their information when \tthey return to our Services and analyzing our client-base; Process payment for our Services; conduct market research; opportunity tracking, conversion and lead generation; test, \tenhance, update and monitor the Services, or diagnose or fix technology problems; help maintain the safety, security and integrity of our property and Services, technology assets and \tbusiness; enforce any terms and conditions, resolve disputes, carry out our obligations and enforce our rights, and protect our business interests and the interests and rights of third \tparties; and prevent, investigate or provide notice of fraud or unlawful or criminal activity.

Consent: In some cases, we may ask you to grant us separate consent to use your personal data.

Compliance with legal obligations. We are obligated to retain certain personal data because of legal requirements, for example, tax or commercial laws, or we may be required by law enforcement to provide personal data on request.

We do not use your personal data for automated individual decision-making.

B. HOW LONG WE STORE YOUR PERSONAL DATA

We will usually store the personal data we collect about you for no longer than necessary for the purposes as set above, and in accordance with our legal obligations and legitimate business interests.

The criteria used to determine the period for which personal data about you will be retained varies depending on the legal basis under which we process the personal data:

Contract. Where we are processing personal data is based on contract, we generally will retain your personal data for the duration of the contract plus some additional limited period of time that is necessary to comply with law or that represents the statute of limitations for legal claims that could arise from our contractual relationship.
Legitimate Interests. Where we are processing personal data based on our legitimate interests, we generally will retain such information for a reasonable period of time based on the particular interest, taking into account your fundamental interests and your rights and freedoms.
Consent. Where we are processing personal data based on your consent, we generally will retain your personal data until you withdraw your consent, or otherwise for the period of time necessary to fulfil the underlying agreement with you or provide you with the applicable service for which we process that personal data.
Legal Obligation. Where we are processing personal data based on a legal obligation, we generally will retain your personal data for the period of time necessary to fulfil the legal obligation.
Legal Claim. We may need to apply a “legal hold” that retains information beyond our typical retention period where we face threat of legal claim or intent to establish a claim. In that case, we will retain the information until the hold is removed, which typically means the claim or threat of claim has been resolved.

In all cases, in addition to the purposes and legal bases, we consider the amount, nature and sensitivity of the personal data, as well as the potential risk of harm from unauthorized use or disclosure of your personal data.

C. MARKETING AND ADVERTISING

From time to time we may contact you with information about our services, including sending you marketing messages and asking for your feedback on our Services. Most marketing messages we send will be by email. For some marketing messages, we may use personal data we collect about you to help us determine the most relevant marketing information to share with you.

We may send you marketing messages if you have given us your consent to do so or where we have relied on the soft opt-in rule (where applicable). If you wish to unsubscribe from such communication, please see the details set out in our Privacy Notice under Control Over Your Information.

D. STORING AND TRANSFERRING YOUR PERSONAL DATA

Security. We implement appropriate technical and organizational measures to protect your personal data against accidental or unlawful destruction, loss, change or damage. All personal data we collect will be stored by our cloud hosting provider on secure servers. We will never send you unsolicited emails or contact you by phone requesting credit or debit card information.

International Transfers of your Personal data. The personal data we collect may be transferred to and stored in countries outside the EEA, UK and Switzerland in countries where we and our third-party service providers have operations, including in the United States, where Vantage is located.

In the event of a transfer by Vantage, we ensure that: (i) the personal data is transferred to countries recognized as offering an equivalent level of protection; or (ii) the transfer is made pursuant to appropriate safeguards, such as standard contractual clauses adopted by the European Commission.

If you wish to enquire further about these safeguards used, please contact us using the details set out under the Contact Us section of the Privacy Notice.

E. YOUR RIGHTS IN RESPECT OF YOUR PERSONAL DATA

In accordance with applicable privacy law, you may have the following rights in respect of your personal data that we hold:

Right of access. You have the right to obtain certain information about our processing of your personal data which includes:
- confirmation of whether, and where, we are processing your personal data;
- information about the categories of personal data we are processing, the purposes for which we process your personal data and information as to how we determine applicable retention periods;
- information about the categories of recipients with whom we may share your personal data; and
- a copy of the personal data we hold about you.
Right of portability. You have the right, in certain circumstances, to receive a copy of the personal data you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.
Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal data we hold about you without undue delay.
Right to erasure. You have the right, in some circumstances, to require us to erase your personal data without undue delay, such as if the continued processing of that personal data is not justified.
Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal data, such as where the accuracy of the personal data is contested by you.
Right to withdraw consent. There are certain circumstances where we require your consent to process your personal data. In these instances, and if you have provided consent, you have the right to withdraw your consent at any time. If you withdraw your consent, this will not affect the lawfulness of our use of your personal data before your withdrawal.
You also have the right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal data, and we will assess and inform you if that is the case. You can object to marketing activities for any reason at any time.

You also have the right to lodge a complaint to your local data protection authority. If you are based in the EU, information about how to contact your local data protection authority is available here. If you are based in the UK or Switzerland, your local data protection authorities are the UK Information Commissioner’s Office ( https://ico.org.uk/global/contact-us/) and the Swiss Federal Data Protection and Information Commissioner(https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact/address.html).

If you wish to exercise one of these rights, we kindly ask you to contact us at legal@vantagegrp.com.

Due to the confidential nature of data processing, we may ask you to provide proof of identity when exercising the above rights.

F. COOKIES AND SIMILAR TECHNOLOGIES

Our EEA, UK, and Switzerland Services, including our emails, use cookies and similar technologies such as pixels and Local Storage Objects (LSOs) like HTML5 (together “cookies”) to distinguish you from other users of our Services. This helps us to provide you with a good experience when you use our Services and also allows us to monitor and analyse how you use and interact with our Services so that we can continue to improve our Services. It also helps us and our partners to determine products and services that may be of interest to you. Please see our Cookie Notice for more information about these practices and your choices regarding cookies.

ADDITIONAL DISCLOSURES FOR THE BRAZILIAN RESIDENTS

Vantage Group maintains operations in Brazil and may direct our services to Brazilian residents and/or collect personal information in Brazil. In these instances, the following additional disclosures apply to our processing of personal information.

CONTROLLERS

Vantage Specialty Chemicals Insumos Cosmeticos e Farmaceuticos, Ltda

Avenida Presidente Jusceliono Kubitscheck, 1600 Cj. 132
São Paulo

Brasil SP04543-000
Tel: +55 (11) 2124-5300

A. LEGAL BASIS FOR PROCESSING

Under the Brazilian General Data Protection Law, Law No. 13.709/2018 (“LGPD”), we may also use your personal information based on the following:

when necessary to enter into a contract with you or a legal entity you represent, to perform our contractual obligations, to provide our services, to respond to your requests or to provide you support (customer support);
where we have a legitimate interest, as described in our Privacy Notice (see “HOW WE USE YOUR PERSONAL INFORMATION”);
as necessary to comply with relevant law and legal obligations, including to respond to lawful requests and orders;
for the regular exercise of rights in judicial, administrative or arbitration procedures;
with your consent.

B. YOUR RIGHTS

In accordance with the LGPD, you have the following rights in respect to your personal information:

Confirmation of whether we process your personal information;
If we do have your personal information, you have the right to have access to the data;
You have the right to ask us to correct or update incomplete, inaccurate or outdated information;
You have the right to ask us to anonymize, block or eliminate any unnecessary or excessive personal information, or any personal information processed in non-compliance with the LGPD;
You have the right to data portability, in accordance with national authority regulations;
You have the right to receive information about the public and private entities with which we have shared your personal information (see the “HOW WE SHARE PERSONAL INFORMATION” section of this Vantage Privacy Notice);
If we are processing your personal information on the basis of your consent, you also have the right to (1) be informed about the possibility of not providing consent and consequences of not providing consent, (2) revoke your consent, and (3) ask us to delete your personal information, subject to our rights to retain data as provided by the LGPD; and
You have the right to file a petition against us, as a controller, with the National Data Protection Authority and to oppose data processing in violation of the LGPD.

To exercise these rights, please write to us at the address above, and a member of our Privacy Team will assist you. Please understand that we may need to verify your identity before we can process your request.

Requests made under the data subject’s rights section of the LGPD (Art. 18) are free of charge. Note that your rights under the LGPD are subject to exceptions, as outlined in the LGPD. For example, we may not be able to delete information where we have a legal obligation to maintain it. If we deny your request, we will explain the reasons for doing so.

If you believe that we have processed your personal information in violation of applicable law, you may contact us at legal@vantagegrp.comor you may file a complaint with a supervisory authority.

C. TRANSFERRING YOUR PERSONAL DATA OUTSIDE OF BRAZIL

Vantage is a global business, and your personal information may be transferred to countries with different privacy and data protection laws than your own, including to countries such as the United States. When transferring data across borders, we take measures to comply with applicable data protection laws related to such transfer.

D. DATA RETENTION

We retain your personal data as long as the information is needed for the purposes set forth above and for any additional period that may be required or permitted by law. You may request that we delete your personal information by writing us at the address above. If we do not have a legal basis for retaining your information, we will delete it in accordance with applicable law.

E. HOW TO CONTACT US AND OUR DATA PROTECTION OFFICER

If you have any questions about this Privacy Notice or about how we process your personal information, please contact us at legal@vantagegrp.com.

Additional DISCLOSURES for THE PEOPLE’S REPUBLIC OF CHINA (EXCLUDING HONG KONG, TAIWAN, AND MACAU)

This section applies to you if: (i) your personal information is processed within the territory of the People’s Republic of China (excluding Hong Kong, Macau and Taiwan, “China”), or (ii) you are within the territory of China and your personal information is processed outside of China for the purposes of providing goods or services to you, or analyzing or evaluating your behaviors. PRC law requires us to disclose certain information set forth below.

When we use the term “personal information” in this section, we mean information relating to an identified or identifiable natural person recorded electronically or by other means, excluding anonymized information.

PERSONAL INFORMATION PROCESSORS

The Vantage Group personal information processor that is responsible for the processing of your personal information depends on how you interact with the Vantage Group. The personal information processors will be disclosed at the time of data collection, and include the following:

Vantage Specialty Ingredients (Shanghai) Co., Ltd

Rm 302, BLDG B, Hongqiao Oriental Commercial Plaza,

No.388, North Fu Quan Rd, Shanghai China 200335

In addition, Vantage is jointly responsible for processing your personal information to perform our contractual services, as further described below.

PROCESSING OF SENSITIVE PERSONAL INFORMATION

Under the Personal Information Protection Law of China (the “PIPL”), sensitive personal information includes information such as biometrics, religious beliefs, race, ethnicity, medical health, financial accounts, and location tracking, as well as the personal information of minors under the age of 14 (“Minor(s)”). For example, we may process your sensitive personal information to process your payment for our Services. We may process certain of your sensitive personal information only when we have your consent or another legal basis to do so. Where your consent is the legal basis for processing your sensitive personal information, we will seek your prior consent separately.

Our Services are not directed to, and we do not intend to, or knowingly, collect or solicit personal information from Minors under the age of 14. If an individual is a Minor, they should not use our Services or otherwise provide us with any personal information either directly or by other means. If a Minor has provided personal information to us, we encourage the Minor’s parent or guardian to contact us to request that we remove the personal information from our systems. If we learn that any personal information we collect has been provided by a Minor, we will promptly delete that personal information.

A. Legal Bases for the Processing

Regularly, we use your personal information based on the following legal grounds according to the PIPL:

Perform our contracts (including our Terms and Conditions) with you, including prior to entering into a contract with you: If you order Services from us or if you contact us to request our Services, we use your personal information to provide you with these Services, including for account and contract management; for opportunity tracking, conversion and lead generation; to administer, improve and personalize our Services, including by recognizing an individual and remembering their information when they return to our Services; to analyze our client-base; to facilitate user benefits and services; to process payment for our Services; to test, enhance, update and monitor the Services, or diagnose or fix technology problems; to help maintain the safety, security and integrity of our property and Services, technology assets and business; to provide customer support; to resolve disputes; to carry out our obligations and enforce our rights, and protect our business interests and the interests and rights of third parties; and to evaluate your candidacy for employment and to facilitate the onboarding process;

Consent: In some cases, we may ask you to grant us separate consent to use your personal information. For example, upon your consent, we may use some of your personal information to send gifts to you; market our Services to individuals; and conduct market research.

Compliance with legal obligations or legal responsibilities. We are obligated to retain certain personal information because of legal requirements, for example, tax or commercial laws, to prevent, investigate or provide notice of fraud or unlawful or criminal activity, or we may be required by law enforcement to provide personal information on request.

Response to an emergency. We may collect and process your personal information in order to respond to a public health emergency or to protect a natural person’s life, health, property and safety in an emergency.

Reasonable processing of legitimately published personal information. We may reasonably process your personal information that has been published by you or otherwise has been published legitimately.

We do not use your personal information for automated individual decision-making.

B. HOW LONG WE STORE YOUR PERSONAL INFORMATION

We will usually store the personal information we collect about you for no longer than necessary for the purposes as set above, and in accordance with our legal obligations and our contracts with you.

The criteria used to determine the period for which personal information about you will be retained varies depending on the legal basis under which we process the personal information:

Contract. Where we are processing personal information is based on contract, we generally will retain your personal information for the duration of the contract plus some additional limited period of time that is necessary to comply with law or that represents the statute of limitations for legal claims that could arise from our contractual relationship.
Consent. Where we are processing personal information based on your consent, we generally will retain your personal information until you withdraw your consent, or otherwise for the period of time necessary to fulfil the underlying agreement with you or provide you with the applicable service for which we process that personal information.
Legal Obligation or Responsibility. Where we are processing personal information based on a legal obligation or responsibility, we generally will retain your personal information for the period of time necessary to fulfil the legal obligation.
Legal Claim. We may need to apply a “legal hold” that retains information beyond our typical retention period where we face threat of legal claim or intent to establish a claim. In that case, we will retain the information until the hold is removed, which typically means the claim or threat of claim has been resolved.

In all cases, in addition to the purposes and legal bases, we consider the amount, nature and sensitivity of the personal information, as well as the potential risk of harm from unauthorized use or disclosure of your personal information.

C. MARKETING AND ADVERTISING

From time to time, we may contact you with information about our services, including sending you marketing messages and asking for your feedback on our Services. Most marketing messages we send will be by email. For some marketing messages, we may use personal information we collect about you to help us determine the most relevant marketing information to share with you.

D. STORING AND TRANSFERRING YOUR PERSONAL INFORMATION

Security. We implement appropriate technical and organizational measures to protect your personal information against accidental or unlawful destruction, loss, change or damage. All personal information we collect will be stored by our cloud hosting provider on secure servers. We will never send you unsolicited emails or contact you by phone requesting credit or debit card information.

International Transfers of your Personal information. The personal information we collect may be transferred to and stored in countries outside China where we and our third-party service providers have operations, including in the United States, where Vantage is located.

In the event of a transfer by Vantage, we ensure that the transfer is made in compliance with the PIPL, including that the recipient has signed a standard contract issued by the Cyberspace Administration of China.

E. YOUR RIGHTS IN RESPECT OF YOUR PERSONAL INFORMATION

In accordance with applicable privacy law, you may have the following rights in respect of your personal information that we hold:

Right to Know and Decide. You have the right to know and to decide about processing of your personal information unless the law provides otherwise. For example, we may be obligated by law to keep certain information confidential or may be exempted from notification under certain circumstances. You also have the right to request that we explain our rules with regards to the processing of your personal information.
Right to Restrict or Object. You have the right to restrict or object to any processing of your personal information unless the law provides otherwise. For example, you may not be able to restrict or object to processing that is made on a legal basis other than your consent.
Right to Access and Reproduce. You have the right to access your personal information or to obtain a copy of your personal information unless we are obligated by law to keep certain information confidential.
Right to Transfer. You have the right to transfer your personal information to another processor appointed by you, provided that the transfer meets the requirements set forth by the Cyberspace Administration of China.
Right to Rectification and Supplement. You have the right to have your personal information rectified or supplemented where that personal information is inaccurate or incomplete.
Right to Erasure. You have the right to request the erasure of your personal information.However, if we are obligated by law to retain your personal information for a longer period of time, or it is technically unfeasible to erase your personal information, we will retain your personal information with necessary security protection measures and will not otherwise process your personal information.
Right to withdraw consent. There are certain circumstances where we require your consent to process your personal information. In these instances, and if you have provided consent, you have the right to withdraw your consent at any time. If you withdraw your consent, this will not affect the lawfulness of our use of your personal information before your withdrawal.

In some cases, our ability to uphold these rights for you may depend upon our obligations to process personal information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.

Please also note that after an individual passed away, their next of kin may be able to exercise the individual rights of the deceased in accordance with law.

You also have the right to lodge a complaint with a competent personal information protection authority.

If you wish to exercise one of these rights, we kindly ask you to contact us at legal@vantagegrp.com.

Due to the confidential nature of data processing, we may ask you to provide proof of identity when exercising the above rights.

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