Stepan Company Website Privacy Statement

Last Modified: October 2018

Introduction

Thank you for visiting the Stepan Company (“Company”, “we”, “our”, “us”) website. The following Privacy Statement (“Privacy Statement”) outlines the types of information we collect from you (“you”, “user”) or that you may provide when you access and use the English version of www.stepan.com (including any sites available through stepan.com, such as http://alkoxylates.stepan.com/, collectively, the “Website”) and our practices for collecting, storing, using, sharing and disposing of that information, as well as advises you of ways in which you can exercise your rights under the European Union’s General Data Protection Regulation (“GDPR”). We use your personal data as disclosed in this Privacy Statement for legitimate interests of operating our business, providing you goods and services, and communicating with you per your requests as is lawful for purposes such as processing your personal data.

This Privacy Statement applies to information collected through the Website. It does not apply to information collected by:

• us offline or through any other means, including on any other website operated by the Company or its subsidiaries or affiliates; or 

• any third party or business partner, including any third-party sites accessed via links from the Website (such as the Careers or Investor Relations pages) or third-party sites containing links to the Website.

Please read this Privacy Statement carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use the Website. By accessing or using the Website, you agree to this Privacy Statement and the terms and conditions set forth on the General Terms of Use (the “Terms”) page, which can be accessed via the link displayed at the bottom of the Website.

In the case of conflicts in translation with any other language, the English version of the Privacy Statement and Terms will prevail.

Data Controller: Who We Are

The Company is responsible for this Privacy Statement. The Company is a “Controller” for purposes of processing “personal data” and as “Controller” is defined in the GDPR. We are responsible for operating and maintaining the Website. Any trusted third parties with which we share your personal data as described in this Privacy Statement are “Processors” as that term is defined in the GDPR. The Company and its servers are located in the United States; therefore, if you access the Website from outside of the United States, please be advised that your information will be “processed” (as defined in the GDPR) in the United States.

Goods and Services: What We Offer

The Website provides information about our products, markets and company. It allows users to contact us, connect on social media, request product samples and literature, view product information, locate sales offices and apply to work for the Company. It does not allow you to purchase products or services offered by the Company.

Personal Data: What We Collect

We collect several types of information from and about users of the Website, both:

• Directly from you when you provide it to us; and
• Automatically as you navigate through the Website.

Information You Provide to Us

The information we collect on or through the Website may include:

• Information that you provide at the time of registering to use the Website, or when contacting us through the Website, including first and last name, e-mail address, phone number, title, company name and your location (address and/or country, and where applicable, overnight carrier tracking numbers) (collectively, “Contact Information”)
• E-mail correspondence with us
• Your responses to surveys that we might ask you to complete
• Your search queries on the Website

Information We Collect through Automatic Data Collection Technologies

As you navigate the Website, we may use automatic data collection technologies to collect details of your visits to the Website, including:

• Last visit date
• IP address
• Accessed PDFs and other files
• Website searches
• Website pages and media viewed
• Emails opened
• Links clicked
• Date and time of log in and log out

Do Not Track Disclosure

Certain cookies on the Website may track personal data across third party systems or sites; however the Website is not configured to alter its behavior based on the receipt of Do Not Track headers if a user’s web browser is configured to send such headers.

Purposes: Why We Need Your Personal Data

We use your Contact Information in order to:

• Provide you with access to the Website and its contents
• Communicate with you, respond to your inquiry or fulfill your request
• Allow you to participate in any interactive features on the Website
• Properly manage your account
• Understand your interactions with the Company, whether through the Website, other websites or offline

We collect other data about your activity on the Website, such as pages and media viewed, login data, and your Website searches to improve the Website and our products and services. We may combine Website data with other data we receive from or about you, such as your attendance at trade shows or your social media engagement with the Company. We use this information for internal business purposes and may share this information with trusted third parties to respond to your requests or provide you with additional information or content.

We may use your personal data in any other way we may describe when you provide the information, or for any other purpose with your consent.

Marketing Purposes

We may use your personal data to contact you for the purpose of marketing Company products or services. You will always have the opportunity to opt out of further marketing communications by following the link provided in any such communication or responding with a request to the Company to unsubscribe from future marketing communications. Please note that the Company retains your personal data, even if you opt out of further marketing communications, for the Company’s internal business purposes, including any future marketing communications you may request. Accordingly, we do not delete your personal data following an opt-out request. Please see the “Retention: How Long We Keep Your Personal Data” section below.

You Can Choose to be Contacted or Not

During the Website registration process, you are given the option to decline receiving correspondence as a result of your Website registration. You can update this flag using the Email Preferences page. If your email doesn't automatically populate in the Email Preferences page, this indicates that you have not signed up for marketing emails and do not need to take further action to remove yourself from email communications. However, if you believe Stepan has collected your information elsewhere on the site (e.g. you've ordered a sample in the past or previously applied for a job), please contact us at dataprivacy@stepan.com to remove your information.

We will not distribute your personal data to third parties for the purposes of marketing third party products to you without obtaining your consent in advance.

Processing: What We Do with Your Personal Data

We may disclose aggregated (non-personally identifiable) information about our users without restriction.

We may share personal data with trusted third parties in the United States and brand agencies for purposes of assisting us with our marketing. Any sharing of personal data with third parties is subject to a written agreement and strictly for the purposes of maintaining and operating the Website and assisting the Company’s marketing efforts.

While unlikely, we may disclose or transfer your personal data to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data collected by the Website is among the assets transferred. In such an event, we will provide you notice of any such transition and update this Privacy Statement accordingly.

We may otherwise disclose your personal data only:

• With your informed consent
• For the purposes disclosed to you in this Privacy Statement or the Website
• To comply with the law, enforce the Terms, or if disclosure is otherwise necessary or appropriate to protect the rights, property, or safety of the Company, its subsidiaries, affiliates, customers, or others

Data Security

Processing of personal data happens in strict accordance with our Company’s data governance program. We have put in place commercially reasonable and appropriate administrative, technical and physical procedures to safeguard the information that you provide or that is collected by the Website against unauthorized use, disclosure or destruction. The Website is hosted by the Company in the United States. If you access other websites (for example, the Careers or Investor Relations pages) through the Website, you should review the applicable terms and privacy and data security policies of those websites before you access them.

You are responsible for maintaining the confidentiality of your Website account and password and for restricting access to your computer. Although we do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to the Website. Any transmission of personal data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Cookies

The Website uses cookies in accordance with its Cookie Policy.

Retention: How Long We Keep Your Personal Data

We retain your personal data as required to process it in accordance with the purposes described in this Privacy Statement, including the Company’s ongoing internal business purposes, which include being able to measure and analyze sample order related metrics and trends over time, prepopulate fields on the Website with your account information and track historical sample orders and shipments, and the Marketing Purposes described above. If you are an E.U. user, see the “Visitors and Users in the E.U.: What Are Your Rights?” section below for more information about your rights.

Children

The Website is not for use by children (anyone under the age of 18), and we do not knowingly collect registration data from children. We take commercially reasonable steps to ensure that any requests for samples are not shipped to children.

Visitors and Users in the E.U.: What Are Your Rights?

If you are a Website visitor or user in the European Union, you are afforded additional rights under the law. You can exercise any of the following rights by directly making changes in your account or notifying us as described below. We cannot delete your personal data except by also deleting your user account, which will require you to re-register should you choose to access our PDFs in the future. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. If making a change to your personal data would be administratively burdensome, we may instead choose to delete your user account.

• Access.   You can access and verify what personal data the Website has collected and currently contains by logging into your account and visiting your account profile page.
• Correction or Rectification.   If any of your personal data is incorrect, you may change or request that your personal data be corrected by submitting a request as described below. Where applicable, we will ensure such changes are shared with any trusted third parties.
• Restrict Processing.   When applicable, you may restrict the processing of your personal data through the Website by submitting a request via email as described below. When such restrictions are not possible, we will advise you accordingly. You can then choose to exercise any other rights under this Privacy Statement, to include withdrawing your consent (resulting in deleting your account and any associated personal data). Where applicable, we will ensure such changes are shared with any trusted third parties.
• Object to Processing.   When applicable, you have the right to object to the processing of your personal data by submitting a request via email as described below. When such objections are not possible, we will advise you accordingly. You can then choose to exercise any other rights under this Privacy Statement, to include withdrawing your consent (resulting in deleting your account and any associated personal data). Where applicable, we will ensure such changes are shared with any trusted third parties.
• Portability.   Upon request, and when possible, we can provide you copies of your personal data. When such a request cannot be honored, we will advise you accordingly. You can then choose to exercise any other rights under this Privacy Statement, to include withdrawing your consent (resulting in deleting your account and any associated personal data). Where applicable, we will ensure such changes are shared with any trusted third parties
• Withdraw Consent.   At any time, you may withdraw your consent to our processing of your personal data by notifying us at dataprivacy@stepan.com. Using the same email address associated with your account, simply type the words “WITHDRAW CONSENT” in the subject line of an email and send it to the email address below.
  Upon receipt of such a withdrawal of consent, we will confirm receipt, proceed to stop processing your personal data and erase your data (and delete your account and any associated personal data) in accordance with this Privacy Statement. Where applicable, we will ensure such changes are shared with any trusted third parties.
• Erasure.   If you should wish to cease use of your account and have your personal data deleted from the Website, please notify us at the email address below. We will confirm receipt and erase your personal data (and delete your account and any associated personal data). Where applicable, we will ensure such changes are shared with any trusted third parties.
• Submit complaints or questions.   If you wish to raise a complaint on how we have handled your personal data, you can contact us as described below. If you reside in an E.U. member state, you may also lodge a complaint with the supervisory authority in your country.

Will this Privacy Statement Change?

This Privacy Statement may change from time to time. Your continued use of the Website after we make changes is deemed to be acceptance of those changes, so please check this Privacy Statement periodically for updates. It is our policy to post any changes we make to this Privacy Statement on this page with a notice on the Website home page that the Privacy Statement has been updated. If we make material changes to how we treat users’ personal data, we will notify you by e-mail to the e-mail address specified in your account and/or through a notice on the Website home page. You are responsible for ensuring we have an up-to-date active and deliverable e-mail address for you, and for periodically visiting the Website and this Privacy Statement to check for any changes.

How Can I Get Help?

To ask questions or comment about this Privacy Statement and our privacy practices, contact us at:

dataprivacy@stepan.com
Stepan Company
22 West Frontage Road
Northfield, Illinois, USA 60093