Privacy policy
Welcome to www.spectroalloys.com (“website”), which is owned and operated by Spectro Alloys LLC, a subsidiary of Emirates Global Aluminium PJSC (“EGA”). This Privacy policy explains how Spectro Alloys LLC (“Spectro” “we,” “our,” or “us”) use your personal data when you interact with us, including your interactions with our website. It also describes the rights that you have and the steps that we take to keep your personal data safe.
If you have any questions about the content of this Privacy policy, you can contact us by using the details provided in the ‘Contact us’ section at the bottom of this page.
If you are a California resident, please review this Privacy policy and the below section, ‘Additional Information for California Residents’ for additional disclosures, our Notice at Collection, and a description of your rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (with any implementing regulations and as may be amended from time to time, “CCPA”). To exercise your right to opt out of the “selling” or “sharing” of “personal information,” all as defined in the CCPA, please review the section ‘Additional Information for California Residents.’
What personal data do we process, and what reasons do we process it for?
Depending on how you interact with us, we may collect personal data directly from you when you visit our website or otherwise interact with us, including when you visit our site and offices. “Personal data” for the purposes of this Privacy policy means any information that can help us directly or indirectly identify you.
When you browse our website
When you use this website, we use cookies and other online tracking technologies to record:
- the areas of the website that you visit; and
- information about your computer, such as which browser you are using, your network location, the type of connection you are using (e.g., broadband, ADSL etc.) and your IP address.
We do this so that we can collect and analyze information on our website’s performance, which helps us to develop and improve the site, and to allow us and our partners to show you relevant advertisements when you visit our website and other third-party websites, including social networks. Processing your personal data for these purposes is based on your consent, unless the cookies are strictly necessary to the website’s functionality.
We may use third-party web analytics services on the website, including Google Analytics. We use Google Analytics to help us understand how people are using our website. To find out more about how Google Analytics collects and processes data, please click here. Google Analytics has its own cookies that it uses to track and aggregate this information. You can prevent the use of Google Analytics relating to your use of our website by downloading and installing the browser plugin available here.
Some web browsers may transmit “do not track” (“DNT”) signals. We currently do not respond to DNT settings in your web browser.
You can control which cookies you consent to through the cookie banner on our website, or by visiting the Cookie Policy, which also provides more information on how we use cookies, and how you can opt out of them.
When you submit an inquiry
If you submit an inquiry, either through this website, through another contact option (such as a contact email address or telephone number), or directly to one of our employees, we will process your personal data for the purposes of responding to, and managing, your query.
The personal data we process for these purposes includes your name and contact details, including your email address and telephone number, as well as any other personal data that you provide when you submit your inquiry.
When you are in contact with us as part of your role as an employee of one of our partners
If you are communicating with us on behalf of your employer, we will process your personal data so that we can manage the relationship with your employer, such as administering any orders that have been, or will be, placed. This includes activities such as emailing or calling us to discuss orders that have been placed for our products, or discussing our products in meetings and at trade shows.
The personal data we process for these purposes includes your name and contact details, including your email address and telephone number.
When you visit our site and offices
When you visit our site and offices, we will process your personal data for the purposes of ensuring the safety and security of you, other visitors, and our staff.
We also use personal data of visitors to accurately identify them upon arrival at our site. The personal data we process for these purposes includes images, such as through the use of CCTV cameras, as well as your name and contact details.
When you submit a complaint
If you make a complaint to Spectro, either through this website, through another contact option (such as a contact email address or telephone number), directly to one of our employees, or to a relevant authority, we will process your personal data for the purposes of investigating and managing your complaint.
To comply with legal or regulatory obligations
In some circumstances, Spectro may be obliged to process your personal data for the purposes of complying with legal and regulatory requirements applicable to Spectro’s business, such as record-keeping and reporting obligations, conducting audits, compliance with government inspections and other requests from government or other public authorities.
For marketing and research purposes
We will process your personal data for the purposes of sending you marketing materials when you sign up to receive marketing communications from us.
We may also process your personal data to seek your input into market research that we are conducting.
The personal data we process for these purposes includes your name and contact details, including your email address and telephone number.
To improve our products and services
In some circumstances, we will use your personal data to help improve our products and services. This may involve conducting analytics to understand how we have performed in delivering our services to you, and reviewing how we can improve for the future.
This may require us to process personal data you have provided to us, such as your contact details or information relating to queries and complaints.
When you engage with us on social media
When you interact with us on social media, such as by liking or commenting on posts made by us, we are able to view the personal data that you have made publicly available, such as your name, profile picture and comment, and will process this personal data to respond and interact with you accordingly.
To protect Spectro from fraud and other illegal activities
Spectro uses personal data in order to maintain a safe environment for our partners and employees, and to protect the interests of Spectro’s shareholders and the wider public. This includes, for example, monitoring the emails that are sent to Spectro email accounts to detect fraud and phishing attempts.
The personal data we process for these purposes includes your name and contact details, including your email address and telephone number.
Who do we share your information with?
We share your personal data with trusted third parties who perform functions on our behalf and who also provide services to us, such as professional advisors, IT consultants carrying out testing and development work on our business technology systems, research, media and mailing houses and function coordinators.
We may also share your personal data with EGA and its other subsidiaries for internal reasons, primarily for business and operational purposes. To find out more about the companies within the EGA group that may handle your personal data please click here.
As we continue to develop our business, we may sell or purchase assets. If another entity acquires us or merges with us your personal data will be disclosed to such entity. Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such information will be considered an asset of ours and as such it is possible they will be sold or transferred to third parties.
As is noted above, we may also need to share your personal data with third parties when we are obliged to do so, or where it is necessary to protect our interests: to comply with a legal obligation; when we believe in good faith that an applicable law requires it; at the request of government authorities conducting an investigation; to verify or enforce our website Terms and conditions or other applicable policies; to detect and protect against fraud, or any technical or security vulnerabilities; to respond to an emergency; or otherwise to protect the rights, property, safety, or security of third parties, visitors to our website, our business or the public; or auditing purposes.
We make best efforts to ensure we have confidentiality agreements in place with the parties with whom we share information and they comply with information protection requirements of Spectro.
Please note that for purposes of this section, “sharing” does not include “sharing” as defined under the CCPA. For additional disclosures and information on our CCPA practices, please review ‘Additional Information for California Residents’ below.
Transfers of your personal data outside of your home country
Your personal data may be processed by Spectro and those other parties described above, outside the country in which you are based, including the United States, where we are based. Please be aware that data protection laws may be different from those of your country of residence.
If your personal data is transferred to another country, to the extent required by applicable law, we will ensure that there are adequate mechanisms in place to protect your personal data. This includes the use of data transfer agreements and implementing standard data protection clauses where appropriate to help ensure that your personal data is subject to the same standards of protection as it is in your own country.
Security
We are committed to ensuring that your personal data is kept secure. In order to prevent unauthorized access or disclosure we have put in place suitable physical, electronic and administrative procedures to safeguard and secure the information we collect.
If at any point you suspect or become aware of a security incident (e.g., you receive a suspicious communication from someone holding themselves out to be a Spectro or EGA employee or from an unauthorized website claiming to be affiliated with Spectro or EGA), please report the incident by email to info@spectroalloys.com as soon as possible.
How long will we keep your personal data?
We will only keep your personal data for the period necessary to fulfil the purposes outlined above. The retention period for personal data will be determined by various criteria, including the purposes for which we are using it (as it will need to be kept for as long as is necessary for any of those purposes) and our legal obligations (as laws or regulations may set a minimum period for which we have to keep your personal data). In general, we will retain your personal data for as long as we require it to perform our contractual rights and obligations or for periods required by our legal and regulatory obligations.
What are your rights?
By law, you may have certain rights when it comes to your personal data. These rights vary depending on the country or state that you are located in, but they generally include:
- Opt-Out of Receiving Marketing Emails. You can request that we send you marketing information and sign up for electronic newsletters about our products. You can also request that we stop sending you marketing or other promotional communications through the opt-out link in any of these communications, or by using the information provided in Contact us.
- Access Personal Data and Obtain a Copy of Personal Data. You can confirm whether or not we are processing personal data about you, access such personal data, and obtain a copy of such personal data.
Correct Your Personal Data. You can review and edit the personal data we process about you by contacting us using the information provided in Contact us. - Delete Your Personal Data: In certain circumstances you can delete the personal data that we process about you.
- Opt-out: In certain circumstances, you have the right to opt out of the processing of your personal data for purposes of targeted advertising, the sale of personal data, or profiling in furtherance of automated decisions that produce legal effects concerning you or similarly significant effects concerning you.
- Control Cookies. As noted in our Cookie Policy, you can control the cookies and similar technologies used on our Services through your browser or device settings as well as the methods described in that same section.
You may be permitted by law to authorize someone else to act as your agent to exercise some of your rights on your behalf. In such cases, your authorized agent must provide documentation supporting his or her authority to make this request on your behalf. In some cases, we may also require you to verify your identity directly with us and confirm the request before we process it.
For your protection, we take reasonable steps to verify all requests before they are processed. This may include, for example, a request from us for you to confirm your identity, to validate documents you submit to us, to verify your authority to make the request, or for other purposes. In all cases, we reserve the right to deny your request in accordance with applicable law if we cannot verify you or your authority to make the request.
If we decline to take action regarding your request, you may have the right to appeal. Please contact us at info@spectroalloys.com if you would like to submit such an appeal.
Additionally, you may contact your state’s attorney general (see information listed below) if you have concerns about the results of the appeal.
If you are a California resident, please see ‘Additional Information for California Residents’ below for a description of your rights under the CCPA and how to exercise them.
Linking to other websites
Our website or marketing email messages sometimes include links to other websites that are not within our control. Once you have left our website/marketing email message, we cannot be held responsible for the content of other websites or the protection and privacy of any information that you provide to those websites. You should exercise caution and look at the Privacy policy applicable to the website in question.
How to find out more about our website
For more information, you can view our website Terms and conditions which explain the terms on which you are allowed to use our website https://www.spectroalloys.com, which provides a gateway to our products and services, as well as other useful information about Spectro here.
Children’s information
We do not knowingly solicit or collect personal data from children under 18. If you are a parent or guardian and believe that we have inadvertently collected personal data from a child under 18 years old, please contact us using the information provided in ‘Contact us’ below. We will delete such information within a reasonable time.
Additional information for California residents
California Civil Code Section 1798.83 permits the users of the website who are California residents to request certain information regarding our disclosure of personal data to third parties for their direct marketing purposes. To make such a request, please contact us at info@spectroalloys.com.
The CCPA imposes certain obligations on us and grants certain rights to California residents (“California Resident,” “you,” or “your”) with regard to “personal information.” If you are a California Resident, please review the following information about our privacy practices surrounding how and why we collect, use, disclose, and share your personal information and your potential rights with regard to your personal information under the CCPA. The rights described herein are subject to exemptions and other limitations under applicable law.
Terms used in this California-specific section have the meaning ascribed to them in the CCPA.
Personal Information we collect
Depending on how you interact with us, we may collect certain categories of personal information form or about you:
- Identifiers and similar information such as, name, address, date of birth, email address, social security number, driver’s license number, tax identification number, passport number, online identifiers or other similar identifiers.
- Additional information subject to California Civil Code Section 1798.80(e), such as a signature, education information, state identification number, credit card, bank account, assets, account balances, wire instructions, or other financial information.
- Characteristics of protected classifications under certain federal or state laws, including gender, national origin, or marital status.
- Commercial information, including records of products or services purchased, obtained, or considered, or other purchasing histories or tendencies.
- Audio, electronic, visual, or similar information.
- Professional or employment-related information, including, not by way of limitation, occupation, employer, and title.
- Internet or other electronic network activity information, including interactions with our website or use of certain online tools, and IP addresses.
- Inferences drawn from any of the information identified above to create a profile reflecting your preferences or similar information.
- Sensitive personal information under the CCPA such as your passport number, driver’s license, state identification card, and citizenship and immigration status.
Purpose for collection and use of information
We may collect and use your personal information for the purposes listed above in ‘What personal data do we process, and what reasons do we process it for?’
How long we keep information
We retain your personal information as described above in ‘How long will we keep your personal data?’
Sales or sharing of personal information
In the preceding 12 months, we have sold or shared the following categories of personal information for the purpose of advertising and analysis:
- Identifiers; and
- Internet or other similar network activity.
To exercise your right to opt out of the “sale” or “sharing” of your personal information, visit My privacy choices and select “Reject all” or use the toggles to choose which categories of cookies to “opt out” from.
We do not knowingly sell or share the personal information of California residents under 16 years of age.
For more information about our privacy practices, please review our entire Privacy policy above.
Our collection, use and disclosure of personal information and sensitive personal information
Information we have collected, the sources from which we collect it and our purpose for collecting it
In the preceding 12 months, and depending on how you interact with us, we may have collected the categories of personal information from the categories of sources listed above in ‘Personal information We Collect.’ We may have collected all or a few of these categories of personal information for the business or commercial purposes identified in ‘What Personal Data Do We Process, and What Reasons Do We Process It For?’
Disclosure of personal information
In the preceding 12 months, we may have disclosed for a business purpose the following categories of personal information to the following categories of third parties, as described in the following chart:
|
Category of personal information |
Category of third party |
|
Identifiers (for example your name, address, DOB, SSN, driver’s license, passport number and online identifiers) |
|
|
Additional information subject to Cal. Civ. Code § 1798.80(e) (for example, a signature, state identification card number) |
|
|
Characteristics of protected classifications under certain federal or state laws (for example gender, age, national origin, citizenship or marital status) |
|
|
Commercial Information (for example records of products or services purchased, obtained or considered or purchasing histories or tendencies) |
|
|
Internet or Electronic Network Activity Information, including interactions with our website or use of certain online tools |
|
|
Audio (e.g., voicemail), electronic, visual or similar information
|
|
|
Professional or Employment Related Information, including occupation, compensation, employer and title |
|
|
Inferences drawn from any of the information identified above to create a profile reflecting your preferences or similar information |
|
In addition, we may disclose and, in the preceding 12 months, we may have disclosed all of the categories of personal information identified in ‘Personal information We Collect’ above, to the following categories of third parties: (i) judicial courts, regulators, or other government agents purporting to have jurisdiction over us, our subsidiaries or our affiliates, or opposing counsel and parties to litigation; (ii) any relevant third party acquirer(s), in the event that we sell or transfer all or any relevant portion of our business or assets; and (iii) other third parties as may otherwise be permitted by law. We may also transfer to another entity or its affiliates or service providers some or all information about you in connection with, or during negotiations of, any merger, acquisition, sale of assets or any line of business, change in ownership control, or financing transaction. We may disclose personal information to all of the third parties listed above to comply with our legal obligations or for the business or commercial purposes identified above in ‘What personal data do we process, and what reasons do we process it for?’ Additionally, we may disclose your personal information to third parties upon your request, at your direction or with your consent.
We may disclose or make available your personal information with our service providers such as our IT providers, or CRM provider, other entities that have agreed to limitations on the use of your personal information, or entities that fit within other exemptions or exceptions in, or as otherwise permitted by, the CCPA.
Use and disclosure of sensitive personal information
As noted above in ‘Personal information We Collect,’ under the CCPA, certain personal information we collect and process may be considered “sensitive personal information.” The CCPA requires that we provide you with a right to limit our use or disclosure of such sensitive personal information in certain circumstances. Currently, we are not using your sensitive personal information for purposes that would require that we provide you with a right to limit.
California residents’ rights under the CCPA
The CCPA provides consumers with specific rights regarding their personal information, subject to applicable exemptions and limitations. Specifically, consumers may have the right to:
- Be informed, at or before the point of collection, of the categories of personal information to be collected and the purposes for which the categories of personal information shall be used;
- To know what personal information we have collected about you in the preceding 12 months, including: the categories of personal information; the categories of sources from which the personal information is collected; the business or commercial purpose for collecting, selling, or sharing personal information and/or sensitive personal information; the categories of third parties to whom we disclose personal information; and the specific pieces of personal information we have collected about you (“Right to Access”).
- Not to receive discriminatory treatment by us for the exercise of privacy rights conferred by the CCPA, including, not by way of limitation, an employee’s, a job applicant’s, or an independent contractor’s right not to be retaliated against for the exercise of their CCPA rights (“Right to Non-Discrimination”);
- Request that we delete any personal information about you that we collected or maintained, subject to certain exceptions (“Right to Delete”);
Opt-out of the “sale” (as that term is defined in the CCPA) of your personal information if a business sells your personal information;
Opt-out of the “sharing” (as that term is defined in the CCPA) of your personal information if a business shares your personal information with third parties; - Limit the use and disclosure of sensitive personal information (“Right to Limit”) (please note that we are not using your sensitive personal information for purposes that would require that we provide you with a Right to Limit);
- Correct inaccurate personal information (“Right to Correct”); and
- Request that we, as a business that collects personal information about you and that discloses, sells or shares your personal information provide you with certain information about such activities (“Request to Know”).
How to submit a request under the CCPA
You or your authorized agent may submit a Request to Know, Request to Correct or a Request to Delete (“Consumer Rights Request”), as described above, through the following toll-free telephone number +1-651-437-2815, by emailing us at info@spectroalloys.com with “CCPA Rights Request” in the subject line, or through our website at the following link.
We are only required to respond to verifiable Consumer Rights Requests made by you or your authorized agent. When you submit a Consumer Rights Request, we may ask that you provide clarifying or identifying information to verify your request. Such information may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, your name and email address. Any information gathered as part of the verification process will be used for verification purposes only.
You are permitted to designate an authorized agent to submit a Consumer Rights Request on your behalf and have that authorized agent submit the request through the provided methods. We may deny requests from authorized agents who do not submit proof that they have been authorized by you to act on your behalf. We may also require that you directly verify your own identity with us and directly confirm with us that you provided the authorized agent permission to submit the request.
We will provide you with confirmation of our receipt of your request within 10 business days. We will work diligently to satisfy your request within 45 calendar days, and we may request up to an additional 45 calendar days to honor your request, depending on its complexity.
If we decline to take action regarding your request, you may have the right to appeal. Please contact us at info@spectroalloys.com if you would like to submit such an appeal.
Additionally, you may contact the California Privacy Protection Agency if you have concerns about the results of the appeal.
Contact us
If you have questions or concerns about this Privacy policy or about the processing of your personal data, or need additional information, please contact us at info@spectroalloys.com.
This Privacy policy is available in alternative formats upon request. Should you have any questions regarding our policies or about this notice, or to request this Privacy policy in an alternative format, please contact info@spectroalloys.com.
Changes to this Privacy policy
We will regularly review and update this Privacy policy when changes are made to the ways in which we process personal data.