MCL Industries provides this website under the web address www.mcl.bz (this “website”).  While being operated and managed solely by MCL Industries, the website provides information on products and services of MCL Industries (“MCL”).  In context with the website and the services provided on the website, personal data are processed.  MCL is committed to protecting the privacy and security of its online visitors.  MCL has created this Privacy Statement to inform our online visitors on our policy regarding the information gathering activities of mcl.bz. 

In this Privacy Statement, we will inform you of:

• What personal data we collect about you
• How we collect your personal data
• How we use your personal data
• The basis on which we use your personal data
• Who we share your information with
• How long your personal data will be kept
• Transfers of your personal data, particularly transfers of personal data of persons residing in the EU to recipient outside of the EU and what safeguards are applied to protect your data during such transfers
• The steps we take to protect your personal data
• The rights you have in relation to your personal data; and
• How to contact us about this policy
• Further information about the use of cookies

MCL’s Marketing Department oversees compliance with data protection laws and this Privacy Statement and provides guidance and advice to its subsidiaries.  Contact information for our Marketing Department can be found under the “How to contact us about this policy” section of this document.

What personal data we collect about you
When you visit our website, certain data (for example, your IP address) is sent to our servers by the browser on your device through the use of cookies or other online identifiers.  Please see “Further information about the use of cookies” in this document for more information on our use of cookies and your options for managing cookies.  You may also submit personal data to us when you initiate a contact request form, download materials, or subscribe to our blog.

Personal data we collect about you may include:

• Contact information such as your name, email address, phone number, job title, information about your company, country or region
• Information about the nature of your contact request
• Technical data, including your IP address, browser type and version, operating system, referring website or URL (i.e., the last site you visited prior to our website), date and time of your visit
• Cookie data or other similar online identifiers, such as a unique visitor ID for recognizing returning visitors, number of visits, time of visit, pages visited, and duration of time on page

How we collect your personal data
We collect most of this information from you:

• When you submit a “contact us” request to receive more information about MCL as a service  provider to your organization, to inquire about opportunities to be a supplier to MCL, to inquire about career opportunities with MCL, or to submit a general inquiry to us
• When you sign up or subscribe to our blog
• When you fill out a form to access advanced content

To help analyze how you and other visitors navigate our website, and compile aggregate statistics about site use and response rates, we, with assistance from third party analytics service providers (e.g., Google Analytics) collect certain information when you browse our website through the use of cookies, pixel tags or other similar tools.  Please refer to the section titled “Further information about the use of cookies” for additional information.

How we use your personal data
We process the personal data submitted to us by you or collected when you browse our website for the following purposes:

• To respond to your requests for information and general inquiries initiated by you through the “contact us” forms on our website
• To deliver our blog or advanced content to you by email
• To enable the delivery of the content and features of the website and improve its performance
• For example, by understanding the type of browser or operating systems interacting with our site, we can ensure all pages display correctly and load in a timely fashion
• To detect and prevent malicious attacks against our website, such as Distributed Denial of Service attacks, which would disrupt our ability to make our website available
• To analyze visitors’ use of our website at an aggregate level (page visits, frequency and duration of visits) to provide better, more relevant content on our website

The basis on which we use your personal data
Under data protection law, we may only use your personal data if we have a proper reason for doing so.  Our legal basis for processing your personal data for the purposes described above in the section titled “How we use your personal data” is primarily our legitimate business interests, such as:

• The provision of information requested by website visitors (e.g., responses to contact requests, our blog posts or advanced content downloads)
• The protection of the infrastructure used to provide the website, in particular to identify, eliminate and preserve evidence of disruptions
• The measurement of user behavior on the website at an aggregated level (e.g., pages most frequently visited, average durations of visits, rates of response to newly posted content)

Although it is not the primary purpose of our website’s contact request forms, if the nature of a website user’s request is related to an existing contract with MCL (for example, an inquiry about an order, delivery of product or an invoice), our legal basis for using this information is to fulfill the terms of that contract and also our legitimate interest to provide timely response to our business partners.

Who we share your information with

The personal data collected through the use of our website and blog subscriptions is shared with third party service providers – namely our website hosting provider and our website consulting partner – to make the content and features of the website available to you and to maintain the security and functionality of the website.

Depending on the nature of the request, personal data collected through our contact forms may be shared with employees of our MCL affiliates based on the information you provide in the form.  For example, if you are a potential customer who is looking for a metal supplier, we will route your request to our sister company, Metal Fab Solutions, for response.   

We engage third party service providers, such as Google Inc., to analyze the technical data (e.g., IP address, browser type and version, referring URL) and website visitor usage data (pages visited, durations and frequencies) generated by a website user’s activities while on the site to provide aggregated usage statistics to us. 

The account data (email address and password) created by a user who has elected to apply for a job opening through our website is shared with the third party online application tool provider.

We will only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data.  We also impose contractual obligations on service providers to ensure they can only use your personal data to provide the services we have instructed them to provide to us or to you and to ensure compliance with data protection laws.

MCL will not sell, trade or rent personal information obtained through this website to any third parties to be used for their own independent purposes.  However, in the event of a change in control of MCL or sale by MCL of substantially all of its assets, any information owned by or in control of MCL may be transferred to the MCL successor.  We will typically anonymize personal data in this circumstance, but it may not always be possible.

Other than as described above, we will only disclose your personal data to third parties when you have provided your express permission to do so; when we are required to do so under applicable law, regulation or judicial order; or as required to investigate actual or alleged fraudulent or criminal activities.

How long your personal data will be kept
Different retention periods apply to different data.  The retention periods in place take account of:

• The period for which the data is necessary to fulfill the purposes described in this Policy
• Legal and regulatory requirements and guidance
• Limitation periods that apply in respect to legal action
• Our ability to defend ourselves against legal claims or complaints
• The operational requirements of our business

When it is no longer necessary to retain your data, we will delete it or anonymize it.

Transfers of your personal data and what safeguards are applied to protect your data during such transfers.

MCL’s website is controlled and operated by its Marketing Department and its third party service providers in the United States.  In order to provide the content, respond to your requests or deliver our blog to you in an efficient manner, it is necessary to transfer the personal data described in this Policy to servers located in the United States and administered by our third party information technology service providers in the United States.

In regards to contact requests, we may transfer the data provided by you in the contact request form to other MCL departments responsible for providing the requested information.

Such transfers may be subject to additional restrictions under the data protection laws of the country in which the website visitor resides, such as the EU’s General Data Protection Regulation.  We implement appropriate safeguards to ensure such transfers comply with the relevant data protection laws and your personal data will be secure.  If you would like additional information about these safeguards, please contact our Marketing Department as described in the section titled “How to contact us about this policy."

The steps we take to protect your personal data
We implement appropriate technical and organizational measures to keep your personal data confidential and secure.   We have appropriate security measures in place which take into account, in particular, the risks arising from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data.  We require our third party service providers to demonstrate they also have appropriate technical and organizational measures in place.  Those processing your personal data, including our third party service providers, will do so only in an authorized manner and for the purposes outlined in this Privacy Statement.

The rights you have in relation to your personal data
If you are a subscriber to our blog and no longer wish to receive the emails, you may unsubscribe by replying to the e-mail message sent to you by our Marketing Department with an instruction to remove you from our subscriber list, or by clicking the “unsubscribe” link at the bottom of the email.  To provide an updated or new email address to which the blog should be delivered, simply provide that email address using the “subscribe” button on our website.
If you are a natural living person residing in the EU, the General Data Protection Regulation (GDPR) generally provides data subjects with additional rights, subject to the restrictions stipulated in the GDPR or other applicable law.

Under the GDPR, you can ask us to:

• Provide a copy of your personal data as well as information on why it is processed, where and with whom it is shared or transferred to
• Correct, update or revise inaccurate or incomplete data about you
• Remove or delete information we hold about you, particularly if it is no longer required for the purposes it was collected for and if the data is not subject to retention obligations
• Restrict processing of your data in certain circumstances, such as if you contest the accuracy of the personal data
• In certain circumstances, provide you with a copy of the personal data you provided to us in a structured, commonly used and machine-readable format and/ or to transfer it to a third party

In certain situations, EU residents have the right to object to how we use your personal data.  In particular you have the right to object at any time if your personal data is used for marketing purposes.  If you are an EU resident and wish to exercise the rights listed above, please contact our Marketing Department at the contact information provided in the section titled “How to contact us about this policy.”

EU residents also have the right to complain to the supervisory authority in the country in which they normally reside, work or where any alleged infringement of data protection laws occurred.  We would appreciate an opportunity to address your complaint and respectfully request that you contact us prior to filing such complaint with the supervisory authority.

If you reside outside of the EU, you may have similar rights under your local laws.  If you believe these rights apply to you under your local laws, please contact our Marketing Department as outlined in the section titled “How to contact us about this policy.”

How to contact us about this policy
If you have any questions regarding this policy wish to exercise your rights under the General Data Protection Regulation or to notify us of an alleged infringement of your rights, please contact our Marketing Department at 660 Corporate Way, P.O. Box 950, Pulaski, Wisconsin, 54162, USA or via email at mbies@mcl.bz.

Further information about the use of cookies
We use cookies to help us understand how users are using our website and to improve its content and operational performance.
A ‘cookie’ is a small data file containing a string of characters that is sent to your device when browsing a website.  When you visit the website again, the cookie allows the website to recognize your browser.  Some of the cookies we use are essential for the website to function properly.  We also use some non-essential cookies to collect information that helps us improve the site. 

We use the following types of cookies:

• Strictly necessary – these cookies are essential in order to enable the website and its features.  Without these cookies, you will not be able to use the website.  These cookies are deleted when you close your browser.
• Analytical/ performance (e.g., Google Analytics cookies) – these cookies collect information about how website visitors use or navigate the website, for example what pages are visited most often.  The data collected by these cookies does not identify an individual user.  All information collected by these cookies is aggregated and therefore anonymous.  These cookies are used to help us improve the usability and performance of our website.

If you do not wish for your information to be collected using cookies, most web browsers allow you to control cookies through your settings or preferences.  For complete information about how to manage your cookie settings on your browser, please visit Aboutcookies.org.  Please be aware that if you decline all cookies, some features of our website may no longer function for you.

For more information about Google Analytics or to opt out of tracking by Google Analytics on all websites, please visit http://tools.google.com/dlpage/gaoptout.

From time to time, our website may contain links to third party websites that are provided for the convenience of our visitors.  These third party sites are not under our control and may have a different Privacy Policy.  You should carefully review the privacy and legal information provided to you on those sites.  In addition, MCL is not responsible for the content on these sites, and these links do not create or imply any approval or endorsement of that site by MCL.  MCL makes no representations whatsoever as to any other website that you may access through our website.