Cabot Specialty Fluids is part of the Cabot Corporation and follows its corporate privacy policy as detailed below. Consequently, any mention of the Cabot website in this statement should be taken to refer to the Cabot Specialty Fluids website located at www.formatebrines.com as well as the corporate website located at www.cabot-corp.com.
Cabot respects the privacy of its employees, its customers and visitors to its website (together known as “data subjects”) and takes its responsibilities regarding the security of information held on data subjects very seriously. This Data Privacy Policy has been created to explain the way in which Cabot uses personal data.
This policy applies to the Cabot Corporation and all of its subsidiaries and affiliates around the world. References to “Cabot” in this policy refer to the Cabot Corporation, its subsidiaries and its affiliates.
Cabot will only use personal data it has collected in relation to its employees where it has their consent and/or where it is necessary and lawful to do so. Provided such personal data is used for such things as:
• evaluation of employment qualifications
• employee contact directories
• company network access
• benefits and compensation administration, workforce management
• performance management including performance reviews
• development and training
• budgeting and planning
• security management
• transaction processing
• financial administration
In addition, the Cabot Boston Credit Union collects and uses personal financial information from Cabot employees who are members for the purpose of providing financial services to those members. This information is not shared with Cabot Corporation.
Cabot will not collect sensitive personal data about its employees without their express consent. Only authorized employees with valid, work-related need may have access to employee personnel files.
Personal data may be provided to a third party in connection with a possible sale or transfer of all or part of Cabot’s business or in order to comply with legal requirements. Cabot will not sell, disclose or rent personal employee information for direct marketing purposes.
Cabot may update this Data Privacy Policy from time to time. All material changes will be notified to employees through correspondence from Cabot at least 30 days prior to any change being implemented.
What is covered in this policy?
This policy is divided into the following sections:
• What is personal data?
• Transfer of personal data
• Security of personal data
• Rights of a data subject to personal data held by Cabot
• Enforcement of this Data Privacy Policy
• What happens if a complaint is made about Cabot’s use of a data subject’s personal data
• Cabot’s Global Data Protection Officer contact details
1. What is personal data?
Personal data is any information that allows an individual to be identified. The types of personal data Cabot may collect include the person’s name, title, company affiliation, address, and phone number and email address.
Sensitive personal data is information relating to a data subject’s racial or ethnic origin, political opinion, religious beliefs or other beliefs of a similar nature, membership of a trade union, physical or mental health conditions, sexual life, commission or alleged commission of any offence or any proceedings for any offence committed or alleged to have been committed by a data subject, the disposal of such proceedings or the sentence of any court in such proceedings.
2. Transfer of personal data
As Cabot is part of an international group of companies operating globally it may store personal data in a data subject’s home country. Cabot may also transfer it to other Cabot companies and carefully selected business partners and third party suppliers in other countries around the world where it has the consent of the data subject or where it is necessary to do so because it is relevant to Cabot’s dealings with the data subject. The laws of these other countries may not be the same as the laws regulating the use and transfer of personal data in a data subject’s home country. However, because every Cabot employee around the world is obliged to comply with Cabot’s comprehensive data protection compliance policies, including this Data Privacy Policy, Cabot is confident that it is able to protect the security and confidentiality of personal data and provide an adequate level of protection in each of the Cabot offices in each of the countries to which personal data is transferred.
From time to time, Cabot may employ third parties to provide services including, but not limited to, processing of employee expense reports that may include the processing of personal data held by Cabot. Cabot will ensure that such service providers comply with the requirements of this Data Privacy Policy before making personal data available to them.
3. Security of personal data
Cabot has in place appropriate technical and security measures to prevent unauthorised or unlawful access to or accidental loss of or destruction or damage to personal data. These measures ensure an appropriate level of security in relation to the risks inherent in the processing and the nature of the personal data to be protected. Securely held personal data will only be accessible by select authorised members of staff within Cabot. Those members of staff with access to personal data are aware of their responsibility to protect the security of the data and have been given relevant training. Access to this information is controlled through data networks that use technologies such as password protection to limit access to authorised users.
Where Cabot discloses personal data to third parties it will ensure in its contracts with such third parties that they comply with this Data Privacy Policy and applicable data protection laws.
4. Rights of a data subject to personal data held by Cabot
Cabot will only keep personal data for as long as it is required to by law, or as is relevant for the purposes for which it was collected. During this period, a data subject may contact the Cabot Data Protection Officer in his/her home country or the Company’s Global Data Protection Officer located in Boston, Massachusetts at any time if he would like to see details of the personal data that is held about him, details as to the source of that personal data (as far as it is available to Cabot), the purposes for which the personal data is being used and details of the parties with whom Cabot may share the personal data. Additionally a data subject may ask Cabot to correct, update, supplement or delete personal data held on him.
5. Enforcement of this Data Privacy Policy
Cabot has appointed Data Protection Officers for the U.K., France, Belgium, Germany, Spain, Italy and The Netherlands as well as a Global Data Protection officer in the U.S. The Human Resources Manager at the Cabot office in a data subject’s home country will be able to put him in contact with the appropriate Data Protection Officer. If a data subject has a question or enquiry about this Data Privacy Policy or a complaint about the way Cabot has used his personal data he should first contact his local Data Protection Officer who will be able to assist him.
The Cabot Data Protection Officers have the responsibility to ensure that each Cabot office complies with this Data Privacy Policy around the world. It is also the responsibility of the Data Protection Officers to deal with and respond to all enquiries from any national Data Protection authority or governmental authority.
The Data Protection Officers and other members of Cabot’s management team co-ordinate on an “as necessary” basis to discuss this Data Privacy Policy and any individual complaints or disputes not resolved.
The Global Data Protection Officer is accountable for Cabot’s compliance with the Data Privacy Policy. Cabot will conduct periodic audits of its compliance with this Data Privacy Policy.
6. What happens if a complaint is made about Cabot’s use of a data subject’s personal data?
If a data subject complains to the Data Protection Officer and his complaint is unable to be resolved locally, the complaint will be escalated. Any finding of misuse of personal data by Cabot shall be remedied as soon as reasonably possible.
For information about the local Data Protection Officer in the countries listed above, please contact the Global Data Protection Officer whose contact details are set forth below:
Global Data Protection Officer
Cabot Corporation
Two Seaport Lane
Boston, MA 02129
Telephone: (1) 617 345 0100
Fax: (1) 617 342 6256
Users of the Cabot website
This section of the Data Privacy Policy applies specifically to users of the Cabot website that is located at www.cabot-corp.com. The Cabot website may contain links to other websites. This Data Privacy Policy does not cover such websites and Cabot does not accept any responsibility for the data privacy policies and practices or content of these websites. Visitors are encouraged to review the data privacy policies posted on these (and all) third party sites.
Cabot may update this Data Privacy Policy from time to time. Users will be notified of all material changes through the Cabot website at least 30 days prior to any change being implemented.
Collection and use of personal data
Cabot collects personal data from its data subject’s through their use of the Cabot website. Additionally, personal data may be collected from comments and questions from visitors to the Cabot website. Cabot will only use such personal data where it is necessary to do so because it is relevant to Cabot’s dealings with a data subject or where it has his consent.
Cabot does not require personal data from an individual to obtain access to the general public areas of its website but such data may be required for an individual to request or download product information, order products or take advantage of other features on the Cabot website.
Cabot will not collect sensitive personal data about a user of the Cabot website without his express consent.
Cabot will use a data subject’s personal data where it is necessary to do so for such purposes as verifying the identity of visitors to the Cabot website, creating user credentials such as user names and passwords, processing and responding to requests, improving its operations, maintaining details of its business contacts, facilitating business transactions, monitoring market performance and developing new business.
Cabot will only use personal data in a way that is appropriate, taking into account a data subject’s consent, the extent to which it is necessary for Cabot to use personal data in its dealings with a data subject and the purposes which are disclosed to a data subject in this Privacy Policy or which are relevant to the reason for a data subject giving personal data to Cabot.
Direct marketing
With a data subject’s consent, Cabot will use personal data for direct marketing, including sending him details of offers of both Cabot and third party products and services.
If a data subject consents to Cabot (and/or any third party) providing him with direct marketing material he will be requested to elect the type of media via which this material shall be provided (for example by post, e-mail, telephone or fax). Cabot will only provide such material via the chosen media. If at any stage a data subject objects to Cabot’s use of his personal data for direct marketing or to the media in which such material is being sent, he may choose to unsubscribe to its receipt. If he has consented to third party direct marketing it will be necessary to unsubscribe directly with that third party.
Cabot may disclose personal data to carefully selected business partners and third party suppliers with whom it engages to provide services. However, other than as set out in this Privacy Policy, Cabot will not disclose or share personal data with any third party without a data subject’s express consent unless it is necessary to do so to provide the services or products requested by a data subject when providing Cabot with personal data or unless it is required by law.
Cabot does not sell, trade, or rent personal information to any business for direct marketing purposes.
Use of cookies
Cabot may use cookies on its website to allow visitors to use the website without having to log in upon returning, to input information to email forms, to improve the site, to verify that visitors meet the necessary criteria to process their requests and to improve the management and security of the website. A “cookie” is information that a website puts on a visitor’s hard drive so that it can remember pieces of information about them when they next visit the website or a related website. Cabot uses cookies to record personal data about an individual who uses its website in order to facilitate their future activities. Unless otherwise notified by Cabot, Cabot will not use personal data sent in a cookie for marketing purposes and will not share this personal data with third parties.
If an individual does not wish to receive cookies from Cabot’s website, he can set his browser to warn him before accepting cookies and refuse the cookie when alerted by the browser to its presence. Cookies can also be refused by turning them off in the browser. However, if cookies are not accepted by a visitor, the range of features available to the user on the Cabot website will be limited.
Security
Some areas of Cabot’s website may require pre-qualification or registration for access and, if access is granted, may require a user name, password or other technique to control access. Registered visitors should carefully safeguard their username and password and only make it available to authorised agents. They may not sell, assign or transfer such passwords or rights of access. It is Cabot’s policy to grant access to any visitor using an authorised username and password. If data subjects become aware of any unauthorised use of a password, they should notify Cabot.
Last Updated 23 November, 2002.