Privacy Policy

Last Updated: May 2, 2024

This Privacy Policy describes how Flack Steel LLC (doing business as Flack Global Metals) and its subsidiaries and affiliates (collectively, “Flack Global Metals”, “we”, “us” or “our”) collect, use, store, and share your information when: (1) you access and use our website at www.flackglobalmetals.com and any other digital property where this Privacy Policy is posted (“Websites”); (2) you purchase our products and services, including through our Flack Metal Supply or Flack Capital Markets divisions or our Flack Metal Trading SA and Flack Manufacturing Investments LLC subsidiaries (“Services”); (3) you communicate with us in any manner, including by e-mail, text, social media, or telephone (“Communications”); and (4) we interact with our third party partners and service providers.

For California residents, please see our California Privacy Notice.

For individuals in the UK, EU, or other country outside of the United States, please see our Non-US Privacy Notice.

 

1.   What Type Of Information Do We Collect About You?

Depending on how you interact with our Websites and Services, the nature of our Communications, and how we may interact with certain third parties, we may collect the following information about you:

  • Basic Identifying Information. Information such as your full name, postal address, e-mail address, phone number, and other similar identifiers.
  • Corporate Information. Information such as your company name, and other related business and professional information.
  • Device Identifier and other Unique Identifiers. Information such as your device identifier, internet protocol (IP) address, cookies, beacons, pixel tags, mobile ad identifier, and other unique identifiers.
  • Internet or Other Network Activity. Information such as your browsing or search history, and other information regarding your interactions with our Websites, emails, and advertisements.
  • Geolocation Data. Information that permits us to determine your location so that we can determine the best Services to offer you.
  • Commercial Information. Information such as the nature of the Services you’ve considered from us, and related information.
  • User Content. Information such as your Communications with us and any other content you provide, such as social media profiles, photographs of receipts, images, videos, survey responses, comments, product reviews, testimonials, and other content.
  • Audio and Visual Information. Information such as photographs, images, videos, and recordings of your voice (such as when we record customer service calls for quality assurance).
  • Inferences. Information such as inferences drawn from or created based on the information identified above.

 

2.   How Do We Collect Your Information?

We collect your information in three ways: (1) directly from you when you use our Websites, Services, and Communicate with us; (2) automatically using online technologies when you engage with our Websites, Services, and Communications; and (3) from third parties.

  • Directly from you. We collect information directly from you when you visit our Websites, purchase our Services, enter your information through our Websites, access our content, take a survey or a poll or enter a contest, engage in Communications with us, or sign-up to receive emails, text messages, or certain other Communications from us.
  • Automatically Using Online Technologies. When you visit our Websites, open or click on emails we send you or related Communications, or interact with our advertisements, we or other third parties may automatically collect certain information about you using online tracking technologies such as cookies, pixels, web beacons, software developer kids, and related technologies. For more information, see Cookies and Related Online Tracking Technologies
  • From Third Parties. We collect information from our third party partners, such as distributors, suppliers, other members, partners, data analytics providers, marketing or advertising providers, fraud prevention service providers, and vendors that provide services.

 

3.   Cookies and Related Online Tracking Technologies

We and our third-party partners use cookies, pixels, web beacons, software development kits, and other similar online tracking technologies to gather information about you when you use our Websites, interact with our Services, and engage with our Communications. These technologies may include payment processing, advertising, marketing, and related services. Others are used to maintain the security of our Websites, manage your account, prevent crashes, fix bugs, save your preferences, assist with basic Website functions.

Our Websites, for example, use Google Analytics for analytics purposes. You can learn more about Google Analytics by vising How Google uses information from sites or apps that use our services.

To learn more about these technologies, and obtain a list of the tools being deployed on our Websites, please see our Cookie Policy.

 

4.   How Do We Use Your Information?

We use your information for a variety of purposes, including to:

  • Provide our Websites and Services to You. We use your information to provide our Websites and Services to you, including to: (1) create and manage your account; (2) allow you to use the Websites and purchase products; (3) facilitate your purchase of our Services; (4) answer your Communications; and (5) perform other related business functions.
  • Communicate with You. We use your information to engage in Communications with you, such as to respond to your requests, inquiries, issues, feedback, and to provide customer service.
  • Market and Advertise. We use your information for marketing and advertising purposes, including sending marketing, advertising, and promotional communications to you by email, text message, or postal mail. We also use your information to show you advertisements for Services and on our Websites.
  • Conduct Analytics and Personalization. We use your information to conduct research and analytics, including to improve our Websites and Services. We also use your information to understand your interaction with our Websites, advertisements, Services, and our Communications with you. We further use your information to personalize your experience, save you time when you visit our Websites and use our Services, better understand your needs, and provide personalized recommendations for our Services.
  • Security and Fraud Prevention. We use your information to detect, investigate, prevent, or take action regarding possible malicious, deceptive, fraudulent, or illegal activity, including fraudulent transactions. We also use your information to enforce our terms and procedures, prevent against security incidents, and prevent harm to other users of our Services.
  • Legal Obligations. We use your information to comply with our legal and regulatory obligations, to establish and exercise our rights, and to defend against legal claims.
  • Business Functions. We use your information to support our core business functions, including to maintain records related to business management, loss prevention, collecting amounts owed, and identifying and repairing errors or problems in the Websites.

 

5.   How Do We Disclose Your Information?

We may disclose or share your information with affiliated and non-affiliated third-parties, including in the following scenarios:

  • With your Consent. We may disclose or share your information with your consent, which may be obtained in writing; online, through “click-through” agreements; when you accept the terms of use on our Websites; when you accept the setting of cookies and related tracking technologies; orally, either in person or on the phone; or by other means.
  • In a Business Transfer. We may disclose or share your information as part of a corporate business transaction, such as a merger or acquisition, joint venture, corporate reorganization, financing, or sale of company assets, or in the unlikely event of insolvency, bankruptcy, or receivership, in which such information could be transferred to third parties as a business asset in the transaction or otherwise during related proceedings.
  • To Non-Affiliated Third Parties. We may disclose or share your information with certain non-affiliated third parties to facilitate your access and use of our Websites, our Services, to complete a transaction, and to provide us with certain business functions, including but not limited to sharing your information with partners, internet service providers, advertising networks, data analytics providers, governmental entities, operating systems and platforms, social medial networks, and service providers who provide us a service (e.g., customer service, distribution, supply, auditing, marketing, shipping, debugging to identify and repair errors that impair existing intended functionality on our Websites, payment processing, and/or protecting against malicious, deceptive, fraudulent, or illegal activity).
  • For Legal Process And Protection. We may disclose or share your information to satisfy any law, regulation, legal process, governmental request, or where we have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to: (1) enforce or apply our agreements; (2) protect our interests, property, or the safety of others; (3) in connection with claims, disputes, or litigation; and (4) to protect our Websites and Services.

 

6.   How Do We Protect Your Information?

Although no system can guarantee the complete security of your information, we take all commercially reasonable steps to ensure your information is protected in alignment with all applicable laws and regulations, as appropriate to the sensitivity of your information.

 

7.   How Long Do We Keep Your Information?

We keep your information for as long as is necessary in accordance with the purpose for which it was collected, other noticed purposes, our business needs, and our legal and regulatory obligations. If we dispose of your information, we will do so in a way that is secure and appropriate to nature of the information subject to disposal.

 

8.   Links To Third Party Sites

Our Websites and Services may contain links to third party websites and services. Please note that these links are provided for your convenience and information, and the websites and services may operate independently from us and have their own privacy policies or notices, which we strongly suggest you review.

 

9.   Do Not Track

Our Websites may, from time to time, collect information about your online activities, over time and across our different websites. When you use our Websites, third parties may also collect information about your online activities, over time and across different internet websites, online or cloud computing services, online applications, or mobile applications. Some browsers support a “Do Not Track” feature, which is intended to be a signal to websites that you do not wish to be tracked across different websites you visit. Our Websites do not currently change the way they operate based upon detection of a “Do Not Track” or similar signal.

 

10.   Your Rights

For individuals in California, please see our California Privacy Notice below.

For individuals outside of the US, please see our Non-US Resident Privacy Notice below.

For all individuals, regardless of location, you have a right to stop receiving promotional e-mails or other related communications from us at any time by clicking on the “unsubscribe” link at the bottom of any promotional e-mail you receive from us.

You also have the right to manage your preferences as it relates to cookies and related technologies by utilizing our cookie banner and tool to manage your preferences.

 

11.   California Privacy Notice

The following disclosures are made pursuant to the California Consumer Privacy Act, as amended by the California Privacy Rights Act and its implementing regulations (collectively, the “CCPA”).

Definitions

  • Personal information. This is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you or your household.
  • Sensitive personal information. This is information such as your social security number, driver’s license number, state identification card, passport number, account log-in and password, financial account and password, debit or credit card number and access code, precise geolocation information, race, ethnic origin, religious or philosophical beliefs, union membership, the content of your mail, email or texts other than those communications you have with us, genetic data, biometric information, health information, or information that concerns your sex life or sexual orientation.
  • Sell, sale, or sold. This means the selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or other means, your personal information to a third party for money or other valuable consideration.
  • Share, shared, or sharing. This means the sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or other means, your personal information to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration.

 

Your Rights

You or an authorized agent you designate on your behalf may submit the individual requests outlined below. Upon receipt, we will take reasonable steps to verify you and your authorized agent’s identity prior to responding to the request, which may include in certain circumstances you signing a declaration under penalty of perjury. If an authorized agent is submitting a request on your behalf, you must submit a copy of: (1) a written authorization demonstrating you have authorized the agent to submit a request on your behalf; and (2) provide separate proof verifying your identity.

  • Right to Know. You have a have a right to request that we disclose, subject to certain exceptions, information concerning: (1) the categories of personal information we have collected from or about you; (2) the categories of sources from which we have collected that personal information, and the business or commercial purpose for the collection; (3) the categories of third parties with whom we have shared, sold, or disclosed your personal information, including the business or commercial purpose for said sharing, selling, or disclosure; and (4) specific pieces of your personal information, subject to appropriate exceptions.
  • Right to Delete. You have a right to request that we delete your personal information, subject to certain exceptions.
  • Right to Correct. You have a right to request that we correct your personal information, subject to certain exceptions.
  • Right to Non-Discrimination. You have a right to exercise the above rights without being discriminated against under the CCPA.
  • Exercising Your Rights. To submit a request, you may send an e-mail to privacy@flackglobalmetals.com. You may also designate an authorized agent to submit a request on your behalf by sending an e-mail with written proof of such authorization to privacy@flackglobalmetals.com.
  • Responding To Requests. Once you have submitted your request, we will respond within the time frame permitted by applicable law.

 

Notice of Collection

 

Notice of Disclosure for a Business Purpose

To learn more about the categories personal information we have disclosed for a business purpose, and the categories of third parties to which we’ve disclosed such information, please see How Do We Disclose Your Information? above.

 

Notice of Sale or Sharing of Personal Information

We do not sell or share the personal information of California residents. We have no actual knowledge that we sell the personal information of California residents who are under 16 years of age.

 

Notice of Use of Sensitive Personal Information

We do not use California resident sensitive personal information for any purpose other than is permissible under the CCPA. Specifically, we do not use sensitive personal information of California residents to derive characteristics about California residents.

 

Non-US Privacy Notice

Certain data protection laws outside of the United States, such as the European Union’s General Data Protection Regulation (GDPR) and related laws, distinguish between organizations that operate as “processors” of your personal data and act as “controllers” of that data. We act as a “controller” with respect to the personal data we collect, as described above.

 

How Do We Use Your Personal Data?

Please see How Do We Use Your Personal Data? above.

 

What is our lawful basis for processing your personal data?

Your personal data is primarily used to provide you with our Websites and Services. Your personal data may also be used to comply with our legal obligations or to fulfill our legitimate interest, such as to personalize your experience, develop and improve our Websites and Services, or to detect illegal activity. With your consent, we may also use your information to send you offers and promotions.

 

Your Rights

We may take steps to verify your identity by matching the information you provide with your request with the information we have on file about you. Depending on the sensitivity of the information at issue, we may utilize more stringent verification methods.

You have a right to access the personal data we have processed about you, ask that certain of that data be removed (i.e., deleted), correct or change your personal data, or change your marketing preferences by withdrawing your consent at any time. To submit any of the requests below, please submit your request to privacy@flackglobalmetals.com.

We may take steps to verify your identity by matching the information you provide with your request with the information we have on file about you. Depending on the sensitivity of the information at issue, we may utilize more stringent verification methods.

 

Lodging Complaints

You may have a right to lodge a complaint with your local Data Protection Supervisory Authority concerning our data practices. To receive information about your local Data Protection Supervisory Authority, please Contact Us.

 

12.   Children

Our Websites and Services are not intended for children under the age of 13. This includes any links to other websites that we provide for our convenience. We don’t knowingly collect the information of children under 13 for any reason.

 

13.   Changes To Our Privacy Policy

We may change this Policy from time to time. Any and all changes will be reflected on this page, and where appropriate provided in person or by another electronic method. The effective date will be stated at the top of this Policy. You should regularly check this page for any changes to this Policy.

 

14.   Accessibility

If you require a copy of this Privacy Policy in an alternative format, please Contact Us.

 

15.   Contact Us

privacy@flackglobalmetals.com