RPM International Inc.
Last Updated: April 10, 2023
You must be at least eighteen (18) years of age to access the Services. RPM International Inc. is headquartered in the United States, and the personal information you provide to the Company may be processed and stored in the United States and other jurisdictions. For more information on our data transfer practices, please see Section 9 (Data Retention and Localization).
|Personal Identifiers||Identifiers, such as your name, alias, shipping address, email address, account name, telephone number, customer identification number.|
|Registration Data||Information provided when you register for an account to use the Site, including usernames and passwords.|
|Online Identifiers (For more information, see “Technical Data” below)||Persistent identifiers that can be used to recognize you or your device over time and across different Services, including a device identifier, an Internet Protocol (IP) address, cookies, beacons, pixel tags, mobile ad identifiers, and similar technology.|
|Commercial Information||Records of the Services you purchased, obtained, or considered, or your other purchasing or consuming histories or tendencies with respect to our Services.|
|Business Contact Data||Information related to employees, owners, directors, officers, or contractors of a third-party organization (e.g., business, company, partnership, sole proprietorship, nonprofit, or government agency) with whom we conduct, or possibly conduct, business activities.|
|Health Data||You may furnish us with health-related information in the event you, or a third party, suffers an injury or illness while visiting our physical locations or premises, or when using our Services.|
|Marketing and Communications Data||Information with respect to your marketing preferences and your subscriptions to our publications and alerts.|
|Internet and Electronic Network Data||Data pertaining to your access to or use of the Site, including browsing history, search history, and information regarding your interaction with the Site or advertisements embedded on the Site or other third-party websites, and information derived from any device that connects to our Wi-Fi services.|
|Your Feedback||Information you provide about our Services, which may include data gathered from any Company surveys or reviews submitted by you.|
|Visitor Information||Information an individual provides when visiting any of our physical locations or premises, including visitor logs and registries, vehicle and parking information.|
|Video and Images||In some circumstances, you may provide us images (e.g., your use of a Service) or we may record you via a video camera (e.g., on-premises security systems) or through video teleconferencing.|
|Geolocation Data||Information about the general city, state, or region in which a user of the Site resides.|
|Professional or Employment Data||If you apply for a job with the Company, we collect information set forth in a resumé, curriculum vitae, cover letter, and similar documentation, including contact details, employment history, skills, or qualifications, education level, job compensation and benefit preferences, criminal record, credit history and similar data, and information provided about or by your references.|
|Inferences||Inferences drawn from some of the personal information categories identified herein and used to create a consumer profile reflecting your purchasing and marketing preferences, characteristics, and behavior.|
When you access the Site, we collect certain data automatically using technical means and tools. From time to time, the Company or its service providers may release aggregate and de-identified reports derived from this technical and usage information (for example, by publishing a report on trends in the usage of our Site or service provider’s platforms). This data relates to your device, and your experience on the Site and other websites, including the following:
Usage and Device Data. When you access and use the Site, we automatically collect details of your access to and use of the Site, including traffic data, usage logs and other communication data, and the resources that you access and use on or through the Site (e.g., browsing history, search history). We may also collect information about your device and internet connection, including the device’s unique identifier (e.g., device type, IMEI, Wi-Fi MAC, IP address), operating system, browser type, and mobile network information. The Site may collect “diagnostic” data related to your use of the Site, such as crash data and logs, performance data (e.g., launch time, hang rate, or energy use), and any other data collected for the purposes of measuring technical diagnostics.
First Party / Direct Collection. We collect personal information directly from you when you use our Services (e.g., account registration, completing purchases, signing-up for subscriptions), when you provide a Product Review (as defined below), or whenever you directly engage with us, such as when you visit our offices or premises or otherwise contact us.
Automated Collection. We may collect information and data, such as usage data and cookies, through automated means when you use the Site (see “Technical Data” above).
We may use the personal information we collect about you in order to perform our Services, comply with our legal obligations, and promote our business interests.
|How Your Personal Information Is Used|
|Provide, operate, maintain, improve, and promote our Services.|
|Enable you to access and use our Services.|
|Process and complete transactions, and send you related information, including purchase confirmations and invoices.|
|Send you messages and communications related to our Services (e.g., responses to your comments, questions, and requests, customer services).|
|Furnish technical notices, updates, security alerts, and support and administrative messages to you about our Services.|
|Provide you promotional and marketing communications (e.g., information about our Services, features, surveys, newsletters, offers, promotions, contests, and events).|
|Process and deliver contest or sweepstakes entries and rewards.|
|Monitor and analyze trends, usage, and activities in connection with our Services to promote our business interests.|
|Investigate and prevent fraudulent transactions, unauthorized access to or use of our Services, and other illegal activities.|
|Personalize our Services, including providing features or advertisements that match your interests and preferences.|
|Any other purpose for which we obtain your consent.|
For the avoidance of doubt, you hereby agree that the Company may contact you via any means, including via SMS/text message and email and through the use of autodialing systems and services, to furnish you information regarding a product order, shipping status, warranty-related information, and similar data and information pertaining to a commercial transaction.
We may share your personal information with certain organizations and third parties in accordance with applicable law, including as set out below.
Intra-Group. The Company is composed of affiliates and operating businesses all over the world, and we may disclose your personal information to such affiliates and operating businesses to facilitate the purposes for which the personal information was collected including to provide, operate, maintain, improve, and promote our Services. For a list of the Company’s affiliates and operating businesses that may collect, process, and exchange your personal information, please see https://www.rpminc.com/leading-brands/.
Service Providers. We may share your personal information with companies that provide services on our behalf, such as hosting and analyzing the Site, conducting surveys, benchmarking and marketing on our behalf, processing transactions (including rebates and returns), tracking and responding to consumer questions or complaints, and performing analyses to improve the quality of our Services.
Distributors and Business Partners. We may share your personal information with third parties that distribute our goods, products, and marketing materials.
Business Restructuring. Circumstances may arise where for strategic or other business reasons the Company decides to sell, buy, divest, merge or otherwise reorganize our businesses. We may disclose your personal information to the extent reasonably necessary to proceed with the negotiation or with the completion of a merger, acquisition, divestiture or sale of all or a portion of the Company’s assets.
Legal; Compliance; Legitimate Interest. We may disclose personal information to a third party (i) if required by law or government order, or with a legal process, (ii) when necessary to defend or protect our legal, regulatory, or business interests, (iii) to protect and defend our rights or property, or (iv) in urgent circumstances, to protect the health and personal safety of any individual.
Consent. In addition to the reasons for disclosure set forth above, we may also disclose your personal information when you consent to the disclosure.
In the event that you facilitate a transaction with the Company, or request information from or otherwise engage with us, and such activities require the Company to share your personal information with a service provider or other third party, you hereby consent to such disclosure and/or direct the Company to intentionally disclose your personal information to the service provider or third party.
We may engage with you on various social media platforms (e.g., Facebook, Twitter, YouTube, Pinterest, Instagram). If you contact us on a social media platform for customer support or for other reasons, we may contact you via the social media’s direct message tools. Your use of a social media platform is subject to the policies and terms of the relevant social media platform. Certain social media platforms may also automatically provide us with your personal information, and the information we receive will depend on the terms that govern your use of the social media platform(s) and any privacy settings you may have set.
The Site may, from time to time, include social media features and widgets (e.g., the “Facebook Like” button, the “Share This” button) or interactive mini-programs that run on the Site. These features may collect your IP address and which Site page you are accessing and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on the Site. Your interactions with these features are governed by the privacy statement of the relevant social media platform that provides them.
How long we keep your personal information varies depending on why it was collected. We keep personal information to provide you with our Services, to facilitate transactions you have requested, or to engage in marketing activities, and for as long as is necessary to defend our legal or business interests. For example, where you have made a purchase with us, we will keep a record of your purchase for the period necessary for invoicing, tax and warranty, and liability purposes. We may also keep a record of correspondence with you (e.g., if you have made a complaint about a product) for as long as is necessary to protect us from a legal claim. Please note that where you unsubscribe from our marketing communications, we will keep a record of your email address to ensure we do not send you marketing emails in the future.
RPM International Inc. is headquartered in the United States, and the personal information that the Company collects and processes may be retained and stored in the United States. The Company uses service providers that store personal information on our behalf in the United States and in other third countries. Please be aware that the United States, and these other third countries, may not provide the same level of protection of personal information as in your country, state, or other jurisdiction of residence or nationality, and when transferred to the United States or elsewhere, your personal information may be accessible by, or otherwise made available to, local government authorities and officials pursuant to judicial and/or administrative orders, decrees, and demands, and/or other domestic laws, statutes, and regulations. By continuing to provide us such information, you hereby acknowledge and agree that your personal information will be transferred to, and stored in, the United States and in such other third countries.
We use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure. HOWEVER, NO INFORMATION SYSTEM CAN BE FULLY SECURE, AND WE CANNOT GUARANTEE THE ABSOLUTE SECURITY OF YOUR PERSONAL INFORMATION. MOREOVER, WE ARE NOT RESPONSIBLE FOR THE SECURITY OF PERSONAL INFORMATION YOU TRANSMIT TO THE SITE AND/OR THE SERVICES OVER NETWORKS THAT WE DO NOT CONTROL, INCLUDING THE INTERNET AND WIRELESS NETWORKS, AND YOU PROVIDE US WITH ANY PERSONAL INFORMATION AND DATA AT YOUR OWN RISK. TO THE EXTENT PERMITTED BY LAW, WE SHALL NOT BE LIABLE OR OTHERWISE RESPONSIBLE FOR ANY DATA INCIDENT OR EVENT CAUSED BY A THIRD PARTY THAT COMPROMISES THE CONFIDENTIALITY, INTEGRITY, OR SECURITY OF YOUR PERSONAL INFORMATION. The safety and security of your personal information also depends on you. Where we have given you (or where you have chosen) a username and password to access our Services, you are responsible for maintaining the security and confidentiality of those credentials and not revealing them to others. You must contact us immediately if you have reason to believe that your username or password to our Services has been compromised. You acknowledge and agree that we may contact you via email or other electronic communications in the event we are legally required to notify you of a data security incident or event related to your personal information.
The Site is not directed at, nor intended for use by, children. As a result, if you are under the age of eighteen (18), you are prohibited from accessing or using the Services (including the Site) or providing us with your personal information. If the parent or guardian of a child under the age of eighteen (18) believes that the child has, or if you are under the age of 18 and believe that you have, provided us with any information, the parent or guardian of that child should contact us if they want this information deleted from our files, and we will undertake commercially reasonable efforts to comply with the request.
You may, from time to time, have the ability to submit via the Site a comment on, provide an opinion about, rate, or otherwise discuss our Services (a “Product Review”). In other circumstances, you may directly provide us feedback on our business, our business sector, or the Services (“Feedback”). Any information or content you post in a Product Review or in your Feedback may be available to other users of the Site (and our social media platforms) and may be retrievable by third-party search engines, and third parties may also be able to download or share your Product Review and Feedback to social media websites or elsewhere. We recommend that you guard your privacy and anonymity and not upload any information in your Product Review and Feedback that you wish to remain confidential. Any third party with access to your information via the Site will be permitted to use the information in the same manner as if you submitted the information directly to that third party. Publicly posting any information on the Site is entirely voluntary on your part, and we recommend you carefully consider the information you choose to make publicly available. As between you and the Company, any and all Product Reviews and Feedback shall be considered the Company’s confidential and proprietary information. In order for the Company to utilize such Product Reviews and Feedback, you grant to the Company a non-exclusive, perpetual, irrevocable, worldwide, royalty-free license, with the right to sublicense, under all relevant intellectual property rights, to use, publish, and disclose such Product Reviews and Feedback in any manner we choose and to display, perform, copy, make, have made, use, sell, and otherwise dispose of the Company’s and our sub-licensees’ products or services embodying such Product Reviews and Feedback in any manner and via any media we choose, without reference to the source. The Company shall be entitled to use Product Reviews and Feedback for any purpose without restriction or remuneration of any kind with respect to you and/or your representatives.
You are permitted, and hereby agree, to only provide personal information to the Company if such personal information is accurate, reliable, and relevant to our relationship and only to the extent such disclosure will not violate any applicable law, statute, or regulation or infringe upon a person’s data privacy rights or privileges. IF YOU PROVIDE PERSONAL INFORMATION (INCLUDING PERSONAL INFORMATION CONCERNING A THIRD PARTY) TO THE COMPANY, YOU EXPRESSLY REPRESENT AND WARRANT TO THE COMPANY THAT YOU HAVE THE FULL RIGHT AND AUTHORITY TO PROVIDE THE COMPANY WITH SUCH PERSONAL INFORMATION (INCLUDING PERSONAL INFORMATION CONCERNING A THIRD PARTY) AND THAT THE COMPANY’S USE AND PROCESSING OF SUCH PERSONAL INFORMATION AS SET FORTH HEREIN WILL NOT VIOLATE ANY PERSON’S RIGHTS OR PRIVILEGES, INCLUDING RIGHTS TO PRIVACY. YOU HEREBY AGREE TO FULLY AND COMPLETELY INDEMNIFY THE COMPANY FOR ANY CLAIMS, HARM, OR DAMAGES THAT MAY ARISE FROM YOUR PROVISION OF PERSONAL INFORMATION (INCLUDING PERSONAL INFORMATION CONCERNING A THIRD PARTY) TO THE COMPANY.
It is important that the personal information that you provide to us is accurate and reliable. In certain circumstances, you may have the ability to directly edit your online account with the Company to update and change your personal information (e.g., name, telephone number, email, shipping address), and you must do so when such changes are warranted. If your account does not contain such an editing feature, then you must notify the Company directly of any changes or updates to your personal information in accordance with the “Contact Us” section listed below.
You have the right to opt out of receiving email marketing communications and direct-mail marketing from us. Where required by law, the email marketing communications that you receive from us will provide you an option to “unsubscribe” from receiving future email marketing communications from us. You may also unsubscribe from email and direct-mail marketing by contacting us in accordance with the “Contact Us” section listed below. Due to production, mailing and system timelines, it may take some time to process your request. Until your requested change takes effect, you may still receive communications from us. If you send us your request by regular mail, please allow extra time for us to receive your notice. Please note: Although you may have opted not to receive communications, you may still receive business-related communications such as order confirmations, product recall notices, membership information, or other communications that are necessary to complete your transaction. You hereby agree to immediately notify the Company, in writing, in the event you no longer own, license, or use an email address to which you subscribed to receive email marketing from us.
Some web browsers may transmit “do-not-track” signals to the Site with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they are even aware of them. Unless otherwise required by law, we currently do not take action in response to these signals.
The Company hosts and uses video teleconferencing platforms to facilitate conferences, meetings, training events, and other programs. We often use online platforms that are owned and administered by a third-party service provider (e.g., Google, Zoom, WebEx, Skype for Business). Please be aware that our video teleconferencing may record the content, conversations, and discussions thereon, and such records may be stored or retained by our third-party service providers. By participating in our events and video teleconferencing, you hereby consent to the collection and retention of any information provided therein, and you hereby consent to the recording of such activities.
Data Protection Rights. If you are located in the EU, Switzerland, or the UK, you have the following data protection rights:
To exercise any of these data privacy rights, please contact us, or have your designated agent contact us, in accordance with the “Contact Us” section listed below. To the extent permitted by law, we will need to verify your identity (or the identity of your agent) and ensure the authenticity of your request.
Legal Basis for Processing. We process your personal information in accordance with the legal bases set forth in law. For example, our processing of personal information (as described herein) is justified based on the following legal grounds:
Complaints. In the event you have concerns about our data processing, you have the right to file a complaint with your data protection authority. For data protection authorities in the EU, please see here: https://edpb.europa.eu/about-edpb/about-edpb/members_en. For the data protection authority in Switzerland, please contact the Federal Data Protection and Information Commissioner (https://www.edoeb.admin.ch/edoeb/en/home.html). For the data protection authority in the UK, please contact the Information Commissioner’s Office (www.ico.org.uk). We would, however, appreciate the opportunity to deal with your concerns before you approach a data protection authority with a complaint, and invite you to contact us in the first instance.
Data Privacy Rights. If you are a resident of California you have the following data privacy rights:
Submit a Privacy Request. To submit a privacy request, you may contact us using any of the following means: (email) email@example.com, (webform) https://www.rpminc.com/contact-rpm/, (telephone) 1 (800) 776-4488, or (mail) RPM International Inc., ATTN: Privacy Request, 2628 Pearl Road, Medina, OH 44256. If you would prefer, you may designate an authorized agent to submit a CCPA privacy request on your behalf. An authorized agent must be registered with the California Secretary of State to conduct business in California.
Privacy Request Verification Process. If you (or your authorized agent) make any request related to your personal information, the Company will ascertain your identity (and the identity of the authorized agent, to the extent applicable) to the degree of certainty required or permitted under the law before addressing your request. In particular, the Company will, to the extent required or permitted by law, require you (or your authorized agent) to verify your request via email, request certain contact information or government identifiers, and we will match at least two pieces of such personal information with data that we have previously collected from you before granting you access to, erasing, or correcting, specific pieces or categories of personal information, or otherwise responding to your request. We may require written documentation that demonstrates a third party is authorized to serve as your agent for the purposes of submitting the requests set forth herein, unless you have provided the authorized agent with power of attorney pursuant to California Probate Code §§ 4121 to 4130. None of the CCPA’s rights, as amended by the CPRA, are absolute, and such rights are subject to legal and regulatory exceptions and exemptions. For more information about the CCPA or the CPRA, please see: https://oag.ca.gov/privacy/ccpa.
Opt-Out Rights / Do Not Sell My Personal Information. California residents have the right to opt out of the “sale” of their personal information. However, the Company does not sell your personal information to third parties for profit or monetary or other valuable consideration, and therefore we do not provide opt-out request processes for the sale of personal information (because we do not undertake such activities).
Opt-Out Rights / Do Not Share My Personal Information. California residents have the right to opt out of the “sharing” of their personal information. The Company uses third-party analytical and targeted advertising features on our Site and similar web tools provided by our marketing partners, and such features, tools and marketing relationships involve the disclosure of your personal information to third parties and may constitute the “sharing” of your personal information. To opt out of this sharing of your personal information in these circumstances, please click on the cookie management/settings tool (sometimes visible as a “Your Privacy Choices” or as a “Do Not Sell/Share My Personal Information”) link on the footer of the Site to set your cookie preferences. You, or your authorized agent, may also contact us in accordance with the “Contact Us” section listed below.
Children. The Site is not directed at, and should not be used by, minors under the age of eighteen (18), and therefore the Company does not knowingly sell or share the personal information of minors under eighteen (18) years of age.
Limit Use of Sensitive Personal Information. The Company does not use or disclose sensitive personal information for reasons other than those set forth in the CCPA, and therefore we do not provide individuals with the ability to limit how we use or disclose such sensitive personal information.
The Company does not currently conduct “sales” of personal information for purposes of Nevada law. Notwithstanding the foregoing, Nevada residents may submit a request directing us to not sell personal information we maintain about them to third parties who will sell or license their information to others. If you would like to exercise this right, please contact us in accordance with the “Contact Us” section listed below.
Virginia residents are entitled to the following data privacy rights:
Submit a Privacy Request. To submit a privacy request, you may contact us using any of the following means: (email) firstname.lastname@example.org, (webform) https://rpminc.com/contact/, (telephone) 1 (800) 776-4488, or (mail) RPM International Inc., ATTN: Privacy Request, 2628 Pearl Road, Medina, OH 44256.
Privacy Request Verification Process. If you (or your authorized agent) make any request related to your personal information, the Company will ascertain your identity (and the identity of the authorized agent, to the extent applicable) to the degree of certainty required or permitted under the law before addressing your request. In particular, the Company will, to the extent required or permitted by law, require you (or your authorized agent) to verify your request via email, request certain contact information or government identifiers, and we will match at least two pieces of such personal information with data that we have previously collected from you before granting you access to, erasing, or correcting, specific pieces or categories of personal information, or otherwise responding to your request. None of Virginia’s privacy rights are absolute, and such rights are subject to legal and regulatory exceptions and exemptions. For more information about the Virginia Consumer Protection Act, please see: https://lis.virginia.gov/cgi-bin/legp604.exe?211+ful+SB1392ES1.
Privacy Requests Appeals Process. If you would like to appeal a decision the Company has made with respect to your privacy request, please email email@example.com, with the subject line “PRIVACY REQUEST: APPEALS” and describe the nature of your request, and the reason requesting an appellate review. Virginia residents may file privacy complaints with the Virginia Attorney General (https://www.oag.state.va.us/contact-us/contact-info).
Opt-Out Rights / The Sale of Personal Information. Virginia residents have the right to opt out of the “sale” of their personal information. However, the Company does not sell your personal information to third parties for or monetary consideration, and therefore we do not provide opt-out request processes for the sale of personal information (because we do not undertake such activities).
Opt-Out Rights / Targeted Advertising. Virginia residents have the right to opt out of having their personal information used for targeted advertising purposes. The Company uses third-party analytical and targeted advertising features on our Site and similar web tools provided by our marketing partners. To opt out of this sharing of your personal information in these circumstances, please click on the cookie management/settings tool (sometimes visible as a “Your Privacy Choices” or as a “Do Not Sell/Share My Personal Information”) link on the footer of the Site to set your cookie preferences.
Opt-Out Rights / Profiling. Virginia residents have the right to opt out of having their personal information used for profiling in furtherance of decisions that produce legal or similarly significant effects. However, the Company does not engage in such activities.