PRIVACY POLICY
We respect your privacy and we are committed to protecting your personal data. This privacy policy will inform you as to how your personal data is handled when you visit our website. This applies regardless of where you visit it from. It also informs you about your privacy rights and how the law protects you.
Purpose of this privacy policy
Our privacy policy serves the purpose of giving you information on how we collect and process your personal data, including through your use of this website. This includes any data you may provide through this website when you contact us via our contact forms.
This website is not intended for children. Torminerals does not knowingly collect or solicit personal data from children under the age of 16. If we learn that we have collected personal data from an individual under the age of 16, we will promptly delete that information.
The data we collect about you
We collect, use, store and transfer different types of personal data about you, which we have grouped as follows:
- Identity Data including first name, last name, username or similar identifier.
- Contact Data including address, email address and telephone numbers.
- Technical Data including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Usage Data including information about how you use our website and services.
We do not knowingly collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data), nor do we collect any information about criminal convictions and offences.
We will let you know which information is required or optional (on the form on which we collect your data or, where applicable, orally). Failure to provide the information required may prevent us from responding to you or providing you with the product or service you request.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Lawful bases for the processing of personal data
We use your personal data in accordance with applicable law. In particular, we use your personal data in the following circumstances:
- Where necessary to perform the contract we are about to enter into or have entered into with you.
- Where necessary for our legitimate interests, or those of a third party, which we can further explain upon request.
- Where necessary to comply with a legal or regulatory obligation to which we are subject.
We also may use the information we collect about you in other ways for which we provide specific notice at the time of collection and obtain your consent if required by applicable law.
Purposes for which we will use your personal data
We have set out below a description of the purposes for which we use your personal data, and information on the lawful bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.
Please contact us using the details set out below if you have any queries about this table and the lawful bases we rely on for processing your personal data.
| Purpose of the Processing Activity | Type of Personal Data we process | Lawful Basis(es) for Processing |
| To register you as a new customer | (a) Identity Data
(b) Contact Data |
Performance of a contract with you |
| To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey |
(a) Identity Data
(b) Contact Data (c) Profile Data (d) Marketing and Communications Data |
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to keep our records updated and to analyze how customers use our products/services) |
| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity Data
(b) Contact Data (c) Technical Data |
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise) |
| To deliver relevant website content and measure or understand the effectiveness of the content we serve to you | (a) Identity Data
(b) Contact Data (c) Profile Data (d) Usage Data (e) Marketing and Communications Data (f) Technical Data |
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve our website, products/services, marketing, customer relationships and experiences | (a) Technical Data
(b) Usage Data |
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
| To make suggestions and recommendations to you about goods or services that may be of interest to you and to provide details of our exclusive offers | (a) Identity Data
(b) Contact Data (c) Technical Data (d) Usage Data (e) Profile Data |
Necessary for our legitimate interests (to develop our products/services and grow our business) |
| To send you promotional materials, newsletters and other communications about our products and services | (a) Identity Data
(b) Contact Data (c) Marketing and Communications Data |
Necessary for our legitimate interests (to market our products and services) |
Marketing activities
Subject to applicable law, we will collect your consent to send you marketing communications about our products and services. You can opt-out at any time from receiving marketing messages simply by clicking the “unsubscribe” link in the footer of any of our marketing communications. Alternatively, consent to direct marketing can be withdrawn by emailing unsubscribe@torminerals.com. This will not affect the lawfulness of other data processing activities described above.
Further processing
We will only use your personal data for the purposes for which we collected it, in accordance with this policy and applicable law, unless we reasonably consider that we need to use it for another purpose and that purpose is compatible with the original purpose for which personal data was collected. In that case, we will notify you and we will explain the lawful basis which allows us to do so.
Disclosure of your personal data
We may share your personal data with the following data recipients, for the purposes set out in the table :
- Our affiliates and subsidiaries in the Netherlands, the U.S. and Malaysia; and
- Our service providers who perform services on our behalf including CLDO Consulting
We require our service providers to respect the security of your personal data and to treat it in accordance with the law. We do not allow our service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes, in accordance with our instructions and applicable law.
If you are located in the European Union (“EU”), please note that s of these data recipients are located outside the EU, including in jurisdictions that have not been recognized by the European Commission as providing an adequate level of data protection, such as the United States or Malaysia. In this event, Torminerals ensures that appropriate safeguards aimed at ensuring such a level of data protection are in place, including by selecting service providers that are certified to the EU-U.S. and Swiss-U.S. Privacy Shield frameworks pursuant to article 45 of the GDPR, or executing data transfer agreements based on the European Commission’s Standard Contractual Clauses pursuant to article 46 of the GDPR.
Your rights
Subject to applicable law you may (1) have the right to access personal data we maintain about you; (2) request that we correct or erase your personal data; (3) have the right to obtain the restriction of our processing of your personal data; and (4) object at any time to the processing of your personal data on grounds relating to your particular situation and, in any event, to the processing of your personal data for direct marketing purposes; and (5) where you have consented to the processing of your personal data, you have the right to withdraw your prior consent at any time. Subject to applicable law, you also have the right to receive, in a structured, commonly used and machine-readable format, the personal ata that you have provided to us about you, with your consent or based on a contract to which you are party. You also have the right to have this information transmitted to another data controller, where it is technically feasible. You also may lodge a complaint with the relevant supervisory authority for data protection issues in your country, if you are not satisfied with our responses.
Retention of Personal Information
To the extent permitted by applicable law, we retain personal data we obtain about you for the duration of our contractual relationship, plus a reasonable period in order to be able to run regular deletion routines or to take into account the applicable statute of limitation period or to comply with mandatory applicable law.
Cookies
Our website uses “cookies”. A “cookie” is a small text file containing a random and unique identifier that either we or a business partner, such as a third-party web analytics provider, transfers to your computer through your web browser. We use cookies to recognize your browser, track your movement through the website, track the point of registration for those users signing up for mailings or programs, and to track and measure the success of a marketing campaign.
- Analytics cookies
Analytics cookies help us understand our visitors’ needs and interests. Analytics cookies collect information such as your IP address and information about your visits to our website. We use that information to improve our website and the services offered on the individual pages. Additionally, these cookies are used to gather statistical information on how the website is browsed. Some of these analytics cookies are provided by third-party analytics providers, including Google, which provide us Search Engine reports, information and analytics on our behalf across the internet. These cookies are persistent cookies which remain on your computer or other Internet-connected device for a certain period of time after you end your browsing session, unless you delete them.
The following analytics cookies are used on our website:
| Name of Cookie | Purpose of Use |
| [Please include the names of the analytics cookies used on the website] | Cookie used to [Please complete. E.g., hold audience segmentation information] |
| [Please include the names of the analytics cookies used on the website] | Cookie used to [Please complete] |
- Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
- How to control cookies
For the use of cookies described in this policy, we ask you for your consent through a pop-up banner displayed on our site when you first visit it, when you visit it after you have removed the cookies on your device, and when we have added new cookies. In addition, you can stop cookies from being downloaded on your computer by selecting the appropriate settings on your web browser. For more information about cookies, including how to set your internet browser to reject cookies, please go to www.allaboutcookies.org or http://www.networkadvertising.org. You can specifically opt-out of Google Analytics using this tool. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
Changes to the privacy policy
This privacy policy may be updated periodically to reflect changes in our personal data processing practices. We will notify you of such changes on our website.
Contact details
If you have questions about this policy or would like to exercise your rights, please contact us at:
Full name of legal entity: TORMINERALS
For the attention of: Digital Manager
Email address: digitalmanager@torminerals.com
U.S. Postal address: 722 Burleson St., Corpus Christi, TX 78402
EU Postal address: [Please complete]
Data Protection Officer: [Include DPO’s contact details here, if appropriate]