Midrex Technologies Website Privacy Policy

1. Introduction

We at Midrex Technologies, Inc. as well as our subsidiaries, including Midrex UK Ltd.; Midrex Technologies India Private Limited; Midrex Metallurgy Technology Services (Shanghai) Ltd.; Midrex Technologies Gulf Services FZCO; and Midrex Global Logistics, Inc. (collectively, “Midrex”, “we”, “us”, or “our”) respect your privacy and are committed to protecting it through our compliance with this Website Privacy Policy (this “Policy”).  This Policy describes the types of information we may collect from you or that you may provide to us when you visit the websites https://www.midrex.com or https://www.midrexlogistics.com, any successor or subdomains thereof, or any other website where we post this Policy (collectively, our “Websites”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.  For clarity, “you” are a representative of one of our current or prospective customers, suppliers, vendors, or other business partners, a prospective job applicant, or some other user of our Websites.

Please read this Policy carefully. By accessing or using our Websites, you agree to this Policy. This Policy may change from time to time. When we make changes to this Policy, we will post the updated Policy on our Websites and update the Policy’s “Last Modified” date. We will also provide notice of any material changes as explained in the section below titled “Changes to Our Privacy Policy.” Your continued use of our Websites after we make changes is deemed to be acceptance of those changes.

2. Information We Collect About You and How We Collect It

a. Personal Information We Collect – Generally

We may collect several types of information from and about users of our Websites. This may include information by which users may be personally identified or information about a user that is maintained in personally-identifiable form (collectively, “Personal Information”). Specifically, we (or our third-party service providers acting on our behalf) may collect the following:

• Your full name;
• Your company or organization’s name, website address, and/or mailing address;
• Your company or organization’s industry, product line, and/or product description;
• Your position or job title with your company or organization;
• Your e-mail address;
• Your physical and/or mailing address;
• Your telephone number;
• The Technical Information described in the section below titled “Traffic, Usage, and Computer/Device Information;” and
• Any other information (including Personal Information) you choose to provide in any forms or messages submitted by you to us through our Websites or using the contact information provided on our Websites.

b. Personal Information We May Collect – Job Applicants

Please note that if you submit a job application through our Websites, we, or our third-party service providers, may collect additional information concerning your educational background, your employment background, referral source(s), work authorization information and any sponsorship or visa requirements, and any other information you choose to submit in connection with your job application. Please note that we will not knowingly collect certain information from European users of our Websites, such as your gender, ethnicity, information concerning your veteran or disabled-veteran status, religious beliefs, trade union membership, genetic/health data, and the like.

We use third-party service providers to collect and process certain Personal Information from a job applicant, which information may be collected and processed entirely by such third-party screening organizations. Please review the privacy policies of those third-party service providers in connection with an application for employment you may submit to us, which will address the terms applicable to the collection, processing, and handling of your personal information by those entities. For additional information, see section below “Third-party Sites and Services.”

c. How We Collect Information

We primarily collect Personal Information directly from you as you provide it or submit it to us, such as by signing up to receive our e-mails, e-newsletters, or other marketing or promotional information, applying for a job opportunity, responding to a voluntary survey you have agreed to complete, reporting a problem with our Websites, submitting an inquiry to us using the contact methods provided on our Websites, or otherwise contacting us about our Websites or our business. We (or our third-party service providers acting on our behalf) may also collect your Technical Information automatically as you navigate through or interact with our Websites (see section below titled “Traffic, Usage and Computer/Device Information”).

d. Traffic, Usage, and Computer/Device Information

Additionally, as you navigate through and interact with our Websites or interact with the e-mails we send to you, we or our third-party service providers may automatically collect certain traffic data, usage information, and information about your computer equipment or mobile device, such as your browser and operating system, your wireless carrier, the geographic region from which you are accessing the Websites, time-stamped logs regarding access times and duration of visits, the pages of our Websites that you visit, whether you opened the e-mail message we sent to you and whether you clicked on any links in the message, configuration data, clickstream analytics, and your actions and patterns when you use our Websites or interact with our e-mail messages (collectively, “Technical Information”).

The technologies we use for this automatic data collection may include cookies that are stored on the browser of your computer or mobile device, small embedded electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs), and other types of embedded code. We may collect this information to manage our content and improve users’ use of our Websites; to count and review the number of users of our Websites and their usage patterns; to track key performance indicators such as pages accessed, frequency of access, and other statistical information related to our Websites and the performance of our e-mail messages (for example, recording the popularity of certain content and verifying system and server integrity); to identify the portion of users who access our Websites via different web browsers or mobile operating systems; to recognize if a user is a return user of our Websites; to store information about a user’s visits; to remember a user’s preferences; and for similar purposes in connection with monitoring, operating, maintaining, and improving our Websites. Third parties may also collect Technical Information and other information on our behalf as further described in the section below titled “Tracking and ‘DO NOT TRACK’.”

3. How We Use Your Information

a. Generally

We use information we collect about you or that you provide to us, including Personal Information, to:

• Provide our Websites and their contents to you;
• Provide you with information, products, or services you request from us;
• Authenticate or otherwise verify your identity in connection with your requests and inquiries via the Websites or otherwise;
• Update and maintain subscription, e-mail, or mailing lists (such as our e-mail lists to receive e-newsletters or alerts by e-mail);
• Carry out the advertising, promotional, and marketing purposes as described in the section below titled “Use of Personal Information for Marketing Purposes”;
• Register you for seminars and other demonstrations or information sessions related to our products and services;
• If you are a Job Applicant, collect and process your application for a position with us and contact you in connection with such application;
• With respect to Technical Information, fulfill the purposes described in the section above titled “Traffic, Usage, and Computer/Device Information;”
• With respect to aggregated and de-identified information, fulfill the purposes described in the section below titled “Use and Disclosure of Aggregated or De-Identified Data;”
• Notify you about changes to our Website, our products or services, or this Policy;
• Develop and administer voluntary user surveys;
• Respond to lawful requests for information through court orders, subpoenas, warrants, and other legal processes or obligations;
• Enforce any contracts between you and us, including for billing and collection or for the establishment, exercise, or defense of legal claims; and
• Serve any other purpose that we describe when you provide the information and for any other purpose with your consent.

b. Use of Personal Information for Marketing Purposes

We (and certain third-party service providers acting on our behalf) may use your Personal Information for advertising, promotional, and other marketing purposes in various ways. These third-parties may include Constant Contact, Whova, Microsoft Dynamics 365, and SAP Business ByDesign, and may provide the following services with your consent:

• Providing you with informational and promotional content and materials regarding the Websites and our own products, services, and events, such as advertising and promotional information or information about special offers or promotions related to our products, services, and events;
• Processing event registration requests and other information regarding client seminars;
• Collecting and maintaining business contact details and related organizational information; and
• Providing you with informational and promotional content and materials regarding products and services we have developed in collaboration with third parties that we believe may be of interest to you.

If you do not want us to use your information in this manner, see the section below titled “Your Rights and Choices” for more information about how to opt out of such uses.

c. Third-party Sites and Services

Our Websites and e-mail messages to you may include links to blogs, social media, and third-party websites. These third-party sites have their own privacy policies and terms of use and are not controlled by this Policy. You should carefully review any terms, conditions, and policies of such third-party sites before visiting them or supplying them with any Personal Information. If you follow a link from our Websites or e-mail messages to any third-party site, any information you provide to that site will be governed by its own terms of use and privacy policy and not this Policy.

We are not responsible for the privacy or security of any information you provide to a third-party website or the information practices used by any third-party site, including those that are accessed via links from our Websites or e-mail messages. We make no representations, express or implied, concerning the accuracy, privacy, safety, security, or the information practices of any third-party site. The inclusion of a link to a third-party site on our Websites or in our e-mail messages does not constitute any type of endorsement of the linked site by us. We are not responsible for any loss or damage you may sustain resulting from your use of any third-party website or any information you share with a third-party website.

d. Use and Disclosure of Aggregated or De-Identified Data

We may convert or combine some Personal Information of users into de-identified or aggregated data that does not disclose any of the Personal Information of any individual user. We may use and disclose to third parties any such de-identified or aggregated data (including but not limited to traffic and usage data that does not identify you personally) for any lawful purpose.

e. Tracking and “DO NOT TRACK”

Tracking involves the use of cookies, web beacons, or other embedded code or tracking technologies to collect, analyze, and store information on a user’s behavior over time on multiple sites, including information on the sites visited, products viewed, products purchased, and other online interactions. Tracking information can be used to enable companies to make interest-based (behavioral) advertising available to users on multiple sites that they visit.

We do not currently collect Personal Information about your online activities over time and across third-party sites for tracking purposes when you use our Websites. In addition, we do not currently allow third parties to collect Personal Information through or using our Websites that could be used by them to analyze and store information about your online activities over time and across third-party sites for their own tracking purposes. Therefore, our Websites do not respond to any “do not track” signals sent by your computer, browser, or mobile device, and if your computer, browser, or mobile device sends a “do not track” signal to our Websites, our Websites will not treat you differently from users who do not send such signals.

4. Your Rights and Choices

a. Generally

You have certain choices regarding the Personal Information you provide to us. In particular, you can set your browser to refuse all or some browser cookies. If you choose not to accept cookies, you may be unable to access certain parts or pages of our Websites, or certain parts or features of our Websites may not function properly.

If you do not wish to have your Personal Information used by us to contact you with promotional or informational content or messages, you may send us an e-mail stating your request to info@midrex.com or you can opt out by simply clicking on the “Unsubscribe” or similar link in the most recent e-mail you received from us and by following the prompts that appear. This opt-out does not apply to information provided as a result of a subsequent product purchase, customer service or support service inquiry, or other informational or transactional communication, nor does it apply to your disclosure to a third party that is acting on our behalf and under our instructions in support of our permitted uses of your Personal Information.

b. Your Rights with Regard to Your Personal Information

You have the rights to access, rectify, withdraw consent, change, transport, object to the processing of, and request the deletion of certain portions of your Personal Information by sending us an e-mail at info@midrex.com. Please note that these requests will be addressed on a case-by-case basis, and that we may request verification of your identity before complying with such a request. In certain cases, we cannot delete your Personal Information. If we cannot delete your personal information, we will inform you of the reason(s).

c. California “Shine The Light” Disclosure

The California Civil Code permits California residents with whom we have an established business relationship to request that we provide a list of certain categories of Personal Information that we have disclosed to third parties for their direct marketing purposes during the preceding calendar year. To make such a request, please send an e-mail to info@midrex.com. Please mention that you are making a “California Shine the Light” inquiry. However, please know that we do not currently disclose Personal Information to third parties for their direct marketing purposes.

d. Nevada Residents: Sale Opt-Out Rights

Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to this designated address: info@midrex.com. Please mention that you are making a “Nevada Sale Opt-Out Right” request. However, please know we do not currently sell data triggering that statute’s opt-out requirements.

5. Users Outside of the United States

If you are accessing our Websites from Canada, the European Union, Asia, or any other jurisdiction with laws governing personal data collection, use, and disclosure that differ from United States laws, please note that by using our Websites and providing your Personal Information to us through our Websites you are expressly and knowingly consenting to the transfer of your Personal Information from your home country to the United States and other jurisdictions as indicated above (where laws may differ from the laws of your jurisdiction) and you are expressly and knowingly consenting to our use of such Personal Information in accordance with this Policy.

a. Canadian Users

If you are a user accessing and using our Websites from Canada then, upon your request, and subject to certain exceptions under applicable law, we will inform you of the existence, use, and disclosure of your Personal Information and give you access to that information, and you may challenge the accuracy and completeness of the information and have us amend it as appropriate. You may submit a request under this section by sending us an e-mail stating your request to info@midrex.com. Please indicate in your e-mail that you are making an individual access request under Canadian law.

b. European Users

If you are accessing our Websites from European Economic Area countries, Switzerland, or the United Kingdom (“European Users”), please note that by using our Websites and providing your Personal Information to us through our Websites you are expressly and knowingly consenting to the transfer of your Personal Information from your home country to the United States and other jurisdictions as indicated above (where laws may differ from the laws of your jurisdiction) and you are expressly and knowingly consenting to our use of such Personal Information in accordance with this Policy.

i. Legal Basis for Processing

If you are a European User, we have the legal right to collect, process, use, and retain your Personal Information in the ways described in this Policy or based on your consent, the need to use your Personal Information to provide you with goods or services that you have requested, and/or our legitimate interests in furthering our existing relationship with you or preventing fraud. If you do not provide such information, you may be unable to use our Websites and we may be unable to provide any products or services that you request.

ii. Transfers of Your European Personal Information

In connection with our collection and use of your Personal Information, we may transfer all or certain portions of your Personal Information to our servers in the United States or our third-party service providers in the United States. Accordingly, we are transferring your Personal Information from your country to the United States based on your explicit consent, because the transfer is necessary for the performance of a contract between you and us or the implementation of pre-contractual measures taken at your request, because the transfer is necessary for the conclusion or performance of a contract concluded in your interest between us and another natural or legal person (e.g., your organization), and/or because the transfer is necessary for the establishment, exercise, or defense or legal claims, and you acknowledge and agree that we may collect, use, and disclose your Personal Information, both before and after such transfer, in accordance with this Policy

iii. Storage of Your European Personal Information

We securely store your Personal Information in distributed locations in the United States and other countries using our own servers or the servers of reputable, third-party service providers such as our cloud-hosted infrastructure service providers and other cloud-based software service providers. For additional information on the retention of your Personal Information, see below section titled “Retention of Your Personal Information.”

iv. Your European Privacy Rights

We will at all times honor your rights with respect to your Personal Information. If you are a European User, you will have the following rights with respect to your Personal Information (your “European Privacy Rights”):

• Request access to your Personal Information and copies of same that we hold about you;
• Request correction of your Personal Information;
• Request erasure of your Personal Information, where there is no legal obligation or legitimate interest for us to retain such information;
• Request restriction of processing of your Personal Information;
• Request the transfer of your Personal Information to you or to a third party;
• You may object to processing of your personal data where we are relying on a legitimate interest (or those of a third party); and
• You may withdraw consent at any time where we are relying on consent to process your Personal Information.

Any such requests should be made to us at info@midrex.com. Please indicate in your e-mail that you are making such a request under your European Privacy Rights. Generally, you will not have to pay a fee to exercise any of your European Privacy Rights. We may, however, charge a reasonable fee if a request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in those circumstances. We try to respond to all legitimate requests related to European Privacy Rights within a reasonable timeframe. Occasionally, it may take us longer if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated of our progress.

Please note that we may require verification of your identity before complying with any of the above requests, to the extent necessary to protect Personal Information and to ensure this information is not disclosed to any person not authorized to receive it. If we cannot comply with a request with respect to your Personal Information as a result of legal obligations or other legitimate interest, we will notify you in writing. You have the right to lodge a complaint with the competent authority in your country of residence concerning the processing of your Personal Information.

6. Retention of Your Personal Information

We will only process and retain your Personal Information so long as it is necessary to achieve the above-mentioned purposes. We will delete your such information when it is no longer necessary for the above-mentioned purposes, or if you request that we delete it. In some cases, we may have a continuing legitimate interest or legal obligation to retain your Personal Information after a request. For example, we may retain your such information to resolve disputes, enforce contractual obligations, or comply with legal requirements, including retention for purposes of complying with taxation; in such events, your Personal Information will not be utilized for any other purposes.

7. Children Under the Age of 16

We are committed to the protection of children’s online privacy. Our Websites and our products and services are not intended to be used by children under 16 years of age, and we do not knowingly collect Personal Information from children under age 16. If you are under 16 years of age, do not use or provide any information on the Websites or provide any information about yourself to us. If we learn we have collected or received Personal Information from a child under 16 years of age without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under age 16, please contact us at info@midrex.com.

8. Data Security

We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. The safety and security of your information also depends on you. Unfortunately, the transmission of information over the Internet is not completely secure. Although we have implemented security measures that we think are adequate, we cannot guarantee the security of your Personal Information transmitted to or using our Websites. Any transmission of Personal Information is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on our Websites.

9. Change to Our Privacy Policy

We post any changes we make to our Policy on this page. If we make material changes to how we treat your Personal Information, we will notify you by e-mail to the primary e-mail address we have on file for you and through a notice on the home page of https://www.midrex.com. The date the Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date, active, and deliverable e-mail address for you, and for periodically visiting our Websites and this Policy to check for any changes. Please note that we will not collect additional categories of personal information beyond those disclosed in this Policy without providing additional notice to you, and we will not use your Personal Information for additional purposes beyond those disclosed in this Policy without providing notice and obtaining your consent.

10. Disclaimer

This website and the trademarks, copyrights, service marks and logos appearing on this website are the property of Midrex Technologies, Inc. or other related parties. Except as otherwise expressly permitted under copyright law, you may not copy, download, print, remove, publish, redistribute, modify, transmit, display, sell, create derivative works from, or in any way exploit any content of this Site without the express permission of Midrex. Any further rights not specifically granted herein are reserved.

The data, documents, files and information contained in this website have been provided for information purposes only. All services and content included in or available through this Site are provided “as is” and “as available” for use. These services and content are provided without warranties of any kind, either express or implied. Neither Midrex Technologies, Inc., nor its content providers or management or personnel can be held responsible for any errors or omissions in the content of this website, or for any direct, incidental, special, consequential or any other kind of damage or loss whatsoever arising out of or in connection with the use of this website or the information contained herein. Midrex reserves the right to alter, at any time, without prior notice, the elements and/or content of this website, including but not limited to the information, structure, URL and contents. Midrex also reserves the right to interrupt or discontinue operation of this website at any time without prior notice.

11. Contact Information

We are Midrex Technologies, Inc., a Delaware corporation with headquarters in Charlotte, North Carolina. To ask questions or to submit comments about this Policy or your Personal Information, you may contact us:

• Via E-mail: info@midrex.com
• Via Telephone: (704) 373-1600
• Via Postal Mail: 3735 Glen Lake Drive, Suite 400, Charlotte, NC 28208