Data Privacy Notice

Vesuvius plc and its subsidiaries (“Vesuvius Group” or "We") are committed to protecting and respecting your data privacy.

This notice (together with our Terms of Use and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

In accordance with the Data Protection Act 2018 and General Data Protection Regulation (EU Directive 95/46/EC) (the “Act”), Vesuvius plc is registered as a “Data Controller” on the public Register of Data Controllers as maintained by the Information Commissioner in the United Kingdom.

1. Important information and who we are

Purpose of this data privacy notice

This data privacy notice aims to give you information on how Vesuvius collects and processes your personal data through your use of our website, and your other interactions with Vesuvius including potential and ex-employees, customers, suppliers and shareholders. This includes any data you may provide through our website, when you sign up to or benefit from our services or business or purchase or supply a product or service.

By visiting vesuvius.com, vesuvius.de, foseco.com, cid.vesuvius.com, supplier.vesuvius.com, fosecoindia.com, vesuviusindia.in and investors.vesuvius.com you are accepting and consenting to the practices described in this notice.

This website is not intended for use by children and we do not knowingly collect data relating to children.

It is important that you read this data privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This data privacy notice supplements the other notices and is not intended to override them.

Controller

Vesuvius Group is made up of different legal entities, details of which can be found here. This data privacy notice is issued on behalf of the Vesuvius Group so when we use ”Vesuvius”, “we”, “us” or “our” in this data privacy notice, we are referring to the relevant company in the Vesuvius Group responsible for processing your data acting as data controller. Vesuvius Holdings Limited is the controller responsible for our website.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this data privacy notice. If you have any questions about this data privacy notice, including any requests to exercise your rights, please contact the DPO using the details set out below.

Contact details

The Vesuvius Group Data Protection Officer is:

Helen Botting, Legal Counsel and DPO
Telephone: 0044 7780956787
Email address: [email protected]

We have also appointed Data Protection Officers in countries where there is a legal requirement to do so. For information, please contact the DPO.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on 8th September 2022 and historic versions can be obtained by contacting the DPO.

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.

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 notice of every website you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer the following types of personal data about you:

Identity Data includes [first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender, CV and employment details (Vesuvius or other employers) and in limited circumstances Identity Data of your dependents when provided by you].
Contact Data includes [billing address, delivery address, email address and telephone numbers].
Financial Data includes [bank account and payment card details].
Transaction Data includes [details about payments to and from you and other details of products and services you have purchased from us or details about products and services you have supplied to us].
Technical Data includes [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].
Profile Data includes [your username and password, purchases or orders made by you, your interests and preferences].
Usage Data includes [information about your visit to our websites, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page].
Marketing and Communications Data includes [your preferences in receiving marketing from us and your communication preferences].

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not 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.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that personal data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your [Identity, Contact and Financial Data] by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

- apply for our products or services;

- sell us your products or services;

- create an account or register your interest on our website;

- subscribe to our service or publications;

- request marketing information to be sent to you;

- register as a shareholder or director of a Vesuvius company;

- receive benefits as an ex employee or a dependent of an ex employee;

- contact us in relation to human resources and recruitment purposes;

- contact us with a general enquiry or correspondence

- use and interact with us using Microsoft Forms

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. Please see our cookie policy for further details.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

- Technical Data from the following parties:

(a) analytics providers such as Google outside the EU;

(b) search information providers based inside or outside the EU;

- Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside or outside the EU.

- Identity, Contact and Financial Data from benefit and shareholder service providers based inside or outside the EU

- Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.

4. How we use your personal data

We will only use your personal data in accordance with applicable Data Protection Legislation. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by unsubscribing to those direct marketing communications.

Purposes for which we will use your personal data

We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact the DPO if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new customer

(a) Identity

(b) Contact

Performance of a contract with you

To register you as a user of further functionality within our websites, such as www.foseco.com

(a) Identity

(b) Contact

(d) Profile Data

Necessary for our legitimate interests (to enable the facility to download case studies, technical datasheets and technical articles free of charge as often as you like and to allow us to keep you updated with latest news and developments on our products/services)

To process and deliver your order including:

(a) Manage payments, fees and charges and our ongoing customer relationship

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To purchase goods and services from you including:

(a) Manage payments, fees and charges and our ongoing supplier relationship

(a) Identity

(b) Contact

(d) Transaction

(e) Marketing and Communications

(a) 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 notice

(a) Identity

(b) Contact

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To manage our relationship with you as a shareholder or director of a Vesuvius company

(a) Identity

(b) Contact

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

To provide you with benefits you are entitled to as an ex employee of Vesuvius or a dependent of an ex employee.

(a) Identity

(b) Contact

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(a) 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 reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

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 manage our relationship with you in relation to human resources and recruitment purposes.

(a) Identity

(b) Contact

(a) Necessary for our legitimate interests (for providing recruitment services)

To respond to a general enquiry or correspondence from you.

(a) Identity

(b) Contact

(a) Necessary for our legitimate interests (to provide a response to your enquiry or correspondence)

To collect and manage data provided by you using Microsoft Forms

(a) Identity

(b) Contact

(a) Performance of a contract with you

(a) Necessary for our legitimate interests (to provide a service in relation to the data provided by you)

Marketing

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details during a marketing event/trade fair or registered for marketing information and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside the Vesuvius Group for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, sale experience or other transactions where we have a legitimate interest to keep any personal data that is necessary.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see the Vesuvius Cookie Policy.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact the DPO.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

The Vesuvius Group and its employees
Consultants and agents of the Vesuvius Group in order to provide specific services
External Third Parties providing services in relation to shareholders, ex employees and their dependents, customers and suppliers such as:

- Database providers

- Pension trustees

- Employment agencies

- Banks

- Debt Collectors

- Service providers who provide services such as IT and system administration services

- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services

- HM Revenue & Customers, regulators and other authorities who require reporting of processing activities in certain circumstances

- Agents and consultants of Vesuvius for the purpose of providing goods and services.

External Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

We share your personal data within the Vesuvius Group. This will involve transferring your data outside the European Economic Area (EEA).

We ensure your personal data is protected by maintaining appropriate technical and contractual measures to prevent the unauthorised disclosure of your personal information by implementing the following safeguard for intercompany transfers:

Within the Vesuvius Group, we use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
Where we use certain service providers in countries that have been deemed not to provide an adequate level of protection for personal data by the European Commission, we require those service providers to enter into a contract with us confirming that the appropriate technical measures and safeguards are in place for the same protection of personal data as in Europe.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from the DPO.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal information to another party.
Right to withdraw consent where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact the DPO or the Human Resources representative of your local Vesuvius Operating Company.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month 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.

10. Glossary

Lawful basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.