Privacy Notice
Effective Date: August 2018
This EU Privacy Notice provides information related to the following topics:
- Scope
- Information We Collect
- Purposes and Legal Bases for Use of Personal Information
- Disclosure of Information
- Cookies, Analytics and Targeted Ads
- Interest-based Advertising
- Direct Marketing
- International Transfers
- Security
- Retention
- Your Choices and Rights
- Third-party sites
- Information About Children
- Changes to this EU Privacy Notice
- Contact Us
Introduction
W. L. Gore & Associates, Inc. is a global company, providing a variety of services and products to consumers, customers, vendors, and suppliers. We recognize the importance of protecting the privacy of the personal information we collect and explaining how we handle the personal information of our website users, customers, vendors and suppliers. We encourage you to read this Gore EU Online Privacy (“EU Privacy Notice”) carefully so that you are informed about how we treat your personal information and what rights you may have in relation to your personal information.
Scope
This Gore EU Privacy Notice describes how W. L. Gore & Associates, Inc. and its affiliate and subsidiary companies (together, “Gore”, “we”, “us”, “our”) collect, use, and disclose personal information which is subject to EU Data Protection Laws. In this EU Privacy Notice we use the term “EU Data Protection Laws” to include the EU General Data Protection Regulation, the ePrivacy Directive, and associated national laws, and “personal information” (sometimes referred to as ‘personal data’) refers to information relating to an identified or identifiable natural person.
This EU Privacy Notice applies to our handling of personal information about users of of our websites, including associated pages and online services, that display this EU Privacy Notice (the “sites”), as well as personal information about our former, current and prospective customers and others with whom we do business, including our vendors, agents and service providers, users of our products, as well as others who engage with us regarding our products or services or otherwise communicate with us. It does not apply to the personal information we collect from our employees, associates or applicants for employment. Unless you are notified otherwise, W. L. Gore & Associates, Inc. is the controller of your personal information and where the processing of personal information is also undertaken by other Gore entities with whom you engage, they are joint controllers with W. L. Gore & Associates, Inc. for your personal information. See the “Contact Us” section below for a list of affiliate controllers and their locations and for details on how to contact Gore or exercise your rights with respect to your personal information.
This EU Privacy Notice does not address the collection, use or disclosure of information by any third parties, on other websites. In such cases, please refer to the respective privacy notice of such third parties.
Information We Collect
We may collect personal information directly from you, such as when you register for news and information, contact us online or submit forms through the sites. We may also collect personal information from third parties and automatically through your use of our sites.
Information Collected Directly
We collect information that you provide to us or share on the sites, such as:
- Registration, subscriptions and forms. Many of our sites and other information available on our sites can be accessed without registering. However, you will be required to register in order to use or access some of our services. The information that we collect will vary depending upon the context of your request, but for general inquiries, we require your first and last name and contact information, such as address, telephone number and email address, and other relevant information relating to your request. Fields marked with an asterisk are mandatory for processing your inquiry or your registration; all other details are optional.
- Communications. When you email us, call us or contact us, we maintain records about our interactions and communications with you.
- Customer Service and Support. We maintain records related to customer support and customer service-related requests, including the nature of the request in order to process questions or comments directed to our customer service team, or to settle complaints. For questions or comments directed to our customer service team relating to an order or invoice, or in the event of a product complaint, we may require additional information about the product, for example, product size, time and place of purchase and additional information about previous inquiries.
- Comments and Content. Some areas of the sites may allow you to comment, share or post other content. When you view this content, we keep a record of our content and it may be viewable by other users of the sites. You may ask us to remove such content as set out below.
- E-Commerce. If you purchase products from us directly, for example from our online stores for GORE WEAR® or ELIXIR® guitar strings, we will require additional information, such as billing and delivery address, and bank and/or credit card details. When you use our online store, we will use personal information to process contracts and orders that you have placed through our website, any inquiries relating to contracts and orders, as well as assess your creditworthiness when purchasing a product, for which we may contract a third-party service provider. When you purchase a product, we may contact you in order to ask you for your opinion on the purchase or the product.
- Accidents and Claims. We may collect personal information from individuals related to accidents and other claims. Information includes name, contact information, accident reports, payment details and other information necessary to asses or respond to claims.
- Business Relationship Information. We work with external professionals, contractors, suppliers, consultants and others in the operation of our business. For example, we may engage with suppliers, contractors, consultants and others who provide services or products to us. We also engage with customers and partners related to the provision of our products and services. We collect information such as business contact information, accounting and payment related information and other information related to our business relationship with a third party. We may also conduct due diligence and background checks subject to applicable law to ensure the reliability of third parties with whom we conduct business.
Automatically-collected Information.
When you visit the sites, some data is automatically transferred from your browser to our server, in order to offer you a better service with personalized information and to make it easier for you to use our sites. We use cookies, pixel tags, web beacons, and similar technologies to automatically collect information when users access or use the sites. This data is collected and processed by us or by external service providers on our behalf and includes, in particular, the following information:
Your IP address and device identifiers, browser type and operating system, the time spent on the website, pages you have visited and products you have viewed, and preferred languages. For more information, please refer to the Cookies Notice on the site.
Monitoring of Communications.
Subject to applicable laws we may monitor and record calls, emails, and other communications with us. We do this to protect the security of our communications systems and procedures, for quality control and staff training purposes, fraud detection and prevention, and when we need to see a record of what has been said between us. We will also monitor for regulatory compliance (where applicable) as well as crime prevention and detection purposes.
Purposes and Legal Bases for Use of Personal Information
In the course of conducting our business, we use personal information to provide and improve our services, to provide information about our products and services, to process job applications, to respond to requests and to otherwise communicate with you and others.
Legal Bases
In general, we use personal information for the purposes set out in the table below, under the following legal bases:
- Perform / Enter into Contract with You: as necessary to enter into or perform any type of contract with you.
- Comply with Law: for compliance with our legal obligations under EU law, including responding to legal and regulatory requests and court orders.
- Establish, Defend and Protect Legal Rights: as necessary to establish, defend and protect our legal rights and interests, or those of third parties.
- Legitimate Business Interests: Pursuant to our legitimate business interests, to improve the way we deliver our Services, to develop new offerings and tools, for industry benchmarking and trend analysis, to deliver more relevant content and information, to secure our systems, and to prevent misconduct and fraud, which are not overridden by your interests and fundamental rights.
- Explicit Consent: for sensitive data, with your express consent, or where necessary to carry out our obligations under employment, social security and similar laws.
We may also create anonymous and aggregated data sets and reports in order to assess, improve and develop our business, products and services, prepare benchmarking reports on our industry, and for other research and analytics purposes; provided this data is not identifiable to, and cannot be linked or re-identified to a particular individual, it is no longer subject to the restrictions in this EU Privacy Notice.
Purposes of Processing | Legal Bases of Processing |
Verifying Identity and Authorisation
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Services, Events, and Customer Service
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Operate our Business
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Research. Development and Reporting
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Personalised Support and Content
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E-Commerce
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Marketing, Surveys, and Promotions
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Evaluating and Engaging With Third Parties
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Protecting Our Legal Rights and Prevent Misuse
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Complying with Legal Obligations
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Disclosure of Information
Gore is a global enterprise that consists of various entities worldwide. For more information, see the list of Gore affiliates. To facilitate Gore’s global operations personal data may need to be shared with and transferred between Gore affiliates. Gore affiliates may access and use your personal data as described in this EU Privacy Notice.
We do not sell your personal information to third parties. In general, we disclose the personal information we collect as follows:
- Gore Affiliates. As a global company, your personal information may be shared amongst our affiliated and subsidiary companies (listed here), who are subject to this EU Privacy Notice when processing your personal information.
- Service Providers. We may share your information with third party service providers, whose services we use, for example, for web hosting, data analysis, IT technology, infrastructure and security. With third parties whose services we use to provide customer services, for example for communicating with you by email or phone, for market research, carrying out surveys, handling payment transfers, advisory services, maintenance and other similar services.
- Third-Party Advertising and Marketing. Third-party companies that we work with to display online advertising that is more relevant may collect cookie IDs, IP address and other identifiers as well as information about the pages you visit on our sites and other websites, to enable them to display advertising for products and services that may be of interest to you when you visit our website or other websites.
- Business Transfers. We may disclose or transfer information, including personal information, as part of any in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including without limitation in connection with any bankruptcy or similar proceedings), including related to due diligence conducted prior to such event where permitted by law.
- Legally Required. We may disclose your information if we are required to do so by law (e.g., to law enforcement, courts or others, e.g., in response to a subpoena or court order).
- Protect our Rights. We may disclose information where we believe it necessary to respond to claims asserted against us or, comply with legal process (e.g., subpoenas or warrants), enforce or administer our agreements and terms, for fraud prevention, risk assessment, investigation, and protect the rights, property or safety of Gore, our customers or others.
- Anonymized and Aggregated Data. We may share aggregate or de-identified information with third parties for research, marketing, analytics and other purposes, provided such information does not identify a particular individual.
Cookies, Analytics and Targeted Ads
We and our service providers use cookies, pixels, java script and other tracking mechanisms to track information about your use of our Site and Services, and we may combine this information with other information, including personal information, we collect about you. We may also work with third party ad networks, analytics companies, measurement services and others to display advertising on our Services, and to manage our advertising on third party sites, mobile apps and online services. Please also see our Cookie Notice for more information about how we use cookies and work with third party ad networks and analytics providers.
Interest-based Advertising
On some of our sites, we may work with third party ad networks, analytics companies, measurement services and other parties (collectively “ad companies”) to display advertising on our sites, and to manage our advertising on third-party sites, mobile apps and online services. We and these third-party ad companies may use cookies, pixels tags, and other tools to collect activity information on our sites (as well as on third party sites and services), as well as IP address, device ID, cookie and advertising IDs, and other identifiers, general location information, and, with your consent, your device’s geolocation information; we and these third party ad companies use this information to display you more relevant ads and content and to evaluate the success of such ads and its content.
Please see our Cookie Notice for information about the third parties we may work with to display targeted ads.
Direct Marketing
We may send periodic promotional emails to you, and where required by law we will obtain your consent to do so. If you would like to opt-out of receiving further electronic communication from Gore, and/or wish to stop Gore disclosing your personal data for marketing purposes, you can contact us to withdraw your consent. You may opt-out of such communications by following the opt-out instructions provided in the email. If you opt-out of receiving emails about recommendations or other information we think may interest you, we may still send you emails about administrative emails relating to your account or any services you have requested or received from us.
International Transfers
As a global company we may transfer your personal data to, access or store it in, and subject to requests from law enforcement in jurisdictions outside of your home jurisdiction, the United States, Japan, Hong Kong, the European Union, and other jurisdictions (see affiliated companies listed here) in which we (or our service providers) operate. Some of these jurisdictions, including the United States, may not provide equivalent levels of data protection as your home jurisdiction. We will take steps to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it, including through appropriate written data processing terms and/or data transfer agreements.
If you are in the European Economic Area, and we process your personal information in a jurisdiction that the European Commission has deemed to not provide an adequate level of data protection (a "third country”), we will implement measures to adequately protect your personal information, such as putting in place standard contractual clauses approved by the European Commission (the form for these clauses can be found here or another measure that has been approved by the EU Commission as adducing adequate safeguards for the protection of personal information when transferred to a third country.
Security
We have implemented organizational, technical, and administrative measures to protect personal data under our control from unauthorized access, use, or disclosure. While the security safeguards we have put in place are routinely reviewed and updated, the security of any data transmissions and data storage systems cannot be completely guaranteed.
Retention
As a general rule, we will retain your personal data for the period necessary to fulfill the purposes outlined in this EU Privacy Notice until all such purposes cease to exist, unless a longer retention period is required or permitted by law. The retention period depends on the information and the reason for which we have collected it. For example, we generally retain personal data records related to technical support and customer service requests for seven years, unless a longer or shorter retention period is required by law, is necessary in the course of legal obligations, to resolve disputes, maintain appropriate business records, and enforce our agreements proceedings or is otherwise needed for a particular purpose under applicable law.
Your Choices and Rights
We will take steps to maintain accurate and complete personal information about you. In order to do so, we need you to notify us of changes in your personal circumstances (for example, change of address) so that we can update our records. Subject to the conditions set out in the applicable law you have the following rights with regard to our processing of your personal information:
- Your right of access. If you ask us, we will confirm whether we are processing your personal information and, if necessary, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.
- Your right to correction (rectification). If the personal information we hold about you is inaccurate or incomplete, you are entitled to request to have it corrected. If you are entitled to have information corrected and if we have shared your personal information with others, we will let them know about the rectification where possible. If you ask us, we will also tell you, where possible and lawful to do so, with whom we have shared your personal information so that you can contact them directly.
- Your right to erasure. You can ask us to delete or remove your personal information in some circumstances, such as where we no longer need it or if you withdraw your consent (where applicable). If you are entitled to erasure and if we have shared your personal information with others, we will let them know about the erasure where possible. If you ask us, we will also tell you, where it is possible and lawful for us to do so, with whom we have shared your personal information with so that you can contact them directly.
- Your right to restrict (block) processing. You can ask us to restrict the processing of your personal information in certain circumstances, such as where you contest the accuracy of that personal information or you object to our use or stated legal basis. If you are entitled to restriction and if we have shared your personal information with others, we will let them know about the restriction where it is possible for us to do so. If you ask us, we will also tell you, where it is possible and lawful for us to do so, with whom we have shared your personal information so that you can contact them directly.
- Your right to data portability. You have the right, in certain circumstances, to receive a copy of personal information we have obtained from you in a structured, commonly used and machine readable format, and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.
- Right to object. You can ask us to stop processing your personal information, and we will do so, (i) to the extent that we are relying on our legitimate interests to use your personal information, in which case you have the right to object to such use, unless we can either demonstrate compelling legitimate grounds for the use that override your interests, fundamental rights and freedoms or where we need to process the data for the establishment, exercise or defence of legal claims, and (ii) where we are processing your personal information for direct marketing purposes.
- Your rights in relation to automated decision-making. You have the right not to be subject to a decision when it is based on automatic processing if it produces a legal effect or similarly significantly affects you, unless it is necessary for entering into or performing a contract between us.
- Your right to withdraw your consent. In the event your personal information is processed on the basis of your consent, you have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
- Your right to lodge a complaint. You also have the right to lodge a complaint with a supervisory authority if you consider that the processing of your personal information infringes applicable law.
Please note that some of these rights may be limited, such as where we have an overriding interest or legal obligation to continue to process the data. Please contact us as indicated in the “Contact Us” section below if you wish to exercise any of your rights, or if you have any enquiries or complaints regarding the processing of your personal information by us.
Third-party sites
This EU Privacy Notice does not address, and we are not responsible for, the privacy practices, information collected, or other activities and practices of any third parties. The inclusion of a link on the website does not imply endorsement of the linked site by us or by our affiliates.
In some cases, we may permit you to use third-party payment services to make payments. If you wish to make a payment using a payment service, you will be directed to a webpage that is hosted by the payment service and not by us. Any information that you provide through this page will be subject to the applicable payment service’s privacy policy, rather than this EU Privacy Notice. We do not have control over, and are not responsible for, any payment service’s use of information collected through any payment service page.
Use of Website by Children
Our sites are not directed at individuals under the age of sixteen (16) and we request that these individuals refrain from providing any personal data to us. We do not knowingly collect any personal information from children under the age of 16. If you have reason to believe that a child under the age of 16, without a parent or guardian's consent, has provided personal information to us through the sites, please contact us at [email protected].
Changes to this EU Privacy Notice
We may change this EU Privacy Notice from time to time to reflect changes, and will indicate changes by posting the new version of this EU Privacy Notice (and effective date) on this website and in case we make any material changes that affect how we treat your personal information, we will try to notify you in advance, by prominently adding a note to the homepage or by directly sending you a notification. We encourage you to periodically review this website and our EU Privacy Notice to understand how Gore protects your personal information. Once effective, the revised EU Privacy Notice will apply to you and your personal information.
Contact Us
If you have questions or concerns regarding this EU Privacy Notice, please contact our EU Data Protection Officer via email at: [email protected].