Privacy Statement
Revised: April 22, 2022
This website privacy policy covers Hemlock Semiconductor Operations LLC’s, Hemlock Semiconductor, L.L.C.’s and Hemlock Semiconductor Pte. Ltd.’s (collectively, “Hemlock Semiconductor” “we” or “us”) corporate website, www.hscpoly.com. Hemlock Semiconductor, is the sole owner of information collected on this site.
BY USING THIS WEBSITE, YOU AGREE TO BE BOUND BY THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH ANY OF THE TERMS OF THE PRIVACY POLICY, PLEASE DO NOT USE THIS WEBSITE OR PROVIDE US WITH YOUR INFORMATION.
1. Our pledge to you
Your privacy is important to us. Hemlock Semiconductor is committed to safeguarding your privacy, and we will not share any personal information we collect through this site with third parties except as described in this privacy policy without your consent. If you have questions about this privacy policy, please contact us as detailed at the end of this policy.
Hemlock Semiconductor will:
- NOT sell, rent, or lease your personal information
- NOT keep you on our mailing lists if you have requested to be removed
- NOT share your information with any trading partners unless you have requested information, products, or services that can be best handled by another company
Hemlock Semiconductor will:
- Treat your privacy very seriously and will adhere to this Privacy Policy
- Promote this Privacy Policy internally so all employees abide by it
- Keep this Privacy Policy accurate.
This Privacy Policy is subject to change so check back often.
2. What information do we collect and what do we do with it?
Information You Give Us
If you contact Hemlock Semiconductor, including via e-mail or a “Contact Us” form, we may keep a record of that correspondence and your contact information, which may include your first and last name, email address, mailing address, and phone number. Hemlock Semiconductor also occasionally asks users to complete surveys that we use for research purposes. From time to time we may provide you with special offers based upon information you have provided within your e-mail. Note: If you unsubscribe or remove yourself from our mailing lists it will not stop e-mail that responds to your specific request or activities, including follow up e-mail on samples, order confirmations, and responses to your questions.
Automatically Collected Information
Like most standard websites, we use log files to capture IP address, browser type, machine ID, referring/exit pages, platform type, date/time stamp, number of clicks, and other information. We use this information to analyze trends, administer the site, track users’ movement in aggregate, troubleshoot problems, and gather broad demographic information for aggregate use. IP addresses, etc., are not linked to personally identifiable information. However, if you are also registered on our site (by providing your e-mail address when asked in a variety of places), we capture your e-mail address in our log files in order to understand your interests to better serve you.
Information We Get from Others
We do purchase/rent/lease e-mail lists for which we do not have direct access to the addresses and therefore are unable to remove you from the e-mail communication if you have previously unsubscribed from receiving communications from Hemlock Semiconductor. We rely on the fact that you gave permission to the owner of the purchased/rented/leased e-mail list and therefore we are in compliance with this Privacy Statement.
Additional Used of Your Information
In addition to the purposes described above, Hemlock Semiconductor may use your personal information to manage and serve ads in the Site or on third party sites and to tailor ads to your interests and browsing history (see our Cookie Policy below for more details). For example, Hemlock Semiconductor uses an ad management partner, DoubleClick, to recognize a unique cookie on your Web browser, which in turn enables us to learn what advertisements bring users to our website. To support this interest-based advertising solution, we and the companies we have contracted with may use anonymous information about your visits to our and other websites and applications. The information collected and used by this process is always anonymous and does not enable any third party to identify you individually. You can learn more about interest-based advertising and opt out of such advertising from certain companies at aboutads.info.
We may use your personal information as we believe appropriate to: (a) investigate or prevent violation of the law or your agreements with us; (b) protect our, your or others’ rights, privacy, safety or property (including by prosecuting and defending legal claims); (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity; (d) comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities; and (e) where permitted by law in connection with a legal investigation. For example, we may share information with law enforcement to reduce the risk of fraud or if someone uses or attempts to use our site for illegal reasons.
3. How We Share Your Information
We will not share your personal information with third parties without your consent except in the following circumstances: as needed for third party service providers to provide us with services (for example, to help us design and operate this site, provide services to support the site, process your information, and provide communication on our behalf); with our partners who may offer services to you jointly with us; and as necessary to comply with applicable law and for other compliance, fraud prevention and safety purposes. Unless otherwise indicated at the time we collect your information, if we allow third parties to access the personal information we collect, we will have contractual provisions or other appropriate protections in place to ensure such access is for limited purposes and in compliance with this privacy policy.
4. Use of “Cookies” and other Tracking Technology
Cookies are pieces of information that are used to store and track information about you, and they are stored on your computer’s hard drive. We use cookies:
- To track usage so we can improve the site’s navigation, layout, and general design.
- To determine what is useful to users of the site.
- To determine areas you are interested in so that we are better able to serve you.
- So you do not have to enter your e-mail address each time you visit this site and/or each time you submit a “Contact Us” form.
We also place cookies with non-personally identifiable information such as last visit date, number of visits, survey and other information in order to not display information/offers you have already seen. We may from time to time place other cookies on your device with non-personally identifiable data in order to better support and serve you.
Cookies are not the only way to track visitors to a website. We may use similar technologies from time to time, like web beacons (sometimes called “tracking pixels” or “clear gifs”). These are tiny graphics files that contain a unique identifier that enable us to recognize when someone has visited our sites. If you sign up to receive our e-mails, we will also use cookies in conjunction with these emails. When your browser downloads any graphic content in the e-mail, we may also place a cookie on your computer that will tell us if you come to our site later.
Google Services
In addition to our own cookies and tracking technologies, we allow Google to place third-party cookies on our site. We use Google Analytics to help us gather statistical information about the visitors to our Site and how they use the Site on an anonymous, aggregate basis. We also use Google DoubleClick to help manage online advertising. However, we will not associate any data collected or used with these services with your personally identifiable data unless required to do so to cooperate with law enforcement activity or other governmental request or to comply with law. We may use this information to gain a better understanding of the users of our Site, to improve our Site, to improve our services, and to deliver more targeting advertising to you. Depending on the type of browser and device that you use, you may have the ability to control the type of information that Google uses. To understand how Google collects and processes data, click here.
How Can You Disable Cookies and Other Tracking Technology?
For more information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com.
Most browsers let you remove or reject cookies. To do so, locate your browser-specific options menu and delete the cookie files. Information about opting out of cookie-based advertising can be found at: http://optout.networkadvertising.org and https://www.neustar.biz/privacy/opt-out. Please keep in mind that cookies and similar technologies are an important part of how the Sites work, and removing, rejecting, or limiting the use of these tools might affect the availability and functionality of our Sites.
Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
5. Your Choices
You are not required to provide all personal information identified in this privacy policy to use our site or to interact with us offline, but certain functionality will not be available if you do not provide personal information. For example, if you do not provide personal information, we may not be able to respond to your request, perform a transaction with you, or provide you with marketing that we believe you would find valuable. You may opt out of marketing-related emails by following the opt-out prompt in the email. To opt out of other forms of marketing communications, please contact us using the contact information provided at the end of this policy.
6. Protection of Information; Data Transfers
Hemlock Semiconductor takes steps to ensure that your information is treated securely and in accordance with the relevant terms and conditions and this privacy policy. Unfortunately, data transmission over the Internet cannot be guaranteed as 100% secure. Therefore, while we strive to protect your information, Hemlock Semiconductor cannot ensure or warrant the security of this site, and you use it at your own risk.
Hemlock Semiconductor will release your personal information if required to do so by law or by search warrant, subpoena or court order.
The Hemlock Semiconductor website is currently hosted in the United States, but we may have affiliates and service providers located in other countries. Therefore, your personal information may be collected, used and stored in the United States or other locations outside of your home country. Privacy laws in the locations where we handle your personal information may not be as protective as the privacy laws in your home country. By submitting your information through this site, you are consenting to this information being processed by Hemlock Semiconductor and its services providers on servers located outside of your home country.
7. Other Important Privacy Information
Third Party Sites and Services
This site may contain links to other websites and services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. We do not control third party websites, applications or services, and we are not responsible for their actions. Other websites and services follow different rules regarding their collection, use and sharing of your personal information. We encourage you to read their privacy policies to learn more.
Verifying, Changing, and Deleting Your Information
You can contact us as detailed below and ask us to change, update or fix your information in certain cases, particularly if it is inaccurate. You can also request that we erase or delete all or some of your personal information or otherwise object to, limit, or restrict the use of such information (if we have no legal right or legitimate business interest in retaining such information).
Children
This site is not intended for use by anyone under the age of 13, nor do we knowingly collect or solicit personal information from anyone under the age of 13. If you are under 13, you should not attempt to use this site or send any information about yourself to us.
8. Notice to European Residents
The following applies to individuals in the European Economic Area.
Controller. Hemlock Semiconductor Operations LLC is the controller of your personal information covered by this privacy policy for purposes of European data protection legislation.
Legal bases for processing. We are required to inform you of the legal bases of our processing of your personal information, which are described in the table below. If you have questions about the legal basis of how we process your personal information, contact us using one of the methods detailed at the end of this policy.
| Processing Purpose | Legal Basis |
|---|---|
| To provide our site and communicate with you. | You are subject to a contract with us and we need to use your personal information to provide services you have requested or take steps that you request prior to providing services. |
| To send you marketing communications. For compliance, fraud prevention, and safety. | These processing activities constitute our legitimate interests. We consider and balance the potential impact on your rights before we process your personal information for our legitimate interests. We do not use your personal information 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). |
| For compliance with law. | Processing is necessary to comply with our legal obligations. |
| With your consent. | Where we specifically ask for your consent to process your personal information, such processing is based on your consent. Where we rely on your consent, you have the right to withdraw it anytime in the manner indicated on this site. |
| To share your personal information as described in this Privacy Policy. | This sharing constitutes our legitimate interests, and in some cases may be necessary to comply with our legal obligations. |
Retention. We will only retain your personal information 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 information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
Your Rights. European data protection laws give you certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:
- Access. Provide you with information about our processing of your personal information and give you access to your personal information.
- Correct. Update or correct inaccuracies in your personal information.
- Delete. Delete your personal information.
- Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice
- Restrict. Restrict the processing of your personal information.
- Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.
You may submit these requests by contacting us as detailed at the end of this policy. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.
Cross-Border Data Transfers. Any information you provide to us through the use of our site may be stored, processed, transferred among, and accessed from the United States and other countries which may not guarantee the same level of protection of personal information as the one in which you reside. However, we will handle your personal information in accordance with this Privacy Policy regardless of where your personal information is kept. Regarding transfers from the European Economic Area (EEA) and United Kingdom (UK) to the United States, we rely on the derogations for transfers which are necessary to perform the transaction with you. Where required by law, you may request a copy of the suitable mechanisms we have in place by contacting us as detailed below. If you reside in other non-US jurisdictions outside the EEA or UK, your use of our site or provision of any personal information constitutes your consent for the transfer of such data to the United States for the purposes identified above. If you have questions about cross-border transfers, please contact us as detailed below.
9. Notice to California Residents
The following section applies to California residents.
Shine the Light
Under California’s “Shine the Light” law, you have the right to ask us once a year if we have shared your personal information with third parties for direct marketing purposes. To make a request please contact us as instructed at the end of this Policy and specify you are making a Shine the Light request.
California Consumer Privacy Act (“CCPA”)
The CCPA creates consumer privacy rights and requires businesses to make disclosures about their privacy policies and practices. Pursuant to the CCPA, both our privacy practices and your privacy rights are discussed in detail in the following information.
Personal Information We Collect. We collect your personal information when you interact with our site or otherwise communicate with us. For the purposes of this privacy policy, “personal information” means information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device. We have collected the following categories of personal information covered by the CCPA from consumers within the past 12 months, and have used it for the following business purposes:
| Category of Personal Information Collected | Business Purpose of Collection | Source(s) of information |
|---|---|---|
| Identifiers, including real name, mailing address, email address, telephone numbers, and unique personal identifiers such as online identifiers and IP address | To provide our site, products and services and to market our products and services to you | Directly from you when you contact us or respond to promotions as well as through third party mailing lists |
| Geolocation data | To provide our products and services and assist in marketing and identify website traffic patterns | Passively when you visit our site |
| Internet or other electronic network activity information, including browsing history, search history, and information regarding an individual’s interaction with an internet site, application, or advertisement | To provide you more relevant content, track original site visits, and optimize your site experience as well as to ensure our systems are properly functioning | Passively when you visit our site |
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible business purposes without providing you notice.
Sharing Your Information. We do not sell your personal information, but may disclose it to third parties for a business purpose. Specifically, in the past 12 months we have disclosed unique personal identifiers such as online identifiers and IP address and Internet or other electronic network activity information to our internet service providers, operating systems and platforms, and marketing intelligence service providers.
Your Rights. The CCPA gives you certain rights regarding your personal information:
- Right to Know. You may request no more than twice in a 12-month period that we provide you with copies of specific personal information we have collected, sold, or disclosed about you. However, under California law, we cannot provide you with certain sensitive information, despite your request (for example, we will not send you copies of your social security number even if it is something we collected).
- Right to Delete. You may request that we delete certain personal information we have collected about you, with certain exceptions.
Exercising Your Rights. To exercise your rights above, please contact us as instructed at the end of this Policy and specify you are making a CCPA request. Please describe your request with sufficient detail so we can properly respond to your request. As part of your request, please specify which right you are exercising and be prepared to provide the following information: name, email address, and the type of request you wish to make. We may ask for additional information to verify your identity. The information you provide in your request and any follow up information we ask for from you will be used solely to verify your request. After receiving your request, we may need to contact you for further information and will notify you if your request has been granted or declined, or if an exception applies to your request. Only you or an individual designated as your authorized agent to act on your behalf may make a request related to your personal information. We may not discriminate against you if you choose to exercise your rights.
Responding to Your Rights Request. We will try to respond to your request within 45 days. If we need more time, we will contact you with the reason we need more time and the extension period. We will deliver our written response by mail or electronically, at your option. In response to your request to know, we will only disclose the information we have collected in the 12 months prior to our receipt of your request. Our response will also explain the reasons we cannot comply with any request, if applicable. We do not charge a fee to process or respond to your request unless your request is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate prior to completing your request.
10. Notification of Changes
If we decide to change our privacy policy, we will post those changes to this privacy statement and other places we deem appropriate so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. We will use information in accordance with the privacy statement under which the information was collected. Please check back often for updates.
11. How to Contact Us
Hemlock Semiconductor Group
12334 Geddes Road
P.O. Box 80
Hemlock, Michigan 48626
United States of America
Email: hsclegal@hscpoly.com
Phone: +1 (989) 301-5000