Privacy Policy, Terms of Use and Cookies

PRIVACY POLICY
TERMS OF USE
COOKIES POLICY

Privacy policy

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This Policy aims to demonstrate our commitment to safeguarding your privacy and protecting your personal data, clarifying the rules on processing, as well as explaining your rights as Data Subjects and how to exercise them. The Privacy Policy applies to everyone who accesses Aperam’s physical and logical environments, whether employees of Aperam and its subsidiaries, customers, suppliers, consultants, service providers to Aperam, shareholders, representatives, investors, analysts, among others and is part of the company’s compliance program. We carry out mandatory periodic training for main managers with responsibilities in areas considered relevant from the point of view of personal data protection, such as, but not only, human resources and IT. Please read this Policy carefully, because its guidelines are mandatory and, therefore, must always be observed by everyone. If you have any questions, please contact our Data Protection Officer at dataprotection@aperam.com. Basic Concepts Terms and expressions contained in this Policy will be interpreted in accordance with applicable data protection laws, including, but not limited to Regulation 2016/679 (GDPR) of the European Union and their future amendments, replacements or amendments (“Data Protection Laws”). To better understand this Policy, the following definitions must be considered: Applicable legislation: all legislation that deals with privacy and protection of personal data, especially the General Data Protection Regulation (GDPR). Cookies: small files sent to your browser or devices, which store your preferences and other information about the access to our environments, as well as the number of people visiting them. Data Protection Officer (DPO): a person appointed by Aperam to act as a communication channel between us, the Data Subject and the National Data Protection Authority (CNPD). Data Subject: Individual whose personal data will be processed by Aperam. Logical environment: operating systems, software, networks and websites. Personal Data: is data relating to an individual, which is capable of identifying or making him or her identifiable. For example: name, email, ID number, personal preferences, IP address, geolocation, etc. Physical environment: company physical space and physical infrastructure where personal data may be stored. Processing: any operation carried out with personal data, such as those relating to collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, elimination, evaluation or control of information, modification, communication, transfer, diffusion or extraction. Sensitive Personal Data: are any data on racial or ethnic origin, religious belief, political opinion, membership of a trade union or organization of a religious, philosophical or political nature, data relating to health or sexual life, genetic or biometric data, when linked to a natural person. Technical and Organizational Security Measures: means measures aimed at protecting personal data against accidental or purposeful destruction, as well as loss, alteration, disclosure or unauthorized access of Personal Data, especially when processing involves the transmission of data over a network, and against any other irregularities during processing. About the data we collect How we collect Data. Data, including personal data, may be collected when you interact with our environments.  You may not be required to disclose your personal data as a condition of using Aperam environments. However, in some interactions, Aperam may request that the following Data Subjects provide their personal data:

  • customers, suppliers, consultants and third parties, who already have or will have some type of interaction with Aperam;
  • employees, shareholders, representatives and people related to them who, for any reason, need to collect data;
  • investors, analysts, among others linked to this market;
  • representatives, employees, indirect Data Subjects, among other Data Subjects involved in contractually current relationships or that Aperam is in the process of establishing;
  • candidates for job vacancies, internships, trade apprentices, trainees or other professional development programs discussed on our website (in the “Careers » tab for example). In this case you accept that the application will be processed by Aperam or the relevant subsidiary within the Aperam group. Aperam or the relevant subsidiary will use the personal data provided by candidates for the purpose of processing the application. Candidates have the right to consult their personal data, correct it if necessary and withdraw their consent to the use of their personal data, when applicable. For this purpose, send a message to Human Resources via Contact/Contact Request and select Career opportunities on the website.
What data we collect. Personal data processed by Aperam may include, but is not limited to, the following types of data:
  • data for identification and registration (name, surname, date of birth, gender, photo, etc.);
  • contact information (email, postal address, telephone, etc.);
  • numbers of documents issued by the government (Individual Person Registration, General Registration, Work Card, Registration with a Class Body/Entity, etc.);
  • Financial information (Bank details, etc.);
  • Navigational data on our website, i.e. your IP address, which will only be used to identify the owner, in cooperation with your Internet provider, if we deem it necessary to ensure compliance with our Terms of Use or to protect our service, websites, customers or others.
  • Any other personal data necessary for registration, execution of a contract or compliance with a legal duty.
Most of the personal data we process is provided to us directly by Data Subjects. However, in some cases, we may process personal data received through third parties with the due knowledge of the Data Subjects of such data. Update and veracity of data. You are solely responsible for the accuracy, veracity or updating of the data you provide to us. We are not obliged to process your data if there are reasons to believe that such processing could result in us violating any applicable law, or if you are using our environments for any illegal or illicit purposes. Database. The database formed through data collection is our property and is under our responsibility, and its use, access and sharing, when necessary, will be within the limits and purposes described in this Policy. Technologies used. We can use Cookies in our logical environments, and it is up to you to configure your internet browser to allow or not allow its use, when possible. In this case, some features we offer may be limited. For more information, visit our Cookies Policy. Personal data processing hypotheses Personal Data is processed, mainly, but not exclusively, to meet the following goals:
  • To fulfill any prior or ongoing contractual obligations relating to Data Subjects or relating to Data Subjects’ employers;
  • To contact candidates to participate in selection processes;
  • To comply with laws or regulations that so determine;
  • To legitimize the interests of Aperam or third parties, as necessary to carry out Aperam’s daily activities, such as, for example, to manage relationships with customers or third-party service providers, manage sales, communicate efficiently with our investors and shareholder base, prevent fraud and other criminal activities, implement changes to our corporate or corporate structure;
  • For the progress of legal proceedings (including conflicts and collections), accountability, ombudsman and auditing.
  • With the consent of the Data Subject, collected in a specific way.
Aperam guarantees that only necessary personal data is processed and that it applies its best efforts to keep updated the personal data in its possession or under its control . Data sharing  Hypotheses of data sharing. The data collected and activities recorded (logs) can be shared:
  • With competent judicial, administrative or governmental authorities, whenever there is a legal obligation or determination, request or order to that effect;
  • With Aperam companies and business areas, which are in accordance with this Policy;
  • With service providers or partner companies, to facilitate, promote or carry out activities related to our environments, remembering that these third parties, in general, have their own Privacy Policies and are, in general, contractually bound to Aperam;
  • Automatically, in the case of corporate movements, such as merger, acquisition or incorporation of Aperam;
  • When you deem that sharing is appropriate or necessary to conduct the company’s activities, comply with our Policies and other agreements, or protect the rights, assets or safety of Aperam, its employees or others.
Aperam has an Ambient Reporting system so that employees, service providers or any other Data Subjects may send compliments, suggestions, complaints and reports on specific matters. This process is managed by a service provider. To use this service, if you are eligible, you must agree to the platform’s terms of use, but this does not mean that you will be identified, given the possibility of accessing the service anonymously. The veracity of the files sent through the form are the sole responsibility of the applicant. Data anonymization. For the purposes of market intelligence research, disseminating information to the press and carrying out advertisements, the data should be shared anonymously, so that your identification is not possible. Transfer of personal data As a global company, Aperam processes data in different countries, with different sources, and transfers information in accordance with Data Protection Laws and any other applicable laws. Aperam may share data within the natural course and scope of its activities with its affiliates and, likewise, with the third parties mentioned above. Data Subjects are informed that some recipients may be located outside the territory of the European Union and in countries that may not offer a level of protection equivalent to that offered in the European Union (“Third Countries”). The transfer of data to affiliates and third parties located in Third Countries, depending on the nature of the transfer, must:
  • be protected by the appropriate contractual safeguards, approved by the European Commission, and the Data Subject may obtain copies of these safeguards by contacting us; or
  • be authorized, in accordance with data protection laws, as applicable, such transfer being necessary for the fulfillment or execution of a contract concluded, at the request of the Data Subject, to establish, exercise or defend legal claims or to enter into a contract between the Data Subject and Aperam, or their employer and Aperam.
How we protect your data and how you can do the same Security and Governance Practices. To safeguard your privacy and protect your Data, we have a Governance Program that contains rules of good practice, Internal Policies and Procedures, which establish organizational conditions, training, educational actions and supervision and risk mitigation mechanisms related to the processing of personal data. The security of all personally identifiable information is extremely important to us. Once we receive your transmission, we make our best efforts to ensure its security on our systems, adopting technical and organizational security measures. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, although we strive to protect your personal information, Aperam cannot ensure or warrant the security of any information you transmit to us, and you do so at your own risk. Access to data, proportionality and relevance. Internally, the data collected is accessed only by duly authorized professionals, respecting the principles of proportionality, necessity and relevance to the objectives of our business, in addition to the commitment to confidentiality and preservation of your privacy under the terms of this Policy. Adoption of good practices. You are also responsible for the confidentiality of your data and must always be aware that sharing passwords and access data violates this Policy and may compromise the security of your data and our environments. If you identify or become aware of a compromise in the security of your data, please contact our Data Protection Officer via email at data.protection@aperam.com. External Links. When you use our logical environments, you may be led, by link, to other websites, portals or platforms, which may collect your data and have their own Privacy Policy. It is up to you to read these Policies, and it is your responsibility to accept or reject them. We are not responsible for the Privacy Policies of third parties nor for the content of any sites or services linked to environments other than ours. Processing by third parties under our direction. We seek to carefully evaluate our partners and service providers and enter into contractual obligations of confidentiality, information security and data protection with them, with the aim of protecting you. How we store your data and activity recods (logs) Storage location. The collected data and activity records (logs) are stored in a safe and controlled environment, which may be on our servers located in Europe, as well as in an environment where resources or servers are used in the cloud computing, which may require the transfer and/or processing of your data outside Europe. These transfers only involve companies that demonstrate that they are in compliance with applicable legislation, maintaining a level of compliance similar to or more stringent than that provided for in European legislation. Storage period. We store data only for as long as necessary to fulfill the purposes for which it was collected or to comply with any legal, regulatory or rights preservation obligations. Data Disposal. Finished the maintenance period and legal necessity, the data will be deleted using secure disposal methods or used in an anonymized form for statistical purposes. Your rights and how to exercise them  Your basic rights. The Data belongs to you and entails a series of rights under the applicable laws. You may exercise any of them by sending a request to data.protection@aperam.com. (i) Confirmation and access: you can request Processing confirmation and access your Data, including by requesting copies of our records about you. (ii) Correction: you can request the correction of any incomplete, inaccurate or out of date Data about you. (iii) Anonymization, blocking or deletion: you can request the anonymization of your Data so that it can no longer be related to you, the blocking of your Data, which suspends the possibility of Data Processing for certain purposes, or the deletion of your Data. (iv) Portability: you may request that we provide your Data in a structured and interoperable format in order to transfer it to a third party, except for our intellectual property or business secret. (v) Information about disclosure: you may request information about third parties to whom we disclose your Data, limiting such disclosure to information that does not violate our intellectual property or business secret. (vi) Consent withdrawal: you may choose to withdraw your consent for any reason. The withdrawal will not affect the legality of any Processing carried out prior to the withdrawal. If you withdraw a consent essential for the regular functioning of our environments and services, they may become unavailable to you. (vii) Opposition: you may oppose the Processing of your Data, if you do not agree with any of its purposes. (viii) Right to lodge a complaint. In addition, whenever you consider our personal data processing not to be compliant with the applicable law, you have the right to lodge a complaint with the competent data protection authority. (ix) Requests. For your safety, whenever you submit a request to exercise your rights, we may require additional information to attest your identity and prevent fraud. Information about this policy Change of content and update. You acknowledge our right to change the content of this Policy at any time, depending on the purpose or need, and it is your responsibility to check it whenever you access our environments. Inapplicability. If any point of this Policy is considered inapplicable by a Data Protection Authority or court, the other conditions will remain in full force and effect. Contact. If you have any questions regarding the provisions contained in this Policy, including the exercise of your rights, you may contact our Data Protection Officer, who is available at the following email: dataprotection@aperam.com. Applicable law. This Policy will be interpreted in accordance with GDPR legislation, with regards to the national applicable regulations of Luxembourg.

Terms of use

Introduction

Aperam operates this website (the “website”) to provide online access to information about Aperam and the products, services and opportunities we provide.

Please read the terms and conditions set forth herein (the “Terms of Use”) carefully before using the website.

The website is available for your access and use only on the condition that you agree to the Terms of Use. By accessing or using the website, you and the entity you are authorized to represent signify your agreement to be bound by each provision of the Terms of Use. If you do not agree to all of the Terms of Use, do not access or use the website.

Scope

These Terms of Use shall govern your use of the website and all applications, software and services available via the website.

To the extent that any of our webpages or applications accessible through the URL http://www.aperam.com is ruled by additional or different practices or policies, these practices or policies will be accessible on that page.

Modifications

Developers aimed at maximum suitability for the most popular computer browsers and mobile devices.

The Platform and its functionalities are presented to the User as they are now. However, they may undergo future improvements and updates.

Aperam reserves the right to modify or update the Terms of Use at its sole discretion, at any time and without prior announcement. You are responsible for informing yourself of the Terms of Use in force at the time of use of this website. Your continued usage of the website following the posting of changes to these Terms of Use will mean you accept those changes.

Copyright

Any and all intellectual property rights associated with the website and its contents (including, but not limited to: text, graphic images, audio, video, html code, buttons, trademarks, software, logos) are the sole property of Aperam or its affiliates, unless otherwise clearly indicated or in any other way perceivable as third party rights.

The abovementioned content may not be sold, distributed, transmitted, copied, modified or decompiled, in any way, without the prior written consent of Aperam. Any unauthorized use of the content is expressly prohibited and may constitute a violation of copyright law, trademark law, patent law or other industrial property rights.

You may only download, display and print one copy of the website on your personal computer for private and personal purposes and/or purposes allowed by the applicable law.

All news, information, images, videos, texts and trademarks made available on the Platform by Aperam, in any language or form, are licensed to Aperam or owned by it. The use of the Platform does not imply transfer of that property or license.

The trademark Aperam is a registered property and shall not be reproduced without Aperam’s express consent. Photographs and videos require the company’s consent to be reproduced or used in advertising materials of any kind.

Restrictions of use of the website

Aperam may refuse, cancel or limit any access, when it ascertains that the User is using the Platform for illegal purposes or in a way that does not comply with these Terms of Use.

The User shall not access programming areas of the Platform, its database, source codes or any other data set available in these environments, as well as not perform or allow reverse engineering,  translate, decompile, copy, modify, reproduce, rent, sublicense, publish, disclose, transmit, loan, distribute or otherwise improperly dispose of the Platform’s functionalities.

The use of data mining software (bots, crawler, spider, among others) of any kind is expressly forbidden.

In addition to other restrictions otherwise set forth in these Terms of Use, you agree that:

  • you shall not disguise the origin of information transmitted through the website;
  • you shall not place false or misleading information on the website;
  • you shall not use or access any service, information, application or software available via the website in a manner not expressly permitted by Aperam;
  • some areas of the website may be restricted to suppliers and or customers of Aperam.

Disclaimer of Warranties 

Aperam has compiled and organized the content of this website to the best of its knowledge and provides it on an “as is” basis. No representation is made or warranty given, either express or implied, for the completeness, accuracy, reliability, security, timeliness, or fitness for a particular purpose, of the content of the website or the non-existence of any viruses on the website.

No information obtained by you from the website shall create any warranty not expressly stated by Aperam in these Terms of Use.

Aperam reserves the right to modify or close the website at its own discretion and without prior announcement.

Limitation of liability

You agree to access and to use the website at your own risk. Aperam cannot be held liable for any direct or indirect or other losses or damages of whatsoever kind (whether based on contract, tort, delict, warranty or any other legal theory) resulting from access or use, or from the inability to use this website, from inaccuracies or omissions in this website, from any decisions you may make based on information contained in this website, from viruses from this website, or non-accessibility of this website, even if Aperam has been advised of the possibility of such damages. If you are dissatisfied with the website, its services, its content, or with the Terms of Use, your sole and exclusive remedy is to discontinue using the website.

Aperam will make its best efforts to maintain the Platform continuously available to the User. However, the Platform may be temporarily unavailable from time to time due to necessary maintenance or force majeure events such as natural disasters, failures in communication systems or Internet access, invasive cyber-attacks, or any third party’s actions beyond our control.

Under no circumstances will Aperam, its officers or employees be liable for any direct or indirect damage, loss or expenses arising from the use or inability to use this Platform, or with respect to any performance failure, error, omission, interruption, defect or delay in operation or transmission, computer virus, line or system failure, even if Aperam or its representatives have been advised of the possibility of such damage, loss or expense.

Without prejudice to other provisions of the Terms of Use, Aperam is not liable for:

  • User’s improper use of the information, instruments, materials and/or equipment used by this Platform, for any purposes. The User is solely liable for any damage incurred by the User or third parties, whether or not arising from such inappropriate use;
  • Any problems, bugs, glitches or improper functioning that occur on the User’s devices and equipment;
  • For any direct or indirect damage caused by third party events, such as cyber-attacks, system/server errors, internet connection problems or programs that may cause hardware or software damage due to access, use or navigation on the Platform, as well as the transfer of data, files, images, texts, audios or videos contained in the Platform; and
  • The User’s access to any external links made available on the Platform.

Financial disclaimer

Nothing contained in the website shall be deemed to be either advice of a financial nature to act or not to act in any way whatsoever or an invitation to invest or deal in any form of investment, whether listed or unlisted, in Aperam or any of its entities.

The website has not been submitted to any authority of finance control nor to any other competent authority as required whenever there is a public offer or financial products and services.

Certain information discussed in this website may constitute forward-looking statements regarding the financial positions, results of operations, business and industrial strategy of Aperam. More generally, when used in this website, the words “foresee(s)”, “aim(s)”, “expect(s)”, “intend(s)”, “will”, “may”, “believe(s)”, “anticipate(s)” and similar expressions are intended to identify forward-looking statements. Such statements are based on hypotheses that may prove incorrect and are subject to risks and uncertainties, including fluctuations in exchange rates, raw material costs, the capacity to achieve cost reductions without negatively impacting on operations, environmental regulation issues and general economic and financial conditions.

Aperam is under no responsibility to update such statements in light of new information or future or other events.

Compliance with law

You agree to use the website in strict compliance with all applicable laws, rulings, and regulations and in a fashion that does not, in the sole judgment of Aperam, negatively reflect on the goodwill or reputation of Aperam and shall take no actions which would cause Aperam to be in violation of any laws, rulings or regulations applicable to Aperam.

Indemnity

You agree at all times to indemnify, defend and hold harmless Aperam, its agents, affiliates and their respective directors, employees and third parties against all actions, proceedings, costs, claims, damages, demands, liabilities and expenses whatsoever sustained, incurred or paid by Aperam directly or indirectly in respect of (i) any information or other content you provide on or through this website and (ii) your use or misuse of the content of this website, including without limitation infringement claims.

Links

Links to this website are allowed, provided that Aperam is informed prior to the publication of the link: stainless@aperam.com. Aperam reserves the right to withdraw this permission in the future. By receiving information about such links, Aperam makes no judgment or warranty with respect to the websites providing such links and Aperam takes no responsibility for these websites.

This website may contain links to websites not operated, controlled or supervised by Aperam. These links are provided solely as a convenience for you. If you follow these links, you’ll leave the website, and will be subject to the terms of use and privacy policy applicable to those websites. By providing such links, Aperam makes no judgment or warranty with respect to the websites accessible through the links and Aperam takes no responsibility to these websites.

General

You may not assign these Terms of Use or any of your interests, rights or obligations under these Terms of Use. If any provision of these Terms of Use is found to be invalid by any court having competent jurisdiction, the invalidity of such provision shall not affect the validity of the remaining provisions of these Terms of Use, which shall remain in full force and effect. No waiver of any of these Terms of Use shall be deemed a further or continuing waiver of such term or condition or any other term or condition.

Jurisdiction

TO THE FULLEST EXTENT PERMITTED BY LAW, YOU HEREBY EXPRESSLY AGREE THAT ANY PROCEEDINGS ARISING OUT OF OR RELATING TO YOUR USE OF THE WEBSITE, ITS INFORMATION, SERVICES AND CONTENT SHALL BE SUBJECT TO THE LAWS OF LUXEMBOURG. THE COURTS IN LUXEMBOURG SHALL HAVE EXCLUSIVE JURISDICTION.

Cookies Policy

We aim to provide a more transparent user experience, by explaining the concept of cookies, how we use them and the possibility of customizing their use.

If you do not agree with the use of cookies as presented, you may configure your internet browser and refuse the use of cookies. You may also decide not to register and use our Platform.

It is important to mention that disabling the use of cookies may affect your user-experience on our Platform.

Concept of cookies

Cookies are small digital files in text format that are stored on the User’s electronic device when he/she accesses our Platform. Cookies store information related to your preferences, such as preferred language, location, visit frequency and other variables that the Platform’s developers consider relevant to improve your experience.

Cookies make using our Sites easier by, among other things, saving your passwords and preferences for you. These cookies are restricted for use only on our Sites, and do not transfer any personal information to any other party. If you choose to refuse to accept a cookie, some parts of Aperam websites will not function properly or may be considerably slower.

Purpose of the cookies

Cookies help us improve the User experience in terms of performance and usability and allow us to present contents according to your needs and expectations.

They can also be used to carry out anonymous statistical analyses to understand how the Users interact with the Platform, as well as improve structures and content. Due to the anonymous nature of the statistical analysis, the User cannot be personally identified.

Cookies that could be used by our platform

Our Platform may use only those types of cookies:

  • Essential Cookies: these cookies allow the navigation and use of applications, as well as access to restricted areas of the Platform. Without these cookies, the Platform does not function properly.
  • Analytical Cookies: they collect anonymous statistical data for the purpose of analyzing the use and performance of the Platform. These cookies are essential for maintaining a positive performance because they allow us to determine the most popular pages and identify errors. These cookies do not collect any personal data.
  • Functional Cookies: they are used to add additional features to the Platform or save the preferences defined by the User when browsing the internet on the same device.

You can manage your cookies when accessing our website.

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