Privacy Policy

Privacy and Cookies

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.

Privacy and Processing of Personal Data Policy

Data Protection (GDPR)

This Policy aims to show we are committed to protecting and preserving the confidentiality of your Personal Data by setting out rules on Data Processing, as well as providing information on your rights and how to exercise them.

Aperam’s data privacy policy applies to the whole group and is part of the Company’s compliance programme. Training is mandatory to key managers with responsibilities in areas considered relevant from a personal data protection perspective, such as human resources and IT.

Find out more

Read this Policy carefully. Aperam SA (“Aperam”) is the Controller regarding the personal data processed in this site. Should you have any questions, please contact dataprotection@aperam.com.

Basic Concepts

For the purposes of this Policy, the terms described below will have the following meanings:

Cookies: small files sent to your browser or device which store your preferences and other information about the access to Our Environments, as well as the number of people visiting them.

Personal Data or Data: data relating to an individual which identify or make him/her identifiable, such as name, email, ID number, personal preferences, IP address, geolocation, among others.

Sensitive Personal Data: any Data on racial or ethnic origin, religious belief, political opinion, union affiliation or affiliation with religious, philosophical or political organizations, data relating to health or sexual life, genetics or biometrics, in connection to an individual.

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.

Our Environments: all Aperam’s electronic addresses and its subdomains, as well as Aperam’s app.

Applicable law: any law on privacy and protection of Personal Data, especially the General Data Protection Regulation (GDPR).

Data Subject: individual to whom the Personal Data refers to.

Processing: any action involving Personal Data, such as collection, production, reception, classification, use, access, reproduction, transmission, distribution, filing, storage, elimination, assessment or control of information, modification, communication, transfer, diffusion or extraction.

About the data we collect

How we collect Data. Data, including Personal Data, may be collected when you submit it or when you interact with our environments and services.

In general, you are not required to disclose your personal data as a condition of using an Aperam website or application.

However, in your interactions Aperam will ask you to provide your personal data, such as name, email, phone and address, which are considered necessary personal information. If you choose not to provide some of this Data, we may be unable to provide all or part of our services to you.

If you use the e-aperam platform, access to this service will be conditioned to registration. You accept then that your personal data collected by the platform will be processed either by Aperam or by the relevant subsidiary. The holder of an account has the right to consult their personal data, to correct the personal data, if necessary, and to withdraw their consent to the use of their personal data.

If you apply for jobs through the website, you accept that the application will be processed either by Aperam or by the relevant subsidiary within the Aperam group. Aperam or the relevant subsidiary will use the personal data supplied by the applicants for the purpose of processing the application. Applicants have the right to consult their personal data, to correct the personal data, if necessary, and to withdraw their consent to the use of their personal data. For this purpose applicants may contact the recipient of the application at the e-mail address to which they have sent the application.

An IP address is a number that’s automatically assigned to your computer by your Internet provider whenever you’re surfing the Web. When you request pages from Aperam’s website, our servers log your IP address. Aperam collects IP addresses for the purposes of system administration, to audit the use of our Site. We do not link IP addresses to anything personally identifiable, which means that your session will be logged, but you are anonymous to us. We may exceptionally use your IP addresses in cooperation with your Internet provider to identify you if we feel it is necessary to enforce compliance with our Terms of Use or to protect our service, Sites, customers, or others.

Legal Basis for processing Personal Data. Where referenced that Aperam uses Personal Data to fulfill requests, job applications, orders or to provide you with services that you requested, Aperam does this because it is necessary for the performance of an agreement, or with your consent.

Where referenced that Aperam uses Personal Data to improve or develop its services, for reasons of safety and security or regulatory requirements, Aperam does that based on its or third parties’ legitimate interests, or with your consent. 

Accurate and Current Data. You are solely responsible for the accuracy of the Data you provide to us. We have the right to deny processing your Data if there is reason to believe that such Processing may imply violation of any applicable law, or if you have used our environments for any illegal or unlawful purpose.

Database. The Database created from the collection of Data is our property, and it is under our responsibility. The use, access and sharing of the Database, when necessary, will be made within the limits and purposes described in this Policy.

Technologies used by us. We use cookies in our environments. You may configure your internet browser so that it allows or denies the use of cookies. To that effect, some features that we offer may be limited. 

Data sharing

Data sharing conditions. We may share your Data and logs:

  • With competent judicial, administrative or governmental authorities, upon request, requisition or order from such authorities;
  • With service providers or partner companies, in order to facilitate, provide or perform activities in connection with Our Environments;
  • Automatically, in the event of merger, consolidation or spin-off of Aperam.

Data Anonymization. We may disclose your Data for the purposes of carrying out marketing intelligence research; disseminate information to the public by the press; and for creating advertising materials. For these purposes, the Data will be disclosed anonymously, in a way that does not allow user identification.

How we protect your data and how you can do the same

Security and Governance Practices. Our governance program aims to preserve your privacy and protect your Data through good practices, policies and internal procedures, which set out organizational conditions, training, educational actions and mechanisms for overseeing and mitigating risks in connection to the Processing of Personal Data.

Security for 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. Unfortunately, no data transmission over the internet can be guaranteed to be 100% secure. As a result, while 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.

Data access, proportionality, and relevance. Only duly authorized professionals have access to the collected Data, in compliance with the principles of proportionality, necessity and relevance for the purposes of our business. In addition, the authorized professionals are all committed to preserving your privacy under the terms of this Policy.

Adoption of good practices. You are also responsible for the confidentiality of your Data and you must always be aware that sharing passwords and accessing data violates this Policy and may compromise the security of your Data and Our Environments. If you identify or become aware that the security of your Data has been compromised, please contact us through the Channels provided in this Policy.

External Links. While using Our Environments, you can be redirected to other websites, portals or platforms, which may collect your Data and have their own privacy policy. You may decide to read such policies, accept, or reject them. We are not liable for privacy policies of third parties or for the contents of any site or service in connection to environments other than ours.

Third party processing under our guideline. We carefully assess our partners and service providers and enter contractual obligations regarding confidentiality, information security and data protection with them in order to protect you.

How we store your data and logs

Storage location. The collected data and logs are stored in a secure and controlled environment, which may require the transferring and/or processing of your Data outside the EU. These transfers will only involve companies that demonstrably comply with applicable laws, maintaining a level of compliance similar to or tougher than that under EU law.

Storage term. We store the Data only for as long as necessary to comply with the purposes for which it was collected or to comply with statutory obligations.

Data Disposal. After the maintenance period and with respect to all statutory provisions, the Data will be deleted by safe disposal methods or kept anonymously for statistical purposes.

Your rights and how to exercise them

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 dataprotection@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.

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.

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.

Failure to meet requests. We may fail to comply with any request to exercise rights if the service violates our intellectual property or business secret, as well as if there is a legal or statutory obligation to retain the Data. In addition, we may fail to comply with your request if we need to retain the Data to enable our defense or the defense of third parties in disputes of any nature.

Responses to requests. We undertake to respond to all requests timely and in accordance with the applicable laws.

Contact

If you have any questions about the practices of our Sites, or your dealings with our Sites, you can contact: stainless@aperam.com. For questions related to data protection, you can contact the Data Protection Team through dataprotection@aperam.com.

Information provided by you via general e-mail inquiries to Aperam such as your e-mail address is used only to respond to your inquiries in the ordinary course of business, and is never shared with third parties.

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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