Effective Date: March 11, 2019
You have certain choices regarding information collection and communications options explained here including:
Zekelman Industries, and/or its Service Providers (defined below), may collect information you provide directly to Zekelman Industries and/or its Service Providers via the Service. For example, Zekelman Industries collects information when you use or register for the Service, subscribe to notifications, post on the Service, participate in promotional activities, or communicate or transact through the Service. In addition, when you interact with Third-Party Services (defined below), you may be able to provide information to those third parties. For more information on Third-Party Services’ data collection and practices click here. For more information on Service Provider data collection and practices click here.
EEOC / Affirmative Action Reporting. In conjunction with laws and regulations enforced by the Equal Employment Opportunity Commission (“EEOC”), the Office of Federal Contract Compliance Programs (“OFCCP”) and similar state and local regulatory agencies, we may ask you to provide us with self-identifying information (such as veteran status, gender and ethnicity). Providing such self-identifying information is voluntary, but if you do provide us with such information, we may submit that information to the EEOC, the OFCCP and similar state and local regulatory agencies or otherwise use or disclose it for business-related purposes, including, without limitation, responding to information requests, fulfilling regulatory reporting requirements and defending against employment related complaints.
Zekelman Industries, its Service Providers, and/or Third-Party Services may also automatically collect certain information about you when you access or use the Service (“Usage Information”). Usage Information may include IP address, device identifier, browser type, operating system, information about your use of the Service, and data regarding network connected hardware (e.g., computer or mobile device). Except to the extent required by applicable law, or to the extent Usage Information is combined by or on behalf of Zekelman Industries with Zekelman Industries-Collected PI, Zekelman Industries does not consider Usage Information (including, without limitation, unique device identifiers) to be Personal Information or Zekelman Industries-Collected PI. For more information on Third-Party Services’ data collection and practices click here. For more information on Service Provider data collection and practices click here. For information on choices some of these third parties may offer you regarding automated data collection click here.
The methods that may be used on the Service to collect Usage Information include:
Some information about your use of the Service and certain third-party services may be collected using Tracking Technologies across time and services, and used by Zekelman Industries and third parties for purposes such as to associate different devices you use, and deliver relevant ads and/or other content to you on the Service and certain third-party services. See Section 11 regarding certain choices regarding these activities.
Zekelman Industries is giving you notice of the Tracking Technologies and your choices regarding them explained in Section 11 so that your consent to encountering them is meaningfully informed.
Zekelman Industries may share non-Personal Information, and Personal Information that is not deemed Zekelman Industries-Collected PI hereunder (provided that Zekelman Industries is aware of no restrictions of Zekelman Industries’ use, if any), with third parties or other Zekelman Industries companies, including business divisions such as Wheatland Tube and Atlas Tube (the “Zekelman Industries Affiliates”) for any purpose.
Without limiting the generality of the foregoing, we and third parties may convert your Personal Information, including Zekelman Industries-Collected PI, to non-Personal Information, including without limitation through hashing it or substituting a unique identifier for the Personal Information and we and third parties may use and share that data as permitted by applicable law, including to match data attributes to and from other sources. Any such third party activities are subject to their privacy policies and practices. Zekelman Industries’ sharing of Zekelman Industries-Collected PI is, however, subject to the following:
In addition, Zekelman Industries may share your Zekelman Industries-Collected Personal Information (as well as your other Personal Information and your non-Personal Information), in connection with or during negotiations of any proposed or actual financing of our business, or merger, purchase, sale, joint venture, or any other type of acquisition or business combination of all or any portion of Zekelman Industries assets, or transfer of all or a portion of Zekelman Industries’ business to another company, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding (“Corporate Transactions”).Return to Navigation
Additionally, the Service may offer you the option to send a communication to a friend or other contact. If so, Zekelman Industries relies on you to only send to people that have given you permission to do so. The recipient’s Personal Information you provide (e.g., name, e-mail address) will be used to facilitate the communication, but not used by Zekelman Industries for any other marketing purpose unless Zekelman Industries obtains consent from that person. Your contact information and message may be included in the communication.Return to Navigation
Certain functionalities on the Service permit interactions that you initiate between the Service and certain Third-Party Services, such as third-party social networks (“Social Features”). Examples of Social Features include: enabling you to send content such as contacts and photos between the Service and a Third-Party Service; “liking” or “sharing” Zekelman Industries’ content; logging in to the Service using your Third-Party Service account (e.g., using Facebook Connect to sign-in to the Service); and to otherwise connect the Service to a Third-Party Service (e.g., to pull or push information to or from the Service). If you use Social Features, and potentially other Third-Party Services, information you post or provide access to may be publicly displayed on the Service (see Section 5) or by the Third-Party Service that you use. Similarly, if you post information on a third-party service that references the Service (e.g., by using a hashtag associated with Zekelman Industries or other Zekelman Industries Affiliates in a tweet or status update), your post may be used on or in connection with the Service or otherwise by Zekelman Industries and Zekelman Industries Affiliates. Also, both Zekelman Industries and the third party may have access to certain information about you and your use of the Service and any Third-Party Service.
Zekelman Industries may engage and work with Service Providers and other third parties to serve advertisements on the Service and/or on third-party services. Some of these ads may be tailored to your interest based on your browsing of the Service and elsewhere on the Internet, sometimes referred to as “interest-based advertising” and “online behavioral advertising” (“Interest-based Advertising”), which may include sending you an ad on a third-party service after you have left the Service (i.e., “retargeting”).
Zekelman Industries takes reasonable measures to protect Zekelman Industries-Collected PI (excluding public UGC) from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction. Nevertheless, transmission via the Internet and online digital storage are not completely secure and Zekelman Industries does not guarantee the security of your information collected through the Service.
The Service is intended for a general audience and not directed to children less than 13 years of age.
Zekelman Industries does not intend to collect personal information as defined by the U.S. Children’s Online Privacy Protection Act (“COPPA”) (“Children’s Personal Information”) in a manner that is not permitted by COPPA. If we obtain knowledge that we have collected Children’s Personal Information in a manner not permitted by COPPA, we will remove such data to the extent required by COPPA.
Any California residents under the age of eighteen (18) who have registered to use the Service, and who posted content or information on the Service, can request removal by contacting Zekelman Industries here, detailing where the content or information is posted and attesting that you posted it. Zekelman Industries will then make reasonable good faith efforts to remove the post from prospective public view or anonymize it so the minor cannot be individually identified to the extent required by applicable law. This removal process cannot ensure complete or comprehensive removal. For instance, third-parties may have republished or archived content by search engines and others that Zekelman Industries does not control.Return to Navigation
Zekelman Industries may provide web pages or other mechanisms allowing you to delete, correct, or update some of the Zekelman Industries-Collected PI, and potentially certain other information about you (e.g., profile and account information). Zekelman Industries will make good faith efforts to make requested changes in Zekelman Industries’ then-active databases as soon as practicable, but it is not always possible to completely change, remove or delete all of your information or public postings from Zekelman Industries’ databases (California minors see Section 9) and residual and/or cached data may remain archived thereafter. Further, we reserve the right to retain data (a) as required by applicable law; and (b) for so long as reasonably necessary to fulfill the purposes for which the data is retained except to the extent prohibited by applicable law.Return to Navigation
Regular cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options so you may need to set them separately. Also, tools from commercial browsers may not be effective with regard to Flash cookies (also known as locally shared objects), HTML5 cookies, or other Tracking Technologies. For information on disabling Flash cookies, go to Adobe’s website http://helpx.adobe.com/flash-player/kb/disable-third-party-local-shared.html. Please be aware that if you disable or remove these technologies, some parts of the Service may not work and that when you revisit the Service your ability to limit browser-based Tracking Technologies is subject to your browser settings and limitations.
Some App-related Tracking Technologies in connection with non-browser usage (e.g., most functionality of a mobile app) can only be disabled by uninstalling the app. To uninstall an app, follow the instructions from your operating system or handset manufacturer. Apple and Google mobile device settings have settings to limit ad tracking, and other tracking, but these may not be completely effective.
Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no consensus among industry participants as to what “Do Not Track” means in this context. Like many online services, Zekelman Industries currently does not alter Zekelman Industries’ practices when Zekelman Industries receives a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” you can visit http://www.allaboutdnt.com, but Zekelman Industries is not responsible for the completeness or accuracy of this third party information. Some third parties, however, may offer you choices regarding their Tracking Technologies. One way to potentially identify cookies on our web site is to add the free Ghostery plug-in to your browser (www.ghostery.com), which according to Ghostery will display for you traditional, browser-based cookies associated with the web sites (but not mobile apps) you visit and privacy and opt-out policies and options of the parties operating those cookies. Zekelman Industries is not responsible for the completeness or accuracy of this tool or third party choice notices or mechanisms. For specific information on some of the choice options offered by third party analytics and advertising providers, see the next section.
You may choose whether to receive some Interest-based Advertising by submitting opt-outs. Some of the advertisers and Service Providers that perform advertising-related services for us and third parties may participate in the Digital Advertising Alliance’s (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. To learn more about how you can exercise certain choices regarding Interest-based Advertising, visit http://www.aboutads.info/choices/, and http://www.aboutads.info/appchoices for information on the DAA’s opt-out program for mobile apps. Some of these companies may also be members of the Network Advertising Initiative (“NAI”). To learn more about the NAI and your opt-out options for their members, see http://www.networkadvertising.org/choices/. Please be aware that, even if you are able to opt out of certain kinds of Interest-based Advertising, you may continue to receive other types of ads. Opting out only means that those selected members should no longer deliver certain Interest-based Advertising to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). Also, if your browsers are configured to reject cookies when you visit these opt-out webpages, or you subsequently erase your cookies, use a different device or web browser or use a non-browser-based method of access (e.g., mobile app), your NAI / DAA browser-based opt-out may not, or may no longer, be effective. Zekelman Industries supports the ad industry’s 2009 Self-regulatory Principles for Online Behavioral Advertising and expects that ad networks Zekelman Industries directly engages to serve you Interest-based Advertising will do so as well, though Zekelman Industries cannot guaranty their compliance. Zekelman Industries is not responsible for effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs.
You can opt out of receiving certain promotional communications (emails or text messaging) from Zekelman Industries at any time by (i) for promotional e-mails, following the instructions provided in emails to click on the unsubscribe link, or if available by changing your communication preferences by logging onto your account and (ii) for text messages, following the instructions provided in text messages from Zekelman Industries to text the word, “STOP.” Please note that your opt-out is limited to the e-mail address or phone number used and will not affect subsequent subscriptions. If you opt-out of only certain communications, other subscription communications may continue. Even if you opt out of receiving promotional communications, Zekelman Industries may, subject to applicable law, continue to send you non-promotional communications, such as those about your account, transactions, servicing, or Zekelman Industries’ ongoing business relations. Except in connection with Corporate Transactions, to prospectively opt-out of our sharing of your Zekelman Industries-Collected PI, other than with Zekelman Industries Affiliates, for their own direct marketing purposes, contact us here.Return to Navigation
Zekelman Industries provides California residents with the option to opt-in or opt-out to sharing of “personal information” as defined by California’s “Shine the Light” law with third parties, other than Zekelman Industries Affiliates, for such third parties’ own direct marketing purposes. California residents may exercise that opt-out, and/or request information about Zekelman Industries’ compliance with the Shine the Light law, and obtain disclosure of third parties Zekelman Industries has shared information with in accordance with the law for their direct marketing purposes absent your choice and the categories of information shared, by contacting Zekelman Industries here or by sending a letter to Zekelman Industries at 227 West Monroe Street, Suite 2600, Chicago, IL 60606 (Attention: Legal Department) or by emailing firstname.lastname@example.org. Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that Zekelman Industries is only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through the provided e-mail address or mail address.
California minors should see “Children’s Privacy” at Section 9 regarding removal of certain content they have posted.Return to Navigation