Effective Date: March 1, 2023
This Privacy Policy describes how Carpenter Co., its subsidiaries and affiliates (collectively, “we,” “our,” “us,” or “Carpenter”) gather and use Personal Information (as defined below) about you when you communicate with us or visit www.carpenter.com; how we protect and disclose this information; and the rights you may have in relation to this information. Please read this Privacy Policy carefully. By using our website, you agree to our collection, use, transfer, and other processing of your Personal Information as described in this Privacy Policy. Please do not use our website if you disagree with any part of this Privacy Policy.
I. How to Contact Us
The data controller for any Personal Information provided to or gathered by the website is Carpenter Co., 5016 Monument Avenue, Richmond, VA 23230. If you have questions or comments about this Privacy Policy or our collection, use, disclosure, retention or protection of Personal Information, please contact us at this address, at 833-996-1631, or submit the interactive web form available here.
II. The Personal Information We Collect and How We Collect It
“Personal Information” is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you. Personal Information does not include information that is publicly available, de-identified, or aggregated.
We collect different types of information or data about you depending on your contact point with us, and how you interact with us and our website. Some information you may provide directly. Other information may be collected automatically.
Personal Information you provide directly to us includes:
- Your contact details, such as your full name, postal address, email address, and telephone number
- Your employer or other corporate affiliation, such as your title, business contact information, and employer’s name
- Information about products you purchase, consider, or inquire about
- Any Personal Information that you provide in the contents of your communications with us
Certain information, such as your IP address, device identifier, browser type, operating system and information about your use of our website may be collected automatically using tracking technologies when you navigate our website.
Cookies and Other Tracking Technologies
Our website may use cookies, web beacons (or tracking pixels), and embedded scripts, all of which are types of tracking technologies that collect data about you automatically. Cookies, for example, are small text files placed on your device that a website uses to recognize users. Cookies contain information that can later be read by a web server in the domain that issued the cookie to you or that, in some cases, can be read by a third-party domain.
The tracking technologies that we use may record information about your visits to the website so that we can provide an uninterrupted and more personalized experience for you and tailor our marketing and content to you. Tracking technologies can help us to identify visitors, recognize preferences, diagnose problems with our website, assess and analyze website trends and usage patterns, conduct market research, and otherwise improve our website. For example, we use third-party analytics applications such as Google Analytics to measure and analyze the behavior of visitors to the website and associated traffic patterns.
You may limit our use of cookies from Google Analytics by downloading and using the Google Analytics Opt-out Browser Add-on, which is available here.
More information about the cookies Carpenter uses, and your choices for limiting our use of cookies, can be found here.
III. How We Use the Information We Collect
In general, we use your Personal Information to:
- Communicate with you, including to answer your questions, request additional information, and respond to your feedback
- Process transactions and provide the products or services you request from us
- Prevent and address fraud, breaches of our policies or terms, and other threats or harm
- Analyze use of our website, evaluate and enhance website security and stability, and otherwise improve the website
- Comply with applicable legal requirements
IV. How We Disclose Personal Information
We may disclose your Personal Information:
- With our affiliates, subsidiaries, business partners, or vendors when it is reasonably necessary or helpful, such as to assist in communicating with you, or to analyze and improve our website or products
- With our employees, agents, vendors, and consultants who perform functions on our behalf – for example, we may use service providers to help us provide customer support, send various communications, or otherwise assist with the operation of our business
- To comply with applicable law or protect our and your rights and interests – for example, we may disclose your Personal Information if we determine that such disclosure is reasonably necessary to comply with the law, protect our or others’ rights, property, or interests, or prevent fraud or abuse
- In the event we sell or transfer all or a portion of our business assets, including during the negotiation of such transactions
- For any other purpose with your consent or as otherwise allowed by applicable law
V. How Long We Keep Personal Information
We generally maintain Personal Information according to our retention obligations and policies, operational business purposes, and other legal and regulatory requirements. For example, the Personal Information you provide may be retained and used to process future transactions. We discard this Personal Information when reasonably practicable.
We keep the categories of Personal Information described above for as long as is necessary for the purposes described in this Privacy Policy or otherwise authorized by law. This generally means holding the information for as long as one of the following apply:
- Your Personal Information is reasonably necessary to manage our operations, to manage your relationship with us, or to satisfy another purpose for which we collected the information;
- Your Personal Information is reasonably necessary to carry out a disclosed purpose that is reasonably compatible with the context in which it was collected;
- Your Personal Information is reasonably required to protect or defend our rights or property (which will generally relate to applicable laws that limit actions in a particular case); or
- We are otherwise required or permitted to keep your Personal Information by applicable laws or regulations.
Where your Personal Information is used for more than one purpose, we will retain it until the purpose with the latest period expires. For more information about our retention practices, please contact us using the contact details above.
VI. Third-Party Links
Our website may contain links to websites maintained by third parties with which we have no affiliation. This Privacy Policy does not reflect the privacy practices of those sites, and you should consult the privacy policies of those sites to learn about their practices. A link to any third-party site does not mean that we endorse it or the quality or accuracy of information presented on it.
VII. Protection of Personal Information
We take commercially reasonable and appropriate administrative, physical, and technical measures to protect your Personal Information from loss, theft, misuse, manipulation, and unauthorized access, disclosure, alteration, and destruction. However, transmission via the internet is not completely secure and we cannot guarantee the security of your personal information. If you suspect any unauthorized activity associated with your personal information, please report that activity to us immediately.
VIII. Our Commitment to Children’s Privacy
The Carpenter website does not provide products or services to children under the age of 18, and we do not knowingly collect the Personal Information of children through our website.
IX. “Do Not Track” Signals
Your browser may have a “do-not-track” setting that sends signals to websites with the technology to receive them to express your preferences regarding online tracking. We do not currently have the technology to respond to such signals.
X. California Privacy Rights
The following Notice is provided for California residents pursuant to the California Consumer Privacy Act, as modified by the California Privacy Rights Act of 2020 (CCPA). If you work for us, please see our California Employee Privacy Notice for applicable disclosures. California job applicants can find disclosures here.
The categories of Personal Information we collected within the past 12 months, the sources from which we collected Personal Information, the business and commercial purposes for which we collected and shared this information, and how long we retain it are described above. Here is how the Personal Information we collect fits within the categories defined by the CCPA:
- Identifiers—including your full name, postal address, email address, and telephone number and IP address
- Personal information described in Cal. Civ. Code § 1798.80(e)—overlaps with the identifiers we collect
- Commercial information—including purchase history, products purchased, obtained or considered, and other purchasing or consuming histories or tendencies
- Internet or other electronic network activity information—including device and usage information, browsing history, search history, and information regarding your interactions with our website, email engagement activity, information from cookies and other tracking technologies, and website analytics information
- Geolocation data—geolocation data inferred from your IP address
- Audio, electronic, visual, thermal, olfactory, or similar information—audio data collected when you call our customer service numbers
- Professional or employment-related information—including information about your employer or other corporate affiliation, such as your title, business contact information, and employer’s name
- We also collect the contents of your communications with us, which may include personal information that does not necessarily fit within one of the specific categories defined by the CCPA
We may disclose to our service providers any category of Personal Information we collect in order to further the business purposes described in this Policy. Within the past 12 months, we did not sell the Personal Information of California consumers, or share it for cross-context behavioral advertising.
If you are a resident of California, you have the right to submit certain requests relating to your Personal Information as described below. To exercise any of these rights, please submit a request through our webform or call us at 833-996-1631. Please note that if you submit a request to know, request to delete, or a request to correct, you will be asked to provide 2-3 pieces of Personal Information that we will match against our records to verify your identity before action is taken. You may designate an authorized agent to make the requests below on your behalf. An authorized agent must submit proof to us that he or she has been authorized by you to act on your behalf, and you will need to verify your identity directly with us before we will be able to process your request.
a. Right to Know
If you are a California consumer, you have the right to request more information regarding the following, to the extent applicable:
- The categories of Personal Information we have collected about you
- The categories of sources from which we collected your Personal Information
- The business or commercial purpose why we collected your Personal Information
- The categories of third parties, if any, with whom we shared your Personal Information
- The categories of Personal Information that we disclosed for a business purpose, and for each category identified, the categories of third parties to which we disclosed that particular category of Personal Information
The specific pieces of Personal Information we have collected about you
b. Right to Request Deletion of Your Personal Information
You have the right to request that we delete the Personal Information we collected from you, subject to certain exceptions. Where we use deidentification to satisfy a deletion request, we commit to maintaining and using the information in deidentified form and will not to attempt to reidentify the information.
c. Right to Correct Inaccurate Personal Information
If you believe that Personal Information we maintain about you is inaccurate, you have the right to request that we correct that information.
d. Right to Opt Out of the Sale and Sharing of Your Personal Information
Although California consumers have the right to opt out of sales of their personal information, we do not sell Personal Information or share it for cross-context behavioral advertising, so there is no need to submit such a request to us.
e. Right to Non-Discrimination for the Exercise of Your Privacy Rights
If you choose to exercise any of the privacy rights conferred by the CCPA, you also have the right not to receive discriminatory treatment by us. This means that, consistent with California law, we will not deny providing products to you, charge you different prices or provide a different level or quality of products to you unless those differences are related to the value of your Personal Information.
XI. International Users
If you are using our website outside the United States, please be aware that Personal Information we obtain about you may be transferred to and processed in the United States, Canada, or other jurisdictions outside your own. Your Personal Information may be accessible by public authorities where it is processed. By using our website and providing your Personal Information, you acknowledge that your Personal Information may be transferred to and processed in jurisdictions other than your own. Please be aware that the data protection laws and regulations that may apply to your Personal Information transferred to the United States, Canada, or other countries may be different from the laws in your country of residence.
XII. European Notice
As a supplement to the information provided throughout our Privacy Policy, Carpenter provides the following additional information relevant to users of our website who are residents of the European Economic Area or the United Kingdom.
Legal Bases. We rely on the following legal bases for processing your Personal Information:
- The processing is necessary for us to provide you with the products and services you request or to respond to your inquiries.
- We have a legal obligation to process your Personal Information.
- We have a legitimate interest in processing your Personal Information. In particular, we have a legitimate interest in the following instances:
- To analyse and improve the safety and security of our website, including by implementing and enhancing security measures and safeguards and protecting against fraud, spam, and other abuse;
- To maintain and improve our website; and
- To operate our website and provide you with information and communications about our products and services that are tailored to, and in accordance with, your personal preferences.
- You have consented to our processing of your Personal Information. When you consent, you may change your mind and withdraw your consent at any time.
Data Retention. We keep Personal Information for no longer than necessary to achieve the purposes for which the Personal Information was collected or as required or permitted by applicable law. To determine the appropriate retention period, we consider the scope and sensitivity of the Personal Information; the potential risk of harm from unauthorised access to, use of, or disclosure of the information; the purposes for which we process the information and whether we can achieve those purposes through other means; and applicable legal requirements. Unless otherwise required by applicable law, at the end of the retention period, we will securely destroy your Personal Information or take appropriate anonymization steps.
European Privacy Rights. You have the right to access, correct, erase, and obtain a copy of any Personal Information we maintain about you. You also have the right to object to or further restrict our processing of your Personal Information. If you are a resident of the European Economic Area or United Kingdom, you may exercise any of these rights by making a request through our contact form.
Before we can provide, delete, or change any of your information or otherwise respond to your request to exercise your rights, we may ask that you verify your identity. We may also ask for more details to help us respond to your request. Please note that applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to any legal restrictions on providing this information.
If you believe that we have violated any of your data protection rights under the European Union’s or United Kingdom’s General Data Protection Regulation, you may contact us as provided at the top of this Privacy Policy or submit a complaint directly to the data protection authority in your jurisdiction. If you reside in the European Economic Area, you can find information about your data protection authority here. If you reside in the United Kingdom, you may file complaints with the Information Commissioner’s Office here.
XIII. Canadian Privacy Notice
As a supplement to the information provided throughout our Privacy Policy, Carpenter provides the following additional information for residents of Canada. You have the following rights with respect to your personal information:
• Access to your personal information;
• Verify or correct inaccuracies in your personal information;
• Delete your personal information; and
• Where you have provided your consent to the collection, use, transfer, or other processing of your personal information, withdraw your consent under certain circumstances.
You may submit these requests using our contact form. We may require specific information from you to help us verify your identity prior to processing 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 any legal or regulatory restrictions on disclosing this information. Please note, if you withdraw your consent, we may not be able to provide you with a particular product or service. We will explain any impact to you to help you with your decision.
XIV. Changes to This Privacy Policy
We may change this Privacy Policy from time to time. Should we do so, we will post the changes to this page. We suggest that you periodically consult this Privacy Policy to review any changes. Your continued use of our website after the effective date of any modification to the Privacy Policy will be deemed to be your agreement to the changed terms.