Privacy Policies

Privacy Statement

INTRODUCTION
East Coast Stainless Inc. and its subsidiaries, affiliates and JV companies (together “East Coast Stainless”, “ECS”,“we”, “our” or “us”) are committed to protecting your privacy and complying with applicable data protection and privacy laws globally.

This statement details how we collect, use and manage the personal information provided to us, whether by individuals we do business with, job applicants or by visitors or users of our website.

We want to help you make informed decisions, so please take a few moments to read this statement.

DATA COLLECTION & USE
East Coast Stainless collects personal information from a range of individuals in the context of its business activities, including:

  • Representatives of our counterparties and advisors
  • Job applicants
  • Users of our website
  • Anyone who provides their personal information to us

Data collected directly from individuals
The types of personal information we may collect from you, includes:
contact details such as your name, title, company name, job position, email address, telephone numbers and
physical address

  • photographic identification
  • Information disclosed by you in communications via telephone, letter, email, social media or in meetings
  • Information collected from due diligence checks and clearance questionnaires
  • Attendance records where you attend our offices and sites
  • Feedback from you about our products and services, including our websites
  • Third party references and details of your education and employment history together with salary information and additional personal information as described in your CV if you are applying for a job

We collect personal information from you through our websites in the following situations:

  • you complete one of the “Contact Us” forms which appear on many pages of our websites or you click on the“Email” tab
  • you apply for a position with East Coast Stainless through the careers page of our website
  • you use one of the customer or supplier tools available through our websites and submit your personal information through these tools
  • you register with us to receive alerts

When collecting information that might be used to contact you about products or services, we give you the opportunity to opt out from receiving such communications.
We only use the personal information collected from you for legitimate business‐related purposes, including:

  • To respond to queries or requests submitted by you
  • To process orders or applications submitted by you Page 2 of 3
  • To perform any contract between you and us
  • To manage accounts and records
  • To conduct clearance procedures
  • For demographic analysis and to personalize your web experience
  • To support our corporate social responsibility activities and company policies
  • To comply with any law or regulation

Data collected by automated means
We automatically collect certain standard information that is sent by your browser to our website when you usethem. This includes technical information such as the type of internet browsers you use, the websites from whichyou linked to our websites, language and time zone settings, access times and your IP address, which may berecognized as personal information.

We use this information to administer our website and for legitimate internal operational reasons including troubleshooting, data analysis, testing, research and statistical and survey purposes.

We also collect limited personal information from cookies on our websites, which we explain more about below.

OUR USE OF COOKIES
Like many websites we use cookies for a variety of purposes.

A cookie is a small data file, which often includes an anonymous unique identifier that is sent to your browser from a website’s computers and is stored on your computer’s hard drive, if your browser settings allow it. These technologies collect information about your device hardware and interactions with our site. We use this information to help us to analyze how our site is used so we can continually improve its content and functionality and to remember your preferences in case you revisit our site. We do not use cookies to target advertising or to share information with social networking sites or other services.

To learn about what cookies and similar technologies are and how you can delete or reject cookies, we recommend that you visit the following third‐party website: http://www.allaboutcookies.org/.

DISCLOSURE OF PERSONAL DATA
East Coast Stainless will only disclose personal information if absolutely necessary in all circumstances. We may disclose your personal information, strictly for the following purposes:

  • To third‐party providers who use your personal information to provide a service to us
  • If East Coast Stainless decides to sell, buy, merge or otherwise reorganize its businesses
  • To protect any intellectual property rights in any materials displayed or otherwise available from our websites,portals and apps
  • To respond to a legal request or comply with a legal obligation

Any third‐party provider we appoint must act in accordance with our written instructions when processing your personal information and must protect your personal information in accordance with contractually agreed security measures.

East Coast Stainless does not sell, trade or rent your personal information, or use or disclose it for marketing purposes, and does not give or distribute it to any third parties except as described above.

INTERNATIONAL TRANSFERS OF PERSONAL DATA
Personal information collected on our websites, portals and apps may be stored and processed in the United States or any other country in which East Coast Stainless operate worldwide. Page 3 of 3 Where we store or transfer your personal information to a third‐party provider based outside of the European Economic Area, we take steps so that your personal information is adequately protected.

SECURITY
East Coast Stainless is committed to protecting the security of your personal information. Whilst no security measure can guarantee against a data breach, we use a variety of security technologies and procedures to help protect data from accidental or unlawful destruction, accidental loss, unauthorized access, destruction, misuse, modification or disclosure.

YOUR RIGHTS
You may, under certain circumstance and pursuant to applicable law, have the right to access the personal information we hold about you and ask for it to be rectified and deleted at any time. You can do so through the “Contact Us” page on our websites.

DATA RETENTION
We only hold your personal information for as long as necessary to fulfil the purposes for which it was collected,before making it non‐identifiable or deleting it.
If you choose to unsubscribe from a service then we may keep a list containing your details so we know you have unsubscribed.

LINKS TO OTHER WEBSITES
Our websites may contain links to those of other third‐party companies. These websites operate independently from our websites and are not subject to this Privacy Statement. You should review the privacy statements of those websites to determine how they use and protect personal data.

CHILDREN
Our websites are general audience sites, however East Coast Stainless does not seek to gather information about children through its websites and will not do so deliberately. If you are under 16 years old, please do not send us your personal information (for example your name, address and email address). If you are under 16 years old and you do wish to ask a question or use this website in anyway which requires you to submit your personal information please ask your parent or guardian to do so on your behalf.

QUESTIONS
If you have any questions or concerns regarding this privacy statement or our handling of personal information,please contact us through the “Contact Us” page on our websites.

CHANGES TO THIS PRIVACY STATEMENT
East Coast Stainless may update this privacy statement from time to time. When we do we will revise the effectivedate at the top of the privacy statement.

Website Notice

PLEASE READ THE FOLLOWING TERMS OF USE AND DISCLAIMERS CAREFULLY BEFORE USING THIS WEBSITE
Legal Notices and Terms of Use
Welcome to our internet or intranet Site. East Coast Stainless Inc. (“ECS”) offers this Site to you conditioned on your acceptance without modification to the following terms and conditions (“Terms”). Your use of this Site shall be your agreement to abide by each of the following terms and conditions set forth. If you do not agree with any of the terms stated herein, please do not use this Site.

General Use Limitations
ECS or third parties granting rights to ECS hold all right, title, and interest in and to the materials on this Site, which are the copyrighted work of ECS or such third parties. ECS grants you a limited, personal, non‐commercial, non‐exclusive and non‐transferable license to use and display the materials only on your personal computer only for purposes associated with your interaction with this Site. Except as stated herein, you may not copy (whether by printing off onto paper, storing on disk, downloading or in any other way), distribute (including distributing copies), broadcast, reproduce, alter or tamper with in any way or use any material contained in the Site. This limited license terminates automatically, without notice to you, if you breach any of these Terms. Upon termination, you must immediately destroy any downloaded and printed materials. You have no right, title or interest (and no copyright, trademark or other intellectual property right) in or to the Site or any materials.

ECS does not routinely monitor your postings to our Site but does reserve that right. However, in our efforts to promote good citizenship within the Internet community, if ECS becomes aware of inappropriate use of the Site or any of its services, ECS will respond in any way that, in its sole discretion, ECS deems appropriate. You acknowledge that ECS will have the right to report to law enforcement authorities any actions that may be considered illegal, as well as any reports it receives of such conduct. When requested, ECS will cooperate fully with law enforcement agencies in any investigation of alleged illegal activity on the Internet.

Disclaimer of Warranties
Your use of this Site is at your own risk. This Site may include inaccuracies or errors that may affect the quality of the materials on the Site. The materials have not been independently verified or authenticated in whole or in part by ECS. ECS does not warrant the accuracy or timeliness of the materials. ECS has no liability for any errors or omissions in the materials, whether provided by ECS or third parties. ECS reserves the right to change the terms for which this Site is offered. As such, you are responsible for regularly reviewing these terms. All provisions relating to Copyrights and Trademarks, Disclaimer, Limitation of Liability, Indemnification, Applicable Laws, Warranties and General Use Terms shall survive any termination.

THIS SITE AND THE MATERIALS, INFORMATION, SERVICES, AND PRODUCTS CONTAINED IN THIS SITE ARE
PROVIDED TO YOU ON AN “AS IS” BASIS, WITHOUT WARRANTIES OF ANY KIND, WHETHER EXPRESS OR IMPLIED. ECS, FOR ITSELF AND ANY THIRD PARTY PROVIDING MATERIALS, SERVICES, OR CONTENT TO THIS SITE, MAKE NO REPRESENTATIONS OR WARRANTIES IN CONNECTION WITH THE SITE INCLUDING BUT NOT LIMITED TO THE QUALITY, SUITABILITY, TRUTH, ACCURACY OR COMPLETENESS OF ANY MATERIAL, INFORMATION, PRODUCT, OR SERVICE CONTAINED ON THE SITE. ALL CONDITIONS, REPRESENTATIONS AND WARRANTIES, WHETHER EXPRESS,IMPLIED, STATUTORY OR OTHERWISE, INCLUDING ANY IMPLIED WARRANTY OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, OR NON‐INFRINGEMENT OF THIRD PARTY RIGHTS, ARE HEREBY DISCLAIMED. ECS WILL NOT BE LIABLE TO YOU OR ANY THIRD PARTY FOR ANY DAMAGES OF ANY KIND, INCLUDING BUT NOT LIMITED TO, DIRECT, INDIRECT, INCIDENTAL, CONSEQUENTIAL OR PUNITIVE DAMAGES, ARISING FROM OR CONNECTED WITH THE SITE, INCLUDING BUT NOT LIMITED TO, YOUR USE OF THIS SITE OR YOUR INABILITY TO USE THE SITE, EVEN IF ECS HAS PREVIOUSLY BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.

To increase value in your use of the Site, you may enter into correspondence with, purchase goods and/or services from, or participate in promotions of advertisers or members or sponsors of the Site. Unless otherwise stated, any such correspondence, advertisement, purchase or promotion, including the delivery of and the payment for goods and/or services, and any other term, condition, warranty or representation associated with such correspondence, purchase or promotion, is solely between you and the applicable third party. You agree that ECS has no liability,
obligation or responsibility for any such correspondence, purchase or promotion between you and any such third party.

This Site may include links to external websites. These links are provided to help you find relevant websites, services and/or products which may be of interest to you quickly and easily. It is your responsibility to decide whether any services and/or products available through any of these websites or for any goods or services they supply or for the content of their websites and does not give or enter into any conditions, warranties or other terms or representations in relation to any of these or accept any liability in relation to any of these (including any
liability arising out of any claim that the content of any external website to which this website includes a link infringes the intellectual property rights of any third party). You acknowledge that ECS is providing these links to you only as a convenience, and you agree that ECS is not responsible for the content or links displayed on such sites to which you may be linked.

ECS is not and will not undertake any obligation or liability relating to any contents or activities on this Site. ECS does however, reserve the right to block or remove any communications or materials that it determines to be offensive, abusive, deceptive, defamatory or any other communication that is deemed inappropriate at its sole discretion.

Errors or Omissions
The descriptions, pictures and other representations of products on this site may contain inaccuracies, omissions and errors. ECS does not make any warranty or representation with respect to the accuracy or completeness of any such information.

Furthermore, the prices and availability of products on this site may change without notice to you at any time in ECS’s sole discretion.

ECS shall have the right to refuse or cancel any orders placed for product listed at incorrect prices. ECS shall have the right to refuse or cancel any such orders whether or not the order has been confirmed and your credit card charged. If your credit card has already been charged for the purchase and your order is canceled, ECS shall promptly issue a credit to your credit card account in the amount of the charge.

Local Laws; Export Control
ECS controls and operates this Site from its headquarters in the State of Delaware, located in the United States of America, and makes no representation that the materials are appropriate or will be available for use in other locations. Unless otherwise explicitly stated, all marketing or promotional materials found on this Site are solely directed to individuals, companies or other entities located in the United States. If you use this Site from outside the United States of America, you are entirely responsible for compliance with applicable local laws, including but
not limited to the export and import regulations.

The materials on this Site are subject to the United States Export Administration Laws and Regulations. Diversion of such materials contrary to United States law is prohibited. Neither the materials, nor any information acquired through the use of the Site, may be acquired for, shipped, transferred, or re‐exported, directly or indirectly, to proscribed or embargoed countries or their nationals, nor may it be used for nuclear activities, chemical biological
weapons, or missile projects, unless specifically authorized by the United States Government for such purposes. You shall comply strictly with all United States export laws and assume sole responsibility for obtaining licenses to export or re‐export as may be required.

Trademarks
The East Coast StainlessTM logo, and all products or services denoted with TM or ® are trademarks or service marks or registered trademarks or service marks of ECS. ECS trademarks may not be used in connection with any product or service that is not an ECS product or service.

Terms of Use Changes
ECS may change the terms, conditions and use and disclaimer set out above from time to time. By browsing and using this Site, you are accepting that you are bound by the current terms, conditions, use and disclaimer and therefore you should check these each time you revisit the site. Your continued use of the Site after such modifications have been made will constitute your acceptance of such revised Terms.

Choice of Laws
Your use of this Site shall be governed in all respects by the laws of the State of Delaware, without regard to the choice or conflicts of law provisions of any jurisdiction. You agree to submit to the jurisdiction of the courts located in the State of Delaware, for the resolution of all disputes arising from or related to these Terms and/or your use of the Site.

Unauthorized Conduct
You are responsible for ensuring that your use of this Site and content herein is lawful under the laws of any country in which you use them. You may not use any ECS content on any website which (or includes content which) would or may damage the reputation of ECS in any way. Without limiting the above, you may not use any ECS content on any website which (or includes content which):
1.is unlawful, defamatory, obscene, profane, discriminatory, objectionable or inappropriate;
2.defames, threatens, harasses, abuses or otherwise violates the rights of others;
3.promotes or provides instruction on unlawful conduct or promotes any form of violence or physical harmtowards others; or
4.infringes the rights of another party.

Submissions and unauthorized use of any materials contained on this Site may violate copyright laws, trademark laws, the laws of privacy and publicity, certain communications statutes and regulations and other applicable laws and regulations. You alone are responsible for your actions or the actions of any person using your user name and/or password. As such, you shall indemnify and hold ECS and its officers, directors, employees, affiliates, agents, licensors, and business partners harmless from and against any and all costs, damages, liabilities, and expenses (including attorneys’ fees) incurred in relation to, arising from, or for the purpose of avoiding, any claim or demand from a third party that your use of the Site or the use of the Site by any person using your user name and/or password (including without limitation your participation in the posting areas or your submissions) violates any applicable law orregulation, or the rights of any third party.

Contact Information
If you have any questions about the Terms or Site usage, please contact us.





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