This Notice describes how your personal information is used by The Dow Chemical Company and its subsidiaries and affiliates (collectively, “Dow”) – what information we collect, how we use it, and why. This Notice applies to information gathered from Dow’s former, current and prospective customers.

Dow must keep and process certain information, including personal data, to maintain our commercial relationships and to enable us to run our business. This information will typically come directly from you, and in some cases is supplemented by information gathered by Dow from external sources. Dow’s collection and use of your personal information is subject to all applicable legal requirements and to the Privacy Statement set forth on Dow.com (see https://legal.dow.com/en-us/privacy-statement).

What Information Dow Collects

During our commercial relationship, Dow may collect personal information about you. The specific types of information that Dow collects include:

• Contact information, such as name, job title, business name and mailing address, email, phone numbers, and industry or business segment
• Marketing and promotional communication preferences and interests that you provide to Dow
• Digital actions captured via cookie tracking in electronic communications and website visits

Dow collects this information for several purposes, including performance of our contracts with you, complying with Dow’s legal obligations, and to pursue our legitimate business interests in marketing and promoting Dow products.

How Dow Collects Your Information

In most cases, Dow collects personal information directly from you through completion of marketing segmentation and profiling inquiries, or through interactions with you during meetings with Dow employees and/or contractors such as commercial negotiations and trade shows. In some cases we collect information about you from external parties such as market research and surveying firms.

How Dow Uses Your Information

Dow uses your personal information in the following ways:

• To pursue Dow’s legitimate business interests in marketing and selling Dow products;
• To comply with our contractual obligations to you; and
• To comply with legal requirements.

Dow may seek your voluntary consent to use your personal information for other purposes, such as marketing and promotional communications or surveys. Your consent to such activities is entirely voluntary and can be withdrawn at any time.

Transfer and Sharing of Personal Information

In conducting its global business operations, Dow will share your personal information among personnel employed by Dow affiliates in different countries. In some cases, personal information held by Dow is shared with third parties such as vendors, contractors and other Dow service providers, as well as with legal and regulatory authorities. Dow uses contracts requiring third parties to respect the security of your data and to treat it in accordance with applicable law.

Automated Decision-Making or Profiling

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. Dow does not use automated decision-making processes to make significant decisions about its customers. If Dow has a lawful basis and need to use any automated decision-making or profiling systems, Dow will provide you with notice of this.

Data Security

Dow has put in place security measures to prevent your personal information from being accidentally lost, altered, disclosed, used or accessed in an unauthorized way. We limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality. Dow has procedures in place to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Data Retention

Dow will retain your personal information for as long as necessary to fulfill the purposes for which we collect it, including for the purposes of satisfying any legal, accounting, or reporting requirements.

Your Rights to Your Data

Different legal systems impose different requirements on Dow with respect to your rights over your personal information. Dow will comply with all legal requirements in every jurisdiction where we operate and will make reasonable efforts to comply with reasonable requests with respect to your personal information, wherever we operate.
No fees or payments are required to exercise your legal rights, though Dow may charge fees for duplicate or excessive requests. Dow may request information from you to allow us to confirm your identity and your rights over the data, as a security measure.

Changes to this Privacy Notice

Dow has the right to update this Privacy Notice, and to provide you with a new Notice in the event of any significant updates. Dow may also notify you in other ways from time to time about our processing of your personal information.

For European Union Customers

Additional Privacy standards may be required in certain jurisdictions, like the EU General Data Protection Regulation (GDPR) standards applicable to customers (former, current, prospective) in the European Union countries. If you are based in the European Union, you can contact Dow’s Data Privacy team at FGLPRIV@dow.com  to identify the Data Controller responsible for the processing of your information. The following specific rights apply to customers (former, current, and prospective) in the European Union:

• Right of Access: You have a right to know whether Dow holds personal data about you, to access that information, and to receive a copy of it. You are entitled to information on the purposes of our processing, the categories of personal data we keep, to whom your data is transferred, how long we keep it, and other information contained in this Notice.
• Right to Rectification: You have the right to have inaccurate information corrected and incomplete data completed.
• Right to Erasure: You can ask us to delete your personal information where it is no longer necessary or there is no good reason for us to keep it, or where you have exercised your right to object to processing (as described below). However, Dow may have the right to keep information which is legally required or necessary for purposes of legal claims.
• Right to Restrict: You can ask us to restrict our use of your data where you believe that the data is inaccurate, or that our use is unlawful, unnecessary or otherwise objectionable.
• Right to Transfer: You have the right to ask us to transfer data about you collected through your consent or in accordance with your employment contract to another entity, where technically feasible.
• Right to Withdraw Consent: If our collection or use of your data was based on your consent, you can change your mind and withdraw that consent at any time.
• Right to Complain: If you believe we have not complied with legal requirements, you have the right to lodge a complaint with the relevant data protection authorities.
• Right to Object: You have a general right to object to processing of your personal data, and to have Dow limit such processing unless we have an overriding legal justification to do so.

European personal data is transferred out of Europe only (1) to countries or entities which ensure an adequate level of data protection in accordance with the European Commission’s requirements, or (2) after implementation of appropriate data transfer agreements to ensure an adequate level of protection and compliance with all applicable data protection laws. To request copies of such agreements, contact FGLPRIV@dow.com .

Contacting Dow

Questions, requests and inquiries concerning this Privacy Notice and the information set out in this Notice may be directed to your local Dow representative, or directly to Dow’s Data Privacy team at FGLPRIV@dow.com .