Privacy Policy

DATED: 2 December, 2024

A. Fundamental Principles

a. This Privacy Policy is formulated and presented on behalf of Westlake Chemicals & Vinyls LLC. In this policy, when we refer to "Company", "we", "us" or "our", it pertains to the specific entity within Westlake Chemicals & Vinyls LLC that is responsible for the management and processing of your data.

b. We are resolutely committed to safeguarding and respecting your privacy and, simultaneously, to upholding the trust and confidence of our customers. This privacy policy elucidates the mechanisms through which your personal information is gathered, the underlying justifications for its collection, and the strategies employed to ensure its security. We are wholeheartedly dedicated to fulfilling our obligations in accordance with all applicable global data privacy laws, such as the General Data Protection Regulation (‘GDPR’), the California Consumer Privacy Act (‘CCPA’), the Virginia Consumer Data Protection Act (‘VCDPA’), and the Canadian Personal Information Protection and Electronic Documents Act (PIPEDA), along with any provincial laws that bear substantial similarity.

B. Scope of Information Collection

a. Personal Information encompasses any data related to you that can distinctly identify you or from which your identity can be reasonably inferred. Irrespective of the accuracy of the information, if it serves to identify you, it is regarded as Personal Information. When anonymous information is directly or indirectly associated with personal information, the resulting amalgamation is also deemed as Personal Information. Anonymous information, on the other hand, is data that neither directly nor indirectly reveals your identity and cannot be reasonably utilized to identify an individual. Aggregate information pertains to groups or classifications of customers and does not single out any particular individual.

b. We primarily amass two principal types of information – Personal Information and anonymous information. Additionally, we may generate a third type, namely aggregate information, by leveraging personal and anonymous information.

c. The specific information we collect includes:

- Contact particulars such as your first and last name, email address, residential address, and mobile or other phone numbers.

- Personal attributes like your gender, age, age range, or image; account login credentials including your username, password, and pictures associated with your profile.

- Information exchanged between two parties or within a small group via email, post, or other communication channels.

- Information procured from third parties, such as site or platform providers, regarding your utilization of or interest in our services.

- Location data, including that furnished by a mobile or other device interacting with our Websites or linked to your IP address (where legally permissible).

- Activity, technical, and device details about your usage of our Game, such as the content you peruse, the time and duration of your visits to our Game, the frequency of your service usage, how you initially discovered our Game, your preferences, and information about your interaction with the content offered through our Game. This also encompasses your hardware model, device type, unique device identifiers, operating system version, browser type, and IP address.

- Sensitive information like biometric data, geolocation, driver's licenses, and financial information for fulfilling our legal and regulatory obligations.

C. Technology-Driven Data Collection

a. When you engage with our Game, our objective is to render the experience seamless and beneficial. We and our partners employ industry-standard identifiers, such as cookies or other analogous technologies.

b. Our Game may incorporate technologies to enhance your experience. These technologies manifest as small files that are deposited on your computer, tablet, mobile phone, or other devices when you visit a website. They empower us to record specific details whenever you visit or interact with the Game. Usage information may incorporate browser type, operating system, device type, an approximation of your geographic location based on your IP address, the location of your mobile device, the page served, the time, referring URLs, and other information typically transmitted in HTTP requests. This statistical data offers valuable insights into your utilization of the services, such as your interaction with a specific page, the nature of the content on that page, and the duration of your stay. Generally, usage information is non-identifying. However, if the Company correlates it with you as a specific and identifiable individual, it will be treated as Personal Information.

c. Illustrative examples of these technologies are as follows:

- APIs: These function by facilitating the communication between different software. They streamline the work of programmers and augment the experience for end users.

- Cookies: Small text files placed in your device browsers to store your preferences. Although most browsers permit you to block and delete cookies, doing so might impede the proper functioning of the service.

- Event tagging: Enables us to monitor actions on the Game, such as application installs and purchase events. By tracking these events, we can dissect data, evaluate ad performance, and formulate target audiences for advertising.

- Mobile device identifiers: We may share the advertising identifier associated with your mobile device or tablet (like the Apple IDFA and Google Advertising ID) with advertisers. This is utilized to identify your device for internet-based advertising. For instructions on using the advertising choice mechanisms provided by popular mobile operating systems, visit the NAI’s Mobile Choices page here.

- Pixel tags/web beacons: A pixel tag (also known as a web beacon) is a segment of code embedded in the Game that gathers information about your engagement on a web page. For instance, it allows us to record that a user has visited a particular web page or clicked on a specific advertisement. We may also incorporate web beacons in emails to ascertain if messages have been opened, acted upon, or forwarded.

D. Information Acquisition Methodologies

a. We collect information through a diverse range of means, as detailed below. You affirm that any contact information you provide is accurate and bona fide.

b. Information furnished directly by you, including when you visit our Game, register on it, respond to a survey, fill out a form, or engage with other activities, services, features, or resources we offer on our Game.

c. In addition to gathering information via our Game, we collect information from you through telephone, video, or correspondence (encompassing email, live chat, mail, text message, or social media). All telephone or video calls between you and Company representatives may be recorded for training, quality control, and compliance purposes. By persisting with any such call, you implicitly consent to its recording.

d. We also collect information about your utilization of our products and services through various technologies present when you visit our Websites, including the Game, or use our applications on third-party sites or platforms (irrespective of whether you are logged in or registered). This includes cookies, flash cookies, pixels, tags, and application programming interfaces (“API”).

e. For further details, refer to the section titled “Personal Data Collected via Technology” below. Analytics tools are also deployed by us to collect information when you visit our Game or use our applications or services on third-party sites or platforms.

f. Finally, we utilize reliable sources to update or supplement the information you provided or that we have collected, including for the purpose of verifying or validating information (such as postal address, documentation, and names).

E. Utilization of Collected Information

a. We utilize the collected information to operate our Game, furnish our products and services, address your queries, and meet all applicable regulatory requisites.

b. In accordance with applicable laws and any available options for you, the Company may collect and employ your information for specific objectives:

- To provide and administer the services you solicit. This entails processing your registration, establishing and maintaining your account, and conducting fraud prevention checks.

- To augment customer service and our services. The information you provide assists us in more efficaciously responding to your customer service requests. We may also leverage your feedback to refine our products and services.

- To customize the user experience. We may utilize aggregated information to fathom how our users as a collective utilize the services and resources proffered on our Game.

- To reach out to you regarding our services, including for marketing intents. This can be through email, live chat, telephone, text message, mail, or social media.

- To adhere to our legal and regulatory obligations. We may utilize the information we collect about you for regulatory purposes, including detecting, investigating, and preventing activities that contravene our terms and conditions or may be illegal.

- To offer alternative dispute resolution services. We may provide information we collect about you to our service provider partner for the specific purpose of resolving disputes that have not been satisfactorily resolved through our internal processes.

- To conduct market research and analysis. This encompasses analyzing how you interact with our products and services, monitoring and analyzing usage and activity trends, and for other research, analytical, and statistical purposes.

c. We do not engage in automated decision-making as defined by global data protection laws.

d. We may collaborate with a third-party service provider to display advertising on our Game or any application accessible via our Game or to manage our advertising on other websites. Our third-party service provider may utilize technologies such as cookies to gather information about your activities on our Game and other websites in order to present you with advertising based on your browsing activities and interests.

F. Your Rights

a. If we process your personal information for direct advertising purposes, you possess the right to object at any juncture. This also holds true for profiling, if pertinent, insofar as it is associated with such direct advertising.

b. You can elect to cease receiving commercial messages from us by following the instructions in those messages or by contacting Customer Support. In the event of your objection to processing for direct advertising purposes, we will desist from processing your personal information for these purposes.

c. By law and subject to certain conditions, you are endowed with several rights concerning the personal information we hold about you. These rights include the right to access the personal information we hold about you, the right to object to the processing of your data, the right to update and correct the information we hold about you, and the right to withdraw any consent provided. In some circumstances, you can request us to delete the personal information we hold about you.

d. We will not discriminate against you (for example, by denying products and services or providing a different level or quality of goods or services) for exercising any of the rights afforded to you.

e. If you wish to employ an agent authorized in accordance with applicable law to exercise your rights, we may request proof that you have bestowed such agent with power of attorney or that the agent otherwise has valid written authority to exercise those rights on your behalf.

G. Information Protection Protocols

a. We have instituted physical, electronic, and operational procedures to shield the information we collect. We adopt appropriate data collection, storage, and processing practices and security measures to safeguard against unauthorized access, alteration, disclosure, or destruction of your personal information, username, password, transaction information, and data stored on our Game. Our security measures are periodically reviewed and updated to keep pace with technological advancements.

b. We employ reasonable means to protect your personal information from misuse, interference, or loss, as well as any unauthorized access, modification, or disclosure.

c. If we suspect that a reportable data breach has occurred, we will adhere to the legislative requirements to notify you of the data breach and any steps taken by the Company to contain and investigate the data breach.

H. Information Retention Duration

a. We will retain your information for a period requisite to reasonably fulfill the purposes delineated in this Privacy Policy, unless a lengthier retention period is mandated by law.

b. We will take reasonable measures to destroy or permanently de-identify any Personal Information when we no longer require it for any purpose for which it was collected or for a related purpose, and when we are not obliged by law, by a regulator, or by a court/tribunal order to retain it.

I. Information Sharing Practices

a. We do not sell, trade, or rent your personal information. However, there are circumstances under which we share your personal data with the following categories of third parties:

- Affiliates: Other companies within the Company.

- Service providers: Other companies that provide services to you on our behalf.

- Third parties that interact with us in connection with the services we perform.

If data is shared with a third party, we require them to maintain the same level of protection over your data as we do and to only perform services on our behalf. In other words, they are precluded from using your personal information for purposes other than those requested by us or required by law.

b. We only share information with third parties in circumscribed circumstances, including the following:

- When you authorize us to share your information with third parties.

- When providing you with products and services and apprising you of significant changes or developments in the features and operation of those products and services.

- In response to lawful requests by public authorities, including for national security or law enforcement purposes, when ordered to do so by any regulatory body and/or under any legal provision contained in the governing law of a particular jurisdiction.

- When instructing and authorizing the financial institution holding a user’s account to disclose any information as may be requested by a regulator in respect of the user’s account.

- To enforce our terms and conditions set out on our Game, to protect our rights and property and the rights and property of our customers and third parties, to detect fraud or other illegal activities, and to comply with the law or legal processes.

- To perform customer due diligence, including ID verification.

J. Policy Updates

a. This Privacy Policy may be amended from time to time to mirror changes in our operational modalities or the regulatory framework governing our work. We will apprise you of significant changes and, where mandated by law, obtain your consent. Notification may be effected by posting the changes on our Game or through other means in accordance with applicable laws.

b. Any alterations to the Privacy Policy will take effect when the updated policy is published on our Game.

c. We encourage you to routinely check this page for any modifications to stay informed about how we are protecting the personal information we collect.

d. This Privacy Policy, effective as of the last modified date stated below, supersedes and replaces all previous Privacy Policies.

K. Contact Us

a. If you have specific inquiries regarding your personal information or how we use it, please contact our Data Protection Officer directly by email at [email protected].