Last Updated: December 2022
- What Personal Data we collect
- How we use that Personal Data
- How we may share that Personal Data
- How we protect that Personal Data
- Your choices regarding your Personal Data
To the extent possible, before you submit your Personal Data to Lincoln Electric, you will be informed about certain rights you have regarding Personal Data you submit and how that Personal Data will be processed and used by Lincoln Electric. At that time, you may consent to the use of and submit your Personal Data by Lincoln Electric or decline to consent to such use and not submit your Personal Data.
What is Personal Data?
The term “Personal Data” means “any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.”
What Personal Data We Collect and How We Use That Personal Data?
Customer, Vendor, and Suppliers: Lincoln Electric may collect and process the following categories of Personal Data concerning our customers, vendors, and suppliers: name and surname, contact details (e.g., email address, telephone number, residential address), job title, bank account details and financial information (including credit/income history), transaction history, communications and criminal records. We process this information for facilitate routine and common business practices, such as those related to sales orders and management, promotion and quotation submitting, warranty management, credit collection, compliance with the US Foreign Corrupt Practices Act, Export Controls and other legal requirements, accounting, corporate transactions, and defense of our interests and claims.
Website Users: Lincoln Electric collects Personal Data for the purpose of providing information or updates about Lincoln Electric or its products or arc welding to individuals who visit the Site. We may also use Personal Data you submit for internal purposes including the administration of the Site, data analytics, corporate transactions, and compliance with law or legal process and Lincoln Electric's policies and procedures. You also provide new, or updated or corrected Personal Data to Lincoln Electric from time-to-time
Job Applicants : Lincoln Electric collects Personal Data from prospective employees, independent consultants and advisers who submit applications for consideration.
Video Conferencing Events Participants : Lincoln Electric may collect Personal Data such as voice and/or video recordings, in the course of training events, meetings, conferences and other events we may organize.
Who Provides Us With Your Personal Data?
The Personal Data that we collect and process on our customers, vendors, suppliers and video conferencing events participants, is derived from the individual or from his/her business. For website users, we collect Personal Data that you choose to enter into the Site.
Lincoln Electric may also receive Personal Data from distributors to incentivize sales and from third parties who provide services to us, such as trade shows, mailing or other list services. Lincoln Electric may receive the following categories of Personal Data, such as your name, email address, phone number, job title, business or personal address.
As for job applicants, Lincoln Electric generally collects Personal Data directly from the job applicants (e.g. via a dedicated, online talent management platform or via email communication). Lincoln Electric may also receive Personal Data about job applicants from third parties who provide services to us, such as a third party staffing or recruiting firm.
Why Do We Process Personal Data?
Categories of Personal Data collected and purposes for which they are processed are listed below:
- Complete a Transaction: You provide Personal Data to Lincoln Electric so we can provide you services and products or information pertaining to our services and products. Often, this transaction is governed by a binding contract and in order for Lincoln Electric to fulfil the terms and conditions of that contract, we need to collect, use, and retain, your Personal Data.
- Contact Us and Ask the Experts: You may submit an inquiry or comment to Lincoln Electric along with your name, and contact information (such as address, phone number and email address). Lincoln Electric uses this information for the purpose of replying to your inquiry.
- Questionnaires and Surveys: Lincoln Electric may ask users of the Site to complete optional online surveys and opinion polls for the purpose of obtaining their input relating to our present or planned products and their use. These surveys help us to better meet your needs. In conducting these surveys we may ask you to provide your name and contact information (such as address, phone number and email address) so that we can provide you with information about our products and about welding and cutting, for example, by sending you newsletters or other marketing material.
- Product, Accessory and Extended Warranty Orders: If you purchase products from the Site, we ask for your name, contact information (such as address, phone number and email address), shipping and billing information. You will also be asked to provide your credit card number and security code solely to our credit card processing vendor, Cybersource ( https://www.cybersource.com/en-us.html), for purposes of payment. Lincoln Electric will not have access to or store your credit card information. For U.S. products, you may also register your Lincoln Electric product on our website so we can provide information updates to you and for this purpose we will ask you for your name, contact details and product serial and code number.
- Locating a Distributor: If you use the Site to locate a nearby Lincoln Electric distributor, we will ask you for a location. Information about your location will be retained and analyzed for statistical business reasons.
- Customer and Investor Updates: Lincoln Electric asks you to provide name and contact information (such as address, phone number and email address) so that updates to our products, safety data sheets (SDS), safety and corporate investor information may be sent to you.
- myLincoln Account: If you create an account on a Lincoln Electric Site, we collect the account information that you submit, such as your name, email address, and log-in information. We also collect information regarding your orders through the account, such as your history of purchases.
- Mobile Applications and Internet Connected Devices: Lincoln Electric may receive Personal Data during your access to and use of any Lincoln Electric mobile application. We may collect first and last names, email addresses, online identifiers, and other Personal Data used to register with, download, or access the relevant mobile application. We may monitor, record, and analyze the operation, location, maintenance and/or performance of welding and other equipment made, sold or provided by Lincoln Electric and connected to the mobile application. We may de-identify, aggregate, and analyze this data in order to develop more effective and efficient products and services.
- From Third Parties: Lincoln Electric may also receive Personal Data from third parties who provide services to us, such as trade shows, mailing or other list services. Lincoln Electric may receive the following categories of Personal Data, such as your name, email address, phone number, job title, business or personal address.
- Corporate Transactions: Lincoln Electric may need to use some of the above Personal Data in order to comply with requests of prospective or actual purchasers interested in Lincoln Electric or its assets, or relation to a prospective or actual purchase of companies or assets by Lincoln Electric.
- Recruiting Talent: You may submit your application for an available position at Lincoln Electric or such an application can be made on your behalf. We will carry out an initial screening of applications received and may choose to proceed to an interview or further assessment stage with certain job candidates. In the process we will collect and process CVs, information on your qualifications (professional and otherwise), experience, employment history (including job titles, salary and benefits packages and any relevant working hours), interests, information about your previous academic history and qualifications including professional certifications and credentials, and language skills. We may collect details of your right to work in the location for which you are applying (including citizenship, passport data, visa data, details of residency or work permit). Where permitted or otherwise authorized by applicable laws, information received from third parties about you may include the results of background checks and referencing. Where required by law we need to collect information about disabilities from our job applicants.
- Video Teleconferencing Training Events, Meetings, Conferences and other Events: Lincoln Electric may record the content, conversations, and discussions in the course of these video teleconferencing events and such records may be stored or retained by us or our third party service providers for the following purposes: training; the need to document corporate decision-making processes; to make the video teleconferencing events available to registered participants of the events to allow them to review the events after they have finished.
Do We Collect Special Categories of Personal Data or Information on Children?
Lincoln Electric does not ask for, and does not collect, Special Categories of Personal Data related to our customers, vendors, suppliers, website users, or video teleconferencing events participants.
Job Applicants: In some countries such as Italy, companies are required by law to employ a certain number of people with disabilities. For this reason, Lincoln Electric needs to collect certain information on disabilities from job applicants in such countries.
Children’s Privacy: The Site is not directed to children under the age of sixteen, unless otherwise provided by applicable laws, and we do not knowingly collect Personal Data from children. We may ask you to confirm that you have not and will not provide such information to us or in postings on the Site when you register. If we become aware that such information has been provided or posted on the Site, we will delete it from our records.
Lincoln Electric does not sell or lease any Personal Data, such as email addresses, collected from customers, vendors, suppliers, Site users, job applicants, or from video teleconferencing participants. The following are the ways we share your information:
- Intra-Group: We share Personal Data about you within Lincoln Electric for all the purposes listed above. A list of all Lincoln Electric entities is available here.
- Third-Party Service Providers: We will share your Personal Data with third-party
- service providers under contract with Lincoln Electric to help us provide services or events to you and process Personal Data on our behalf for the above-mentioned purposes. We may retain a third party to help us determine what marketing information you might find useful or help us make video teleconferencing events available to you. The service providers are bound by law and/or contract to protect the confidentiality and security of Personal Data, and to only process your Personal Data to provide requested services and only act on our documented instructions.
- Lincoln Electric also shares data with other companies, vendors and business partners to perform functions for it, whereby these companies are themselves responsible to determine the purposes and/or means of the processing and for the lawfulness of the processing. We may disclose your Personal Data to an attorney in the process of obtaining legal advice. We use a third-party service provider to process credit card information you submit.
- Required Disclosures: We may be required to share Personal Data with courts, tribunals, opposing or other related parties to the proceedings and their professional advisors, in response to a court order, subpoena, civil discovery request, other legal process, or as otherwise required by law.
- Legal Compliance and Protections: We may disclose account and other Personal Data to courts, tribunals, opposing or other related parties to the proceedings and their professional advisors, when we believe disclosure is necessary to comply with the law or to protect the rights, property, or safety of Lincoln Electric, our users, or others. This may include exchanging Personal Data with other companies and organizations for fraud prevention and credit risk reduction.
- Corporate Transactions: We may disclose your Personal Data to prospective or actual purchasers, their lawyers or professional advisors, of any interest in Lincoln Electric or its assets, or in relation to a purchase of companies or assets by Lincoln Electric.
How Do We Address Site Privacy and Tracking?
We support the Do Not Track (DNT) browser setting. DNT is a preference you can set in your browser’s settings to let the websites you visit know that you do not want the sites collecting your personally identifiable information.
How do we comply with the California Consumer Privacy Act (“CCPA”)?
If you are a California resident you have certain rights regarding the collection, use, and sharing of your Personal Data.
- Right to Know You have the right to request that we disclose to you: (1) the specific pieces of personal information we have collected about you; (2) the categories of personal information collected or shared; (3) the purposes for which we collected or shared your personal information; and (4) the categories of third parties to whom we have disclosed personal information about you. Prior to disclosing the information, we are required to verify that the individual making the request is indeed the individual to whom the information relates. Once we receive a verifiable request, we must disclose to you the information requested for the twelve months preceding your request. The law gives us 45 days to provide the information to you. Please note that if the information you are requesting reveals details directly or indirectly about another person, we will need to seek consent of that person before we can disclose that information to you. In certain circumstances, where disclosure of part or all of the information you have requested would adversely affect the rights of others, we may not be able to disclose the information to you, in which case we will inform you promptly and give you the reasons for our decision. Please further note that CCPA provides for certain exclusions for information that relates to business to business communications and information protected under evidentiary privileges.
- Right to Delete . You have the right to request deletion of the personal information about you that we have received from you. Prior to deleting the information, we are required to verify that the individual making the request is indeed the individual to whom the information relates. Once we receive a verifiable request, the law gives us 45 days to respond. As a general rule, we must delete the information at your request and require our vendors to do so as well. However, the law provides certain exceptions and exclusions that allow us to retain the information even if you have requested that it be deleted. If we do not erase the information pursuant to one of those exceptions we must inform you of that fact and of any rights you may have to appeal our decision.
- Right to Opt Out. You have the right to opt out of the sale of your Personal Data.
- Right against discrimination. California residents have the right to not be discriminated against for exercising their rights under the CCPA.
Please note that your CCPA rights are subject to certain conditions and exceptions and that the law allows for extensions to the mandatory period to respond to your requests in certain cases.
Should you have any questions regarding the rights you might have under California law or wish to exercise your CCPA rights, please make such a request by emailing us at Privacy@lincolnelectric.com , or by calling 1-888-935-3877 or by mail to:
The Lincoln Electric Company
22801 St. Clair Avenue
Cleveland, OH 44117
Attn: Privacy Coordinator
How We Protect Your Personal Data?
Lincoln Electric will take reasonable steps to protect the Personal Data it collects from loss, misuse, unauthorized access, disclosure, alteration, and destruction. Lincoln Electric has put in place appropriate physical, electronic and managerial procedures to safeguard and secures the Personal Data it collects from loss and misuse and unauthorized access, disclosure, alteration, or destruction. Please note that despite our reasonable efforts, no security measure is ever perfect or impenetrable, so we cannot guarantee the security of your Personal Data.
What About Third Party Websites?
This Site contains links to other third-party websites. Lincoln Electric does not control and is not responsible for the operation of such websites. Please refer to the privacy policies of those websites if you have questions about their privacy practices.
Can I Unsubscribe from Emails?
How Can I Update My Personal Data?
You may use the link in the “Contacting Us” section of this policy to provide us with your updated or corrected Personal Data or to request that we delete your Personal Data.
If you have an account and login with us, the Site provides you the option to update or correct information previously provided by logging into your account and clicking User Admin left and then My Profile to access your Personal Data and correct, amend or delete inaccurate information.
What is Our Data Retention Policy?
Lincoln Electric retains your Personal Data collected as reasonably necessary to fulfill the purposes for which Personal Data are collected and to comply with legal obligations or for the establishment, exercise or defense of a legal claim.
For our customers, vendors, and suppliers, we retain their Personal Data for the duration needed to complete or facilitate our contract, agreement, or engagement, and for a reasonable amount of time thereafter in accordance with our legitimate business needs and functions.
We shall retain certain Personal Data of Site visitors for no longer than reasonably necessary to fulfill the purposes for which Personal Data are collected, to comply with legal obligations or for the establishment, exercise or defense of a legal claim.
The Personal Data of unsuccessful job applicants will be deleted in accordance with the normal document retention policy at Lincoln Electric.
We retain any video or voice recordings of our video teleconferencing events in accordance with the normal retention policy at Lincoln Electric.
Is Personal Data Transferred Across Borders/Internationally?
Personal Data collected from our customers, vendors, and suppliers, Site users, job applicants or from video teleconferencing events participants is stored on servers located in the United States. In some cases, your Personal Data may also be stored on servers in a country where the Lincoln Electric affiliate is located.
If you have any questions about this privacy statement, the practices of the Site or your dealings
with the Site, you can email us or contact us at the following addresses:
The Lincoln Electric Company
22801 St. Clair Avenue
Cleveland, OH 44117
If you are located in a country in the EU, please see the following details about the processing of your Personal Data by Lincoln Electric.
Who is responsible for processing of your Personal Data?
The entity with which you have a primary relationship with (such as the entity that concluded sales/services/supply contract with you; or a primary entity in the country for which we created a local website; or an entity, representatives of which you have been video teleconferencing with) (“Lincoln Electric”) is the controller of the Personal Data collected from customers, vendors, or suppliers, or submitted on this Site, or recorded in the course of video teleconferencing events from participants.
As for the job applicants, the relevant controller for your Personal Data is the Lincoln Electric entity to which you have submitted your job application.
You can find the full list of our entities and their respective contact details here.
What Personal Data do we process about you?
The categories of Personal Data that Lincoln Electric processes about you, for the purposes described below are listed herein .
Why are we processing your Personal Data and on which legal bases?
Lincoln Electric processes Personal Data for the purposes we have outlined herein and for your
convenience, also in this section. Where applicable, we will point out, at the time of the data collection, if the provision of the Personal Data is a statutory or contractual requirement and whether you are obliged to provide the Personal Data and the possible consequences of failure to
provide such Personal Data.
Information on Our Customers, Vendors, or Suppliers
Lincoln Electric may collect and process Personal Data concerning our customers, vendors, and suppliers to facilitate routine and common business practices, such as those related to sales orders and management.
Legal Bases: The processing is justified based on statutory provisions that (1) processing is based on the consent; (2) processing is necessary for Lincoln Electric’s legitimate interests as set out herein ; (3) processing is necessary for the performance of a contract to which you are a party; and (4) Lincoln Electric is required to comply with a legal or statutory obligation in the EU or a Member State.
Information on Lincoln Electric, Distributors and its Products
This includes processing Personal Data to: provide information or updates about Lincoln Electric or its products, arc welding, safety data sheets (SDS), safety and corporate investor information; carry out optional online surveys and opinion polls to obtain Site visitor’s input relating to our present or planned products and their use; locate a nearby Lincoln Electric distributor.
Legal Bases: The processing is justified based on statutory provisions that (1) processing is based on the consent of the Site visitor; (2) processing is necessary for Lincoln Electric’s legitimate interests as set out herein ; (3) processing is necessary for the performance of a contract to which you are a party; and (4) Lincoln Electric is required to comply with a legal or statutory obligation in the EU or a Member State.
Site and myLincoln Administration
This includes processing Personal Data to: carry out Site and myLincoln Account administration.
Legal Bases: The processing is justified based on (1) your consent; (2) processing is necessary for Lincoln Electric’s legitimate interests as set out herein ; and (3) processing is necessary for the performance of a contract to which you are a party.
Compliance with Law, Internal Regulations and Protection
This includes processing Personal Data to: comply with law or legal process, Lincoln Electric's policies and procedures and to protect the rights, property, or safety of Lincoln Electric, our users, or others.
Legal Bases: The processing is justified based on statutory provisions that (1) Lincoln Electric is required to comply with a legal or statutory obligation in the EU or a Member State; (2) to protect the vital interests of the data subject or of another natural person; and (3) processing is necessary for Lincoln Electric’s legitimate interests as set out herein .
Communication with Site Visitors
This includes processing Personal Data to: enable visitors to submit an inquiry or comment to Lincoln Electric and reply to such inquiries.
Legal Bases: The processing is justified based on statutory provisions that processing is necessary for Lincoln Electric’s legitimate interests as set out herein .
This includes processing Personal Data to: comply with requests of prospective or actual purchasers interested in Lincoln Electric or its assets, or in relation to a purchase of companies or assets by Lincoln Electric.
Legal Bases: The processing is justified based on (1) your consent; (2) processing is necessary for Lincoln Electric’s legitimate interests as set out herein .
This includes processing Personal Data to: provide (e-)newsletters and other marketing materials.
Legal Bases: The processing is justified based on (1) your consent; (2) processing is necessary for Lincoln Electric’s legitimate interests as set out herein .
Warranty and Registration
This includes processing Personal Data to: provide product registration and extended warranty orders.
Legal Bases: The processing is justified based on statutory provisions that (1) processing is necessary for the performance of a contract to which you are a party; (2) processing is necessary for Lincoln Electric’s legitimate interests as set out herein ; and (3) Lincoln Electric is required to comply with a legal or statutory obligation in the EU or a Member State.
This includes processing Personal Data for the purposes of initial screening of applications and further evaluation during interviews or online assessments, and in some countries, for the purposes of complying with the law requiring companies to employ a certain number of people with disabilities.
Legal bases: The processing is (1) justified on your consent; or necessary: (2) for the purposes of Lincoln Electric’s legitimate interest to carry out appropriate assessment of applications and to select suitable candidates for the roles available; (3) to comply with a legal obligation of Lincoln Electric to hire individuals with the right to work in the country you have applied to work in; (4) if applicable in the country you have applied to work with, to comply with a legal obligation of Lincoln Electric to employ a certain number of people with disabilities; (5) to take steps as necessary prior to entering into an employment contract; and (6) to comply with a legal obligation or for the establishment, exercise or defense of a legal claim.
Video Teleconferencing Events
This includes processing Personal Data recorded in the course of training events, meetings, conferences and other events we may organize.
Legal Bases: The processing is justified based on (1) your consent; (2) processing is necessary for Lincoln Electric’s legitimate interests as set out herein .
With whom do we share your Personal Data?
Personal data are shared within the Lincoln Electric (i.e. intra-group) or with third parties. In some cases, external companies collect Personal Data directly from you on our behalf.
The categories of recipients of Personal Data are listed herein .
Do we disclose your Personal Data internationally?
Due to the global nature of our operations, some of the recipients mentioned herein may be located in countries outside the European Economic Area (EEA), which do not provide an adequate level of data protection by law. International transfers will be to countries where Lincoln Electric entities have offices, including the United States of America, United Kingdom (following the end of the Brexit transition period), Canada, Mexico, Argentina, Brazil, Colombia, Venezuela, Russia, Ukraine, Australia, China, India, and Japan. The transfer of your Personal Data outside the EEA takes place on the basis of our Global Intra-Group Data Transfer and Processing Agreement, which is based on standard contractual clauses adopted by the European Commission to protect the Personal Data when transferred outside the EEA and in accordance with applicable law.
Some of the third parties with whom we share Personal Data are also located outside the EEA. Certain third countries have been officially recognized by the European Commission as providing an adequate level of protection. You can find the list of these countries at the following address: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en . Transfers to third parties located in other third countries outside the EEA take place using an acceptable data transfer mechanism, such as the EU Standard Contractual Clauses, Binding Corporate Rules, approved Codes of Conduct and Certifications or in exceptional circumstances on the basis of permissible statutory derogations.
Please contact firstname.lastname@example.org , if you want to receive further information or, where available, a copy of the relevant data transfer mechanism.
How long does Lincoln Electric keep my Personal Data?
To find out more about Lincoln Electric’s retention of your Personal Data, click here .
Rights in relation to your Personal Data
Under the conditions set by applicable data protection laws, you may exercise the following rights regarding your Personal Data:
You have the right to obtain from us confirmation if Personal Data are being processed, the purpose of processing, the categories of data, the legal basis of the processing, information on recipients of the data and the non-EU countries in which they are located, the safeguards put in place for the transfer of data to non-EU countries, the storage period of data or criteria to determine it, further information on your rights, our processing activities, the sources of information and the significant and envisaged consequences of processing.
You have the right to request the rectification of inaccurate Personal Data and to have incomplete data completed.
You have the right to object to the processing of your Personal Data for compelling and legitimate reasons relating to your particular situation, except in cases where legal provisions expressly provide for that processing. In addition, you have the right to object at any time where your Personal Data are processed for direct marketing purposes.
You may receive your Personal Data that you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit them to other data controllers without hindrance. This right only exists if the processing is based on your consent or a contract and the processing is carried out by automated means.
You may request to restrict processing of your Personal Data if (i) you contest the accuracy of them – for the period we need to verify your request; (ii) the processing is unlawful and you oppose the erasure of them and request restriction instead; (iii) we no longer need them, but you tell us you need them to establish, exercise or defend a legal claim; or (iv) you object to processing based on public or legitimate interest – for the period we need to verify your request.
You may request to erase your Personal Data if they are no longer necessary for the purposes for which we have collected them, you have withdrawn your consent and no other legal ground for the processing exists, you objected and no overriding legitimate grounds for the processing exist, the processing is unlawful, or erasure is required to comply with a legal obligation.
Right to lodge a complaint
You also have the right to lodge a complaint with a supervisory authority, in particular in the EU Member State of your residence, place of employment, or the location where the issue that is the subject of the complaint occurred.
Right to refuse or withdraw consent
Please note that in case we ask for your consent to certain processing, you are free to refuse to give consent and you can withdraw your consent at any time without any adverse negative consequences. The lawfulness of any processing of your Personal Data that occurred prior to the withdrawal of your consent will not be affected.
To find out more about how to contact Lincoln Electric, click here .
You may also contact the Data Protection and Privacy Coordinator for Europe:
Data Protection and Privacy Coordinator
Lincoln Electric Europe
25 Boulevard de la Paix | 95800 Cergy | France
+184.108.40.206.30.21 | Office
+220.127.116.11.24.99 | Mobile
Protection of Username and
Some areas of the Website may require that you register and log in. You are responsible for protecting your username and password and all activities on your account. Additionally, we may rely upon any communications we receive on the Website under your login. Notify us immediately if you have reason to believe your login has been or may be used by someone not authorized to do so.
Summary of Key Points
What Personal Data do we collect?
- We collect the information that you provide to us directly, including your name, contact information, job title, financial information, year of birth, information provided in resumes and interviews (job applicants), login details (if you create a myLincoln account) and the content of your communications with us.
- We collect information regarding your transactions (e.g., purchases, returns, product registrations, warranty claims, etc.).
- If you use the Site to locate a nearby Lincoln Electric distributor, we will collect information regarding your location.
- We collect voice and/or video recordings when you attend training events, meetings, conferences and other events (“Event Recordings”).
- We also collect certain information from third parties with your consent, including (without limitation), your location and contact information obtained from trade shows and/or mailing or other list services, information regarding job candidates that is obtained from staffing/recruitment firms, and information collected in connection with credit checks and other background checks.
Why do we collect Personal Data and how is it used?
- We use your information for the purpose of completing your transactions, providing our mobile applications, product registration and extended warranty orders, fulfilling our contractual obligations, providing you with customer and investor information (where applicable), providing customer service, responding to your communications, and for marketing purposes. We will also send you newsletters, surveys and other communications (including marketing materials) with your consent, or as otherwise permitted by applicable law.
- Financial information is used to process payments.
- We also use your information for internal business purposes (e.g., data analytics, improving our products and services, etc.).
- Information regarding job applicants is used to assess their suitability for employment with Lincoln Electric.
- The information that is collected automatically when you visit our Site is used in aggregate and de-identified form to operate, maintain, evaluate and improve the Site, and to enhance your experience when visiting our Site. We also use this information to provide you with relevant advertising, based on your online activities.
- Location information is collected when you use the Site to locate a distributor, and this information will be retained and analysed for internal statistical business purposes.
- Event Recordings are used for training, and to document corporate decision-making processes.
- We also collect Personal Data as otherwise required or permitted by applicable law.
Is Personal Data shared or disclosed?
- We share Personal Data with our affiliates and service providers for the purposes of obtaining assistance and services related to research, marketing, co-branding and advertising, administration of sweepstakes and contests, recruitment and employee onboarding services, data analytics, and website administration.
- Event Recordings are made available to registered participants of the events.
- We may disclose certain information in the event of a corporate transaction (i.e., the sale of all or part of our business).
- Personal Data may also be disclosed to law enforcement, courts and regulatory authorities, and as otherwise required or permitted by applicable law.
What are the risks?
- Although we take steps to safeguard the Personal Data under our control, "perfect security" does not exist. In particular, we cannot guarantee the security of: (1) information communicated to us online or via email, as it is possible that third parties may unlawfully intercept or access such information; and/or (2) Personal Data that is Processed (as defined below) by third parties.
- - -
Additional Information and Modifications to our Policy for Canadian Data Subjects
To the extent applicable, in the event of any conflict or inconsistency between the Policy and the terms of this Addendum, this Addendum shall govern and prevail for Canada.
For the purposes of the Policy (including this Addendum), “Personal Data” includes all “personal information” as defined under the Personal Information Protection and Electronic Documents Act and/or any applicable substantially similar provincial legislation.
Notwithstanding anything potentially to the contrary in the Policy, Lincoln Electric will always obtain consent to Process Canadian Personal Data, express or implied in accordance with applicable law, except where otherwise required or permitted by applicable Canadian or provincial laws. In some circumstances, consent may be implied if you provide us with your information for a specific purpose and we will only use it for that purpose. In addition, by using our Site, you thereby consent to our Processing of Personal Data that is collected via the Site, as described in the Policy. Notwithstanding the above, we will obtain your express consent to Process your Personal Data where required by applicable law.
If we materially change our privacy policies or practices (including this Policy) in a way that affects how we Process your Personal Data, we will notify you and obtain consent to such changes, where required by applicable law.
- Access to Your Personal Data within Our Organization
Your Personal Data will be accessible to our IT, compliance and legal teams, on a need to know basis, as well as the following categories of Lincoln Electric personnel:
- Personal Data regarding Customers, Vendors and Suppliers is accessible to accounting, sales, warranty administration, collections and procurement personnel;
- Personal Data regarding Website Users is accessible to marketing personnel, as well as our website development team;
- Personal Data regarding job applicants it accessible to human resources personnel and hiring managers; and
- Personal Data regarding video conference events participants is accessible to our event coordinators and marketing personnel.
- How Do We Share Your Personal Data
We share Canadian Personal Data with affiliates and third party service providers, for the purposes of providing the following services to Lincoln Electric entities located in Canada: marketing and advertising, administration of sweepstakes and giveaways, recruitment , completion of online transactions, business operations, data analytics, website administration, compliance with legal obligations and for the purposes of corporate transactions. Such information includes: contact information (including name, address, phone number, email address), demographic information (age, gender), website purchase information and website analytic information,. These affiliates and third parties may process Personal Data in the following countries: the United States, Ireland, Singapore, Germany. More information regarding our service providers and affiliates can be obtained by contacting us, as described below.
We may also disclose your Personal Data to third parties not listed in the Policy or this Addendum, where permitted or required by applicable laws, including (where permitted) for the purposes of collecting a debt.
- Cookies and Other Tracking Technologies
Cookies and Other Tracking Technologies used on the Site collect the following information: your IP (Internet Protocol) address, date and time of Site visits, page visits and requests, browser type, device type, operating system, time spent on the Site, user movement and actions taken on the Site, error messages received while on the Site, referring website or advertisement, language preferences, myLincoln User ID and log-in status, hashed data, click stream information, location information (including the city, province/state and country where you access the Site) and demographic information (including your age range and gender). You can prohibit Lincoln Electric from using non-essential cookies and online tracking, including those used for targeted advertising, by clicking here Reject All Non-Essential Cookies.
- How We Protect Your Personal Data
Lincoln Electric implements appropriate physical, technological, administrative and organizational security safeguards to protect Personal Data that is collected, used, communicated, kept, destroyed or otherwise Processed by Lincoln Electric, in any format, against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. Such safeguards are determined based upon the sensitivity of the information that has been collected, the purposes for which it is to be used, the amount/quantity, distribution, and format of the information, as well as the method and medium of storage. Please note that despite our reasonable efforts, no security measure is ever perfect or impenetrable, so we cannot guarantee the security of your Personal Data.
- Risks and Consequences
As indicated above, despite our reasonable efforts, no security measure is ever perfect or impenetrable, so we cannot guarantee the security of your Personal Data. In addition, you should be aware that although Lincoln Electric takes steps to protect information that is Processed on its behalf by third parties, it is possible that such third parties may not adequately protect your Personal Data and we cannot provide a definitive guarantee of the security of Personal Data that is Processed by third parties.
- Is Personal Data Transferred Across Borders/Internationally?
Personal Data collected from our customers, vendors, and suppliers, Site users, job applicants or from video teleconferencing events participants is stored on servers located in Cleveland, Ohio, as well as in the cloud. In some cases your Personal Data may also be Processed by affiliates or service providers in other countries (as described in the Policy). Personal Data that is transferred, stored, or otherwise Processed outside Canada may be accessible to courts, law enforcement and national authorities in other countries.
Without limiting the above, we will take all reasonable steps to ensure that Personal Data regarding Quebec Data Subjects that is Processed outside Quebec or entrusted to a person outside Quebec will not be used for any purpose other than for the purposes that it was collected (or other purposes permitted/required by applicable law), or disclosed to third parties, without the consent of the relevant Data Subject(s).
- What is Our Data Retention Policy?
We retain Canadian Personal Data for only as long as it is needed for the purposes that it was collected, or for compliance with applicable legal requirements. Once the purposes for which the Personal Data is collected and/or used are achieved, we will (subject to any preservation period provided for by applicable laws) either destroy the Personal Data or, where permitted by applicable law, anonymize it in order to use it for a serious and legitimate purpose.
- Rights in relation to your Personal Data
Your rights in relation to your Personal Data may vary depending upon the province where you are located and your relationship to Lincoln Electric. Such rights may include the right to:
- require deletion of your Personal Data if it was not collected in accordance with applicable law;
- access, correct, rectify or update your Personal Data;
- be informed of the existence, use, and disclosure of your Personal Data, and to challenge the accuracy and completeness of such information and have it amended as appropriate
- withdraw consent to continued collection, use or disclosure of Personal Data;
- require that Lincoln Electric cease disseminating information or de-index any hyperlink that provides access to the information by technological means, if the dissemination contravenes the law or a court order and/or if certain other conditions are met under applicable laws;
- address a challenge concerning compliance with applicable privacy laws to the person(s) designated as being accountable for Lincoln Electric’s compliance with such laws.
- Contacting Us
You may contact Lincoln Electric Canada’s Director, HR Canada & Latin America at email@example.com in order to:
- Exercise your rights in relation to your Personal Data (as described above), subject to any applicable exceptions and limitations pursuant to applicable law;
- Ask questions or express concerns about this Policy or any other matter related to Lincoln Electric’s collection, use, disclosure or other Processing of your Personal Data; or
- Ask questions about the collection, use, disclosure or storage of Personal Data by our service providers and affiliates outside Canada, or obtain written information about our policies and practices with respect to such service providers and affiliates.