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Privacy

1. Purposes of this Privacy Policy

This privacy policy aims to give you information about how your personal data is collected and processed when you use this website, including any data you may provide through this website when you sign up to our newsletter.

This website is not intended for children and we do not knowingly collect data relating to children.

This privacy policy supplements other notices and privacy policies and is not intended to override them. It is important that you read any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

2. Who we are and how do you contact us

Luxfer Holdings PLC is the controller and responsible for your personal data (referred to as "Luxfer ", "we", "us" or "our" in this privacy policy). Luxfer is part of a wider group of companies collectively referred to as the Luxfer group in this privacy policy.

We have appointed a representative who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, our privacy practices, including any requests to exercise your legal rights, please contact us using the details set out below;

Name: Peter Gibbons
Tel: +44 (0) 161 300 0603
Postal Address: Luxfer Group Limited, Lumns Lane, Manchester,M27 8LN, United Kingdom

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

3. Changes to the privacy policy and your duty to inform us

We keep our privacy policy under regular review and this version was last updated in December 2018. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

4. What personal data will we collect?

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows;

• "Identity Data" includes first name, maiden name, last name, username or similar identifier.

• "Contact Data" includes address, company address, email address and telephone numbers.

• "Technical Data" includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.

We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

5. How will we collect your personal information?

We use different methods to collect data from and about you including through:

• Direct interactions: You may give us your Identity Data or Contact Data and by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

      • subscribe to our services or publications;
      • give us feedback or contact us.

• Automated technologies or interactions: As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
Please see our cookie policy at the bottom of the page for further details.

6. What will we use your personal information for?

Pursuant to the General Data Protection Regulation (EU) 2016/679 (“GDPR”) we must have a "legal ground" to use your personal data in each case. We set out below further information about each legal ground that we may rely on;

Legitimate Interest: means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract: means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation: means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Grounds for Processing

We have set out below a description of the ways we plan to use your personal data, and which of the legal grounds we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

To respond to your general enquiries about our company, services or products and to direct your enquiry to the appropriate Luxfer group company

Type of data
(a) Identity
(b) Contact

Legal grounds for processing including basis of legitimate interest
Necessary for our legitimate interests (e.g. to facilitate sales of our services/products and improving our products and services)

Purpose/Activity
To manage our relationship with you which will include any communication with you (e.g. to inform you of changes to this policy)

Type of data
(a) Identity
(b) Contact

Legal grounds for processing including basis of legitimate interest
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to keep our records updated and to study how customers use products/services)
(c) Necessary to comply with a legal obligation

Purpose/Activity
To use data analytics to improve our website and to develop new services.

Type of data
(a) Technical

Legal grounds for processing including basis of legitimate interest
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

Purpose/Activity
To keep you informed by email about new information that is published on the Luxfer website

Type of data
(a) Identity
(b) Contact

Legal grounds for processing including basis of legitimate interest
Necessary for our legitimate interests (to develop our products/services and grow our business)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

You will receive such marketing communications from us if you have requested information directly form us.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see details of our Cookie Policy at the bottom of the page.

7. Sharing your personal information

We may share your personal data with the parties set out below for the purposes set out in the table above.

• Internal third parties which include other companies in the Luxfer group and who are based in the EU and are the entities within the Luxfer group that will be able to supply the services and products your enquiry relates to. Further information about how those entities deal with your personal data can be found on the following websites;

https://www.luxfercylinders.com/

https://www.superforming.com/

https://www.magnesium-elektron.com

https://luxfermagtech.com/

http://www.zrchem.com/

• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

8. Data Security

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

9. Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

If you require further information about retention periods for different aspects of your personal data are you can request that from us from us by contacting our representative using the details set out in Section 2.

10. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Further information is set out below about these rights:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• If you want us to establish the data’s accuracy.

• Where our use of the data is unlawful but you do not want us to erase it.

• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.

• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

No Fee Usually Required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

INFORMATION ABOUT OUR USE OF COOKIES

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

We use the following cookies:

Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.

Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

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Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

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