Tensar Western Hemisphere Corporate Privacy Policy

This privacy policy applies to the Tensar geogrid business in the Western Hemisphere (i.e. the United States, Canada, Central and South America and the islands of the Caribbean Sea), namely the Western Hemisphere businesses of Tensar Corporation, Tensar Holdings LLC, Tensar International Corporation, and Tensar Corporation LLC (individually and collectively referred to as “the Company,” “we,” “us” or “our”). Tensar is the industry leader in geogrid products, systems, technologies and solutions. Our success is a result of and depends on our employees, customers, distributors, licensees, vendors and other business associates. These relationships with our business associates are important to us, and we take seriously the protection of their personal information.

In the ordinary course of our business, we collect and process information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual (“Personal Information”) as described in this Tensar Western Hemisphere Corporate Privacy Policy (“Policy”).

We are committed to the responsible use and protection of Personal Information. This Policy contains details about how we collect, use, maintain, and share with third parties Personal Information that we obtain from or about you, whether through visiting a Tensar Western Hemisphere website (“Website”), your other interactions with us, or otherwise as described in this Policy. This Policy applies to the mentioned Website(s), your further interactions with us, and our other activities. Please read this Policy carefully.

Overview and Scope

We obtain Personal Information about you from various sources in connection with providing our products, systems, technologies and services, managing our Websites and for other business purposes as described below.   If you are a California resident, please see “Your California Privacy Rights” at the end of this Policy for more information about your privacy rights under California law.  If you are a resident of the United Kingdom or the European Economic Area, please see the Tensar UK/EU Privacy Policy.

Personal Information We Collect

We may collect the following types of Personal Information:

• Identifiers, such as name, title, employer, email address, physical address, telephone number, account number or name and password.
• Professional or employment-related information, such as employment history, educational background, professional or trade association membership or other professional information.
• Financial information, such as tax identification number, bank account information, credit history, credit limits, and any background information provided by you or collected by us as part of you personally transacting business with us, or as part of our business analysis, customer or vendor onboarding, regulatory compliance checks and other related processes. 
• Internet usage information, such as your browsing history, IP addresses, cookie IDs, search history, and information regarding your interactions with and use of our Website or mobile applications and information from our online forms, applications or questionnaires you have completed. For more information, see “Cookies,” below.
• Commercial information, including products, technologies or services purchased, obtained or considered, order history, or other purchasing or consumer history.
• Audio, electronic, visual or similar information such as from cameras located on our premises or your attending online training, conferences or meetings, organized by us.
• Inferences drawn from any of the information we collect to create a profile about you reflecting your preferences and to enhance your user experience.

We may also collect deidentified or aggregated information that does not identify you.

How We Collect Personal Information

We collect Personal Information about you in the following ways and from the following sources:

• From you directly. We will collect Personal Information that you provide by completing forms, applications, questionnaires, surveys, placing orders with us on behalf of customers, customer service or other information requests, conference attendance applications, or the “contact” section either on any of our Websites or collected by other means such as email, meetings, in-person events, contests, and other interactions with us. We may also collect Personal Information provided voluntarily to us. This includes information provided at the time of registering to use any of our Websites or Company software, subscribing to our newsletters or other services, or requesting further services or information. We may also ask you for your information when you report a problem with any of our Websites or software or report another concern or issue to us.
• Through cookies. We may collect information about how you use our Websites or otherwise interact with us online automatically, such as IP address, information about your device, internet usage, browsing preferences, browser type, Website activity, and other technical information when you interact with us online. For more information, see “Cookies,” below.
• From session recording tools. We monitor, evaluate and retain information on your use of and access to the Website and how you navigate and use different functionality of the Website. We collect this information for analytics purposes to better understand how people use the Website so that we can make it more intuitive and useful. We use certain third party vendor session recording tools for these purposes. We and our service providers use appropriate technologies to limit the session recording data to avoid unnecessary collection of your Personal Information.
• From third parties. We may collect Personal Information from third parties, such as our distributors, dealers, licensees, customers, contractors, vendors, other business associates, professional or trade associations, background check services as part of “know your customer” or other due diligence activities, companies that provide or sell lists of potential customers, data enrichment services or data analytics providers (including but not limited to Google analytics), or from others who interact with us.
• From public sources. We may collect information about you from public sources such as government entities that maintain public records, media sources, social network sources (such as but not limited to LinkedIn), or information you submit in public forums.

We may combine information that we receive from the various sources described in this Policy, including third party sources and public sources.

How We Use Personal Information

We may use Personal Information for the following purposes:

• In connection with our products, technologies and services, such as to provide information regarding such items or to notify you of changes to our business.
• In connection with contractual obligations or transactions with us, such as to carry out a notification or other obligation arising from any contracts entered into between you and us, or to deliver on requested transactions with us.
• For our own internal business purposes, such as to evaluate or audit the usage, performance and other aspects of, or projects for the potential use of our products, systems technologies and services; to design new products, systems, technologies and services; to operate our Websites; for internal research and analytics; to evaluate the effectiveness of our advertising or marketing efforts; to evaluate and improve the quality of your interactions with us; to catalog your responses to surveys or questionnaires; or to maintain internal business records.
• For marketing, such as for contextual ad customization or to market our products, systems, technologies and services or those of our affiliates, business associates, or other third parties. We may use Personal Information we collect to send you newsletters, updates, surveys, questionnaires, promotions, contests, or information about events, or to invite or admit you to attend activities such as webinars or virtual events.

We may use deidentified or aggregated information for any legal purpose.

With Whom We Share Personal Information

We may share Personal Information with the categories of recipients described below:

• Affiliates. We may share Personal Information with our affiliates who directly or indirectly control, are controlled by, or under common control with us, which includes parents, subsidiaries and other company affiliates, their shareholders, and other business units.
• Business Associates. We may share information with our distributors, licensees or other business associates who are part of our business channel in providing (or seeking to provide) our products, systems, technologies or services to you, or with another company with whom we may partner for a particular event.
• Service providers. We may share information with service providers or subcontractors that help us with our Websites or software, or perform business or administrative functions on our behalf, including completing a transaction you request or supporting our relationship with you, such as IT providers, training and communication providers, accountants, logistics providers, analytics companies, and marketing or advertising providers.
• Law enforcement and other government agencies. We may share information with third parties like law enforcement or other government agencies and other authorities to comply with the law or legal requirements and to protect our and/or third party rights, property, safety or other legitimate interests.
• Parties to a corporate transaction. In the event that we enter into, or propose to enter into, a transaction that directly or indirectly alters the structure, ownership or control of any of our companies or businesses, such as a reorganization, merger, sale, joint venture, assignment, transfer, change of control, or other disposition of all or any portion of our business, assets or securities, we may share Personal Information with third parties in connection with such transaction. Any other entity which buys us or part of our business will have the right to continue to use your Personal Information, but only in the manner set forth in this Policy, unless you agree otherwise.

Cookies

What are Cookies? A “cookie” is a small text file that is sent to or accessed from your web browser or your computer’s hard drive. Some cookies exist only during a single browsing session and some are persistent over multiple browsing sessions. A cookie typically contains the name of the domain (internet location) from which the cookie originated, the “lifetime” of the cookie (when it expires), and a randomly generated unique identifier. A cookie may also contain information about your computer, such as user settings, browsing history and activities conducted while using one of our Websites.

How We Use Cookies. We use Cookies to enhance your user experience with us and for other purposes as follows:

• Storing your preferences and settings. We may store settings that enable our Websites to operate correctly or that maintain your preferences over time. For example, we save preferences, such as language and browser settings, so those do not have to be reset each time you return to one of our Websites. We may also use cookies to power personalization of our Websites.
• Sign-in and authentication. When you sign into your account on our Websites, we store a unique ID number, and the time you signed in, in an encrypted cookie on your device. This cookie allows you to move from page to page within a particular Website without having to sign in again on each page. You can also save your sign-in information so you do not have to sign in each time you return to the Websites.
• Security. We use cookies to detect fraud and abuse of our Websites and software.
• Interest-based advertising and communication. We use cookies to collect data about your online activity and identify your interests so that we can provide advertising or other communications that are most relevant to you. 
• Analytics. To improve your user experience on our Websites, we use cookies to gather usage and performance data. For example, we use cookies to count the number of unique visitors to a Website page or to develop other statistics about the operations of our Websites. This includes cookies from us and from third-party analytics providers.
• Performance. We use cookies for load balancing to ensure that our Websites remain up and running.

Controlling cookies. Most web browsers automatically accept cookies but provide controls that allow you to block or delete them. For example, in most modern browsers, you can block or delete cookies by clicking Settings > Privacy > Cookies. Instructions for blocking or deleting cookies in other browsers may be available in each browser's privacy or help documentation.

Certain features of our Websites depend on cookies. Please be aware that if you choose to refuse or delete cookies, some of our Website functionality may be impaired.  If you change computers, devices or browsers, or use multiple computers, devices, or browsers, and delete your cookies, you may need to repeat this process for each computer, device, or browser. Please refer to your browser’s Help instructions to learn more about how to manage cookies.

Data Security

We maintain organizational, technical and administrative measures designed to protect Personal Information within our Company against unauthorized access, destruction, loss, alteration or misuse, consistent with applicable regulatory requirements and applicable published security standards. 

 However, no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially reasonable means to protect your Personal Information, we cannot guarantee absolute security. If you have reason to believe that your Personal Information is no longer secure (for example, if you feel that the security of your account has been compromised), please contact us immediately at (855) 237-8950 or databreach@tensarcorp.com. 

Children's Privacy

We recognize the importance of children’s safety and privacy on the Internet. For this reason, we do not knowingly collect from or sell any information (including Personal Information) about children under 16 years of age.  Our products, systems, technologies and services are intended for individuals over 16 years of age. They are not directed at, marketed to, or intended for, children under 16 years of age. We may occasionally sponsor contests involving participation by children, for example, to submit a drawing depicting the use of our products with an award for the most creative illustration; in this situation we would request permission from a parent of the child or other adult caregiver to use any such material and to collect on a voluntary basis any minimum required Personal Information. If you believe that we have without prior authorization or otherwise inadvertently collected Personal Information from a child under the age of 16, please contact us using one of the methods identified in “Contact Information” below, and we will take immediate steps to delete the Personal Information.

External Links

Our Websites may contain links to external sites or other online services that we do not control, including those embedded in third party advertisements. We are not responsible for the privacy practices and data collection policies for such third-party services. You should consult the privacy policies of those third-party services for details.

Your Rights

We may use your Personal Information to send you promotional information about third parties which we think you may find interesting if you tell us that you wish for us to do so.

Acceptance of This Privacy Policy

By using any of our Websites or software you signify your acceptance of this Policy and any related terms of use and/or policy legal statements published on such Websites. If you do not agree to any of these, please do not use our Websites or software.

Contact Information

If you have questions regarding this Policy or our privacy practices in general, please contact us at:

Email: privacy@tensarcorp.com
Phone: (855) 237-8950
Mail: Tensar Corporation
2500 Northwinds Parkway, Suite 500
Alpharetta, GA 30009
Attn: General Counsel

If you feel that the security of your Personal Information has been compromised, please contact us immediately at (855) 237-8950 or databreach@tensarcorp.com.

If you have any questions regarding your interaction with any of our Websites, please contact us at:

Email: privacy@tensarcorp.com
Phone: (855) 237-8950
Mail: Tensar Corporation
2500 Northwinds Parkway, Suite 500
Alpharetta, GA 30009
Attn: VP Marketing

If you are having trouble viewing or accessing this Policy or need it made available to you in an alternative format, please contact privacy@tensarcorp.com. 

 We may update this Policy from time to time. The current Policy will be effective when posted. Please check this Policy periodically for updates. If any of the changes that we may make are unacceptable to you, you should cease interacting with us. When required under applicable law, we will notify you of any changes to this Policy by posting an update on our Websites.

Your California Privacy Rights

This section applies to California residents whose Personal Information is subject to the California Consumer Privacy Act of 2018 (“CCPA”).  If you are not a California resident, the rights described in this section do not apply to you.  

 Please note that the CCPA defines the term “sale” very broadly and includes the disclosure of Personal Information to third parties for which we receive “valuable consideration” (i.e., a benefit other than money), a definition that is much broader than the ordinary understanding of the term “sale.” In the preceding 12 months, we have not disclosed Personal Information to any third parties in exchange for money; however, we have disclosed Personal Information to third parties such as distributors, licensees and other business associates who may use such Personal Information to market their products and services. It is possible that this could be considered a “sale” for “other valuable consideration” under the CCPA.

 Summary of Personal Information Collected, Used, Sold or Shared

 Below is a summary of the categories of Personal Information we have shared for a business purpose or sold (as defined by the CCPA) in the previous 12 months and the categories of third parties with whom we have shared or sold such Personal Information.  Information about the categories of Personal Information we have collected from or about consumers in the previous 12 months, sources from which we collect Personal Information and the purposes for which we collect, use, share and sell Personal Information are described above in “Personal Information We Collect,” “How We Collect Personal Information” and “How We Use Personal Information,” respectively. 

Your Rights under the CCPA

Subject to certain legal limitations and applicable exceptions, California residents may exercise the following rights. 

• Right to Know.  You have the right to request that we disclose to you the categories of Personal Information we have collected about you in the preceding 12 months, the categories of sources from which we collected the Personal Information, the purposes for collecting the Personal Information, and the categories of third parties with whom we have shared or sold your Personal Information.  You may also request information about the specific pieces of Personal Information we have collected about you.  
• Right to Delete.  You have the right to request that we delete your Personal Information that we have collected from you. 
• Right to Opt Out. You have the right to opt out of the sale of your Personal Information.  

How to Exercise Your Rights

 If you have questions about our privacy policies or practices or would like to exercise your rights under the CCPA, you may contact us by either: 

• emailing us at privacy@tensarcorp.com; 
• calling us at (855) 237-8950; or  
• for requests to opt out, visiting our “Do Not Sell My Personal Information (California)” website, here. 
• writing us at:

 Tensar Corporation
2500 Northwinds Parkway, Suite 500
Alpharetta, Georgia 30009
Attn: General Counsel 

 You may also designate an authorized agent to exercise these rights on your behalf by following the process described in “Authorized Agents,” below.

 You may request access to your Personal Information twice in any 12-month period, measured from the date we receive your first request.  If you submit a request to obtain your Personal Information more than twice in any 12-month period, we will either: (i) proceed with honoring your request; or (ii) deny your request in writing.

 In accordance with applicable law, you have the right not to receive discriminatory treatment from us as a result of your exercising these rights.

Verification 

 In order for you to exercise your CCPA rights, we will need to obtain information to locate you in our records, verify that you are a California resident and to verify your identity.  For a report of the specific Personal Information we have processed about you, you must provide us with three of the following in order that we may verify your identity:

• full name;
• email address;
• residential or business address; or
• mobile, residential or business telephone number.

You also must provide us with a signed declaration, under penalty of perjury, that you are who you say you are.  For a report of the categories of Personal Information we have processed about you, or for a request to delete your Personal Information or opt out of the sale of your Personal Information, you must provide us with two of the above-referenced pieces of personal information in order that we may verify your identity (example, full name and email address).  

To the extent reasonably possible, we will use our existing account authentication practices to verify your identity. Where necessary, we may request additional information about you so that we can verify your identity. Where we did not already hold that information, we will use it only for the purpose of verifying your identity and to process your request.  If you are submitting a request on behalf of a household, we will need to verify each member of the household in the manner set forth in this section.

Authorized Agents

You may use an authorized agent to exercise your CCPA rights on your behalf. Authorized agents may demonstrate that the agent has authority to exercise rights on the requesting California resident’s behalf by writing our Head of Information Technology at the street address identified above or by emailing us at the email address identified above. At a minimum, we will require evidence of the agent’s identity via driver’s license or passport page, and at least one of the following documents evidencing proof of your legal authority to act on behalf of the individual who is the subject of the request:

• Written authorization signed by the California resident;
• Certified copy of a Power of Attorney granted under the California Probate Code; or
• With respect to requests made on behalf of a minor, written evidence of parental responsibility.

Whenever you interact with us on behalf of another individual or entity, such as by providing or accessing Personal Information about another individual, you represent that your interactions and exchanges comply with applicable data privacy laws. You shall have sole responsibility for any violation of applicable laws as a result of a failure to obtain any necessary consent from such individual.

Timing

We will respond to Requests to Delete and Requests to Know within 45 calendar days, unless we need more time, in which case we will notify you and may take up to 90 calendar days total to respond to your request.  We will process a Request to Opt Out within 15 business days.

California Shine the Light Law

California residents may opt out of our sharing your Personal Information with third parties for the third parties’ direct marketing purposes. Please contact us at privacy@tensarcorp.com if you would like to do so.

Corporate Privacy Policy – Tensar WH
Effective Date: August 1, 2021
Version Number: 1