Privacy and Cookies Policy
This Privacy and Cookies Policy applies to the website http://www.convergeengineering.com/ (“the Site“) which is run by Converge Engineering LLC (“the Company”), a wholly owned subsidiary of Sims Recycling Solutions, Inc. of 8855 Washington Blvd., Suite 4, Roseville, CA, 95678, USA. On our Site, the Company is referred to as “Converge Engineering”.
This Privacy and Cookies Policy (“Policy”) explains how the Company collects, uses and discloses personal information about you when you visit the Site and when you contact the Company, whether by e-mail, post, fax or telephone using the contact options on the Site. The information you provide to us through the Site will initially be collected by the Company but may then be shared with other Sims companies, including, those based outside of the USA.
All references to “the Company” in this Policy therefore include Converge Engineering LLC and all of its group affiliates flowing up to the ultimate parent company Sims Metal Management Limited (an Australian publicly traded company) (“the Group”), unless stated to the contrary. Depending upon your relationship with the Company, we may separately provide you with further details about our use of your personal information.
What type of information does the Company collect and why?
When you visit our Site, we may automatically collect standard internet and website log information and details of patterns about how website visitors behave. The information we may collect includes information about your Internet service provider, your operating system, browser type, domain name, the Internet protocol (IP) address of your computer (or other electronic Internet-enabled device), your access times, the website that referred you to us, the Web pages you request and the date and time of those requests. This may allow us to find out which parts of the Site are popular or need changing.
The Site allows you to contact us, make a purchase, sign up to our newsletter, create a customer account (with an option to receive our Newsletter) and email details of any of our products to a friend using our “Email a friend” service. If you want to use any of these services, you will need to provide us with some additional personal information so that we can liaise with you in order to deal with your request, query, purchase or customer account registration. If you do choose to provide us with your personal information, we will collect that information for our own use and for the purposes described in this Policy.
If you want to use our “Email a friend” service to send details of our products to someone you know, you will need to provide us with their name, email address and your message to them so that we can send them the details. By providing this information you confirm that you have their consent to share their details with us for this purpose.
What type of personal information does the Company collect?
Where you choose to provide personal details to us, we may collect the following personal information from you:
- your full name and gender;
- your work and home contact details eg address, fax number, telephone numbers and e-mail address;
- the reason for your contact, which may be an enquiry, a purchase, a request or enquiry on behalf of someone else, a customer service need, providing a comment or details in relation to a possible or existing order;
- if you create a customer account – your username, password, e-mail address and your full name;
- if you make a purchase using the Site: delivery information which may include your address and telephone number;
- financial account information, such as credit/debit card number and other payment information; and
- your contact and marketing preferences;
- if you take a survey or interact with us in various other ways – demographics information and information about subjects that may interest you;
- information necessary for legal compliance; and/or
- where you “like” us or make posts on our pages on social networking websites.
This information will be collected primarily from you as information voluntarily provided to us, but we may also collect it where lawful to do so from (and combine it with information from) public sources, third party service providers, individuals who you have indicated have agreed for you to provide their personal information, government, tax or law enforcement agencies and other third parties. We may also collect personal information about you from your use of other Group websites or services.
How does the Company use information about you?
The Company may use information about you for purposes described in this Policy or as otherwise disclosed to you on our Site or with our services. For example, we may use information about you for the following purposes:
- to respond and/or deal with your request or enquiry (including sending details of our products to third parties when you use the “Email a friend” service);
- to process and administer your order(s) or purchase(s) of our products;
- to improve our products and to ensure that content from the Site is presented in the most effective manner for you and for your computer (or other electronic Internet-enabled device);
- to administer the Site;
- for internal record keeping;
- to contact you (directly, either by the Company or by the Group or through a relevant partner or agent) by e-mail or phone for any of the above reasons;
- subject to your consent where required under applicable laws, to carry out direct marketing and/or e-mail marketing that you have requested;
- where necessary as part of any restructuring of the Company or sale of a relevant Group company’s business or assets;
- to perform any contract the Company has with you; and
- for compliance with legal, regulatory and other good governance obligations.
This list is not intended to be exhaustive and may be updated from time to time as business needs and legal requirements dictate. Some of the personal information that the Company maintains will be kept in paper files, while other personal information will be included in computerised files and electronic databases as set out in more detail below.
In most cases, the information the Company processes about you is required to deal with your request, purchase or registration, or required by law, or is necessary for the exercise of the Company’s legitimate business interests and needs, in which case special care is taken to safeguard your rights and to ensure any such use is proportionate.
The Company or Group may also convert personal information into anonymous data and use it (normally on an aggregated statistical basis) for research and analysis to improve Company/Group performance. In addition, the Company or Group may use pixels or transparent GIF files, to help manage online advertising. Any information that we collect and share is anonymous and not personally identifiable.
Does the Company share personal information with third parties?
Your personal information will be made available for the purposes mentioned above (or as otherwise notified to you from time to time), on a ‘need-to-know’ basis and only to responsible management, accounting, legal, logistics, audit, compliance, information technology and other corporate staff who properly need to know these details for their functions within the Group. Please note that certain individuals who will see your personal information may not be based at the Company or in your country (please see below).
We may share personal information within the Group as needed for reasonable management, analysis, planning and decision making, including in relation to taking decisions regarding the expansion and promotion of our product and service offering, order or customer request fulfilment and for use by those companies for the other purposes described in this Policy.
Your personal information may also be made available to third parties (within or outside the Group) providing relevant services under contract to the Company, or the Group (see below for further details), such as marketing agencies, credit card processors, auditors and compliance managers, providers or call centres and IT hosting and IT maintenance providers. These companies may use information about you to perform their functions on our behalf. The Company has put in place various security and data privacy measures, including with such third parties, in order to protect personal information and shall seek to comply with applicable legal requirements.
We will not sell your personal information to any third party other than as part of any restructuring of the Company or Group or sale of a relevant Group business.
Will your personal information be transferred abroad?
Some transfers of personal information have been explained above. Individuals within the European Economic Area (“EEA”) should be aware that recipients of their personal information, within the Group or third parties (as set out in this notice), may not be located within the EEA but instead located in countries which do not have equivalent protection for personal information to that within the EEA. Steps will be taken to protect your personal information in that instance consistent with applicable law.
What choices does the Company offer you with regard to direct marketing?
The Company may wish to provide you with information about new products, services, promotions and offers, which may be of interest to you and may invite you to take part in market research or request feedback on our products and services and the Group’s products and services. This communication may occur by e-mail, telephone, post or SMS. We will obtain your consent and advise you of how to opt-out of receiving such communications where we are required to do so in accordance with applicable law, for example you may opt-out of receiving our newsletter by un-ticking the relevant box on the “my account” section of our website or by clicking the “unsubscribe” link on any email that we send to you.
Where you consent to us doing so, by ticking the relevant box when you create an account, we will also share your information with other consumer electronics companies who we think you would be interested to hear from.
You can choose to opt-out of receiving such marketing communications by either following the “unsubscribe” link in any email that you receive or by un-ticking the relevant box in the “my account” section of our website.
What safeguards are in place to protect your personal information?
The Company takes reasonable steps to maintain appropriate physical, technical and administrative security to help prevent loss, misuse, unauthorised access, disclosure or modification of personal information. While we take these reasonable efforts to safeguard your personal information, we cannot guarantee the security of any personal information you disclose online. You accept the inherent security implications of dealing online and will not hold us responsible for any breach of security unless such breach has been caused by the specific negligence of the Company, the Group or their agents.
What rights do you have to review and amend personal information?
You have the right to review your personal information held by the Company (including any profiling information) and have certain inaccurate information about you corrected. Under UK law, a request for access to your personal data needs to be in writing and accompanied by any applicable statutory fees.
If you wish to do so, or to contact the Company in respect of its data processing activities, please contact firstname.lastname@example.org, or FAO: Legal Department, Sims Recycling Solutions, 200 W. Madison St., Suite 3600, Chicago, IL, 60606, USA.
Keeping you informed
We will keep your details on record until we have completely dealt with your request, enquiry or application and then for a reasonable period afterwards, in accordance with data protection and other applicable legislation.
The Company may keep your details on record for as long as is necessary for the purposes set out above and will then securely delete your details in accordance with the Act.
Like many websites, when you visit our Site we issue a ‘cookie’ or unique code that allows us to identify your computer. We use the cookie to note the different areas of our Site recently accessed through your computer – it is only used in relation to this Site and not in relation to any other websites you may visit. We will use the information collected in this way to tell you about services or products which might be of interest to you when you make further visits to our Site. Most web browsers automatically accept cookies, but your browser’s settings can be altered to prevent this. In addition, Cookies can be deleted from your hard-drive. How you do this will depend upon the Internet browser that you use. Please refer to your relevant Internet browser manufacturer’s website where you should be able to receive the information you need.
Changes to this Privacy and Cookies Policy
We keep this Policy under regular review. We may change this Policy from time to time by updating this page in order to reflect changes in the law and/or our privacy practices. The date at the top of this Policy will be updated accordingly.
We encourage you to check the date of this Policy when you visit the Site for any updates or changes. We will notify you of any modified versions of this Policy that might materially affect the way we use or disclose your personal information.
By using our Site, submitting your personal information to us and/or registering an account, you consent to the use of your personal information as described in this Policy (as amended from time to time).
This Policy only extends to the Site and does not, therefore, extend to your use of, provision of data to and collection of data on any website not connected to us to which you may link by using the hypertext links within this website.
If you have any questions about this Policy, please contact us in writing at:
200 W. Madison St.