This privacy policy (“Privacy Policy”) governs Your use of (1) the website provided by Elemica, Inc. and its affiliates and subsidiaries (collectively, “Elemica”) with a homepage located at www.elemica.com (or any successor or replacement thereto); (2) the Elemica Network (the website and the network collectively referred to as the “Site”); and (3) any services provided by Elemica or available through the Site (the “Services”). Your access and/or use of this Site and/or any Services signifies that You agree to be bound by this Privacy Policy. “You” and “Your” refers to any individual, company or legal entity that accesses or otherwise uses the Site and/or any Services.

Privacy Fundamentals
Elemica is committed to protecting and carefully handling the information that You provide and that Elemica maintains about You, Your company, Your accounts and Your transactions (collectively, “Customer Information”). Elemica’s approach to responsible data handling is founded on providing notice of Elemica’s information practices (“Information Practices”) and other privacy issues to allow You to make informed decisions regarding Your use of the Site and Services. We believe that this Policy complies with the U.S. Department of Commerce safe harbor framework, which has been approved by the European Union as an adequate way for a company to demonstrate that it complies with the protections outlined in the EU Directive on Data Privacy.

Notice
Elemica will provide You notice of its Information Practices through (i) this Privacy Policy; (ii) customer agreements, if applicable; and (iii) specific notices on the Site (collectively, “Information Practices”).

Consent
Elemica offers You choices regarding how Your Customer Information may be used by Elemica. You may use certain public parts of the Site without providing information to Elemica. However, if You want to use the Services, Elemica will request that You provide information about, among other things, You and the company that You represent.

Elemica uses Your Customer Information to assist You in managing Your use of the Site and Services. In addition, Elemica may disclose and/or use Customer Information in special circumstances where it is necessary to enforce our agreements or Terms of Use (for example, when necessary to protect our intellectual property rights). Elemica reserves the right to compile and use aggregate Customer Information, and also to provide such aggregate Customer Information to third parties. Aggregated Customer Information will not be linked to any particular individuals or companies. Elemica will not commercially exploit Your Customer Information that You provide for other purposes without Your consent.

Data Access and Update
Elemica provides You the opportunity to update or correct the Customer Information that You provide to Elemica, and to review Your account and transaction history. Customer Information can be updated at any time by contacting Elemica Global Client Services via email at This e-mail address is being protected from spambots. You need JavaScript enabled to view it or via telephone at 1-800-ELEMICA (U.S. and Canada) or 00-800-4-353-6422 (Europe, except Scandinavia). Transaction history can be reviewed at any time by authorized members using the View Reports option of the Members section of Elemica.com.

Data Security and Integrity
Elemica recognizes industry standards and employs security safeguards in an effort to protect Customer Information from unauthorized access and misuse. When You provide information to the Site over the Internet, Elemica will store this information on its servers and provide You with cryptographically protected communications services (e.g., using Secure Sockets Layer encryption for Internet communications).

Transfer of Data
When You submit Customer Information, You understand and agree that such information may be transferred across national boundaries and may be stored and processed in any of the countries in which Elemica maintains offices, including without limitation, the United States. You also acknowledge that, in certain countries or with respect to certain activities, the collection, transfer, storage, and processing of Your Customer Information may be undertaken by trusted vendors of Elemica.

Change of Control
Your Customer Information may be transferred in connection with a sale, merger, transfer, exchange or other disposition (whether of assets, stock, or otherwise) of all or a portion of a business of Elemica.

Changes to this Privacy Policy
If Elemica makes significant changes to this Privacy Policy, Elemica will post the revised Privacy Policy to the Site at least 30 days before such changes take effect.

Legal Disclosures
Elemica will disclose your Customer Information, without notice, only if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on Elemica or the Site; (b) protect and defend the rights or property of Elemica; and, (c) act under exigent circumstances to protect the personal safety of users of Elemica, its web sites, or the public.

Mandatory and Optional Information
Elemica identifies information that it requires from You that is necessary to provide the Services to You. Whenever Elemica asks for additional or optional information, Elemica identifies that information appropriately so that You know what information is required to provide You the applicable Service.

Consultants and Outsourcers
In some cases, Elemica employs or works with consultants, temporary workers, software developers, or outsourcers to complete a business process or provide a Service (e.g., delivering products, offering online software applications, or sending eMail messages on our behalf). When Elemica employs these agents or offers their services to You, Elemica may need to provide them information about Your account. Except in limited circumstances, these agents or developers are prohibited through their contracts with us from using that information or disclosing it for purposes other than to offer or complete the service that Elemica is outsourcing.

Registration
To use the Services, You need to register an account with Elemica. You must supply certain identification, contact, and certification information that becomes part of Your account profile. Elemica uses information in Your account profile for nearly every Service that Elemica provides.

Order Management
Elemica facilitates transactions between buyers and sellers, using the information supplied by the parties themselves. Elemica transfers only that information that is necessary to complete the transaction from You to the other parties involved, and other information that You specifically provide or indicate. You will see the information required for the specific transaction type, and be able to postpone or cancel the transaction at certain decision points. Some of this information may come from You directly, while Elemica may supply other information from Your account profile. Elemica also supports order tracking and tracing, and management of shipping documents. If You use any of the notification features, information about Your order may be transmitted to You via telephone, email, pager, or other wireless device that You have identified to us. The information transmitted through these services may not be able to be protected by Elemica. Also, when You conduct trades and other transactions through the Site, Elemica establishes and maintains appropriate records that become part of the account history for You and for Your trading partners.

Settlement
Elemica may contract with one or more financial services providers to help You manage invoices and payments. Customer Information needed to manage the settlement requirements that You select will be provided to such financial services providers.

Customer Service and Technical Service
When You engage Elemica’s customer service and technical service teams, Elemica may access Your Customer Information needed to fulfill Your requests or to reply to Your inquiries. Elemica retains records about customer service and technical service requests that You make. Elemica does not use these records for purposes other than to service Your request, maintain appropriate business records, and assess and improve the Services.

Reporting
Elemica provides a variety of tools that allow You to report and analyze Your use of the Services. Elemica will periodically generate statements for internal use that contain statistical information regarding transaction volume and value. Elemica may periodically report and publish aggregate general performance metrics. Such reports will not contain information that links You to such statistics.

Information Retention
Elemica stores the information about its customers, the Site and Services for automated access and processing. Elemica reserves the right to keep records for a period of not less than 20 years as operational records, historical archives, and for analysis and reporting. Elemica will notify You not less than 60 days prior to the destruction of records and will provide You the option of obtaining all of Your records for Your own storage or destruction. You may request that Elemica purge specific information from Elemica’s databases and archives prior to the expiration of the data retention period.

Internet Topics
Here is how and why Elemica uses some common Internet technologies to help manage the Site and Services:
Cookies. A "cookie" is a small piece of information that Elemica may provide to Your browser while You are using the Site or Services. The Site supplies Your browser with cookies that contain a unique identifier used to better understand Site usage in the aggregate.

If You are a registered user, You will receive a session-based cookie when You log in to the Site. This cookie is maintained by Your browser and contains Your identifier. This cookie is also used to authenticate a user’s identity and provide them with access to areas of the Site that are limited to registered users, such as their own account profiles and account histories.

If You simply want to browse the public areas of our Site, You do not have to accept cookies from Elemica. Should You decide, however, that You would like to register and have access to restricted areas of the Site, You will need to accept the cookies that Elemica sends to your browser. Otherwise, You may not be able to use certain portions of the Site or Services.

Third party tracking systems in use on behalf of the Site may assign different cookies to You. These cookies may be used to track Your involvement with certain links on the Site to help Elemica better understand and improve the Site and Services. You may choose not to accept these cookies and You will still have full access to site functionality. These cookies are not linked to the Customer Information You provide Elemica.

Advertising networks that serve ads on the Site may assign different cookies to You. Those cookies may be used to track Your involvement with the advertising on the Site. You may choose not to accept these cookies. Elemica does not control those parties. You should review their privacy policies to learn more about what, why and how they collect and use information they collect.

Web Site Usage Data. With or without cookies, Elemica keeps track of usage data, such as the source address that page requests come from, IP addresses and/or domain names, the dates and times of page requests, the names and/or IP addresses of referring web sites, and other parameters in the Uniform Resource Locaters (“URLs”). Elemica uses this data to better understand Site usage in the aggregate. This information is stored in log files and is used for aggregated and statistical reporting. This log information is not linked to other Customer Information.

Third Party Sites. Elemica may provide links to third party sites, such as those of Elemica’s business partners and customers. On these sites, these parties and others may collect information about You. Elemica is not responsible for the actions of these parties. Elemica encourages You to review their privacy policies to learn more about what, why and how they collect and use information.

Newsletters. You may subscribe to eMail newsletters and other eMail communications by providing Your eMail address to Elemica. You may unsubscribe by following the instructions provided in each eMail newsletter. With your consent, Elemica may use Your eMail address to send You promotional materials.

Surveys. From time to time, Elemica may offer You the option to participate in surveys through the Site or through other media. If You would like to participate, Elemica may ask You for contact information, preferences or other information. This information may be used to conduct research, improve Elemica’s offerings, or report customer perceptions and trends.

Contacting Us
Elemica is committed to protecting Your Customer Information and helping You manage Your privacy. Should You have any questions or concerns about this Privacy Policy, please contact Elemica Global Client Services via email at This e-mail address is being protected from spambots. You need JavaScript enabled to view it or via telephone at 1-800-ELEMICA (U.S. and Canada) or 00-800-4-353-6422 (Europe, except Scandinavia).