Privacy Policy

Your privacy is of the utmost importance to Smalley Steel Ring Company and its affiliates ("Smalley" or "We"). Smalley makes every effort to protect all information collected from this website. We respect your privacy and are committed to protecting it through our compliance with this policy. This Privacy Policy describes the types of information we may collect from you or that you may provide when you visit the website www.smalley.com (our “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

• On this Website.
• In email, text, and other electronic messages between you and this Website.
• When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy

It does not apply to information collected by:

• Us offline or through any other means, including on any other website operated by Company or any third party; or
• Any third party including through any application or content (including advertising) that may link to or be accessible from, or on, the Website.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. This policy may change from time to time. (See Changes to Our Privacy Policy), so please check the policy periodically for updates.

Children Under the Age of 16

Our Website is not intended for children under 16 years of age. No one under age 16 may provide any personal information to [or on] the Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website or through any of its features, make any purchases through the Website, use any of the interactive or public comment features of this Website, or provide any information about yourself to us, including your name, address, telephone number, or email address. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will immediately delete that information. If you believe we might have any information from or about a child under 16, please contact us at www.smalley.com/contactus.

Please see Notice for Residents of the United States for more information.

Information Collection and Use

We collect several types of information from and about users of our Website, including the following.

Information You Provide Directly to Us.

The information we collect on or through our Website may include:

• Information that you provide by filling in forms on our Website. This includes information provided at the time of registering for any application on our Website, and information provided when you fill out forms on our Website, such as our “Contact Us” form and requests for information, samples, catalogs, and additional assistance. This information may include first and last names, phone numbers, email addresses, job titles, company industry, annual usage, passwords, and IP addresses.
• Records and copies of correspondence (including email addresses and email communications) when you submit inquiries via email.
• Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website. This information may include billing addresses, shipping addresses, and credit card numbers.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Website, including location data, log data, usage data, and other communication data and the resources that you access and use on the Website.
• Information about your computer and internet connection, including your IP address, specific computer information, and location data.

The information we collect automatically may include personal information. It helps us to improve our Website and to deliver a better and more personalized service including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Website according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
• Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.
• Web Beacons. Pages of our Website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
• Online Analytics. We may use third-party analytics services for our websites. These service providers use cookies and other technologies described in this Privacy Policy to help us analyze how users, like yourself, use our services.

No Biometric Information

We do not knowingly collect or solicit "biometric identifiers" (as that term and similar terms are defined in applicable laws) or use such information for purposes of identifying an individual. We strongly encourage you to not provide any biometric identifiers to us. If you believe we possess information that could be considered a biometric identifier, please notify us and we will promptly delete such information.

Third Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. We use third party service providers and vendors to help provide our services to you. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. Any information collected by third parties is subject to their respective privacy policies. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For more information regarding our use of cookies, please see our Cookies Policy.

How We Use Your Information

We use the information that we collect about you or that you provide to us, including any personal information, for the following purposes.

• To present our Website and its contents to you.
• To provide you with information, products, and services that you request from us, including customer care.
• To fulfill any other purpose for which you provide it.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection and fulfilling orders and processing returns.
• To notify you about changes to our Website or any products or services we offer or provide through it.
• To allow you to participate in interactive features on our Website.
• To administer contests and promotions and register you for websites or programs.
• To improve our products and services, including improving store layouts and digital content, maintaining and verifying the safety and quality of our services, identifying and repairing errors that impair existing intended functionalities of our services, and enabling certain features on our Website.
• To perform services on behalf of our organization, including fraud prevention, security protection, and asset protection.
• To personalize digital content, deliver marketing and advertising communications, customize user experience, and preserve user preferences.
• Analyze how you use and interact with our services, including advertisement impressions.
• Maintain our facilities and infrastructure.
• Comply with law, legal process, and internal policies.
• Exercise and defend legal claims.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

SMS Messages
By providing your mobile number and opting to receive SMS messages from us, you agree that we may send you SMS messages at the phone number you provide to enhance your customer experience (e.g., regarding order status, order tracking, appointment reminders, and account alerts). You may opt out of receiving these SMS messages at any time by replying STOP. Message and data rates may apply. 

How We Share Your Information

We may disclose aggregate information about our users, and information that does not identify any individual without restriction. We may disclose personal information that we collect or you provide to us as described in this Privacy Policy to:

• Subsidiaries and affiliates.
• Contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
• A buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer or some or all of Smalley’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Smalley about our Website users is among the assets transfers.
• Third parties to market their products or services to you.

We may also disclose your personal information:

• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent.
• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply our terms of use and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Smalley, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

For clarity, we do not sell personal information to third parties.

Retention of Your Information

We retain your personal information for as long as necessary to provide our services and fulfill the transactions you have requested, comply with our legal obligations, resolve disputes, enforce our agreements, and fulfill other legitimate and lawful business purposes. In general, we will retain your personal information for as long as necessary for the purposes set out in the Privacy Notice. Because these needs can vary for different data types in the context of different products and services, actual retention periods can vary significantly based on criteria such as user expectations or consent, the sensitivity of the data, the availability of automated controls that enable users to delete data, and our legal and contractual obligations.

We may also retain specific limited information related to your account and any data deletion or other access request you may submit as necessary to document our fulfillment of your requests. In some cases such as by court order, subpoena, or other legal or regulatory obligations, Smalley may be required by law to store your personal information.

How We Protect Your Information

We use technical, physical, and administrative safeguards to protect the confidentiality, integrity, and availability of your information. In other words, we use different types of controls and procedures to protect your information from misuse and unauthorized access or disclosure. We employ a range of measures that are commensurate with the dynamic cyber-threat landscape to secure your information, but we also recognize that electronic communications and the processing and storage of data can be inherently insecure and may contain unknown weaknesses. Consequently, while we cannot guarantee absolute security in such a dynamic threat landscape, we are strongly committed to continuously keeping your data as secure as possible. Please keep this in mind when disclosing any information to us via the Internet or other electronic means, including through our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Your Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information.

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this Website may then be inaccessible or not function properly.
• Opting Out on Website Pages. If you do not want your online browsing while on such pages to be used for interest-based advertising purposes, you may click on the Ad Choices link in the footer to opt-out of such uses by the listed advertising partner(s). An opt-out applies only to the device and browser in use at the time of opting out. If you clear your browser cookies and wish to remain opted out of interest-based advertising, you must opt-out again. See the following paragraph to learn more about how opting out works. Even if you opt-out through this service, we may still collect non-personally identifiable information regarding your site activities and use it for non-interest based advertising purposes.
• Opt-Out Compliance Service for Interest-Based Advertisements. This site and advertisements on third-party sites that link to this Privacy Policy use the Ghostery assurance service to comply with the cross-industry Self-Regulatory Program for Online Behavioral Advertising (now generally known as interest-based advertising) managed by the Digital Advertising Alliance (DAA) . When you opt-out on site pages, or through such advertisements, Ghostery conveys your opt-out election(s) to the applicable advertising partner(s), which then know to place a cookie on your specific computer and browser (and only the specific computer and browser from which you optout) indicating that you have opted out. If you clear your browser cookies and wish to remain opted out of interest-based advertising, you must opt-out again. The list of our advertising partners that place cookies on this website may be updated from time to time. To opt-out of internet-based advertising by all DAA-participating companies and to learn more about interest-based advertising, visit ********optout.aboutads.info/.
• Opting Out of in App Interest-Based Advertisements. iOS and Android mobile device users, and possibly users of other mobile devices, may control in App advertisements by disabling or resetting the mobile device advertiser ID. Below are links to instructions for controlling advertising IDs on iOS and Android devices.
  • iOS - click here
  • Android - click here
• Opting Out Through Online Advertisements. Advertisements on third-party websites that contain the Ad Choices link and that link to this privacy statement may have been directed to you based on anonymous, non-personally identifiable information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt-out of the advertising partners' use of this information for interest-based advertising purposes. Even if you opt-out through this service, we may still collect and use information from the advertisements for non-interest-based advertising purposes, such as to determine the effectiveness of the advertisements.
• Opting Out of Interest-Based Advertisements on Other Digital Services. Users of other digital services (such as cable and direct TV) may be able to opt-out of interest-based advertising through the provider of the digital service. We encourage you to review the privacy policy of your digital service

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted advertisements from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.

Depending on where you reside, you may have additional personal information rights and choices. Please see below for more information.

Notice for Residents of the United States

Depending on the state where you reside, you may have additional rights regarding our use of your personal information. This section intends to provide information required under those laws.

Definitions.

• “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal Information includes Sensitive Personal Information, but does not include information that has been aggregated, de-identified, or is considered publicly available.
• “Sensitive Personal Information” means Personal Information that reveals a consumer’s social security, driver’s license, state identification card, or passport number; account log-in, financial account number, debit card number, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin, religious beliefs, or union membership; contents of email or text messages; and genetic data. Sensitive Personal Information also includes processing of biometric information for the purpose of uniquely identifying a consumer and Personal Information collected and analyzed concerning a consumer’s health, sex life, or sexual orientation.'

Categories of Personal Information and Purposes for Processing.

The following table shows the categories of Personal Information we may have disclosed for a business purpose in the preceding twelve (12) months.

We have not sold or shared Personal Information about California consumers in the past twelve (12) months. Relatedly, we do not have knowledge that we sell or share Personal Information of California consumers under 16 years of age. For purposes of the CPRA, a “sale” is the disclosure of Personal Information to a Third Party for monetary or other valuable consideration, and a “share” is the disclosure of Personal Information to a Third Party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration.

Your Rights.

• Non-Discrimination. We will not discriminate against you for exercising your data subject rights.
• Right to Know and to Access. Subject to certain exceptions, and legal obligations, you have the right to request that we disclose certain information to you about our collection, use, and disclosure of your Personal Information, such as the following:
  • The categories of Personal Information we collected about you;
  • The categories of sources of Personal Information;
  • The business or commercial purpose for which we collect, sell, or share your Personal Information;
  • The categories of Personal Information about you that we have disclosed about you and the categories of persons or vendors to whom it was disclosed for a business purpose; and
  • The specific pieces of Personal Information we have collected about you.
• Right to Correction. You have the right to request that we correct any inaccurate Personal Information we maintain about you. In response to your request, we may request additional information showing that the Personal Information you want to correct is inaccurate.
• Right to Deletion. You have the right to request that we delete your Personal Information. This right is subject to certain exceptions, and legal obligations imposed by state or federal laws. We will delete or deidentify Personal Information not subject to one of these exceptions from our records and, to the extent required, we will direct our service providers to take similar action.
• Right to Opt-Out. You have the right to opt-out of the processing of your Personal Information for the purpose of (i) the sale or sharing of your personal data to third parties, (ii) targeted advertising, or (iii) profiling.

To protect your Personal Information, we may request additional information to verify your identity before we act on your request. To the extent legally required, we will provide the information you request, in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance. We may provide this information to you via email to the email address you have provided with your request. Smalley does not use or disclose Sensitive Personal Information.

Exercising Your Rights.

• Submitting your Requests. To exercise any of these rights or if you have any related questions, suggestions or complaints, you can contact Smalley's data protection officer referenced below. Alternatively, you may call (847) 719-5900 or email us at datasecurity@smalley.com.
• Authorized Agents. You may also nominate an authorized agent to submit a data subject request on your behalf. We may request additional information from you to verify that the authorized agent is operating on your behalf. In particular, when a California consumer authorizes an agent to make a request on their behalf, we may require the agent to provide proof of signed permission from you to submit the request, or we may require you to verify your own identity or confirm that you provided the agent with permission to submit the request.

Notice for Residents of the European Economic Area (including, the United Kingdom)

This GDPR Statement applies to persons in the European Economic Area (“EEA”), including those based in the United Kingdom (“UK”). This GDPR Statement supplements our Privacy Policy, however, where our Privacy Policy conflicts with the GDPR Statement, the GDPR Statement will prevail as to persons located in the EEA.

“Personal Information” in this GDPR Statement means any information relating to an identified or identifiable natural person; 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.

Smalley Steel Ring Company is the “controller” of your personal information we collect. A “controller” is an entity that determines the purposes for which and the manner in which any personal information is processed. If you would like to contact us please see section Site Operation below.

If the processing of your personal information is subject to the GDPR, including the UK GDPR, you have certain rights regarding your personal information. Your rights include the following:

• Access: You have the right to ask us for copies of your personal information subject to applicable exemptions, which means you may not always receive all the personal information we process.
• Rectification: You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete personal information you think is incomplete. Note, however, that we may need to verify the accuracy of the new information you provide to us.
• Erasure/deletion: You have the right to ask us to delete or erase your personal information in certain circumstances. 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.
• Restriction of processing: You have the right to ask us to restrict the processing of your personal information under the following circumstances: (a) if you want us to establish the information's accuracy; (b) where our use of the information is unlawful but you do not want us to erase it; (c) where you need us to hold the information even if we no longer require it as you need it to establish, exercise, or defend legal claims; or (d) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.
• Right to object to processing: You have the right to object to processing if we are processing your personal information where the processing is in our (or those of a third party’s) legitimate interests. In some cases, we may refuse to comply where we can demonstrate that we have compelling legitimate grounds to process your information that override your rights and freedoms and where the processing is for the establishment, exercise or defense of legal claims.
• Profiling: The right not to be subject to a decision based solely on automated processing, including profiling.
• Data portability: Where you have provided us with personal information you have the right to ask that it be given to you or transferred to another organization. Note this right only applies when our processing of your personal information is carried out by automated means and based on your consent or performance of a contract with you.
• Lodge a Complaint: You have the right to lodge a complaint with your local data protection authority if you are unhappy with any aspect of our processing of your personal information.

You are not required to pay any charge for exercising your rights. These rights will be exercisable subject to limitations as provided for by the GDPR/UK GDPR. Any requests to exercise the above-listed rights may be made to datasecurity@smalley.com.

You can also withdraw your consent at any time where we are relying on your consent to process your personal information. Please note that your withdrawal will not affect the lawfulness of any processing carried out before you withdrew 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. For personal information collected about you in the EEA and the UK, we set out below, in a table format, a description of the ways in which we use your personal information and the legal bases we rely on to do so.

We may process your personal information for more than one legal basis depending on the specific purpose for which we are using your personal information. Please contact us at datasecurity@smalley.com if you need details about the specific legal basis we are relying on to process your personal information where more than one ground has been set out in Annex I.

Where we transfer your personal information outside the EEA and the UK to other group companies or service providers, we transfer it subject to the appropriate safeguards as permitted under the GDPR/UK GDPR and the UK GDPR, such as the applicable EU Standard Contractual Clauses or their UK equivalent, to facilitate international transfers of personal information collected in the EEA and the UK. Please contact us if you would like to learn about the specific transfer security mechanism we use.

Further to section on Retention of Your Information above, to determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means and the applicable legal requirements.

Notice for Residents of the People’s Republic of China (“China” or “PRC”)

This notice for China residents supplements the information contained in our Privacy Policy and applies solely to individuals who reside in China. We adopt this notice to comply with the PRC Personal Information Protection Law (“PIPL”), Regulation on Network Data Security Management and other applicable Chinese laws and regulations on the collection, storage, use, processing, provision, disclosure and deletion of your Personal Information.

List of Personal Information Collected and Processed by us.

For residents in China, we collect and process your Personal Information in accordance with Section of Information Collection and Use. We will obtain your proper consent for processing of your Personal Information in accordance with the applicable PRC laws and regulations. You may also refer to Appendix I for the list of Personal Information collected and processed by us.

We do not routinely collect your Sensitive Personal Information. However, in case we process your Sensitive Personal Information, we will inform you of the necessity and the impact on your personal rights and interests, unless otherwise required by the applicable PRC laws and regulations.

Provision of Personal Information to Third Parties.

For residents in China, we may provide your Personal Information to third parties in accordance with Section of How We Share Your Information above. You may also refer to Appendix I for the list of personal information we provide to third parties.

Cross-border data transfer
For residents in China, we may need to transfer your Personal Information outside of China to our headquarters, overseas affiliates or external parties for administrative management, business development and operation, compliance and other purposes, to the extent permitted by the applicable PRC laws and regulations. We will implement the appropriate mechanisms for cross-border data transfer and conduct the relevant procedures where required by the applicable PRC laws and regulations. We will keep you informed of the relevant information on the cross-border data transfer according to the applicable laws and regulations, including the category of Personal Information involved, the purpose and method of the processing and how to exercise your rights.

Your Rights.

As a data subject in China, you have the rights according to the PIPL and other applicable PRC laws and regulations. We will try our best to support the exercise of your rights according to the law, but please be aware that your exercise of certain rights may affect the services we can offer or be subject to certain constraints. For example, if you withdraw your consent, we may not be able to provide the relevant services for you; if you would like to delete your Personal Information provided to us, but the retention period prescribed by the applicable laws and regulations has not expired, or it is technically difficult to delete the Personal Information, we will cease the processing of the Personal Information, except for the storage and any necessary measure taken for security protection.

If you reside in China and have any inquiries, please contact us at the following address:

Tianjin Smalley

Technology Limited

Address: Room 302, Growth Power Building, intersection of Dongsan Road and Anhe Road, Tianjin Pilot Free Trade Zone (Airport Economic Zone)

Email: china@smalley.com Telephone: +86 22 8895 6811

Changes to Our Privacy Policy

It is our policy to post any changes we make to our Privacy Policy on this page. The date the Privacy Policy was last revised is at the top of the page. We encourage you to periodically visit our Website and this Privacy Policy to check for any changes.

Contact Us

This site is operated by Smalley Steel Ring Company. If you have any questions regarding this policy, please contact us at:
555 Oakwood Rd. Lake Zurich, IL 60047 Phone: (847) 719-5900
datasecurity@smalley.com

Appendix I List of Personal Information Collected and Processed by Us.

Appendix II List of Personal Information We Provide to Third Parties.