Last updated on May 21, 2018
Introduction
Universal Corporation and its group and affiliated companies (“Universal”, “we”, “our” or “us”) respects your privacy and is committed to protecting it through adherence to this privacy statement.
The entities controlling the processing of your personal information are Universal Corporation and its group and affiliated companies.
This privacy statement describes the types of information we may collect, or that you may provide to us, when you visit our website htl-dht.com (this “Site”). It also describes our practices for collecting, using, protecting, disclosing and otherwise processing this information.
This privacy statement does not apply to information collected by Universal offline or through any other means, including on any other website(s) operated by Universal, its affiliates, or any third party, whether or not links to such website(s) are included on this Site. Any information collected on other websites are governed by those websites’ applicable privacy policies.
Please read this privacy statement 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, please do not use this Site. By accessing or using this Site, you agree to this privacy statement. This privacy statement may change from time to time. Your continued use of this Site after we make changes is deemed to be acceptance of those changes, so please check this privacy statement periodically for updates.
Children under the age of Thirteen
This Site is not intended for children under the age of thirteen and we do not knowingly collect personal information from such children. No one under the age of thirteen may provide any information to this Site. If we learn we have collected or received personal information from a child under the age of thirteen, we will delete that information.
Information We Collect About You and How We Collect It
We may collect several types of personal information about users of this Site, including:
• Information by which you may be personally identified, such as your name, postal address, e‐mail address, and telephone number.
• Information about your internet connection, the equipment you use to access this Site, and usage details. (“Personal Information”)
We collect this Personal Information:
• Directly from you when you provide it to us (for example, when you fill out a form on this Site or correspond with us by using e‐mail or any other electronic message format(s) provided on this Site).
• Automatically as you visit and navigate through this Site.
Information collected automatically may include usage details, IP addresses, location data, traffic data and information collected through cookies. Please see our Cookie Policy found on this Site for further details.
Use of Your Information
We may use information that we collect about you or that you provide to us, including any Personal Information:
• To present this Site and its contents to you in the best possible way.
• To enhance, modify, personalize or otherwise improve and support this Site.
• To provide you with information that you request from us.
• To evaluate our business including to conduct data analytics studies and review and respond to feedback from our customers and Site users.
• To fulfil any other purpose for which you provide it.
• To comply with legal and regulatory requirements applicable to us.
Whenever we process Personal Information for these purposes we ensure that we keep your Personal Information rights in high regard and to take account of these rights. You have the right to object to this processing if you wish, and, if you wish to do so, please contact us at DSO@universalleaf.com. Please bear in mind that if you do object and we cannot demonstrate compelling legitimate grounds to continue processing your Personal Information, we will stop processing your Personal Information which may affect our ability to provide you with certain services and carry out tasks to your benefit.
Protecting and Retaining Your Personal Information
We are committed to protecting your Personal Information. As such, we utilize appropriate technical, physical, and administrative safeguards to help keep your Personal Information
secure.
We retain your Personal Information for as long as we reasonably require it for legal, business or contractual purposes. In determining data retention periods, we take into consideration local laws, contractual obligations, our reasonable business requirements and your reasonable expectations and requirements. When we no longer need your Personal Information, we securely delete or destroy it.
Disclosing and Transferring Your Personal Information
We will not disclose your Personal Information to parties outside of Universal and its group and affiliated companies except when:
• We are required to do so by law or legal process, or in response to a request from
government authorities.
• We believe disclosure is necessary in order to prevent financial loss or physical harm.
• We sell or transfer all or a portion of a business or assets.
• It is provided to a third party to perform services on our behalf and this third party is contractually bound to only use your Personal Information to perform such services or comply with legal requirements.
We may transfer your Personal Information to entities within the Universal group and third parties within or outside the United States. With respect to any Personal Information collected from Site visitors located in the European Economic Area (“EEA”), Universal has put in place an adequate level of protection to ensure that any such transfers comply, and are consistent, with applicable EU data protection laws. At present, to ensure that your Personal Information receives an adequate level of protection when transferred outside the EEA we have put in place data transfer agreements incorporating model clauses adopted by the EU Commission, copies of which can be obtained from the Data Security Officer (DSO) by writing to DSO@universalleaf.com.
Links to Other Websites
This Site contains links to other websites. While we try to link only to websites that share our high standards and respect for privacy, we are not responsible for the content or the privacy practices employed by other websites.
Your rights
To the extent your Personal Information is governed and protected by EU data protection law, you may have certain rights with regard to your Personal Information, including the right to access your Personal Information that we process about you and to request that we correct, amend, or delete it if it is inaccurate or processed in breach of applicable data protection laws.
These rights may not apply in some cases and, if you make a request, we shall inform you if that is the case. For more information on the full extent of your rights or to exercise your rights, you can submit a written request to DSO@universalleaf.com.
If you are not satisfied with how we process your Personal Information, you have the right to make a complaint to the relevant data protection regulator. A list of European Data Protection
Authorities can be found here: http://ec.europa.eu/justice/dataprotection/bodies/authorities/index_en.htmbodies/authorities/index_en.htm
Contacting Us
If you would like to contact us to inquire about this privacy statement or our practices, please contact us at DSO@universalleaf.com.
HTL | Kanaaldijk Noord 123 | 5642 JA Eindhoven | The Netherlands | Tel. +31 (0)40 2810275 | info@htl-dht.com
DHT | 2. Industriestraße 6 | 68766 Hockenheim | Germany | Tel. +49 (0)6205 379100 | info@htl-dht.com