Welcome to EMR Group's privacy notice. The EMR Group is made up of different legal entities across the globe. This privacy notice is issued on behalf of the EMR Group so when we mention “EMR”, "we", "us" or "our" in this privacy notice, we are referring to the relevant company in the EMR Group responsible for processing your data.

EMR respects your privacy and is committed to protecting your personal data. This privacy notice explains how companies within the EMR Group use and protect any personal data that we may collect about you and informs you of your privacy rights and how the law protects you.

You can download a pdf version of the policy here. Please also use the Glossary to understand the meanings of some of the terms used in this privacy notice.

1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
10. GLOSSARY

1. Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how EMR collects and processes your personal data through your use of our online and offline services, including any data you may provide through this website when you sign up for a customer account, to our newsletter or take part in a competition.

This website is not intended for children. We do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller

The EMR Group is made up of different legal entities across the globe. This privacy notice is issued on behalf of the EMR Group so when we mention “EMR”, "we", "us" or "our" in this privacy notice, we are referring to the relevant company in the EMR Group responsible for processing your data. European Metal Recycling Limited is the controller and responsible for this website.

Contact details

Should you wish to contact us, our contact details are as follows:

In the United Kingdom

Company Secretary
European Metal Recycling Limited
Sirius House
Delta Crescent
Westbrook
Warrington
WA5 7NS
England

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

In the United States

Legal Department
EMR (USA Holdings) Inc.
201 N. Front Street
Camden, NJ 08102
USA

Changes to your personal data

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes title, first name, maiden name, last name, and date of birth.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of the products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Profile Data includes your username and password, transactions made by you, your preferences, feedback and survey responses.
• Usage Data includes information about how you use our website and yard services.
• Marketing and Communications Data includes your preferences in receiving marketing information from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law, as this data does not directly or indirectly reveal your identity. For example, we may analyse the number of times you visit a yard to calculate the percentage of customers visiting a specific yard at a given time. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel the product or service you have purchased from us but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your identity, contact and financial data by filling in forms or by corresponding with us by post, phone, e-mail or otherwise. This includes personal data you provide when you:
  • create an account, either at a yard or on our website;
  • subscribe to our services or publications;
  • request marketing information be sent to you;
  • enter a competition, promotion or survey;
  • interact with us via our social media accounts; or
  • give us feedback.
  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your browsing devices, browsing actions and patterns.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below.
    • Technical Data from the following parties:
      • (a) analytics providers such as Google based outside the EU;
      • (b) advertising networks based inside or outside the EU; and
      • (c) search information providers such as Google based inside or outside the EU.
    • Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside or outside the EU.
    • Identity and Contact Data from data brokers or aggregators such as Experian and Oblong UK based inside or outside the EU.
    • Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.

4. How we use your personal data

We will only use your personal data where a lawful basis allows us to. Most commonly, we will use your personal data in the following circumstances:

• Performance of a Contract. Where use of your information is necessary to provide you with EMR Group Services under a contract, for example the relevant Terms of Service.
• Legitimate Interest. Where use of your information is necessary for our or others’ legitimate interests and where the use is not outweighed by your rights and interests. Below are some examples of such interests:
  • providing EMR Group services
  • improving our services and developing new ones
  • recognizing and better understanding our users, including across platforms
  • conducting security and fraud prevention activities
  • marketing and promoting our content and services
  • building and managing business relationships
  • conducting compliance and risk management activities
  • providing and managing access to our systems.
• Legal Obligation. Where use of your information is necessary to comply with laws and regulations such as those relating to anti-bribery and corruption and anti-money-laundering, the Scrap Metal Dealers Act and complying with requests from government bodies or courts or responding to litigation.
• With Consent. We may ask for your consent to process your information in a certain way. Where we rely on this basis, you have the right to withdraw your consent at any time.

Generally, we do not rely on consent as a lawful basis for processing your personal data other than in relation to sending direct marketing communications to you via post, email or text message. You have the right to withdraw consent from marketing at any time by contacting us at marketing@emrgroup.com.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely upon to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us at dpo@emrgroup.com if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Promotional offers from us

We may use your identity, contact, technical, usage and profile data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant to you (we call this marketing).

You will receive marketing communications from us if you have requested information from us, used our services or provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We do not share your information with third parties for their marketing purposes. We will get your express opt-in consent before we share your personal data with any company outside the EMR Group of companies for their marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at marketing@emrgroup.com at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a transaction.

California “Shine the Light” Law

Under California Civil Code Section 1798.83, also known as California’s “Shine the Light” law, California residents with whom we have an established business relationship are entitled to request and receive, free of charge, once per calendar year, certain information about the customer information we shared, if any, with other businesses for their own direct marketing uses in the previous calendar year.

To request a copy, please contact us at dpo@emrgroup.com.

Change of purpose

We will only use your personal data for the purposes for which we have collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at dpo@emrgroup.com.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

• Internal Third Parties as set out in the Glossary.
• External Third Parties as set out in the Glossary.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets.

Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

We share your personal data within the EMR Group. This may involve transferring your data outside the European Economic Area (EEA).

We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. These rules are called "binding corporate rules". For further details, see European Commission: Binding corporate rules.

Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

Please contact us at dpo@emrgroup.com if you want further information on the specific mechanism used by us when transferring your personal data outside of the EEA.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

9. Do Not Track

This website does not currently take any action when it receives a Do Not Track request. Do Not Track is a privacy preference that you can set in your web browser to indicate that you do not want certain information about your webpage visits collected across websites when you have not interacted with that service on the page. For details, including how to turn on Do Not Track, visit www.donottrack.us.

10. Your legal rights

If you are an EU resident, you have the following rights under data protection laws in relation to your personal data.

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

If you are a California resident, you have the following rights under the California Consumer Privacy Act of 2018 (the “CCPA”):

• Right to know what personal data is collected, used, disclosed or sold.
• Right to delete personal data.
• Right to opt-out of the sale of personal data.
• Right not be discriminated against for exercising your rights.

For information on the categories of personal data we have collected about you in the twelve (12) months prior to the effective date of this privacy notice, the categories of sources for such personal data, the business purposes for collecting such personal data and with whom we share such personal data, please refer to the sections titled “The data we collect about you,” “How is your personal data collected?,” “Purposes for which we will use your personal data” and “Disclosures of your personal data,” respectively.

If you wish to exercise any of the rights set out above, please contact us at dpo@emrgroup.com. Users in the United States may also contact us at 1-800-SCRAPIT (1 (800) 727-2748). When contacting us via phone, please reference this privacy notice.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

If you are a California resident, you may submit a request as frequently as you would like, but we are not required to respond to requests to provide personal data to you more than twice in any 12-month period.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

If you are a California resident, you may make a request to exercise any of your rights under the CCPA on behalf of your minor child. You may also designate an authorized agent to make a request to know or delete on your behalf.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

11. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at dpo@emrgroup.com.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

Internal Third Parties

Other companies in the EMR Group acting as joint controllers or processors.

External Third Parties

• Service providers acting as processors based in the UK and Europe who provide IT and system administration services.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK and Europe who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the UK and Europe who require reporting of processing activities in certain circumstances.
• Any other marketing or service related businesses based in the UK and Europe that provide specialised services.

YOUR LEGAL RIGHTS

If you are an EU resident, you have the right to: Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. 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.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground, as you feel it impacts your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data 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 data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw 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.

If you are a California resident, you have the right to:

Request to know what personal data we collect, use, disclose or sell. Specifically, you may request that we disclose the following to you:

1. The categories of personal information we have collected about you.
2. The categories of sources from which we collect the personal data.
3. The business or commercial purpose for collecting or selling personal data.
4. The categories of third parties with whom we share personal data.
5. The specific pieces of personal data we have collected about you.

If we sell your personal data or disclose your personal data for a business purpose, you may request that we disclose to you:

1. The categories of personal data that we collected about you.
2. The categories of personal data that we sold about you and the categories of third parties to whom the personal data was sold, by category or categories of personal information for each third party to whom the personal data was sold.
3. The categories of personal data that we disclosed about you for a business purpose.

We do not sell your personal data.

Request deletion of any personal data we collected from you. If it is necessary for us to maintain the personal data for certain purposes, we are not required to comply with your deletion request. If we determine that we will not delete your personal data when you request us to do so, we will inform you and tell you why we are not deleting it.

Opt-out of the sale of your personal data to any third parties. We do not sell your personal data. Not be discriminated against because you exercised any of your rights under the CCPA.

CHANGES TO THIS PRIVACY NOTICE

Any changes to this privacy notice will be posted to this website so you are always aware of the information we collect and how we use it. Accordingly, please refer back to this website frequently as this privacy notice may change.