Privacy Policy

INTRODUCTION

CSW Industrials, Inc. (“CSW”) and its affiliated operating companies respect your privacy and are committed to handling your data in an open and transparent manner.

In this Privacy Policy, “we” and “us” refer to the CSW company that operates the website that links to this Privacy Policy. Please go to CSW’s Investors site to access a consolidated list of all the CSW companies and their principal locations in CSW’s most recent annual report.

This Privacy Policy describes what kinds of personal data we collect from you through our website and how we use and disclose that data, where the term “personal data” refers to information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you, and includes “personal information” and similar terms as defined in applicable data protection laws promulgated throughout the various countries where CSW operates.

NOTICE AT COLLECTION OF PERSONAL DATA

This notice at collection describes some of the key elements of our website data practices, including the categories of personal data we collect and the purposes for which we collect such data.

A. Categories of Personal Data We Collect

We collect:

Identifiers and biographical information, such as your Internet Protocol (“IP”) address, and other similar online or device identifiers. We also collect your name, postal address, email address and phone number, if you provide this information to us.
Commercial information, such as the products that you purchase or may be interested in purchasing from us.
Internet or other electronic network activity information, including the website pages that you view and the dates and times of your website visits.
Non-precise geolocation data based on your IP address.
Professional or employment-related information, such as your employer and job title.
Inferences based on the categories of personal data listed above.
Sensitive data, specifically, your login information if you choose to create an account on our website.

We may “sell” or “share” (as such terms are defined in US law) some types of personal data with third parties that provide us with website analytics services. Specifically, we sell or share online or device identifiers and network activity information with analytics vendors to gain a better understanding of who uses our website and how to improve it. We do not sell or share any sensitive data.

You can opt out of the sale or sharing of your personal data through the Manage Cookies link on the website or by sending your opt-out preference through a Global Privacy Control (“GPC”) signal. We do not respond to “Do Not Track” signals.

B. The Purposes for Which We Collect and Use Personal Data

We use personal data for several purposes, including, but not limited to:

operate, analyze, and improve our website;
create, maintain, customize, and secure your account with us;
communicate with you about your requests for information about our products, the status of your orders, and the likes;
fulfill your orders and process your payments;
send you marketing materials;
monitor, protect, and maintain the security and integrity of our website and our business;
comply with applicable laws and regulations and respond to lawful requests and communications from law enforcement and other government officials;
carry out sales and business transactions (including bankruptcy) in which information held by us is among the assets transferred or is otherwise relevant to the evaluation, negotiation, or completion of the transaction;
protect our rights, privacy, safety, property and/or those of others; and
fulfill the specific purpose that we describe when we collect your personal data.

C. Retention

We will retain your personal data only for as long as reasonably necessary to fulfill the purposes for which it was collected (i.e., operating our website, including our need to maintain security), including for the purposes of satisfying any legal, accounting, or reporting requirements.

HOW WE COLLECT PERSONAL DATA

We collect personal data when you voluntarily provide it to us. Specifically, we collect personal data:

When you use our services, or when you inquire about or create an account to use our services.
When you make a purchase of goods and services from us and we or our third-party payment processors collect a payment card number or other payment information.

We also collect personal data automatically when you visit and interact with our website. We store information about the use of our website in system logs for security and other essential purposes.

In addition, we and our vendors collect data through cookies, tags, scripts, and similar technologies. The specific types of information that we and our vendors automatically collect include:

Device and browser information, such as your IP address, your device’s identifiers, browser type, device type, internet service provider, and operating system.
Non-precise location information, based on your device’s IP address or similar signals.
Usage information, including the date and time of your visit, the pages you view immediately before and after you access our website, the pages of our website that you visit, form field entries, other use and overall engagement with our website.
Marketing information that may be collected about your interactions with any email you may receive from us (e.g., whether you opened, forwarded, or clicked through to our websites).

Cookies and Similar Technologies:

“Cookies” are text files that are stored by your browser and may be used for website functionality, analytics, and advertising. Other technologies, such as pixels, tags, and scripts, perform similar functions. Providers of cookies and similar technologies (“Tools”) may create or store identifiers that are associated with you or your device and combine the data collected from our website with data they have collected from other sources. You can limit our use of some of these technologies. Please access the Cookies Policy link on the website and see the “Your Privacy Choices and Rights” section below for further information.

We use the following types of Tools:

Strictly necessary: Tools that are essential to enable you to use our website and provide some of its basic functionality.
Performance: Tools that collect information about how visitors use our website so that we can improve its performance.
Functionality: Tools that store your preferences to provide a more personalized experience on our website.
Targeting/advertising: Tools that are usually set by our advertising partners, which may use the personal data that they collect to build a profile of your interests and display targeted ads on other websites or mobile apps. We sell or share personal data to the vendors that provide Tools in this category.

Our Use of Analytics Tools and Advertising Technologies: Our website may use analytics tools, such as Google Analytics, to collect personal data from you for purposes of remarketing, impression reporting, and demographic and interest reporting. This information includes (1) user demographics and information; (2) technical/device data; (3) traffic sources; (4) engagement and event data; and (5) session and conversion metrics. The owners of these analytics tools may combine this data with other data that they have collected about you through their advertising cookies or other technologies. You can opt-out of the use of these tools and technologies through the Manage Cookies link on the website.

HOW WE DISCLOSE YOUR PERSONAL DATA

We may disclose each category of your personal data to the following categories of recipients:

Processors, which provide business, professional, or technical support services We require our processors to use your personal data solely to provide services to us.
Advertising companies, which help us to tailor your experience and share information with you about goods and services you might actually want, rather than random or irrelevant content.
Analytics companies, which help us to not only analyze performance data and identify and implement improvements to enhance your experience and increase efficiency, but may also provide specialized security services to assist us with fraud detection and user authentication.

In certain circumstances, we may disclose each category of your personal data to:

Competent governmental, regulatory, and public authorities in response to lawful requests for information.
Relevant third parties as part of a corporate transaction, such our advisors and other third parties that require access to personal data in connection with a reorganization, merger, sale, joint venture, assignment, transfer, or other transaction involving our business or its assets (including in connection with a bankruptcy or similar proceeding).
Other third parties either (1) at your direction or with your consent; or (2) that we believe necessary or appropriate to (a) comply with applicable law; (b) enforce our terms and conditions; (c) protect our operations; (d) protect our rights, privacy, safety, or property or those of others; and (e) allow us to pursue available remedies or limit damages to our business.

We may create deidentified, anonymized, or aggregated data from personal data. Such data cannot reasonably be associated with you or your device and is not considered personal data, and we may use or disclose it for any purpose.

YOUR PRIVACY CHOICES AND RIGHTS

A. Privacy Rights and Requests

You may exercise the following rights in connection with personal data that we collect about you under this Privacy Policy. You may request to:

Access your personal data (including a copy in a portable format) by requesting a privacy report detailing the personal data we maintain about you and the purposes for doing so, unless your request proves impossible or would involve disproportionate effort to fulfill. Under certain conditions, you may request that we transfer your personal data to another organization, or directly to you, but we may not be required to respond to your requests “to know” or access specific pieces of personal data more than twice in any 12-month period.
Obtain a list of categories of third parties to which we have disclosed your personal data.
Obtain a list of specific third parties with which we have shared or sold your personal data.
Correct or rectify inaccurate personal data that we maintain about you, subject to appropriate verification.
Delete or erase the personal data that we maintain about you, subject to certain limitations.
Restrict or limit processing of the personal data that we maintain about you, under certain conditions.
Object to processing the personal data that we maintain about you based on our legitimate interest, under certain conditions, in which case we will no longer process your personal data unless we can demonstrate compelling legitimate grounds that override your interests, or to establish, exercise, or defend legal claims.
Opt out of sales, sharing, or targeted advertising (as defined by applicable law) by accessing the Manage Cookies link on the website.
Withdraw consent at any time where we rely on consent as the legal basis, with effect for the future, by sending us a written withdrawal consent via the details in the “How to Contact Us” section below.
Appeal a decision made by us or lodge a complaint in the event of a suspected violation of applicable data protection laws, whether directed to us or a supervisory authority.

We do not engage in automated processing or profiling that results in legal affects concerning you as an individual.

You may make a request to exercise any of these rights by emailing us at privacy@csw.com. Once we confirm your identity (if permitted by applicable law), we will work to respond to your request promptly and let you know if we need additional time.

We may decline a request (other than an opt-out request) if we are unable to confirm your identity (or an agent’s authority to make the request) or confirm that the personal data we maintain relates to you.

We will not discriminate against you if you decide to exercise your privacy rights.

If you believe there has been a violation of your privacy rights, please contact us or the appropriate supervisory authority.

B. Agent Requests

If you are a US resident, you may have the right to authorize someone to make a privacy rights request on your behalf (an authorized agent). Authorized agents will need to demonstrate that you have authorized them to act on your behalf. Except when an authorized agent is making an opt-out request, we retain the right to request confirmation directly from you confirming that the agent is authorized to make such a request, or to request additional information to confirm the agent’s identity.

C. Opt-Out Requests

You may request to opt out of the sale or sharing of your personal data, or of targeted advertising, at any time by clicking the Manage Cookies link on the website. You do not need an account with us to make an opt-out request.

Alternatively, you can use a browser-based opt-out preference signal based on the GPC standard. We will apply your GPC-based opt-out to the sale or sharing of personal data linked to that browser and any individual profile we have associated with that browser. You will need to enable the signal on each browser or profile.

D. Right to Appeal

Depending on your place of residence, you may have the right to appeal a decision we have made in connection with your privacy rights request. To appeal a decision, please contact us at privacy@csw.com.

E. Unsubscribing from our Marketing and Promotional Communications

From time to time, we may send you marketing and promotional communications that are relevant to our business. You may opt out of receiving these kinds of messages at any time by following the opt-out instructions included in any promotional or marketing email you receive from us.

LEGAL BASES FOR PROCESSING PERSONAL DATA

Please refer to the table below for information related to the legal bases for which your personal data may be processed, including for how long such data will be retained.

Swipe across the below table to reveal additional columns.

Personal Data Categories	Processing Purposes	Legal Basis of Processing	Storage Period or Standard
IP address; user agent string (identifying operating system and browser type and version); time and date of website visits and page views	Website functionality and security	Legitimate interests (GDPR art. 6(1)(f)) in providing, monitoring, and improving service functionality and security	Stored for as long as reasonably necessary for purposes of website operation and security
Name, postal and email address, phone number	Account administration, including securing and communicating with you about your account Marketing	Legitimate interests and performance of contract (GDPR art. 6(1)(b)) for account administration Your consent (GDPR art. 6(1)(a)) for marketing	Stored until you delete your account or request the deletion of your personal data, subject to exceptions under applicable law
Non-precise geolocation data	Website functionality and security	Legitimate interests	Stored for as long as reasonably necessary for purposes of website operation and security
Internet or other electronic network activity information, including the website pages that you view and the dates and times of your website visits	Website functionality and security Analytics Advertising	Legitimate interest (for website functionality and security) Your consent (for analytics and advertising)	Stored for as long as reasonably necessary for purposes of website operation and security
Commercial information, such as the products that you purchase may be interested in obtaining from us	Fulfilling your orders and requests for information	Your consent and performance of a contract	Stored for the duration of the commercial relationship or for as long as reasonably necessary for legal or accounting purposes
Professional or employment-related information, such as your employer and job title	Fulfilling your orders and requests for information	Your consent and performance of a contract	Stored for the duration of the professional or employment relationship or for as long as reasonably necessary for legal purposes
Inferences based on other personal data that we collect about you	Marketing	Your consent	Stored until you delete your account or request the deletion of your personal data, subject to exceptions under applicable law

EXTERNAL LINKS

Our website may link to third-party sites, which may have privacy policies that differ from our own. We are not responsible for the practices of such sites.

CHILDREN’S PRIVACY

We do not direct our goods and services to individuals under age 18, nor do we knowingly solicit or collect any personal data from minors.

DATA SECURITY

We have implemented physical, administrative, and technical safeguards to maintain the security, confidentiality, and integrity of your information. However, as no transmission of information over the internet is absolutely secure, we cannot guarantee the safety of your personal data.

INTERNATIONAL TRANSFERS

CSW is a global business. We or our processors may transfer personal data to destinations outside of the EEA or UK, including the US. In some of these locations, data protection laws may be less stringent than in the EEA or UK.

Where required by law, we implement an approved data transfer mechanism in place, such as the EU Standard Contractual Clauses. To find out more about how we safeguard your information (including obtaining a copy of such safeguards) in relation to transfers outside the EEA, please contact us via the details in the “How to Contact Us” section below.

REVISIONS TO THIS PRIVACY POLICY

We reserve the right to revise this Privacy Policy at any time. When we do, we will post the revised Privacy Policy. If we change the Privacy Policy in a material way, we will provide appropriate notice to you, such as by posting a temporary banner on our website, sending an email notice to individuals for whom we have an email address, or by temporarily noting “UPDATED” next to the Privacy Policy link on the footer of our website.

HOW TO CONTACT US

If you have any questions or concerns about this Privacy Policy or the practices described herein, you may contact us:

By email:
privacy@csw.com

By mail:
CSW Industrials, Inc.
Attn. Policy Administration
5420 Lyndon B. Johnson Freeway, Suite 500
Dallas, TX 75240