This Policy applies to all Personal Information received by WPMRS in any format including electronic, paper or verbal. WPMRS collects, stores and processes Personal Information concerning current and former employees, as well as applicants for employment through its Internet websites, its intranet site, electronic mail and manually. WPMRS will not sell or share this information with third parties in ways different than what is disclosed in this Policy. On a global basis, WPMRS will establish and maintain business procedures that are consistent with this Policy. Notwithstanding the foregoing, WPMRS has separate policies governing the processing of employee personal data and external personal data in those countries that are members of the EU. These policies are consistent with EU data protection law.
WPMRS collects, stores, and processes Personal Information from prospective customers, vendors, professional advisers and consultants, distributors, dealers, suppliers, business partners and others, such as name, contact and financial information. This information may be maintained at its offices in Lake Geneva, Wisconsin or at other WPMRS facilities, and its authorized agents, consistent with local legislation. WPMRS collects this Personal Information for, among other things, legitimate business reasons such as processing and fulfilling orders; customer service; the provision of services or products to WPMRS, product, warranty and claims administration; meeting governmental reporting and records requirements; maintenance of accurate accounts payable and receivable records; marketing; internal marketing research; safety and performance management; financial and sales data; and contact information. All Personal Information collected by WPMRS will be used for legitimate business purposes consistent with this Policy.
WPMRS may process and disclose Personal Information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which an WPMRS business is acquired by or merged with another business, or sells, liquidates, or transfers all or a portion of its assets.
WPMRS also may process or disclose Personal Information as is reasonably necessary or legally required on important public interest grounds, to respond to lawful requests by public authorities (including to meet national security or law enforcement requests), to meet governmental reporting or records requirements, or for the establishment, exercise or defense of legal claims by WPMRS or other companies within its corporate group.
For purposes of this Policy, the following definitions shall apply:
“Agent” means any third party that processes Personal Information provided by WPMRS to perform tasks on behalf of or at the instruction of WPMRS.
“WPMRS” means Wisconsin Precious Metals Refining Services.
“Personal Information” means any information or set of information that identifies or could be used by or on behalf of WPMRS to identify an individual. Personal Information does not include information that is encoded or anonymized, or publicly available information that has not been combined with non-public Personal Information.
“Sensitive Personal Information” means Personal Information that reveals race, ethnic origin, trade union membership, political opinions, or religious or philosophical beliefs, that concerns health or sex life, or that contains criminal records. In addition, WPMRS will treat as Sensitive Personal Information any Personal Information received from a third party where that third party treats and identifies the Personal Information as sensitive.
WPMRS commits to subject the Personal Information covered by this policy to the following principles:
For Sensitive Personal Information, WPMRS will give individuals the opportunity to affirmatively and explicitly consent (opt-in) to the disclosure of the information to a non-Agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.
WPMRS will provide individuals with reasonable mechanisms to exercise their choices should requisite circumstances arise.
Any questions or concerns regarding the use or disclosure of Personal Information should be directed to the WPMRS Data Protection Point of Contact via the contact information below. WPMRS will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Information in accordance with the principles contained in this Policy and as required by law.
WPMRS sees the Internet and the use of other technologies as valuable tools for communicating and interacting with consumers, employees, vendors, business partners and others. WPMRS recognizes the importance of maintaining the privacy of Personal Information collected through websites that it operates. WPMRS’s purpose for operating its websites is to provide information concerning products and services to the public. In general, visitors can reach WPMRS on the Web without revealing any Personal Information. Visitors on the Web may elect to voluntarily provide Personal Information via WPMRS websites but are not required to do so. WPMRS collects information from visitors to the websites who voluntarily provide Personal Information by filling out and submitting online questionnaires concerning feedback on the website, requesting information on products or services, or seeking employment. The Personal Information voluntarily provided by website users is contact information such as the user’s name, home and/or business address, phone numbers and email address. WPMRS collects this information so it may answer questions and forward requested information. WPMRS does not sell this information.
WPMRS may also collect anonymous information concerning website users through the use of “cookies” in order to provide better customer service. “Cookies” are small files that websites place on users’ computers to identify the user and enhance the website experience.
Company personnel periodically audit WPMRS’s commercial websites to determine what cookies are used on each. The cookies used are typically not intrusive and are not typically connected to visitors’ contact or other identifiable information. Visitors may set their browsers to provide notice before they receive a cookie, giving the opportunity to decide whether to accept the cookie. Visitors can also set their browsers to turn off cookies. Visitors can learn how to control or delete cookies used on WPMRS’s websites by visiting http://www.aboutcookies.org for detailed guidance. If visitors do suppress the website cookies, however, some areas of WPMRS websites may not function properly.
The list below describes the cookies used on www.wpmrs-refining.com.
Google Analytics – we use this to understand how the site is being used in order to improve the user experience. User data is not linked to any of your contact information.
You can find out more about Google’s position on privacy as regards its analytics service at https://support.google.com/analytics/answer/6004245?hl=en
WPMRS’s website is not directed toward children. Nevertheless, WPMRS is committed to complying with applicable laws and requirements, such as the United States’ Children’s Online Privacy Protection Act (“COPPA”).
WPMRS website users have the option to request that WPMRS not use information previously provided, correct information previously provided, or remove information previously provided to WPMRS. Those that would like to correct or suppress information they have provided to WPMRS should forward such inquiries to:
647 Main St. Suite 200B
Lake Geneva, WI 53147