Privacy Policy

Last Updated: March 4, 2022

We at Inolex Inc. (“Inolex”) respect your concerns about privacy. This Privacy Policy describes the types of personal information we collect, how we use the information, with whom we share it, and the rights of and choices available to individuals regarding our use of their information. We also describe the measures we take to protect the security of the information and how you can contact us about our privacy practices and to exercise your rights.

If you reside in the State of California, please see the Privacy Notice for California Residents below to learn more about your privacy rights. To the extent that there is a conflict between this Privacy Policy and the Privacy Notice for California Residents, the Privacy Notice for California Residents will prevail with respect to California Residents (as defined below) only.

A. CONSENT

By accessing or using the services, you consent to this Privacy Policy. If you do not agree with this Privacy Policy, please do not access or use the services. Information gathered through the services may be transferred, used, and stored in the United States or in other countries where our service providers or we are located. If you use the services, you agree to the transfer, use, and storage of your Personal Data (as defined below) in those countries. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. You agree that all transactions relating to the services or Inolex are deemed to occur in the United States, where our servers are located.

B. COLLECTION OF INFORMATION

Your privacy is important to us and we have taken steps to ensure that we do not collect more information from you than is necessary for us to provide you with our services and to protect your “Personal Data,” as explained below:

• Information including first name, last name, company, address, and email address, may be collected at the time you subscribe to our newsletters.
• Information including first name, last name, email, phone, and other information you voluntarily provided when contacting us may be collected if you contact us through this website.
• If you contact our customer service department, we may record your conversation with us and collect additional information to verify your identity.
• From time to time, we collect information about our customers and prospective customers during trade shows, industry events and other functions. The information we may collect at these events includes, but not limits to, first name, last name, address, phone number, fax number and email address.
• When you visit this site, we may collect Personal Data and Non-Personal Data (as defined below) by automated means, such as cookies, web beacons and web server logs. The information we may collect in this manner includes IP address, unique device identifier, browser characteristics, device characteristics, operating system, language preferences, referring URLs, information on actions taken on this site, dates and times of visits to this site and other usage statistics. A “cookie” is a file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon”, also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and is used to transmit information collected through cookies back to a web server. Through these automated collection methods, we may obtain “clickstream data,” which is a log of the links and other content on which a visitor clicks while browsing a website. As the visitor clicks through the website, a record of the action may be collected and stored. We link certain data elements we have collected through automated means, such as your browser information, with other information we have obtained about you to let us know, for example, whether you have opened an email we sent to you. Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. Please note, however, that without cookies you may not be able to use all of the features of this site. To the extent required by applicable law, we will obtain your consent before collecting personal information using cookies or similar automated means.

We also collect non-Personal Data relating to the services, that is, information that does not personally identify an individual (“Non-Personal Data”). The Non-Personal Data we collect includes how you interact with the services, information generally collected or “logged” by Internet websites or Internet services when accessed or used by users, and information about your web browser or device accessing or using the services.

Examples of the Non-Personal Data we collect are:

• The pages of our website that you viewed during a visit;
• What information, content or advertisements you view or interact with using the services;
• Language preferences;
• The city and state in which you are located (but not your precise geographic location); and
• Unique identifiers that are not connected and cannot reasonably be connected to your identity.

We will not use Non-Personal Data to try to identify you, and if we associate any Non-Personal Data with information that personally identifies you, then we will treat it as Personal Data. As discussed in more detail below, we sometimes use cookies and other automatic information gathering technologies to gather Non-Personal Data.

C. USE OF PERSONAL DATA

We collect and use your Personal Data for the following purposes:

• verifying your identity;
• creating and managing online accounts;
• managing our customer and vendor relationships;
• sending promotional materials;
• communicating about employment opportunities;
• communicating about, and administering participation in, special events, promotions, programs, offers, surveys, contests and market research;
• responding to individuals’ inquiries;
• operating, evaluating and improving our business (including developing, analyzing and improving our services; managing our communications; performing data analytics; and performing accounting, auditing and other internal functions);
• protecting against, identifying and seeking to prevent fraud and other unlawful activity, claims and other liabilities;
• complying with and enforcing applicable legal requirements, relevant industry standards, contractual obligations and our policies;
• alerting about product safety issues; and
• personalizing your user experience based on your browsing records, equipment information we collected and your order history; performing research or statistical analysis to improve the content and layout of our website, and to improve our product offerings and services.

We may also use your Personal Data for other purposes that are not incompatible with the purposes we have disclosed to you (such as archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes) if and where this is permitted by applicable data protection laws.

D. INFORMATION WE SHARE

We share the Personal Data and Non-Personal Data we collect from you with vendors and Service Providers who perform services on our behalf based on our instructions. We do not authorize these vendors and Service Providers to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements. By “Service Providers” we mean companies, agents, contractors, service providers, or others engaged to perform functions on our behalf (such as processing of payments, provision of data storage, hosting of our website, marketing of our products and services, and conducting audits). When we use a Service Provider, we require that the Service Provider use and disclose the Personal Data and Non-Personal Data received from us only to provide their services to us or as required by applicable law.

In addition, we may disclose information about you if we are required to do so by law or legal process; to law enforcement authorities or other government officials based on a lawful disclosure request; and when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity. We also reserve the right to transfer personal information we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution or liquidation).

Information collected through third-party plug-ins and widgets on this site (such as information relating to your use of a social media sharing tool) is collected directly by the providers of the plug-ins and widgets. This information is subject to the privacy policies of the providers of the plug-ins and widgets, and Inolex is not responsible for those providers’ information practices.

Lastly, we may also disclose Non-Personal Data, aggregated with information about our other users, to our clients, business partners, merchants, advertisers, investors, potential buyers and other third parties if we deem such disclosure, in our sole discretion, to have sound business reasons or justifications.

E. RIGHTS REGARDING PERSONAL DATA

We offer you the option to personalize certain aspects of the Personal Data we collect about you and how we communicate with you. To update your preferences, ask us to remove your information from our mailing lists, exercise your rights or submit a request, please contact us as indicated in the “how to contact us” section of this Privacy Policy. To the extent provided by the law of your jurisdiction, you may request access to the personal information we maintain about you or request that we correct, amend, delete or block the information by contacting us as indicated below. But, we may need to retain your personal information for legal reasons or for legitimate business purposes. However, we (and you) are not able to control information that you have already shared with other users or made available to third parties through the services. Where provided by law, you may withdraw any consent you previously provided to us or object at any time on legitimate grounds to the processing of your personal information, and we will apply your preferences going forward.

We ask individual users to identify themselves and the information requested to be accessed, corrected, or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, would be extremely impractical (for instance, requests concerning information residing on backups), or relate to information that is not associated with your Personal Data. In any case, where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort.

Please be aware that if you ask us to delete your Personal Data, you may not be able to continue to use the services. Also, even if you request that we delete your Personal Data, we may need to retain certain information for a limited period of time to satisfy our legal, audit and/or dispute resolution requirements.

Visitors from the European Union, you may have additional rights not afforded by the privacy laws of other countries. Your rights are specified below in the section entitled. “Visitors from the European Union”.

If you have any questions regarding this Privacy Policy or if you wish to access or correct your Personal Data, you may send your request to [email protected].

F. COOKIES

Cookies, Beacons, and Clickstream

We use "cookies" to store specific information about you and track your visits to our sites, either through a computer or via a mobile device. A "cookie" is a small amount of data that is sent to your browser and stored on your computer's or mobile device’s hard drive. If you do not de-activate or erase the cookie, each time you use the same browser or mobile device to access our sites our web servers will be notified of your visit to our sites and in turn we may have knowledge of your visit and the pattern of your usage. The cookies will enable us to remember your information so you do not have to re-enter it every time you use the Site. You can determine if and how a cookie will be accepted by configuring the privacy setting of the browser you are using to access our sites or the privacy setting of your mobile device. As the means by which you can refuse cookies through your web browser controls vary from browser-to-browser, you should visit your browser's help menu for more information. If you adjust the privacy setting in the browser, your mobile device will continue collecting data unless you adjust the privacy setting of the device, and vice versa. Certain features of the Site depend on cookies. Please be aware that if you choose to block cookies, you may not be able to sign in or use those features, and preferences that are dependent on cookies may be lost.

We use “web beacon” to be informed of your interaction with our website. A “web beacon,” also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and is used to transmit information collected through cookies back to a web server.

Through cookies and beacons, we may obtain “clickstream data,” which is a log of the links and other content on which a visitor clicks while browsing a website. As the visitor clicks through the website, a record of the action may be collected and stored. We link certain data elements we have collected through automated means, such as your browser information, with other information we have obtained about you to let us know, for example, whether you have opened an email we sent to you. Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. Please note, however, that without cookies you may not be able to use all of the features of this site. To the extent required by applicable law, we will obtain your consent before collecting personal information using cookies or similar automated means.

Google Analytics

Our Sites uses Google Analytics, an internet analytics service provided by Google, Inc., 1600 Amphitheater Parkway Mountain View, California, 94043, USA ("Google"). Google Analytics uses "cookies", which are text files that are stored on your computer and used to analyze the use of our sites. For example, Google's cookies allow us to tell us which pages our users are viewing, which ones are most popular, what time of day our sites are visited, if users have previously visited our Sites, from which website users are redirected to our Sites were and the like. The data generated by the cookie about your use of our sites will be transmitted to Google and stored by Google on servers in the United States. For more information about Google Analytics cookies, visit the Google Help pages and Privacy Policy:

Google Privacy Policy: https://policies.google.com/privacy

Google Analytics Help Center: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage

To opt-out from the use of Google Analytics: http://tools.google.com/dlpage/gaoptout

Third Party Plug-ins

The providers of third-party apps, tools, widgets and plug-ins on our sites, such as social media sharing tools, also may use automated means to collect information regarding your interactions with these features. This information is collected directly by the providers of the features and is subject to the privacy policies or notices of these providers. Subject to applicable law, Inolex is not responsible for these providers’ information practices.

G. MINORS

We do not knowingly collect information about minors (those under the age of 18) and we do not intend to sell any of our products or services to minors. If a minor has provided us with Personal Data accidentally, the parent or guardian should inform us to remove the information by sending a request to [email protected].

H. SECURITY MEASURES

We employ commercially reasonable security methods to prevent unauthorized access to our sites, to maintain data accuracy and to ensure the correct use of the information we hold. We maintain administrative, technical and physical safeguards designed to protect the personal information you provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. However, no data transmission over the Internet and no method of data storage can be guaranteed to be 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its security.

We restrict access to Personal Data in our possession to our employees and Service Providers, who need to know that information in order to operate, develop, improve or support our services. If we share Personal Data with Service Providers, we take reasonable measures to require that they also use reasonable information security measures to safeguard your Personal Data, comply with any applicable laws or regulations with respect to information security.

I. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time in response to changing legal, technical or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Policy changes if and where this is required by applicable data protection laws.

Any changes to this Privacy Policy will be communicated by us posting an amended Privacy Policy on this site. Once posted on this site, the new Privacy Policy will be effective immediately. You can see when this Privacy Policy was last updated by checking the “Last Updated” date displayed at the top of this Privacy Policy.

J. RESIDENTS OF NEVADA OR CANADA

Residents of Canada

If you have an objection to the use of your Personal Data as described in this Privacy Policy, you may file a complaint by sending an email to [email protected]. We will attempt to accommodate your objection or complaint, but you understand that, to the extent you object to our processing of Personal Data that is necessary for us to provide the services to you, certain features and functionalities of the services may no longer be available to you. Nothing in this Privacy Policy prejudices your rights to file a complaint with the Office of the Privacy Commissioner of Canada, and/or with any other applicable data protection authorities.

Residents of Nevada

We do not sell your Personal Data. However, you may contact us at [email protected] with questions.

K. VISITORS FROM THE EUROPEAN UNION

This section of the Privacy Policy applies only if you use this site or services covered by this Privacy Policy from a country that is a Member State of the European Union.

Legal Basis for Data Processing

We process Personal Data for the purposes set out in this Privacy Policy, as described above. Our legal basis to process Personal Data will depend on the Personal Data concerned and the specific context in which we collect it. We normally collect and process Personal Data about you only when necessary for the performance of our business; necessary to comply with legal requirements (for example, to comply with applicable accounting rules and to make mandatory disclosures to law enforcement); necessary for our legitimate interests and not overridden by your rights; and/or where it is based on your consent.

If we collect and use your Personal Data in reliance on our legitimate interests (or those of any third party), this interest will normally be to operate our websites and services, manage our relationship with you and communicate with you as necessary to provide our services to you and for our legitimate commercial interest, for instance, when responding to your queries, improving our websites and our services, undertaking marketing, or for the purposes of ensuring the security of our websites and services and detecting or preventing illegal activities such as fraud. We may have other legitimate interests and if appropriate we will make clear to you at the relevant time what those legitimate interests are.

If we ask you to provide Personal Data to comply with a legal requirement or to enter into a contract with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Data is mandatory or not (as well as of the possible consequences if you do not provide your Personal Data). In some instances, you may be required to provide us with Personal Data for processing as described above, in order for us to be able to provide you all of our services, and for you to use all the features of our sites.

We retain your Personal Data as long as we have an ongoing legitimate business need to do so for example to provide services or products to you, or as required or permitted by applicable laws, such as product safety regulations, tax and accounting laws, etc. When we have no ongoing legitimate business need to process your Personal Data, we will either delete or anonymise it or, if this is not possible (for example, because your Personal Data has been stored in backup archives), then we will securely store your Personal Data and isolate it from any further processing until deletion is possible.

Internal Transfers of Personal Data

Our business may require us to transfer your Personal Data to countries outside of the European Economic Area (“EEA”), including to countries that may not provide the same level of data protection as your home country such as the United States. We take appropriate steps to ensure that recipients of your Personal Data are bound to duties of confidentiality and we implement appropriate measures to ensure your Personal Data will remain protected in accordance with this Privacy Policy.

Your Rights

If you are a resident of the European Economic Area, you have the following data protection rights, which you can exercise at any time by contacting us using the contact details provided under section “how to contact us” below.

• The right to access, correct, update or request deletion of your Personal Data.
• The right to object to processing of your personal information when it is based on our legitimate interests, and separately the right to object to direct marketing.
• The right to ask us, in some situations, to restrict processing of your personal information or request portability of your personal information.
• The right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you.
• If we have collected and process your personal information with your consent, then you have the right to withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
• The right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

L. JOB APPLICANTS

If you have applied for employment with Inolex, the Personal Data submitted with your job application will be used to process and consider your job application. We will not sell the data on your application to unaffiliated third-parties for their marketing purposes. We may share the data on your applications with recruiters, consultants, attorneys, background services and our affiliates. The data on your application may also be used for certain regulatory, compliance and legal purposes, consistent with this Privacy Policy.

To the extent of the Personal Data you provide, you expressly authorize Inolex to handle such details for the purposes of your job application and for the other purposes described herein.

By submitting data to us online, you are sending it to the United States, where it will be subject to the protections afforded under US laws that may be different from the laws in your country and which your country may consider not to provide adequate privacy protections. If you do not agree that your submission of your application data will be governed solely by United States law, Inolex will not accept your application.

M. HOW TO CONTACT US

If you have any requests, questions or concerns about our use of your Personal Data and this Privacy Policy, please contact us at [email protected]. Or write to:

Inolex Inc.

Attention: Privacy Officer

601 Walnut Street, Suite 220

Philadelphia, PA 19106 USA

Privacy Notice for California Residents

This Privacy Notice for California Residents (the “Notice”) supplements the information contained in our Privacy Policy and applies only if you are resident of the State of California (a “California Consumer”).

For purposes of this Notice “Sell,” “Selling,” “Sale,” or “Sold,” means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, Personal Data to another business or a third party for monetary or other valuable consideration.

“Verifiable Request” means that the identifying information provided by a California Consumer in connection with a request matches the personal information of the California Consumer already maintained by us or a third-party verification service. Identifying information you can submit in order to permit Inolex to verify your request may include your name, company name, email address, and phone number.

a) Information We Collect

In the past twelve (12) months, Inolex has collected the following categories of Personal Data from California residents:

• Account Identifiers (first and last name, age, email address, and phone number).
• Usage Information (IP address, unique device identifiers (such as account authentication token and password tokens)).
• Communications with our Customer Service Department – Information about your conversations with our customer service department that we may collect in order to verify your identify.
• Geographic Location (the city and state in which you are located, but not your precise geographic location)
• Customer and Prospective Customer Information – Information about our customers and prospective customers that is collected during trade shows, industry events and other functions (first name, last name, address, phone number, fax number and email address).
• Other information which is not required to use our services but that you choose to provide to us on an online form, or messages that you send through the services.

Inolex obtains this Personal Data directly from you. For example, from forms you complete or products and services that you purchase.]

b) Use of Personal Data

Inolex may use, or disclose the Personal Data we collect for one or more of the following “Business Purpose(s):”

• To fulfill or meet the reason you provided the information
• To provide our website, online services
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations
• To respond to your requests under the California Consumer Privacy Act of 2018 (the “CCPA”)
• For any other purpose described to you when we collect your Personal Data; and
• For any other acceptable purposes as set forth in the CCPA.

Unless we notify you otherwise, we will not collect additional categories of Personal Data, nor use the Personal Data we collect for any other materially different, unrelated, or incompatible purposes.

c) Sharing Personal Data

Within the last twelve (12) months Inolex has disclosed your Personal Data as described in this Notice.

Inolex discloses Personal Data to third parties for a Business Purpose. When we disclose Personal Data for a Business Purpose, we enter into an agreement with the receiving party that describes the purpose for sharing the Personal Data, and that requires the receiving party to keep that Personal Data confidential and not use it for any purpose other than performing the services according to the agreement.

We may disclose your Personal Data with the following categories of third parties: Service Providers, as described in our Privacy Policy.

In the past twelve (12) months, Inolex has not Sold any Personal Data about its California Consumers.

d) Your Rights and Choices

If you are a California Consumer, you may request information about our collection, use, disclosure and Sale of your Personal Data over the past twelve (12) months, whether or not it was collected electronically. If you submit a Verifiable Request, we will disclose:

• the categories of Personal Data we have collected about you; the categories of sources from which your Personal Data was collected; our business or commercial purpose for collecting or Selling your Personal Data; the categories of third parties with whom we share that Personal Data; and the specific pieces of Personal Data we collected about you; and
• if we Sold or disclosed your Personal Data for a Business Purpose: what categories of Personal Data we Sold, and to which categories of recipients we Sold it to; and what categories of Personal Data we disclosed for a Business Purpose, and to which categories of recipients we disclosed it to.

You also have the right to request that we delete any of your Personal Data that we collect or maintain by submitting a Verifiable Request. We may deny your deletion request if retaining your Personal Data is necessary for us or our service providers to:

• Complete the transaction for which we collected your Personal Data, provide goods or services that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
• Debug products to identify and repair errors that impair existing intended functionality;
• Exercise free speech, ensure the right of another consumer to exercise their right of free speech, or exercise another right provided for by law;
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.);
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the achievement of such research, if you previously provided informed consent;
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
• Comply with a legal obligation; or
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

If you choose to exercise a privacy right under the CCPA, you have the right not to receive discriminatory treatment.

You may submit a Verifiable Request for the information listed above, or exercise any of your rights enumerated under this Notice, by emailing us at [email protected], or by calling us at 1-800-521-9891, or by completing a form on our website at https://inolex.com/contact. You may also submit a Verifiable Request on behalf of your minor child.

After we receive your Verifiable Request, we will provide to you, in writing and free of charge (unless your request is excessive, repetitive, or manifestly unfounded), the requested information for the twelve (12)-month period preceding your request. You can choose to have this information delivered to you by postal mail or electronically. We will try to respond to your verified request within forty-five (45) days of receipt, but if we require more time (up to another forty-five (45) days) we will inform you of the reason and extension period in writing. Please note that we are not required to comply with your request for information more than twice each year. If applicable, our response will explain the reasons why we cannot comply with your request.

Inolex does not and will not, without first obtaining your consent, Sell Personal Data.

Should you choose to exercise any of the rights enumerated under this Notice, we will not:

• Deny you goods or services;
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
• Provide you a different level or quality of goods or services; or
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, please be aware that it may be a functional necessity for our services to have Personal Data about you in order to operate, and we may not be able to provide some or all of our services to you if you direct us to delete your Personal Data.