Privacy Policy

Updated: May 29, 2019

1. Purpose of this statement

This privacy statement (this Statement) explains how and why JAM Industries USA, LLC (JAM) and certain of its subsidiaries (each, a division of JAM Industries USA, LLC) process personal information (called Personal Data under applicable data protection law and in this Statement) that we collect from or that are provided to us by people and organizations with whom we have contact as part of our business activities, including through our main website, www.jamindustries.com (our Main Website) and our subsidiaries’ websites (links are located at the bottom of our home page).

This Statement does not cover how the principal subsidiaries and joint ventures of JAM process Personal Data. Where relevant, those JAM Industries USA, LLC Companies and joint ventures will issue separate statements on how they process Personal Data.

2. Who we are:

JAM Industries USA, LLC is located at 310 West Newberry Rd, Bloomfield, CT 06002. JAM is the controller of and is responsible for your Personal Data. Consistent with our core values of Integrity and Partnership, we are committed to protecting and using fairly any Personal Data that we hold.

3. Terms we use in this Statement

This section explains three terms that we use in the rest of this Statement.

  • Legitimate Interests means the interests of JAM and JAM Industries USA, LLC Companies in conducting their business activities. When we process your Personal Data based on our Legitimate Interests, we consider and balance any potential impact on you and your data protection rights. We will 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 by law. You have certain rights when we process your Personal Data on this basis. For more on your data subject rights please see section 8 of this Statement.
  • Performance of a Contract means processing your Personal Data where it is necessary for the performance of a contract to which you or an organization with which you are connected is a party.
  • Comply with Legal Obligations means processing your Personal Data where it is necessary for compliance with a legal or regulatory obligation that applies to JAM or a JAM Industries USA, LLC Company.

4. When do we process Personal Data?

We may process your Personal Data:

  • If you visit our Websites. Please see section 4.1 of this Statement for more on this.
  • If you are a prospective, current or former employee of JAM. Please see section 4.2 of this Statement for more on this.
  • If we deal with you, or an organization with which you are connected, in the course of our business activities. Please see section 4.4 of this Statement for more on this.

4.1. If you visit our Websites

4.1.1. What Personal Data do we process about visitors to our Websites?

We process Personal Data about visitors to our Websites. This may include:

  • The name of the domain and host from which you access the internet.
  • The internet protocol (IP) address of the computer you are using.
  • The browser software you are using.
  • The operating system you are using.
  • The date and time at which you access our Websites.

JAM and JAM Industries USA, LLC Companies will also collect and process information about your interaction with our Websites using cookies. For more information on how we use cookies, please see section 10 of this Statement or see our full cookie notice here.

4.1.2. What is the legal basis for this processing?

We rely on the following legal grounds for this processing:

Legitimate Interests, for example:

  • Providing access to our Websites and enabling their use.
  • Protecting the security and integrity of our Websites, IT systems and other systems.
  • Providing, improving, monitoring and testing the effectiveness of our Websites.
  • Ensuring the content on our Websites is presented in an effective, accessible and user-friendly format.
  • Monitoring metrics such as numbers of visitors, traffic data and demographic patterns.

4.1.3. When do we share your Personal Data?

We may disclose some or all of the Personal Data we collect from you to certain trusted third parties, in accordance with contractual arrangements we have in place with them, including:

  • IT service providers.

4.2. If you are a prospective, current or former employee of certain JAM Companies

4.2.1. What Personal Data do we process about prospective, current or former employees of JAM Companies?

We process Personal Data about prospective, current and former employees of certain JAM Companies. This may include:

  • Name.
  • Qualifications and career history.
  • Contact information such as home addresses and who to contact in an emergency involving existing employees.
  • Special category Personal Data, for example on illness, disability or dietary requirements.

4.2.2. What is the legal basis for this processing?

We rely on the following legal grounds for this processing:

Legitimate Interests, for example:

  • Considering applications for employment in JAM.
  • Supporting existing employees in the development of their careers.

Performance of a Contract, for example:
Paying salaries and other employment benefits.

Comply with Legal Obligations, for example:

  • Paying taxes.
  • Meeting health and safety obligations.

Consent, where we process special category Personal Data, for example on illness, disability or dietary requirements.

4.2.3. How do we share your Personal Data?

We may disclose some or all of the Personal Data we collect from you to certain trusted third parties in accordance with contractual arrangements we have in place with them, including:

  • Suppliers and service providers to whom we outsource certain employment services, including recruitment consultants, payroll providers, retirement advisors and insurance brokers and providers.
  • IT service providers.

4.3.3. How do we share your Personal Data?

We may disclose some or all of the Personal Data we collect from you to certain trusted third parties in accordance with contractual arrangements we have in place with them, including:

  • Suppliers and service providers to whom we outsource relevant services.
  • IT service providers.

4.4. If we deal with you, or an organization with which you are connected, in the course of our business activities

4.4.1. What Personal Data do we process if we deal with you, or an organization with which you are connected, in the course of our business activities?

We process Personal Data about people we deal with in the course of our business activities. This may include:

  • Name.
  • Employer.
  • Role or job title.
  • Contact details, including address, email address and phone number.
  • Details of visits to JAM and correspondence, communications and connections with our employees.
  • Special category Personal Data, for example on disability or dietary requirements in connection with meetings at our premises.
    Publicly-available information.
    Information which is provided to us by you or by an organization with which you are connected.

4.4.2. What is the legal basis for this processing?

We rely on the following legal grounds for this processing:

Legitimate Interests, for example:

  • Entering into a contractual relationship with the organization with which you are connected.
  • Managing and administering your or your organization’s business relationship with us.
  • Carrying out due diligence.

Performance of a Contract, for example:

  • Executing the purchase of a new business.

Comply with Legal Obligations, for example:

  • Meeting health and safety obligations.

Consent, where we process special category Personal Data, for example:

  • Where visitors to our premises advise us of special dietary requirements.

4.4.3. How do we share your Personal Data?

We may disclose some or all of the Personal Data we collect from you to certain trusted third parties in accordance with contractual arrangements we have in place with them, including:

  • Suppliers and service providers to whom we outsource support services.
  • IT service providers.

5. Personal Data that you provide to us

It is your responsibility to ensure that all Personal Data you provide to us are complete, accurate, up-to-date, and not misleading.

You may provide Personal Data to us about yourself or about other people. If you provide us with Personal Data about another person, you must ensure that you are entitled to disclose the Personal Data of that other person to us and that we may process that Personal Data in accordance with this Privacy Statement without having to take any further steps. It is your responsibility to ensure that the person concerned is aware of the content of this Privacy Statement.

6. How long do we keep your Personal Data?

We will keep your Personal Data for the longer of the following two periods:

  • Any period required for the Performance of a Contract or to Comply with Legal Obligations.
  • For as long as it is relevant to and useful for the purpose for which they were originally collected.

9. Changes to this Statement

We may amend this Statement on occasion, in whole or part, at our sole discretion. Any changes will be effective immediately. You should check this page from time-to-time and take note of any changes we make, as they will be binding on you. We will include the effective date on each version of this Statement that we issue.

If at any time we decide to use your Personal Data in a manner significantly different from that described in this Statement, or as otherwise disclosed to you at the time they are collected, we will notify you by e-mail or by telephone, and you will have a choice as to whether or not we use your Personal Data in the new manner.

10. Cookies and web beacons

We may collect information about your computer, including, where available, your IP address, operating system and browser type, for system administration and to collate aggregate information about how you browse our Websites. We use Google Analytics on our Websites. Google Analytics uses cookies and web beacons in connection with the services it provides.

Information about your general Internet use may be obtained by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. Web beacons may also be used. These facilitate the transfer of data from our Websites to the Google Analytics website. Cookies and web beacons help us to improve our Websites. They may be used to enable us to:

  • Estimate usage numbers, patterns and related activity.
  • Store information about how you accessed and use our Websites and your preferences, and so allow us to customize our Websites according to your individual interests.
  • Recognize you when you return to our Websites.

Information collected may be transmitted to and stored by Google on servers in the United States. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. You may refuse to accept cookies by activating the relevant setting on your browser. However, if you select this setting you may be unable to access certain parts of our Websites or be unable to avail of some services we provide. Unless you have adjusted your browser setting so that it will refuse cookies, cookies will issue when you log on to our Websites.

See our full cookie notice here.

11. Contact

If you have any questions or concerns, please contact us at:

Washburn/ JAM Industries USA LLC
Attn: Legal
310 West Newberry Road
Bloomfield, CT 06002