1. Introduction

1.1. Purpose of the Policy

This Privacy Policy is established to inform you of our practices concerning the collection, use, and protection of personal information provided by users of our website, https://www.hplubricants.com. The guidelines within this document are crafted with diligence to ensure transparency, accountability, and compliance with applicable privacy laws, including but not limited to, the General Data Protection Regulation (GDPR) and U.S. federal and state laws.

1.2. Scope and Applicability

This policy applies to all information collected through our website and any related services, sales, marketing, or events. It is crucial for users to understand what data we collect, how it is used, and under what circumstances, if any, we disclose it.

1.3. Acknowledgment of User Acceptance

By accessing and using our website, you acknowledge that you have read and understood this Privacy Policy. You also agree to the terms and conditions expressed herein. If you do not agree with any part of this policy, you should refrain from using our website. Continued use of our website following the posting of changes to these terms will indicate your acceptance of those changes.

2. Information Collection

2.1. Types of Information Collected

2.1.1. Personal Identifiable Information (PII)

Personal Identifiable Information refers to data that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. This may include, but is not limited to, your name, email address, phone number, and any other details you provide voluntarily through forms on our website for the purpose of downloading documents or requesting bespoke lubricant blends.

2.1.2. Non-Personal Identifiable Information

We collect non-personal information about users whenever they interact with our site. This information may include the browser name, the type of computer, and technical information about users’ means of connection to our sites, such as the operating system and the Internet service providers utilized, along with other similar information.

2.2. Methods of Collection

2.2.1. Directly Provided by Users

Most of the personal information we hold is provided directly by users through our website when signing up for an account, downloading documentation, or initiating requests for services. We ensure that consent is freely given, specific, informed, and unambiguous for the collection of this data.

2.2.2. Automatically Collected Information

Information about your interaction with our site may be automatically collected and stored in log files. This information is used to manage the website, track user movement, analyze trends, and gather demographic information about our user base as a whole. The information collected may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.

2.2.3. Information Collected from Third Parties

We may receive information about you from third parties such as partners or service providers who are involved in delivering the services you have requested. Additionally, we may receive information from marketing partners who provide us with information in the course of joint marketing efforts or demographic profiling.

This data collection is designed to provide services explicitly requested by you and to enhance your experience on our website. We are committed to handling your personal information with high standards of information security.

3. Use of Information

3.1. Providing Requested Services

The information we collect is primarily utilized to deliver the services specifically requested by you. This includes processing your requests for downloading lubricant specifications documents or submitting inquiries for bespoke lubricant blends. We ensure that the personal information provided is used solely for fulfilling the purposes for which it was originally collected.

3.2. Communication and Response to Inquiries

Your contact details are used to communicate with you regarding your account and to respond to your inquiries. This may include sending notifications about changes to our services, security alerts, and support messages. Our goal is to provide you with timely and efficient customer service.

3.3. Improvement of Website and Services

We analyze the information collected to understand user behavior and preferences. This helps us improve the functionality and user experience of our website. It also assists in developing new products and services that meet the needs and expectations of our users. The insights gained are essential for enhancing the quality and usability of our offerings.

3.4. Legal Compliance

We may use your information to comply with applicable laws, regulations, and legal processes as required or permitted by law. This could include using personal information to protect our company’s rights or property, to protect the safety of any person, or to prevent or take action against activities that are, or may be, in breach of our website terms of service or applicable law.

In using your information for the above purposes, we respect and take into consideration your rights and our obligations. We commit to using your personal data in ways that are consistent with your expectations and the trust you have placed in us, always underpinned by legal compliance and transparency.

4. Legal Basis for Processing

4.1. Consent

We rely on your explicit consent as a primary legal basis for processing personal data. Consent is obtained when you voluntarily provide personal information via our website, for instance, when signing up for an account or submitting a request. This consent is specific and informed, affirming that you are aware of the reason your data is being collected and how it will be used.

4.2. Contractual Necessities

If you enter into a contract with us, for example, when requesting bespoke lubricant blends, the processing of personal data is necessary to fulfill the obligations of that contract. This includes any actions required to provide the service you have requested or to respond to your inquiries related to services.

4.3. Legal Obligations

We process your personal data as necessary to comply with legal obligations to which we are subject. This includes regulatory requirements, tax laws, and other legal mandates that require data processing as part of our business operations.

4.4. Legitimate Interests

We process your data on the basis of legitimate interests pursued by our company or by a third party, provided those interests are not overridden by your interests or fundamental rights and freedoms. These legitimate interests include:

  • Enhancing, modifying, personalizing, or otherwise improving our services and communications for the benefit of our customers.
  • Identifying and preventing fraud.
  • Ensuring the security of our network and information.
  • Conducting business analyses to improve the overall performance of the company.

In each case, we maintain a balanced approach to ensure that the processing of your data is necessary for legitimate business purposes while taking into consideration your rights and freedoms. This ensures our processing actions are conducted with fairness and respect for your privacy.

5. Information Sharing and Disclosure

5.1. Third-Party Service Providers

We engage various service providers, contractors, and affiliated organizations to facilitate the operation of our website, to provide the website on our behalf, to perform site-related services, or to assist us in analyzing how our website is used. These third parties have access to your personal information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

5.2. Legal Requirements

High Performance Lubricants, LLC may disclose your personal information in the good faith belief that such action is necessary to:

  • Comply with a legal obligation, such as cooperating with law enforcement in a lawful investigation.
  • Protect and defend the rights or property of High Performance Lubricants, LLC.
  • Prevent or investigate possible wrongdoing in connection with the website.
  • Protect the personal safety of users of the website or the public.
  • Protect against legal liability.

5.3. Business Transfers

In the event that High Performance Lubricants, LLC undergoes a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, your personal information may be among the assets transferred. You will be notified via email and/or a prominent notice on our website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

5.4. With Explicit Consent

Apart from the scenarios outlined above, we will inform you when personal information about you might go to third parties, and you will have an opportunity to choose not to share the information. This ensures that your data is not shared without your explicit consent, maintaining control over your personal information.

This policy of transparency and strict adherence to guidelines ensures that all sharing and disclosure of information are conducted ethically, legally, and with respect for your privacy. We commit to maintaining your trust in every interaction, as we understand the value of your privacy and strive to protect it.

6. Data Subject Rights

6.1. Right to Access

You have the right to request access to the personal information that we hold about you. This enables you to receive a copy of the personal data we have about you and to check that we are lawfully processing it.

6.2. Right to Rectification

You have the right to request that we correct any information you believe is inaccurate. You also have the right to request us to complete the information you believe is incomplete. This ensures that your data remains up-to-date and accurate.

6.3. Right to Erasure

You have the right to request that High Performance Lubricants, LLC erase your personal data, under certain conditions. This is also known as the “right to be forgotten” and can be exercised where there is no good reason for us continuing to process it.

6.4. Right to Restrict Processing

You have the right to request that we restrict the processing of your personal data, under certain conditions. This means that you can request us to suspend the processing of personal information about you, for example, if you want us to establish its accuracy or the reason for processing it.

6.5. Right to Data Portability

You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions. 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.

6.6. Right to Object

You have the right to object to our processing of your personal data, under certain conditions. This includes the right to object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you.

6.7. Rights Related to Automated Decision Making and Profiling

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. This includes ensuring that you have the opportunity to obtain human intervention, to express your point of view, and to contest the decision.

High Performance Lubricants, LLC is committed to upholding these rights and will facilitate your requests in accordance with applicable law. Requests can be directed to our designated Data Protection Officer whose contact details are available under our contact information section. It is our policy to respect your rights fully and to ensure that the protection of your privacy is consistently maintained.

7. Data Security

7.1. Security Measures

High Performance Lubricants, LLC is committed to ensuring the security of your personal data. We have implemented appropriate technical and organizational measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. Among these measures are encryption, firewalls, and secure server facilities. Our security policies are regularly reviewed and enhanced as necessary and only authorized personnel have access to personal data.

7.2. Data Breach Notification Procedures

In the event of a data breach that is likely to result in a risk to the rights and freedoms of individuals, we will notify the appropriate authorities without undue delay and, where feasible, within 72 hours of becoming aware of it, as required by law. Affected individuals will also be notified as soon as possible if the data breach is likely to result in a high risk to their rights and freedoms. Our notification will include all necessary information to understand the nature of the breach and the steps we are taking to deal with the situation.

7.3. Employee and Contractor Access Controls

Access to personal data is strictly limited to personnel and contractors who need access to perform their job functions. We ensure that our employees and contractors are aware of and follow our data security policies and procedures. Training on data protection and information security is provided to these individuals, and we require confidentiality agreements as part of their employment or contractual obligations.

Through these comprehensive data security practices, High Performance Lubricants, LLC aims to protect personal data against unauthorized or unlawful processing and against accidental loss, destruction, or damage, thereby providing a robust defense of such sensitive information.

8. Data Retention

8.1. Retention Period

High Performance Lubricants, LLC retains personal data only for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. The retention period for each category of personal data varies depending on the nature of the information and the reasons for its collection. Our retention policies reflect applicable laws and regulations that dictate the minimum and maximum periods for retaining personal data.

8.2. Criteria for Retention

We determine the appropriate retention period for personal data based on the amount, nature, and sensitivity of the data, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process the personal data, and whether we can achieve those purposes through other means. Additionally, applicable legal, tax, and regulatory requirements are considered in determining the retention periods.

8.3. Secure Disposal of Data

Once the retention period has expired, personal data is securely deleted or destroyed in accordance with our data disposal policy. This ensures that the information is disposed of in a manner that protects the privacy of the data subjects. We employ secure methods of disposal to prevent unauthorized parties from gaining access to the data during and after the process of deletion.

By adhering to these data retention guidelines, High Performance Lubricants, LLC ensures that personal data is not kept longer than necessary and that it is disposed of securely, thereby minimizing potential risks associated with data retention and disposal.

9. International Data Transfers

9.1. Transfer Mechanisms

High Performance Lubricants, LLC recognizes that it operates in a global environment and that it may be necessary to transfer personal data across international borders. When transferring personal data outside of the United States, particularly to countries not recognized by the European Commission as providing an adequate level of data protection, we implement appropriate safeguards. These safeguards may include standard contractual clauses approved by the European Commission, binding corporate rules, or reliance on certification mechanisms such as the Privacy Shield framework.

9.2. Safeguards

To ensure that your personal data receives an adequate level of protection, High Performance Lubricants, LLC employs the following measures:

  • Assessing the privacy laws and practices of the destination country prior to initiating any transfer, to ensure they meet the standards required by European Union law and other relevant regulations.
  • Implementing stringent contractual obligations with any third-party recipients that mandate the same level of data protection that the data would receive in the European Union.
  • Regularly reviewing the policies and practices of our data processing vendors and partners to ensure ongoing compliance with our data transfer policies.

These measures are designed to protect your personal data from unauthorized access or processing and to ensure that the rights of data subjects are not compromised by the transfer of data across borders. High Performance Lubricants, LLC is committed to maintaining the security and integrity of personal data, regardless of where the data resides.

10. Third-Party Websites and Services

10.1. Links to Other Websites

The website of High Performance Lubricants, LLC may contain links to third-party websites that are not operated or controlled by us. These links are provided for your convenience and do not signify our endorsement of such third-party websites or their content. We are not responsible for the privacy practices or the content of these third-party websites. We strongly advise you to review the Privacy Policy of every site you visit. Our Privacy Policy applies solely to information collected by our website.

10.2. Interactions with Third-Party Services

In the course of providing services and enhancing our business operations, we may interact with a variety of third-party service providers, such as payment processors, analytics providers, and technology services partners. While we choose our service providers carefully and only share with them the minimum information necessary to perform their services, their processing of your information is governed by their own privacy policies. It is our policy to engage with third-party service providers that maintain a comparable level of data protection that complies with industry standards and applicable laws.

High Performance Lubricants, LLC remains committed to protecting your privacy when you use our website. However, when you interact with third parties through our site, it is important to understand that you are sharing your information with those third parties under their respective privacy policies. We encourage you to be vigilant and to review the privacy statements of any third-party provider with which you interact through our website.

11. Children’s Privacy

11.1. Age Limitations

High Performance Lubricants, LLC recognizes the importance of protecting the privacy and safety of children. Our website and services are not directed towards children under the age of 16 years. We do not knowingly collect personal information from children under 16. If a parent or guardian becomes aware that his or her child has provided us with personal information without their consent, we urge them to contact us. If we become aware that a child under 16 has provided us with personal information, we will take steps to delete such information from our servers immediately.

11.2. Parental Consent and Rights

In instances where we may collect personal information from children under the age of 16, we will do so only with the requisite parental consent or as allowed by law. Parents or guardians who believe that their child has provided us with personal information and wish to have it removed may contact our designated privacy officer. Additionally, parents or guardians have the right to request access to the personal information of their child, can request corrections to any inaccuracies in that information, and can request the cessation of further collection or use of their child’s personal information.

High Performance Lubricants, LLC is committed to complying with applicable laws and regulations concerning the collection and use of personal information from children, including the Children’s Online Privacy Protection Act (COPPA) in the United States and similar laws in other jurisdictions. We undertake to provide necessary protections and to conduct any data processing activity involving children’s information with the utmost care and responsibility.

12. Updates and Changes to the Privacy Policy

12.1. Notification of Changes

High Performance Lubricants, LLC reserves the right to update or modify this Privacy Policy at any time and from time to time without prior notice. However, we will notify you of any significant changes to our Privacy Policy by posting a notice on our website’s homepage and/or sending an email to the email address provided by you. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting the personal information we collect. Your continued use of the website constitutes your agreement to this Privacy Policy and any updates.

12.2. Review and Compliance

We are committed to continuously reviewing and updating our policies and procedures to comply with applicable laws and regulations. This ongoing process helps ensure that our Privacy Policy adheres to new legal requirements and aligns with best practices in data protection. This review process also involves assessing newly implemented technologies and methods in data processing and security to enhance the protection and management of user information.

By maintaining this approach, High Performance Lubricants, LLC ensures that our Privacy Policy is not only compliant with current laws but also robust and effective in safeguarding your personal information against emerging threats and challenges.

13. Contact Information

13.1. Data Protection Officer Contact

High Performance Lubricants, LLC has appointed a Data Protection Officer (DPO) to oversee compliance with this Privacy Policy and applicable data protection laws. If you have any questions or concerns about our privacy practices or handling of your personal information, please contact our DPO via the following details:

  • Email: [email protected]
  • Phone: +1 815-907-7801
  • Mailing Address:
    Attn: Data Protection Officer
    High Performance Lubricants, LLC
    500 S. Spruce Street
    Manteno, IL 60950
    USA

13.2. Contact Details for Privacy Concerns or Complaints

Should you have any concerns regarding the privacy or handling of your personal data, or if you wish to exercise any of your rights as described in our Privacy Policy, please reach out to us through the contact details provided above. We are committed to resolving any issues concerning your privacy promptly and transparently.

Our goal is to ensure your trust in our privacy practices and our ability to protect your personal information. High Performance Lubricants, LLC values your feedback and aims to address your concerns diligently.

14. Governing Law and Jurisdiction

14.1. Applicable Law

This Privacy Policy shall be governed by and construed in accordance with the laws of the State of Illinois, without regard to its conflict of law provisions. By using this website, you agree that the laws of Illinois will govern any dispute of any sort that might arise between you and High Performance Lubricants, LLC regarding your use of this website and the collection and use of your personal information.

14.2. Jurisdictional Considerations

Any disputes arising under or in connection with this Privacy Policy shall be subject to the exclusive jurisdiction of the state and federal courts located in Kankakee County, Illinois. By using this website, you consent to the jurisdiction and venue of such courts in any such dispute.

This section ensures that both parties are aware of the legal framework within which our Privacy Policy operates. It specifies the governing law that will apply to the terms of the policy and the handling of any disputes, providing clarity and predictability for both High Performance Lubricants, LLC and our users.

15. Cookie Policy

15.1. Use of Cookies

High Performance Lubricants, LLC utilizes cookies and similar tracking technologies to enhance user experience and improve the functionality of our website. Cookies are small text files placed on your device to collect standard internet log information and visitor behavior information. The information provided by cookies helps us analyze web traffic or lets you know when you visit a particular site.

15.2. Types of Cookies Used

We use various types of cookies on our website, including:

  • Essential Cookies: These are necessary for the website to function properly. They enable you to move around the website and use its features. Without these cookies, services that you have asked for, like secure login areas, cannot be provided.
  • Performance Cookies: These cookies collect information about how visitors use a website, for instance, which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor; all information these cookies collect is aggregated and therefore anonymous. It is only used to improve how a website works.
  • Functionality Cookies: These are used to recognize you when you return to our website. They enable the personalization of content, greet you by name, and remember your preferences (for example, your choice of language or region).
  • Advertising Cookies: These cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign.

15.3. Managing Cookies Preferences

You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website. Instructions for managing your cookies settings are typically found within the ‘Help’, ‘Tools’, or ‘Edit’ menus in browsers.

Our Cookie Policy is designed to help you understand the use of cookies on our website. The implementation of this policy ensures that users are informed about their data and have the control to manage their privacy. For more detailed information on how we use, store, and keep your personal data secure, refer to our Privacy Policy.

16. GDPR Specific Provisions

16.1. Scope and Applicability

High Performance Lubricants, LLC acknowledges that the General Data Protection Regulation (GDPR) imposes rigorous standards for data protection for individuals within the European Union (EU). We are committed to ensuring compliance with the GDPR for all data we collect from individuals residing in the EU.

16.2. Principles of Data Processing

Under GDPR, our data processing activities adhere to the following principles:

  • Lawfulness, Fairness, and Transparency: Processing of personal data must be lawful, fair, and transparent to the data subject.
  • Purpose Limitation: Data is collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes.
  • Data Minimization: We ensure that the personal data collected is adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed.
  • Accuracy: Personal data must be accurate and, where necessary, kept up to date.
  • Storage Limitation: Personal data is kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed.
  • Integrity and Confidentiality: Processing is done in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage.

16.3. Data Subject Rights under the GDPR

We provide robust rights to individuals in accordance with GDPR, including:

  • Right to Access: Data subjects have the right to access their personal data.
  • Right to Rectification: Individuals have the right to have inaccurate personal data corrected.
  • Right to Erasure: Also known as the ‘right to be forgotten,’ allowing data subjects to have their data erased.
  • Right to Restrict Processing: Data subjects can request the restriction of processing of their personal data.
  • Right to Data Portability: Individuals can request the transfer of their data to another organization.
  • Right to Object: Data subjects can object to the processing of their personal data.
  • Rights Related to Automated Decision Making and Profiling: Individuals have the right not to be subject to decisions based solely on automated processing.

16.4. Data Protection Officer (DPO)

We have designated a Data Protection Officer (DPO) to oversee compliance with GDPR requirements. The DPO is responsible for educating the company and its employees about compliance, training staff involved in data processing, and conducting audits to ensure alignment with GDPR.

16.5. Data Breach Notification

In accordance with GDPR, we will notify the relevant supervisory authority within 72 hours of becoming aware of a data breach where it is likely to result in a risk to the rights and freedoms of individuals. Affected individuals will be notified without undue delay if the breach could result in a high risk to their rights and freedoms.

Through these provisions, High Performance Lubricants, LLC demonstrates its commitment to data protection and to the rights of individuals under GDPR, ensuring compliance across all operations involving the handling of personal data from the European Union.