Covestro LLC Privacy Notice for California Residents

This Notice for California Residents (“CCPA Notice”) is a supplement to our Privacy Statement and applies to the “personal information,” as such term is defined in the California Consumer Privacy Act of 2018 (“CCPA”), or “sensitive personal information,” as that term is defined in the California Privacy Rights Act (CPRA) of 2020, of natural persons who reside in the State of California (“consumer” or “you”). To the extent of any conflict between this CCPA Notice and any other provision of the Privacy Statement, this CCPA Notice shall control only with respect to California residents and their personal information. If you reside elsewhere, please see the rest of our Privacy Statement in the link above.

Information We Collect About California Residents

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, device or household (“Personal Information”). In particular, we may collect the following Categories of Personal Information from consumers:

Identifiers and Contact Information - A real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, or other similar identifiers.

Sensitive Personal Information - A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some Sensitive Personal Information included in this category may overlap with other categories.

Commercial information - Records of personal property, products or services purchased, obtained or considered, or other purchasing or consuming histories or tendencies.

Internet or other similar network activity - Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

Geolocation data - Physical location or movements.

Professional employment related information - Current or past job history or performance evaluations.

Inferences drawn from other Personal Information - Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Categories of Sources of Personal Information

We obtain the Categories of Personal Information listed above from the following Categories of Sources:

• Directly from Consumer, e.g., forms consumers complete or submissions you make to us on our Website or other websites or platforms controlled by Covestro, provide to us in person at trade shows or other marketing and sales related events, or products and services consumers purchase from us, or any of the above activities through our service providers and vendors.
• Indirectly from Consumer, e.g., from observing consumer actions on our Website and other websites.
  • Consumer Interactions with Website
  • Cookies
  • Social Media Websites
• Business Relationships directly with consumers or with other business partners, such as customers, suppliers, distributors, consultants, sponsorships, trade memberships, etc.
• Information Publicly Available Online, such as government databases, online profiles, social media, and Internet search engines.

Table I sets forth the Categories of Sources for each Category of Personal Information collected:

Use of Personal Information of California Residents

We may use any of the Categories of Personal Information set forth above for one or more of the following Business Purposes:

• to meet requirements imposed by law, including court orders, subpoenas, or compliance with the legal process;
• to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
• as described to a consumer when collecting Personal Information or Sensitive Personal Information; and
• to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about our Website users is among the assets transferred.

In addition to the above, we collect each Category of Personal Information for the Business Purposes as set forth in Table II:

Disclosure of Personal Information of California Residents

Disclosures of Personal Information for a Business Purpose

Covestro may disclose the following Categories of Personal Information for a Business Purpose:

• Identifiers and Contact Information
• Categories of Personal Information
• Commercial information
• Internet or other similar network activity
• Geolocation data
• Professional or employment related information
• Inferences drawn from other personal information

Categories of Recipients to Whom We Disclose

Covestro may disclose Personal Information for a Business Purpose to the following Categories of Recipients:

• Service Providers (for-profit legal entities that process information on behalf of Covestro and to which Covestro discloses a consumer's personal information for a business purpose pursuant to a written contract)
• Governmental Agencies (Federal or State)
• Trade or Industry Groups
• Affiliates and subsidiaries of Covestro and other members in the Covestro group of companies (“Affiliates”)
• Recipients in connection with legal or equitable claims, actions or proceedings (“Proceeding Recipients”)

Table III sets forth each Category of Personal Information collected from or about consumers, and the Categories of Recipients to whom we disclosed such Personal Information:

Sale or Sharing of Personal Information

For purposes of the CPRA, a “sale” is the disclosure of Personal Information to a third party for monetary or other valuable consideration, and a “share” is the disclosure of Personal Information to a Third Party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration.

We do not have actual knowledge that we sell or share Personal Information of California consumers under 16 years of age. However, we may share your personal information with our affiliates and/or service providers in arrangements that may meet the broad definition of “sale” or “share” under the CCPA. In these arrangements, use of the information we share is limited by policies, contracts, or similar restrictions.

Knowing Your Rights Under the CCPA

The CCPA provides consumers with specific rights regarding their Personal Information. In this section, we describe your rights under CCPA and explain how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that Covestro provide certain information to you about our collection and use of your Personal Information over the past 12 months. If you wish to exercise either your right to access or your data portability right, you must submit a verifiable consumer request (see Exercising Access, Data Portability, Correction and Deletion Rights).

Deletion Request Rights

You have the right to request that Covestro delete your Personal Information, subject to certain exceptions. If you wish to exercise this right, you must submit a verifiable consumer request (see Exercising Access, Data Portability, Correction and Deletion Rights).

Correction Rights

You have the right to request that Covestro correct inaccurate Personal Information that Covestro maintains about you.

Exercising Access, Data Portability, Correction and Deletion Rights

To exercise the access, data portability, correction and deletion rights described above, please submit a verifiable consumer request to us by one of the following methods:

• Email: DataPrivacyUS@covestro.com
• Calling us at 1-877-229-3778. A consumer may submit a request by calling the phone number provided and an operator will take your information. Covestro will contact you directly to provide more instruction and procure verification information.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of a minor child to whom you are parent or guardian.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period.

Verification Process

A verifiable consumer request must:

• Provide sufficient information in response to the website/email/phone verification question asked in the creation of your request that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative of such a person. In the event we need additional information, we will reach out to you personally to ask additional questions.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. Covestro or a third party on behalf of Covestro may follow up with you to determine whether a request is a verifiable consumer request under applicable law.

If we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you, Covestro will deny the consumer request. Covestro will respond to any such consumer request with a denial and will also explain why it has no reasonable method by which it can verify the identity of the requestor.

Response Timing and Format

We will confirm receipt of a verifiable consumer request within ten (10) days of its receipt.

We will respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to an additional 45 days), we will inform you of the reason and extension period in writing.

We will deliver our written response by mail or electronically, at your option. If you do not indicate a preference for delivery, Covestro will use its discretion in choosing the method for delivery of the information.

We do not charge a fee to process or respond to your verifiable consumer request.

Personal Information Sales Opt-Out and Opt-In Rights

We do not sell or share your Personal Information. Further, we do not sell or share the Personal Information of minors under 16 years of age.

Our affiliate Covestro AG manages all cookies on our website. Our affiliate will only set non-essential cookies after they have obtained your consent. Please refer to Covestro AG’s Privacy Statement for more information. In addition, you can manage your cookie preferences through the UserCentrics button located at the bottom right of the website.

You have the right to limit the use or disclosure of Sensitive Personal Information. To the extent Covestro uses or discloses Sensitive Personal Information, such processing is restricted to the permitted business purposes set forth under the CCPA and the CCPA Regulations. Therefore, Covestro does not offer to limit the use or disclosure of Sensitive Personal Information at this time.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, 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.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Right to Designate an Authorized Agent

If you submit a request for access, portability, correction or deletion through the use of an authorized agent, we may require that you (i) provide the authorized agent written permission to act on your behalf, and (ii) verify your identity directly with us. We may deny a request from an authorized agent that does not submit proof of authorization or where you have not verified your identity directly with us.

Data Retention

Your Personal Information will be deleted or blocked as soon as the purpose for the storage no longer applies and the storage is no longer necessary to comply with regulatory requirements, usually for the duration of the respective contractual relationship, including any applicable statutory retention period.

Details on the deletion periods can be found in the Information Retention Disposal Schedules.

Financial Incentives

Under California law, we do not offer financial incentives to consumers.

Accessibility

If you encounter difficulty accessing this Notice due to a disability, please contact our Data Privacy Officer to request access to this Notice in an alternative format.

Contact

If you have any questions about this Notice or concerns about how we manage your personal information, please contact the office of our Data Privacy Officer by telephone, in writing or by e-mail. We will endeavor to answer your questions and advise you of any steps taken to address the issues raised by you.

Julia DiPasquale
Telephone: 412-413-2901
Mobile: 412-277-6096
julia.dipasquale@covestro.com
1 Covestro Circle
Pittsburgh PA 15205

Effective: January 1, 2020
Updated: January 1, 2024