Privacy Policy

Your data privacy is important to us.

This privacy policy (“Privacy Policy”) describes how ǿմý Inc. and, to the extent this Privacy Policy is posted on their site or otherwise adopted by such affiliates,  (collectively, the “Company”) collect, use, share, and otherwise processes individually identifiable data about visitors to websites and any other online platform where this Privacy Policy is posted (the “Sites”), or that otherwise interact with us or request services from us, such as our customers, prospects, distributors, sales representatives, vendors, investors, end users, and suppliers. References in this Privacy Policy to “we,” “us,” or “our,” are references to the relevant Company to which this Privacy Policy applies. These Sites contain links and references to other websites administered by unaffiliated third parties. This Privacy Policy does not apply to such third-party websites. When you click a link to visit a third-party website, you will be subject to that website’s privacy practices.

What Personal Data Do We Collect?

In connection with the operation of our Sites and businesses, we collect limited personally identifying information, defined in this Privacy Policy as “Personal Data,” that includes:.

Information you choose to submit: Generally, you are not required to disclose your personal information as a condition of using the Sites. However, the Sites’ various registration forms, surveys, and some online services may request that you give us your individual contact information (such as your name, affiliation, employer, mailing, phone number, and/or email address) and profile data (such as preferences that are linked to you). In many cases, you choose the amount of information you supply (e.g., when sending us information through the Sites, you may choose to include only an email address for replies). There may be cases, however, where some of the information requested is identified as mandatory and some as voluntary. In such cases, if you do not provide mandatory Personal Data with respect to a particular activity on the Sites, you will not be able to engage in that activity. Also, any information we collect that is associated or reasonably linked to you, or that is defined as “personal data,” “personal information,” or a similar term under applicable law, will be considered Personal Data under this Privacy Policy.

Information we collect automatically: When you visit the Sites, certain information, some of which may qualify as Personal Data depending on your jurisdiction, is recorded by the standard operation of our Internet servers in order to monitor and enhance your online experience. Such recorded information includes your IP address, the name of your internet service provider, the operating system and the type of browser you used, the date and duration of your visit, the name(s) of the visited page(s), and the amount of transferred data. This information is stored in aggregate form or is anonymous (i.e., it is not linked to a specific individual). This information may be collected through the use of online tracking technologies, such as cookies. For more information on how we use these technologies and the information we collect, see our Cookies Notice, which follows this policy.

How Do We Use Your Personal Data?

We use the above categories of Personal Data for the following purposes:

  • Provide the products and services you requested, respond to your inquiries, and allow us to contact you;
  • Manage your accounts, maintain our business operations, and allow you access to our proprietary systems;
  • Make our Sites more personal, intuitive, and easy to use;
  • Protect the security and effective functioning of our Sites and information technology systems;
  • Provide relevant marketing about our or our affiliates’ products and services, or promotions that we are developing, and opportunities that may be available to you; and
  • Address our compliance and legal obligations and exercise our legal rights.

Where we need to collect Personal Data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to provide access to services and content available on the Sites. In this case, we may have to cancel a product or service you have with us, but we will provide you prior notice.

Storage of Your Information Outside of the United States and Canada: Your Personal Data may be transferred to or stored on servers in any country where we conduct business, which includes outside of the United States and Canada. By using our Sites, and products or services from these Sites, or otherwise providing information to us through the Sites, you understand that your Personal Data may be transferred to and/or stored in countries outside of your country of residence.

Automated decision-making: We do not use automated decision-making without human intervention, including profiling, in a way that produces legal effects concerning you or otherwise significantly affects you.

Legal basis of processing: Some jurisdictions may require that we provide an explanation of the legal basis for the collection and processing of your Personal Data. We have several different legal grounds on which we collect and process your Personal Data, including: (a) as necessary to perform a transaction (such as in order to provide the products and services you requested); (b) as necessary to comply with a legal obligation (such as when we use Personal Data for record keeping to substantiate tax liability); (c) consent (where you have provided consent as appropriate under applicable law, such as for direct marketing); and (d) as necessary for legitimate interests (such as when we act to maintain our business generally, including maintaining the safety and security of the Sites). With respect to legitimate interests, given that we are a B2B company, we typically collect and process limited Personal Data about customer contacts and other individuals acting in their business capacities as part of our overall effort to reduce the privacy impact on individuals.

Information about children: We do not direct our services or our Sites to children or individuals under eighteen (18) years of age, and, therefore, we do not knowingly collect or sell Personal Data of children. Individuals under the age of eighteen (18) should consult with their parent or guardian about the use of these Sites for their benefit.

Who Do We Share Your Personal Data With?

  We share the Personal Data that we collect with the following categories of recipients:

  • Affiliates: We share Personal Data with our affiliated group of companies as necessary for the purposes we described above.
  • Service providers: We share Personal Data with service providers to enable such parties to perform functions on our behalf and under our instructions in order to carry out the purposes identified above, such as marketing and web hosting.
  • Auditors and advisors: We share Personal Data with auditors for the performance of audit functions and advisors for the provision of legal and other advice.
  • Business reorganization: We share Personal Data with any corporate purchaser or prospect to the extent permitted by law as part of any merger, acquisition, sale of company assets, or transition of service to another provider, as well as in the event of insolvency, bankruptcy, or receivership in which Personal Data would be transferred as an asset of the Company.
  • Mandatory disclosures and legal rights: We share Personal Data in order to comply with any subpoena, court order or other legal process, or other governmental request.  We also share Personal Data to establish or protect our legal rights, property, or safety, or the rights, property, or safety of others, or to defend against legal claims.
What Choices Do You Have Regarding Marketing?

If you request information through the Sites and supply us with your email address or your name and postal address, you accept and agree that this information will be used for the purpose of providing the requested information and that we may use this data in the future to provide other information about us and our business partners that might be of interest to you.

If you no longer wish to receive any communications from us, remain on a mailing list to which you previously subscribed, or receive any other marketing communication, you can choose to not receive such communications at any time. Please follow the unsubscribe link in the relevant communication or contact us as detailed below.

What Security Measures Do We Have in Place to Protect Your Personal Data?

The security of your Personal Data is important to us. We will put in place appropriate technical, physical, and organizational or administrative measures to protect your Personal Data from accidental or unlawful disclosure or access, taking into account the state of the art, costs of implementation, and risk. Unfortunately, no method of transmission over the Internet or method of electronic storage is 100% secure. As a result, while we will strive to protect your Personal Data, we cannot and do not guarantee or warrant the absolute security of any of your Personal Data. You should not share your username and password with anyone, and you should not re-use passwords across more than one website. We will not be and are not liable for disclosures of your Personal Data due to errors in transmission, networks that we do not control, nor unauthorized acts of third parties.

Employee, contractor, and applicant privacy issues: Personal Data about our employees and contractors are addressed through internal company policies and procedures, and are outside the scope of this Privacy Policy.

If you make an employment inquiry or apply for a position through our Sites where available, you accept that the application will be processed by us or by a third party on our behalf. We will use the Personal Data supplied by the applicants for the purpose of processing the application. Applicants have the right to consult their Personal Data, to update or correct the Personal Data, if necessary, and to withdraw their consent to the use of their Personal Data. For this purpose applicants may contact the recipient of the application at the email address to which they have sent the application or through the Site if permitted

 How Long Do We Keep Your Personal Data?

For Personal Data that we collect and process for the purposes described above, we typically retain such Personal Data for so long as it is necessary to fulfill the purposes outlined in this Privacy Policy and as otherwise needed to address tax, corporate, compliance, litigation, and other legal rights and obligations.

With respect to Personal Data used for direct marketing, we typically retain such Personal Data for as long as you accept marketing communications from us. We will also retain such Personal Data to process your choice not to receive such communications, and to maintain a record of your marketing choices.

Please note, we keep your Personal Data only as permitted by applicable laws.  

What Choices Do You Have Regarding Your Personal Data?

You may request information on the general categories of Personal Data we maintain about you, and to verify its accuracy. You may also request that we delete your Personal Data by contacting us as described below. In particular, you have the right to object to our use of Personal Data for direct marketing and in certain other situations at any time. Contact us below for more details. Please note that we need to retain certain Personal Data as required or permitted by applicable law.

Depending on your local law, you may have certain rights regarding Personal Data we have collected about you, including the right to:

  • Access: The right to know what Personal Data we have collected about you and what Personal Data about you was disclosed to third parties.
  • Correction/Rectification: The right to update or correct Personal Data if you believe there is an inaccuracy. For information displayed in your profile, you may also update or correct this information at any time.
  • Restriction: The right to restrict the processing of your Personal Data under certain circumstances (such as where you contest the accuracy of your Personal Data, processing is unlawful, your Personal Data is no longer needed for the purposes of processing, or you have otherwise objected to processing related to automated individual decision-making).
  • Deletion/Cancellation: The right to request the deletion of your Personal Data. Please note that the deletion of your Personal Data may prevent us from providing you content or other benefits that depend on the processing of your Personal Data.
  • Objection/Opposition: You have the right to object to our use of Personal Data for direct marketing and in certain other situations at any time.
  • Data Portability: The right to request transmission of your Personal Data to another data controller.
  • Withdraw consent: The right to withdraw consent you previously provided to us regarding the processing of your Personal Data at any time. We will apply your preferences going forward and this will not affect the lawfulness of the processing before your withdrawal of consent.

Certain of these rights may be subject to limitations or conditions.

Please note, while you are not required to provide all Personal Data identified in this Privacy Policy to use our Sites or to interact with us offline, certain functionality will not be available if you do not provide certain Personal Data.

If you would like to exercise any of these rights provided under local law, you may contact us at info@clevelandcliffs.com.

If you would like to make a complaint about how we handled your Personal Data, or make a complaint about a breach of data protection laws, please contact us using the information provided in the “Contact” section. Complaints will be investigated and the outcome of the investigation will be communicated to you after the complaint is made in accordance with applicable law. You may have a right in some locations to file a complaint with your local data protection authority.

Is There Any Cross-Border Transfer of Your Personal Data?

We transfer Personal Data to various jurisdictions as necessary for the purposes described above, including to jurisdictions that may not provide the same level of data protection as your home country. We provide appropriate protections for cross-border transfers as required by law for international data transfers.

What Do California Consumers Need to Know?

If you are a California resident, the California Consumer Privacy Act (“CCPA”) requires us to make certain disclosures about our personal information practices and provides you additional rights related to our collection, use, and sale of your Personal Data. We have included this California-specific information below.

  • Personal Data. Consistent with the “Collection of Personal Data” section above, we collect certain categories and specific pieces of information about individuals that are considered “Personal Information” in California.  Specifically, we may collect the following types of Personal Data from California residents:

o    Identifiers: Name, address, telephone number, email address, username and password for our Sites, and IP address;

o    Commercial information: Products or services purchased, obtained, or considered, other purchasing or consuming histories or tendencies, payment information, and transaction history;

o    Professional or employment-related information;

o    Internet or other electronic network activity information: Computer and connection information, statistics on page views, traffic to and from the Sites, ad data, and other standard weblog information; and

o    Geolocation information: Physical location information through the use of our services and/or products.

  • Sources. We collect certain categories of Personal Data from you and other third parties as described in the “Collection of Personal Data” section above. The categories of third parties from whom we collect Personal Data include the following:

o    Third-party partners;

o    Third-party applications (including blogs, chat rooms, or support centers);

o    Advertising networks; and

o    Other companies or organizations, such as market research firms or data aggregators.

  • Purposes. We collect the Personal Data for the business and commercial purposes described in the “Use of Personal Data” section above. We also may share and/or disclose your Personal Data with service providers, third-party partners, public or government authorities, and future business partners for our business purposes. This Personal Data  may include:

o    Personal identifiers, such as your full name, email address, mailing and/or billing address, and other similar identifiers;

o    Information regarding your use of the Sites;

o    Customer relationship information, such as customer service requests and feedback and information requested or provided by or from you;

o    IP address(es); and

o    Any other information you voluntarily provide to us when you communicate with us. 

As described above, examples of business purposes include product and service fulfillment, internal operations, prevention of fraud and other harm, and legal compliance.

  • Do Not Track Signals. Given the divergent practices of organizations that offer browsers and the lack of a standard in the marketplace, we do not respond to DNT signals at this time.
  • California Consumer Rights: If you are a resident of California, the CCPA provides you with the following rights regarding your Personal Data, subject to certain exceptions
  • Right to Know: You have the right to request information about our collection, use, and disclosure of your Personal Data over the past twelve (12) months concerning (i) the categories of Personal Data we collected about you, (ii) the categories of sources from which your Personal Data is collected, and (iii) categories of third parties with whom we share your Personal Data.
  • Right to Deletion: You have the right to request that we delete certain Personal Data that we have about you. We may not be able to fulfill your request if we (or our service providers) need to retain your Personal Data for certain authorized purposes, such as to provide a good or service you requested, to secure our Services, to protect against fraud, to improve our services, or to comply with or exercise rights under applicable law.
  • Right to Non-Discrimination: You have the right not to receive discriminatory treatment against you for exercising any of your privacy rights under the CCPA.

If you would like to exercise any of these rights provided under local law, you can contact us at info@clevelandcliffs.com

Only you or an authorized agent acting on your behalf may make a request related to your Personal Data. We may need to verify your identity (and if applicable, your agent’s authority to make the request on your behalf) before we are able to process your request. We will ask you to provide certain information to verify your identity: name, email address, and telephone number.

If you have an authorized agent who makes the request, then (i) we need proof that you have provided the agent with power of attorney or (ii) you must provide the agent with signed permission to submit a request to know or delete; you must verify your identity directly with us; or you must confirm with us that you provided the authorized agent permission to submit the request.

During the verification process, we will try to match the information you provided against known information in our databases. If we still need additional information, we also may contact you or your authorized agent by email or telephone number to ask you additional questions about the products or services you purchased or your last order with us, so that we can match your identity with the Personal Data we have about you. In some instances, we may ask you to declare under penalty of perjury that you are the California resident whose Personal Data is the subject of the request.

If we cannot verify your identity or sufficiently differentiate you from another consumer, or cannot confirm an agent’s authority to act on your behalf, we are not required to fulfill your request.

How Will We Handle Changes to This Privacy Policy?

We may update this Privacy Policy from time to time as our services and privacy practices change, or as required by law. The effective date of our Privacy Policy is posted above, and we encourage you to visit our Sites periodically to stay informed about our privacy practices. We will post the updated version of the Privacy Policy on our Sites, and ask for your consent to the changes if legally required.

How Should You Contact Us With Questions?

If you have any questions about this Privacy Policy, the practices on our Sites, your dealings with our Sites, or wish to exercise your choices under this Privacy Policy or data protection rights under applicable law with respect to our processing of your Personal Data, you may contact us at the following postal address, via the contact information for our Ethics Reporting Portal, or via e-mail at info@clevelandcliffs.com.

ǿմý Inc.
200 Public Square, Suite 3300

Cleveland, Ohio 44114

Ethics Reporting Portal

Web: -- Enter “ǿմý” in the “Enter Organization Name” field

Telephone:   1-800-866-2416

 

Cookies Notice

This cookie notice (“Cookie Notice”) describes how ǿմý Inc. and   that publish this Cookie Notice on their online platforms (collectively, the “Company”) use online tracking technologies, such as browser cookies, when you interact with our website (the “Sites”). References in this Cookies Notice to “we,” “us,” or “our,” are references to the relevant Company to which this Cookies Notice applies.

What are Cookies and Related Technologies?

A cookie is a small text file that is stored by your web browser when you visit a website. These cookies may store certain information, such as your location, IP address, and content viewed. We and our authorized third-party partners use cookies, web beacons, and other similar technologies (collectively, “cookies”) to learn more about how visitors use our Sites.

What Information Cookies Collect

Cookies allow us and our third-party providers to collect certain information so that we may understand an individual’s interactions with our Sites. For example, cookies on our Sites may collect information about pages visited, time spent on a given page, courses accessed, content viewed, features used, your search queries, click data, date and time of your visit, referrals to our Sites, and other data regarding your use of the platform.

Use of Cookies

We use the following types of cookies and technologies:

  • Necessary cookies: These cookies are essential to enable basic functions on the Sites and make the Sites usable. For example, they enable basic functionality, such as security and website accessibility. Once you close your browser, these cookies disappear. The legal basis for our use of necessary cookies is our legitimate interest in being able to provide and maintain our Sites.
  • Functional cookies: These cookies enable the Sites to save information about the look and behavior of the Sites based on information entered (such as language choices or your region) so that we can offer you more personalized functions. These cookies collect anonymous information and cannot track your movements on other websites. The legal basis for our use of functional cookies is an individual’s consent.
  • Targeting cookies: These cookies record your visit to our Sites, including information about the pages viewed and links clicked, so that we may tailor marketing messages we send to the individual based on interests. We use targeting cookies to market only ǿմý products or services to you on our Sites. The legal basis for our use of targeting cookies is an individual’s consent.

ǿմý participates with affiliate programs where links used by publishers to drive traffic to our website does track if a purchase was made. The information collected includes purchase amount, invoice number, and date of purchase so that the affiliate receives an award based on the purchase amount as agreed to between the publisher (ǿմý) and the advertiser.

The table below explains the cookies we use and why.

Names

Purpose

Expiry

Category

major_announcement

Used by Equisolve to store whether a user has seen a popup announcement on the site

7 days

Necessary Cookies

minor_announcement

Used by Equisolve to store whether a user has seen a popup announcement on the site

7 days

Necessary Cookies

app_93303_DetailedQuoteTab

Used by QuoteMedia in their Qmod stock tool suite.

30 mins

Functional

app_93303_DayYearRange

Used by QuoteMedia in their Qmod stock tool suite.

30 mins

Functional

app_93303_InteractiveChart

Used by QuoteMedia in their Qmod stock tool suite.

30 mins

Functional

app_93303_PriceHistory

Used by QuoteMedia in their Qmod stock tool suite.

30 mins

Functional

1P_JAR

Used by Google reCAPTCHA. We use the Google reCAPTCHA APIs as part of our services to help protect our clients and our systems from cyber spam and abuse. The reCAPTCHA API works by collecting hardware and software information, such as device and application data, and sending this data to Google for analysis. The information collected in connection with your use of the service will be used for improving reCAPTCHA and for general security purposes. You can find further details via this link https://support.google.com/recaptcha/?hl=en.

30 days

Targeting

ANID

Google reCAPTCHA. See above.

1 yr,

11 mos, 23 days

Targeting

APISID

Google reCAPTCHA. See above.

1 yr,

11 mos, 23 days

Targeting

HSID

Google reCAPTCHA. See above.

1 yr,

11 mos, 23 days

Targeting

NID

Google reCAPTCHA. See above.

184 days

Targeting

SAPISID

Google reCAPTCHA. See above.

1 yr,

11 mos, 23 days

Targeting

SID

Google reCAPTCHA. See above.

1 yr,

11 mos, 23 days

Targeting

SIDCC

Google reCAPTCHA. See above.

1 yr

Targeting

SSID

Google reCAPTCHA. See above.

1 yr, 11 mos, 23 days

Targeting

__Secure-3PAPISID

Google reCAPTCHA. See above.

1 yr,

11 mos, 23 days

Targeting

__Secure-3PSID

Google reCAPTCHA. See above.

1 yr,

11 mos, 23 days

Targeting

__Secure-3PSIDCC

Google reCAPTCHA. See above.

1 yr

Targeting

 

  1. How To Manage Cookies

You can review your Internet browser settings, typically under the sections “Help” or “Internet Options,” to manage or disable cookies (except for strictly necessary cookies) at any time using your browser settings. Browsers are different, so you should refer to the settings menu of your browser for instructions on how to change your cookie preferences. If you disable or delete certain cookies in your Internet browser settings, you might not be able to access or use important functions or features of these Sites, and you may be required to re-enter your login details.

You can find information on how to manage cookie settings on certain browsers through these links:

  • Cookie settings in
  • Cookie settings in
  • Cookies settings in
  • Cookies settings in
  • Cookies settings in
  • Cookies settings in

To learn more about certain cookies used for interest based advertising by third parties, including through cross-device tracking and to exercise certain choices regarding such cookies, please visit the  

Within Canada, the local DAA organizations operate a similar “ad choices” scheme: see  

  1. How To Contact Us

If you have questions or concerns about the use of cookies on our Sites, please contact us at  info@clevelandcliffs.com.