Privacy Policy

13 Mar 2023

This Privacy Policy explains how NLMK processes and protects personal data collected through the QUARD & QUEND website, qt.nlmk.com, and in connection with its business activities.

We are committed to processing personal data in accordance with applicable data protection legislation, including Regulation (EU) 2016/679, the General Data Protection Regulation (GDPR).

1. Scope of this policy

This policy applies to:

  • Visitors and users of the QUARD & QUEND website;
  • Contact persons representing customers, suppliers and business partners;
  • Individuals contacting us through forms, email, telephone or other communication channels;
  • Individuals expressing an interest in our products and services.

Personal data relating to job applications may be covered by a separate recruitment privacy notice.

2. Who is responsible for processing your data?

Depending on the relevant business activity, one or more European entities of the NLMK Group may act as data controllers.

For general enquiries, please contact info@eu.nlmk.com.

For matters relating to personal data protection, you can contact our Data Protection Officer:

NLMK Belgium Holdings SA
Rue des Rivaux 2
7100 La Louvière
Belgium
Email: dpo@eu.nlmk.com

3. Personal data we collect

Depending on your interaction with us, we may process the following categories of personal data:

  • Identification details, such as name, surname and professional title;
  • Professional contact information, such as email address, telephone number and company details;
  • Information provided in contact forms, requests for information and commercial correspondence;
  • Professional information relevant to our business relationship;
  • Financial and contractual information where necessary for business transactions;
  • Technical data, including IP addresses, browser information and data generated through cookies.

We primarily collect information directly from you or from the organisation you represent. We may also use publicly available professional information where necessary for legitimate business purposes.

4. Purposes and legal bases of processing

We process personal data only where an appropriate legal basis applies under the GDPR.

Responding to enquiries

We use contact information and correspondence to respond to requests about QUARD, QUEND and other products or services. Processing may be based on pre-contractual measures or our legitimate interest in responding to business enquiries.

Managing business relationships

Personal data may be processed to establish and manage customer, supplier or partner relationships, negotiate contracts, manage orders, provide support and handle claims. Processing may be based on contractual obligations, legitimate interests or legal obligations.

Marketing communications

We may use professional contact information to communicate news, product developments, events and other relevant information. Depending on the circumstances and applicable legislation, processing is based on consent or legitimate interests.

You can object to direct marketing or withdraw your consent at any time.

Website security and operation

Technical information may be processed to ensure the security, availability and proper functioning of the website. Strictly necessary technical processing may be based on our legitimate interests.

Analytics and optional cookies

Where implemented, non-essential cookies and similar technologies are used only in accordance with applicable consent requirements. Further information is available in our Cookie Policy.

Compliance with legal obligations

We may process personal data to comply with accounting, taxation, regulatory and other applicable legal requirements.

5. Sharing personal data

Personal data may be shared with authorised employees of relevant NLMK Group companies where access is necessary for their professional responsibilities.

We may also share data with external service providers, including IT, technical, legal, financial and accounting providers, where required for legitimate business purposes.

Appropriate contractual, technical and organisational safeguards are applied to protect personal data. Information may also be disclosed to public authorities where required by law.

6. International transfers

In the context of the NLMK Group’s international activities, personal data may be accessed or transferred outside the European Economic Area (EEA), including, where applicable, to group entities in Russia.

Where such transfers take place, appropriate safeguards must be implemented in accordance with the GDPR, such as relevant contractual protections and transfer assessments.

For further information regarding international transfers and applicable safeguards, please contact our Data Protection Officer.

7. Data retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable legal or contractual obligations.

Retention periods depend on the nature of the information, the purpose of processing and applicable regulatory requirements.

When personal data is no longer required, it is deleted or anonymised where appropriate.

8. Data security

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, accidental loss, destruction, alteration or unlawful processing.

9. Your rights

Subject to the conditions set out in the GDPR, you may exercise the following rights:

  • Right of access: obtain information about the personal data we process and request a copy.
  • Right to rectification: request correction of inaccurate or incomplete data.
  • Right to erasure: request deletion of personal data where applicable.
  • Right to restriction: request limitations on certain processing activities.
  • Right to data portability: receive certain data in a structured, commonly used and machine-readable format.
  • Right to object: object to processing based on legitimate interests and to direct marketing.
  • Right to withdraw consent: withdraw consent at any time where processing is based on consent.
  • Right to lodge a complaint: contact the competent data protection supervisory authority.

10. How to exercise your rights

To exercise your rights or submit a request regarding your personal data, please contact:

Data Protection Officer
Email: dpo@eu.nlmk.com
NLMK Belgium Holdings SA
Rue des Rivaux 2
7100 La Louvière, Belgium

We may request additional information where reasonably necessary to verify your identity.

Requests are normally answered within one month. This period may be extended by up to two additional months in accordance with the GDPR.

11. Complaints

If you believe your personal data has not been processed in accordance with applicable legislation, you may contact our Data Protection Officer or lodge a complaint with the competent supervisory authority.

In Belgium, you may contact the Belgian Data Protection Authority.

12. Changes to this policy

We may update this Privacy Policy to reflect changes in our activities, technical systems or applicable legislation.

We encourage visitors to review this page periodically. Where required, significant changes will be communicated appropriately.