Privacy notice
April 2024
Scope
This Privacy Notice (“Notice”) sets out how ASM uses personal data of our (potential) clients, suppliers, visitors and other third parties. The Notice applies when you browse our website, when accessing one of our online portals or tools, when using our services, when purchasing our products or when interacting with us (jointly referred to as “Services”).
For purposes of this Notice, "personal data" means any information through which we can identify an individual, as further described below under paragraph “The Personal Data We Collect”. This Notice does not apply to corporate company information if no personal data from individuals can be derived from such corporate information.
This Notice is maintained by ASM International N.V. on behalf of itself and affiliates in the ASM group of companies (“ASM”, “we”, “us” or “our”). For a complete list of affiliates please refer to this link.
The ASM entity responsible for your personal data will either be ASM International N.V. or in case of using the supplier portal the ASM company that you entered into a contract with.
For the purposes of applicable European data protection legislation, ASM International N.V., Versterkerstraat 8, 1322 AP, Almere, The Netherlands is the representative company for non-EU ASM entities and serves as point of contact for European data subjects and Data Protection Authorities.
The personal data we collect
The categories of personal data that ASM collects and processes will depend on our relationship with you:
Suppliers
When we are doing business with our (corporate) suppliers (business-to-business), the personal data we collect relates to our suppliers and their representatives/contact persons. In particular, we may collect:
-
Contact Information: your name, address, telephone number, email address, and any other contact details you provide to us;
-
Account Information: your username and password when using our Website or our online (supplier) portals and tools;
-
Service History: information relating to your use of Services, such as sales you make (on behalf of the company you work for);
-
Financial Information: that has been disclosed to us (either upon request or voluntarily) and can be linked to you as a supplier (representative), such as bank account details or invoicing details;
-
Communication Information: requests and complaints submitted on behalf of your company and any other data that we receive when we communicate with you; and
-
Other Personal Data: that you disclose to us during the course of your contractual relationship with us, either voluntarily or upon request.
Website visitors, on-site visitors, and other users of our online portals and tools
When you visit our Website (including use our online portals or tools), ASM may collect information about your use of our Website that will help ASM improve its online services. We will also collect information when you communicate with us, register for and attend webcasts or live events, or visit us in person. In particular, we may collect:
-
Usage Information and Device and Browser Information: the pages you access on our sites and the site that referred you to the Website; the name of your Internet Service Provider, what browser you are using, and your IP address. Our website uses cookies and similar technologies to collect this personal data. For more information, please see “Cookies and Tracking” below;
-
Contact Information: your name, email address, occupation, and other contact details you give us when you make a request, register for webcasts or events, or otherwise contact us;
-
Marketing preferences: If you nominate to receive marketing communications from ASM we will record your marketing preferences;
-
Communication Information: if you choose to post messages in message areas or to, provide feedback, or send an email to us, we may keep a record of that posting or correspondence. Information you disclose in a public message area will naturally be available to and shared with other users of our Website;
-
Photos: if you attend a physical event, we may take photographs at the event (you will be informed beforehand); and
-
Video and Recordings: when you enter or buildings or premises, you may be recorded by our video surveillance systems (CCTV).
Job applicants
If you have applied for a role at ASM or submitted an open application, we will also process personal data to make decisions regarding whether to offer you employment. Please refer to our Careers Privacy Notice for more information about how we process applicant data.
Our purpose and legal bases for using your personal data
We only use personal data as necessary for specific purposes. In addition, certain laws require us to set out our legal basis for processing personal data. Both our purposes and our legal basis are as set out in the table below.
|
Purpose |
Legal basis |
|
As part of our contractual relationship, including:
|
The processing is necessary in order to perform the contract between us or to take steps before entering into a contract with you. |
|
To inform you about other relevant Services and products that we think you find interesting, or you have shown interest in (including to send you marketing communications) |
Our legitimate business interests to ensure that we are providing suppliers and customers with relevant and useful information In some cases, we may ask for your consent to use your personal data for this purpose. |
|
To host webcasts and in person events including to arrange the registration process and set up the event.
|
Our legitimate business interests to host webcasts and events, manage the registration process, send follow up materials, and ensure that adequate resources are available to successfully host the webcast or event. |
|
To respond to non-contractual queries, complaints, and requests |
Our legitimate business interests to communicate with you in a timely manner and answer your requests cost-effectively. |
|
To ensure our website functions properly, securely and is free from errors |
Our legitimate business interests to maintain an up to date, and secure website (including to fight against abuse, threats or infringement activities). |
|
To understand how you are using our Services and offerings
|
Our legitimate business interests to understand how suppliers/customers are using our Services and offerings so that we can (i) improve our Services and offerings and (ii) optimize the attractiveness, content and functionality of the website ultimately to provide you with an excellent and relevant user experience. |
|
To protect our assets, premises and employees including to
This includes retaining and disclosing information with our legal advisors |
Our legitimate business interests to protect our assets and staff and to establish, exercise or defend ourselves against legal claims. |
|
To comply with our regulatory and legal commitments and obligations including to
|
The processing is necessary on the basis of a legal obligation that ASM is subject to. |
Cookies and tracking
We use browser cookies, pixels, and other mechanisms to give you an excellent user experience when visiting our website or using our online portal. For more information about the use of cookies on our website and portal, including how you can manage your cookie preferences, you can review our Cookie Notice.
We also may use clear GIFs (also referred to as web beacons, web bugs, or pixel tags), in HTML emails we send to our customers to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.
Sharing personal data
To fulfill the purposes above, ASM may need to disclose to, transfer, or otherwise share your personal data with affiliates entities or with a third party. In general, we may disclose, transfer or otherwise share personal data as follows:
-
With ASM affiliates: ASM is a global company, and your personal data may be shared amongst our affiliated companies, which are subject to this Notice when processing your personal data. For a complete list of affiliates, please refer to this page.
-
With service providers: we may also share personal data with trusted third parties that perform business functions or provide services on our behalf. This includes, for example, the hosting of our website, data storage and analytics, security services, handling and processing payments, advisory services, maintenance, and other similar services. We will only do this where necessary and consistent with applicable legal requirements, we take commercially reasonable steps to require third parties to adequately safeguard your personal data and only process it in accordance with our instructions.
- With advertising and marketing partners: ASM works with partners to display online advertising that is more relevant. These companies may collect cookie IDs, IP addresses, and other identifiers as well as information about the pages you visit on our sites and other websites to enable them to display advertising for products and services that may be of interest to you when you visit our website or other websites. For more information about this please refer to section 4.
-
Where required by law or to protect our rights: where permitted or obliged by applicable law, ASM may share personal data to investigate or prevent illegal activities, suspected fraud, violations of our terms and conditions, or threats to the property or safety of our personnel or to protect our legal rights or defend legal claims. We also share personal data to comply with tax authorities or binding requests from other law enforcement authorities.
-
As part of a corporate transaction: Further, if an ASM business unit is sold or transferred as part of a corporate transaction, it may be necessary to disclose personal data to a purchasing entity, including during due diligence conducted prior to such event (where permitted by applicable law).
We may share aggregate or anonymous information with third parties for research, marketing, analytics, and other purposes, provided such information does not identify a particular individual.
International transfers of personal data
ASM is a global enterprise, and there may be instances where ASM may need to transfer and process personal data in countries other than your country of residence. These countries may have data protection laws that are different from the laws of your country and in some cases, may not be as protective. ASM assesses these transfers and takes measures to ensure that appropriate safeguards (including, where necessary, implementing additional contractual, technical, and organizational measures) are in place to ensure that personal data is afforded a level of protection that is essentially equivalent.
With respect to the intra-group transfers of personal data, ASM has in place an intra-group data transfer agreement in accordance with applicable laws, which provides for measures to ensure adequate protection of personal data.
For residents of the European Economic Area, you can request a copy of our safeguards by contacting us using the details included below.
How we protect personal data
ASM uses industry-standard efforts to safeguard the confidentiality of personal data. We have taken technical, physical, and organizational measures to protect data from loss, theft, misuse, unauthorized access, disclosure, alteration, copying, accidental or unlawful destruction, and any other unlawful forms of use. Access to personal data is limited to ASM personnel and authorized third-party agents who need it to do their job.
Our data retention standards
ASM stores personal data for as long as it is necessary to fulfill the purposes it was collected for, unless there is a legal, accounting, or reporting requirement to retain the personal data for a longer period (in which case we will store it for as long as required to fulfill such legal, accounting or reporting requirement).
Your rights
ASM is committed to transparently processing your data. Depending upon your jurisdiction and subject to applicable local laws, you have several rights in relation to personal data processed by SABIC. For example, you may have the right to (subject to limitations) to (i) request access to your personal data or for information about how it is processed, (ii) request rectification/correction, restriction, or erasure of such personal data; and (iii) request that the personal data is transmitted to another data controller. Under certain conditions, you may also object to the processing of your personal data or restrict the processing or deregister of your account on the ASM portal.
In the event the personal data are processed on the basis of your consent, you can withdraw consent at any time by contacting us via email at [email protected]. Please note that a withdrawal of consent does not affect the lawfulness of any processing which had taken place before the consent was withdrawn.
If you want to exercise your rights, you can contact us by sending an email to [email protected].
In your request, please tell us which rights you would like to exercise (i.e. the personal data you would like to have changed, whether you would like to have it removed from our database). We will respond to your request consistent with applicable law, and in any event, respond to your request as soon as reasonably practicable. Please note that we may need to retain certain personal data for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion.
For residents of the European Economic Area, you also have the right to lodge a complaint with the Data Protection Supervisory Authority established in your country of residence or where you believe your rights have been infringed.
How can you contact us?
If you have any questions about our Notice and/or the manner in which we process your personal data, you may contact us at [email protected]
Changes to this notice
This Notice may be amended due to changes of relevant laws and regulations, changes of terms and conditions, technical reasons, or any other reasonable basis. All updates to this Notice will be published here and we will notify you of such changes as it is reasonably possible and where required to do so by applicable laws.