PRIVACY POLICY

FLSmidth Cement A/S Data Protection Policy

This Privacy Policy is effective as of January 2024. Please note that this Privacy Policy will
regularly be updated as needed to reflect any changes in the way we handle your personal
data or any changes in applicable laws.

General statement

This Data Protection Policy („Policy“) applies to all personal data that you provide to us as part of a transaction or a customer contract. We also collect personal data when you use our services, apply for a job with us or browse our website www.flsmidth-cement.com, or any of our other FLSmidth Cement A/S related subsites or social media (“Sites”).

The protection of your personal data is very important to us. Your personal data will be processed and used exclusively within the framework of the legal data protection provisions, in particular the General Data Protection Regulation (GDPR).

Other privacy policies relating to non-EU countries

Please refer to FLSmidth’s other data protection regulations that apply in relation to non-EU countries, as far as they are relevant to you:
Brazil

In the following pages you will find information about the type, scope and purpose of the collection, the processing and use of your personal data, and your rights.

This Policy covers:

• What information we collect about you and why
• How do we collect information
• How do we use your personal data
• How will we share information about you with others
• How long do we keep your personal data
• What are our legal basis for data processing
• What are your rights relating to personal data processing
• How do we securely store information about you
• What happens when this Policy is updated
• How to contact us
• What legislation we comply with

What information we collect about you and why

We collect personal data of our employees, potential employees, clients, suppliers, business contacts, shareholders and website users. If the data we collect is not listed in this privacy statement, we will give individuals (when required by law) appropriate notice of which other data will be collected and how it will be used.

We may collect and process the following categories of Personal Data about you:

• Contact data and Business Contact Information

  Name, company details, postal address, email address, other contact information, including your business contact information and your business bank account and any data that would enable us to maintain our business relationship with you.
• Targeted data

  Age, interests, any postings, comments or other content that you upload or post on our websites, webpages or social media, movements and behaviour on our webpages, websites and online systems.
• Automatically collected data

  IP addresses, information about your browser, operating system and other Personal Data that are relevant and necessary for the use of the service.
• Cookies

  Please refer our Cookie Policy for further information on how we use cookies and other tracking technologies.

We also collect communication preferences, product interests and use of FLSmidth products and services, in response to our surveys and participation in events.

If you provide us with any Personal Data of another person, you are responsible for ensuring that such person is made aware of the information contained in this Privacy Policy and that the person has given you his/her consent for sharing the information with us.

How do we collect information

We and our service providers collect Personal data and other information in variety of ways:

• Through your behavior and engagement

  We collect information through the Sites, for example when you request a free trial or demo, register for an event, contact us, subscribe to our email newsletter, download content, complete surveys, or register to use our Sites/applications.
• Offline

  We collect information from you offline when you attend one of our events, during phone calls with sales representatives, or when you contact an FLSmidth representative.
• Through you

  FLSmidth collects information such as your location or your preferred means of communication when you voluntarily provide it. Unless this is combined with Personal Data, this information does not personally identify you or any other user of the Sites.
• Information from other sources

  In order to improve our ability to provide relevant marketing, offers, and services to you, we obtain information about you from other sources such as public databases, joint marketing partners, and social media platforms, as well as from other third parties.
• Through your browser or device

  Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version, and the name and version of the Sites (such as the Apps) you are using. Your “IP Address” is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP Address may be identified and logged automatically in our server log files whenever you access the Sites, along with the time of the visit and the page(s) that you visited. Collecting IP Addresses is standard practice and is done automatically by many websites, applications and other services. FLSmidth uses IP Addresses to calculate usage levels of the Sites, help diagnose problems with its servers, administer the Sites, and for monitoring the regions from which you navigate to FLSmidth’s Sites.
• Through your use of Apps

  When you download and use an App, we and our service providers track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number.
• Through cookies and other similar technologies

  „Cookies“ are commonly used small files that are downloaded to your computer or mobile device to enable you to more easily communicate and interact with the Sites. When you visit our Sites, we may send one or more cookies to your device. They enable us to store information about your device which helps us, amongst other things, to provide you with a better experience when you browse our Sites and enhance the level of services and functions provided. We also use third parties to serve advertisements on other websites that may be of interest to you, based on information collected about your use of our Sites and other websites. To do so, these companies may place or recognise a unique cookie or similar on your browser. FLSmidth recognises automated browser signals regarding tracking mechanisms, which may include ‘do not track’ instructions. Please review our Cookies Policy for more information.
• By aggregating information

  Aggregated Personal Data does not personally identify you or any other user of the Sites (for example, we may aggregate Personal Data to calculate the percentage of our users who have a particular telephone area code).

How do we use your personal data

• To sell products and services to you
• To deliver products and services to you
• To manage invoicing and payments
• To provide customer support for products and services
• To provide and manage our digital services such as customer portals (myfls/customer hub), e-commerce, digital applications, others
• To develop and improve our products and service based on customer surveys and feedback
• To secure and optimise the website experience
• To provide information on feature upgrades, version updates, warranty or other relevant information about sold product or service
• To provide personalised marketing communication and promotional content, targeting advertising and presenting you with relevant content
• To send you information about FLSmidth services, products, promotions and events that we believe may interest you
• To enable us to fulfill our legal and contractual obligations
• To tailor our communication, we improve your individual customer experience regarding our products and services based on the insights of your interaction with our content
• To share the insights of your interest shown by interacting with our content with FLSmidth sales team
• To generate statistical data on the number of customers, purchases, website visits, email opens, and email clicks, other action by you related to our marketing activities, in order to measure effectiveness of our marketing efforts

How will we share information about you with others

We may share your personal data with service providers who help us deliver a product or service to you, carry out marketing services and provide online services. Examples include removing repetitive information from customer lists, analysing data, providing marketing assistance, conducting billing, processing credit card payments, engaging technical support for our services, providing customer service, performing analysis related to our products or services, and to verify or compile aggregate usage data.

These service providers may collect, store and process personal data about you on our behalf. These service providers are only allowed to process your personal data to provide the service we have requested from them. They may not use your personal data for the benefit of their own business.

Such processing is always regulated by data processing agreements in order to ensure that all our service providers keep your personal data safe and process it only in accordance with applicable legislation. These service providers can only process your personal data based on our instructions and use it only for purposes defined by FLSmidth.

We may also share your personal data with companies within the FLSmidth Group within the boundaries of the law.Click here for a list of our Group Companies.

We may share your personal data with some of our service providers and subsidiaries located outside the EU/EEA. This will be done under strict requirements issued by the European Commission, which is designed to protect your personal data when such exchanges happen.

Personal Data may also be disclosed by you through the Sites, on message boards, chat, profile pages and blogs and other services to which you are able to post information and materials (including, without limitation, our FLSmidth Blog, and the Social Media Pages). This information can appear in public ways, such as through search engines or other publicly available platforms, and can be “crawled” or searched by third parties. Please do not post any information on these Sites that you do not want to reveal to the public at large.

We are required by law to provide information to public authorities, such as the Danish tax authorities, when it is requested. This may be for auditing purposes and in line with local legislation and regulations.

How long do we keep your personal data

We will retain your personal data only for as long as necessary. Once personal data is no longer required, it is deleted or made anonymous. We process and store your personal data for the duration of our business relationship, as it is necessary to fulfil our rights and obligations related to the data, which also includes the initiation and execution of a contract as well as the regular limitation period for the defense against or assertion of any legal claims that may arise after the contract conclusion. We are required to keep our accounting records for five years.

Storing website visitors’ personal data depends on the cookies in use. For information about how we use cookies and your choices please refer to our Cookies Policy.

If you have subscribed to receive marketing communications from us, we store your personal data for electronic direct marketing purposes until you withdraw your consent by using the “Manage e-mail subscription preferences | Unsubscribe” link included in the marketing email or contacting us through one of the options specified in the section “How to contact us”.

If you are applying for a job at FLSmidth, you can apply online through our application portal. Your online application will be forwarded directly to Group Human Resources through an encrypted connection and will be treated confidentially. With your consent, we will forward your application within the company, provided your application matches one of our open positions. We will use your details exclusively for processing your application and will not pass them on to third parties outside the FLSmidth group companies.

What is our legal basis for data collection and processing

We process your personal data only if we have a valid legal basis.

Legitimate interest

Your personal data is collected and processed for the purposes of marketing, selling and developing of our products and services, or for the purposes of managing customer relations, providing customer communication and organizing events. It is also in our legitimate interest to measure the effectiveness of our marketing, to deliver our goods and services, to provide you with our digital services, to provide customer support for sold goods and services, and to manage invoices and payments.

Legal obligation

When we are required to do so for compliance with a legal obligation to which we are subject.

Consent

Based on your prior consent to receive our newsletter and other promotional materials. By giving consent, you agree to receive marketing messages and promotional content, as well as to allow us to use demographic and behaviour information (such as website visits, email opens, and email clicks) for personalizing the content for you. You may at any time withdraw your consent for receiving newsletters or other material using the,„Manage e-mail subscription preferences | Unsubscribe” link included in the marketing email or contacting us through one of the options specified in the section “How to contact us”.

Cookie consent with CookieBot

Our website uses CookieBot’s cookie consent technology to obtain your consent to store certain cookies on your final device and to document these in a data protection compliant manner. The provider of this technology is Cybot A/S, Havnegade 39, 1058 Copenhagen Denmark, website: https://www.cookiebot.com/ (hereinafter „CookieBot“).

When you enter our website, a connection is established to CookieBot’s servers in order to obtain your consents and other declarations regarding cookie use. CookieBot then stores a cookie in your browser in order to be able to assign the consents given to you or their revocation. The data collected in this way is stored until you request us to delete it, delete the Consent Manager Provider cookie yourself or the purpose for storing the data no longer applies. Mandatory legal storage obligations remain unaffected.

The use of CookieBot is in our legitimate interest to guarantee your data protection rights in order to obtain the legally required consent for the use of cookies. The legal basis for the processing of your data is Art. 6 para. 1 (f) GDPR.

Contract

When we have entered into a contractual agreement directly with you and/or the company you represent, your personal data is collected and processed for the performance of the contract for delivering our goods and services, providing you with our digital services, providing customer support for sold goods and services, and managing invoices and payments.

What are your rights relating to personal data processing

Under Art. 21 GDPR, you have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data. It is always up to you whether you want to give personal data to us. We will clearly state when you are required to provide us with personal data. If you refuse, we may not be able to complete our requirements in providing you with a product or service. If personal data are processed for the purpose of direct marketing, you may at any time withdraw your consent for receiving newsletters or other material using the “Manage e-mail subscription preferences | Unsubscribe” link included in the marketing email or contacting us through one of the options specified in the section “How to contact us”.

You can request access to the personal data we have about you and you have the right to request rectification, supplementary processing, deletion or blocking of the personal data we process about you. In certain circumstances, you can restrict the processing of your personal data. Data that you have personally provided to us can be accessible by you in a machine-readable format. These rights may be subject to conditions or restrictions.

If, despite our best efforts to protect your personal data, you believe that your data privacy rights have been violated, we encourage and welcome you to contact us first to seek resolution. You will be asked to prove your identity at that time.

We will do our best to resolve any issue you might have related to our processing of your data. However, if you are not satisfied with our answers or actions, you may always turn to the national data protection authority.

How do we securely store information about you

The security of your personal data and our website and IT systems is important to us. Our website and connected IT systems are protected against access by technical and organizational security measures. These security measures protect your Personal Data against unauthorized or unlawful processing and/or against accidental loss, alteration, disclosure or access, or accidental or unlawful destruction of or damage.

You should always treat your access data confidentially and close your browser window when you leave our website.

Our Information Security Policy sets out how we manage and store personal data. We have internal rules and procedures to maintain appropriate security from collection to deletion of personal data. Our employees, and contractual third parties, are trained in securely managing personal data.

With your help we can make our platform even more secure. Should you encounter potential security gaps, please let us know as soon as possible! Please send us a description of the vulnerability (with the relevant URL) and a description of how the vulnerability was found (with screenshots, etc.) to janine.rothbauer@flsmidth.com

What happens when this Policy is updated

We may update this Policy at any time without expressly notifying you of such. The most recent version of the Policy will always be found on this page. We recommend that you revisit this Privacy Policy from time to time in order to review any possible changes. If any substantial changes in the way FLSmidth collects or processes your personal data occur, we will post a notice of such change on our website.