Privacy

It is the policy of Sigma-Aldrich Corporation and its global subsidiaries and affiliates (the “Company”) to respect Personal Information, including Sensitive Personal Information, that is collected or maintained by or on behalf of the Company.

In furtherance of this commitment, the Company has certified to the US-EU Safe Harbor Agreement regarding Personal Information collected in the European Economic Area (EEA), and Switzerland, and transferred to the United States. The Company adheres to the Safe Harbor privacy principles as agreed to by the U.S. Department of Commerce and the European Commission and as outlined in this US-EU Safe Harbor Privacy Statement (the “Safe Harbor Statement”).

Scope
This Safe Harbor Statement sets forth the principles under which the Company manages the processing of Personal Information collected in the EEA, Switzerland and other countries, and subsequently transferred to the United States.

Definitions
“Personal Information” means any information that identifies or describes an identified or identifiable living natural person. “Personal Information” may include, for example, name, user id, password, signature, employee identification number, social security number, address, telephone number, e-mail address, company name, insurance policy number, job title, financial information, account numbers or any other information that is capable of being associated with a particular identifiable individual. Personal Information does not include aggregate data that have been divorced from identifiable characteristics.

“Sensitive Personal Information” is a subset of Personal Information, and includes information pertaining to an individual’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, information related to an individual’s health or sex life, as well as biometric identifiers, such as finger and voiceprints, and information as to commission or alleged commission of a criminal offense or any related proceedings.

We have developed the following practices and policies to safeguard your information.

Safe Harbor Principles
Notice: The Company notifies data subjects (such as employees and customers) about the identity of the data controller or its representative, the purpose(s) for which it collects, processes and maintains the data, and any further information as may be required by the circumstances under which the data are collected including the types of Personal Information the Company collects about data subjects, the recipients or categories of recipients of the data, the proposed transfer of such data to third countries, the types of third parties to which it disclosures such data and the right of access to the data. Notice is provided in clear and conspicuous language at the time of collection, or as soon as practicable thereafter, and before the Company uses or discloses the information for a purpose other than that for which it was originally collected.

Collection of Your Personal Information: The Company asks you to provide Personal Information. The Company is always seeking better ways to serve you. We may collect Personal Information in the following ways:

Use of Your Personal Information: The Company collects and uses your Personal Information to operate and improve its sites and services. These uses may include: verifying users; processing transactions; making the sites or services easier to use by eliminating the need for you to repeatedly enter the same information; performing research and analysis aimed at improving our products, services and technologies; and displaying content and advertising that are customized to your interests and preferences.

Choice: In the event Personal Information are to be used for a new purpose incompatible with the purposes for which the data were originally collected or subsequently authorized or transferred to the control of a third party that is not acting as an agent of the Company, data subjects are given notice of such use and, where feasible and appropriate, an opportunity to decline to have their data so used or transferred. In the event that Sensitive Personal Information are to be used for a new purpose or transferred to the control of a third party not acting as an agent of the Company, the data subject’s explicit consent will be obtained prior to the new use or transfer of the data, unless such new use or transfer is (1) in the vital interests of the data subject or another person; (2) necessary for the establishment of the Company’s legal claims of defenses; (3) required to provide medical care or diagnosis; (4) necessary to carry out the Company’s obligations in the field of employment law; or (5) related to data that are manifestly made public by the data subject. In these cases, data subjects are given notice of such use.

Onward Transfer: The Company only transfers Personal Information to a service provider, vendor or other third party acting as a processor of Personal Information for the Company (an “agent”) where the agent has provided assurances that the agent provides at least the same level of privacy protection as is required by these privacy principles. Where the Company has knowledge that one of its agents is using or sharing Personal Information in a way that is contrary to these principles, the Company will take reasonable and appropriate steps to prevent or stop such processing. The Company occasionally hires other companies, including the following companies, to provide limited services on our behalf, such as handling the processing and delivery of mailings, performing statistical analysis of our services. These types of service providers will be permitted to obtain only the personal information they require to deliver the service.

How the Company Keeps and Uses Personal Information: The Company reserves the right to store personal information from the time of your registration to the end of your site use agreement. The Company processes Personal Information on our servers in the United States of America and in other countries. In some cases, we process personal information on a server outside your own country.

Upon the termination of services, we discard any record with personal information as well as those provided to third parties. (Note: an actual discard occurs two months after the termination of use agreement in order to prevent from re-registration during grace period)

The Company stores personal information for the specified period in the following case:

Disposal of Personal Information:

Security: The Company takes reasonable and appropriate precautions to protect Personal Information in its possession and control from loss, misuse, alteration, destruction, or unauthorized access or disclosure.
Collection and Use of Children’s Personal Information: The Company does not knowingly collect any personal information from children under the age of 14 that require their parent’s consent regarding personal information collection. They are also restricted from customer registration.

Access: Data subjects have reasonable access to their Personal Information, and may request corrections, deletions, or additions, as appropriate, except where the burden or expense of providing such access would be disproportionate to the risks to the individual data subject’s privacy.

Data Integrity: The Company limits the collection, usage, and retention of Personal Information to that which is germane to the relevant purposes and takes steps to ensure that any Personal Information are accurate, complete, current and reliable for the intended use.

Use of Cookies
The Company sites use “cookies” to enable you to sign in to our services and to help personalize your online experience. A cookie is a small text file that is placed on your hard disk by a Web page server. Cookies contain information that can later be read by a Web server in the domain that issued the cookie to you. Cookies cannot be used to run programs or deliver viruses to your computer.

You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to sign in or use other interactive features of the Company sites and services that depend on cookies, and some advertising preferences that are dependent on cookies may not be able to be respected.

If you choose to accept cookies, you also have the ability to later delete cookies that you have accepted. If you choose to delete cookies, any settings and preferences controlled by those cookies will be deleted and may need to be recreated.

Enforcement: The Company has put in place mechanisms to verify its ongoing compliance to these privacy principles. Any Company employee found to have violated the privacy principles in this Safe Harbor Statement will be subject to appropriate corrective actions.

Dispute Resolution: The Company is committed to resolving any disputes that may arise by internal investigation and resolution of the issue. Should the Company’s efforts to resolve an issue be unsuccessful, the Company will facilitate the resolution of such disputes including through the submission of disputes to an independent party. Within the EEA and Switzerland, any questions, concerns or comments about this Safe Harbor Statement may be directed to the Data Privacy Officer at the relevant office of the Company or to the Corporate Legal Department. The Company agrees to cooperate with EEA and Switzerland Data Privacy Authorities regarding any dispute concerning personal (comment: includes customers) data.

Limitation on Scope of Principles
Adherence by the Company to these privacy principles may be limited to the extent necessary to meet the Company’s regulatory, legal, governmental, or national security obligations.

How to Contact Us
Please contact us with any questions concerning this Safe Harbor Statement or any of the Company’s privacy practices at:
Sigma-Aldrich Corporation
General Counsel
3050 Spruce Street
St. Louis, MO 63178
privacy@sial.com

Changes to this Privacy Statement
This privacy statement may be amended consistent with the requirements of Safe Harbor. When we do update the privacy statement, we will also revise the “Last Updated” date at the bottom of this document. Any material changes to this privacy statement will also be posted on the Sigma-Aldrich web page (www.sigma-aldrich.com).