European Privacy Policy

INTRODUCTION

Hexcel respects individuals’ privacy and is committed to protecting it. This policy explains when and why companies in our groups located within the European Union (EU) collect personal information about individuals, how this information is used, to whom it is disclosed and the rights that you have over it.This policy may change from time to time so please check this page occasionally to ensure that you are familiar with any changes. Please see Changes to this Policy below.

This policy was last updated on May 2018.

WHO WE ARE 

The Hexcel group of companies within the European Union is made up of numerous individual companies. For a full list of these companies, please see the table About Our Group below. Whenever dealing with our group companies, the relevant company that corresponds with details in the table About Our Group below is the controller in relation to the processing activities described below. A “controller” is an organisation that decides why and how your personal information is processed.

Where this policy refers to “we”, “our” or “us” below, unless it mentions otherwise, it is referring to the particular company that is the controller of your personal information.

HOW WE COLLECT YOUR PERSONAL INFORMATION

We collect personal information from you in the following ways:

Personal Information You Give to Us Voluntarily

This is information about you that you give to us when:

  • Following and posting on our social media pages

  • Corresponding with us by phone, email or in another way

  • Visiting our offices

  • Providing us with your business cards at events and business meetings

  • Receiving products and services from us as a member of our clients’ personnel

  • Providing products and services to us as a member of our suppliers’ personnel

  • Participating in our corporate social responsibility programmes

If you complete any surveys that we request you complete for research purposes, we will collect information in such circumstances as well. The information you give us includes your name, address, email address and phone number, enquiry details, and may include records of any correspondence and responses to any surveys.

Personal information we collect about you: We may automatically collect information from you when you visit our offices (for example when you use a guest access card at our security gates).

Personal information we may receive from other sources: We obtain certain personal information about you from sources outside of our business which may include our group companies, our suppliers, our clients or other third party companies. The third parties that may send us personal information about you are as follows: 

Source of personal information
Privacy policy
The categories of personal information we obtain from these sources (see below)
Each of our group companies in the EU (see About Our Group)
This policy
The categories described below
Each of our group companies in the U.S. (see About our Group)
http://www.hexcel.com/Site/About/privacy.aspx
The categories described below
LinkedIn, Inc.
https://www.linkedin.com/legal/privacy-policy
Contact, biographical and correspondence details

CATEGORIES OF PERSONAL INFORMATION WE PROCESS ABOUT YOU

We process a range of personal information about you. To make it easier to understand the information that we use about you, we have divided this information into categories in the table below and provided a short explanation of the type of information each category covers.

Category
Personal information included in this category
Behavioural
your activities, actions and behaviours (e.g. your period of attendance at our offices)
Biographical
your life experiences (e.g. your qualifications)
Contact
information which can be used to address, send or otherwise communicate a message to you (e.g. your name, home address, the name of the organisation for whom you work, work address, telephone number, job role, social media handle or email address)
Identity
information contained in a formal identification document or social security or other unique reference relating to you e.g. passport or driving licence
Monitoring
information relating to the surveillance or monitoring of your activities (e.g. CCTV footage)
Performance
information regarding your work performance (e.g. your time sheet)
Fraud
information relating to the occurrence, investigation or prevention of fraud
Legal
information relating to legal claims made by you or against you or the organisation for whom you work or the claims process (e.g. a claim form)
Correspondence
information contained in our correspondence or other communications with you










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HOW WE USE YOUR PERSONAL INFORMATION

The purposes for which we use your information and the legal basis under data protection laws on which we rely to do this are explained below.

  • Where processing is in your VITAL INTEREST: We may use your personal information to protect your safety during your visits to our offices or factory sites. It is in your vital interest for us to use your personal information in this way.
  • Where processing is necessary for us to pursue a LEGITIMATE INTEREST: We may use and process your personal information where it is necessary for us to pursue our legitimate interests as a business, or that of a third party, for the following purposes:
    • Processing necessary for us to promote our business, our brand and our products and services
      • if you work for a corporate business, to contact you by email or by telephone with marketing information about our products and services. We may use your personal information to tailor or personalise the marketing communications you receive to make them relevant to you. 
      • to create a profile of you and analyse this to obtain insight about market or industry trends, client behaviours which inform our marketing strategy, and to enhance and personalise your experience as a visitor (as well as the marketing information we contact you with in the ways described in the paragraph above).
    • Processing necessary for us to support our clients with sales, support and other enquiries
      • to correspond and communicate with you in connection with the products and services we offer.
      • to train and monitor our staff and to identify ways of improving their call handling and your customer service experience.
    • Processing necessary for us to respond to changing market conditions and our customers’ needs
      • for market research in order to improve the products and services that we and our group companies deliver.
      • to notify you about changes to our products and services.
    • Processing necessary for us to operate the administrative and technical aspects of our business efficiently and effectively
      • to enable us to make payments to contractors who provide products and services to us.
      • for the prevention of fraud and other criminal activities.
      • to verify the accuracy of information we hold about you.
      • for network and information security purposes in order for us to take steps to protect your information against loss or damage, theft or unauthorised access.
      • to comply with a request from you in connection with the exercise of your rights (for example where you have asked us not to contact you for marketing purposes, we will keep a record of this on our suppression lists in order to be able to comply with your request).
      • for the purposes of a corporate restructure or reorganisation or sale of our business or assets.
      • for efficiency, accuracy or other improvements of our databases and systems e.g. by combining systems or consolidating records we or our group companies hold about you;
      • to enforce or protect our contractual or other legal rights or to bring or defend legal proceedings.
      • for general administration including managing your queries, complaints, or claims, to send service messages and to provide you with important information about our business.

Where Required to Comply with our Legal Obligations

We will use your personal information to comply with our legal obligations:

  • To assist any public authority, health and safety body, environmental body or criminal investigation body, where we are under a legal obligation to do so.
  • To identify you when you contact us.
  • To verify the accuracy of data we hold about you.
  • To respond to and resolve your complaints in relation to our products and services.

OTHERS WHO MAY RECEIVE OR HAVE ACCESS TO YOUR PERSONAL INFORMATION

Group Companies

We may share your information with other companies within the Hexcel group of companies. They may use your personal information in the ways set out in How We Use Your Personal Information, in connection with services that complement our own or for administrative and audit purposes.Please see the table About Our Group below for the details of those of our group companies with whom we may share your personal information.

Our Suppliers and Service Providers

We may share your information with our third party service providers, agents, subcontractors and other organisations (as listed below) for the purposes of providing services to us or directly to you on our behalf.

Recipient / relationship to us
Industry sector (and sub-sector)
Location
Accountancy services
Professional services (accountancy)
EEA
Banks, payment processors and financial services providers
Financial (banking)
EEA
Cloud storage providers
IT (cloud services)
EEA & U.S.
Financial auditing services
Audit (financial)
EEA
Government tax administration offices
Government (tax)
EEA
Insurance brokers – for claims
Insurance (broker)
EEA
Insurance services – for claims
Insurance (underwriting)
EEA
IT support service providers
IT (support and maintenance)
EEA
Legal advisers
Professional services (legal services)
EEA
On-site security access control services
Security (on-site)
EEA
Taxi service providers
Transportation (on demand)
EEA
Travel & accommodation providers, including expense reporting
Travel/accommodation (business travel)
EEA & U.S.


When we use third party service providers, we only disclose to them any personal information that is necessary for them to provide their service, and we have a contract in place that requires them to keep your information safe and secure.

Other Ways We May Share Your Personal Information

We may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation. We may also transfer your personal information if we’re under a duty to disclose or share it in order to comply with any legal obligation, to detect or report a crime, to enforce or apply the terms of our contracts or to protect the rights, property or safety of our visitors and customers. We will always take steps with the aim of ensuring that your privacy rights continue to be protected.

WHERE WE STORE YOUR PERSONAL INFORMATION 

All information you provide to us may be transferred to countries outside the European Economic Area (EEA). For example, this may happen where any of our group companies are located in a country outside of the EEA or if any of our servers or those of our third party service providers are from time to time located in a country outside of the EEA. These countries may not have similar data protection laws to the U.K. The non-EEA countries to which we transfer your personal data are listed in the table Others Who May Receive or Have Access to Your Personal Information.

If we transfer your information outside of the EEA in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this policy. These steps include imposing contractual obligations on the recipient of your personal information or ensuring that the recipients are subscribed to "international frameworks" that aim to ensure adequate protection. For more information about the safeguards on which we rely in respect of transfers to our group companies located in the U.S., please see the Hexcel Privacy Policy. Please contact us using the details at the end of this policy for more information about the protections that we put in place and to obtain a copy of the relevant documents.

If you use our services whilst you are outside the EEA, your information may be transferred outside the EEA in order to provide you with those services.

HOW LONG WE KEEP YOUR PERSONAL INFORMATION 

If we collect your personal information, the length of time we retain it is determined by a number of factors including the purpose for which we use that information and our obligations under other laws. We do not retain personal information in an identifiable format for longer than is necessary. We retain the personal information we have about you for the following periods:

Data Records
Standard Retention Period
Accounting and Financial, which may include: Contact data
7 years from the end of the financial year in which payments/reports were made.
Environmental (incident reports / inspections)
Indefinitely
Health and Safety
Illness and Injury Log(s)
Exposure Record(s)
Incident Reports
Inspections and Hazardous Work Permits
- 5 years from the end of the calendar year in which entry was made
- 50 years after termination of engagement
- 5 years from date of entry
- 3 years
Export and Import, which may include: Contact data
5 years from issue date or last revision (as applicable)
IT
Duration of engagement
Insurance (accident reports and notice of/settled claims)
10 years from issue date, last revision or payment period (as applicable)
Legal, which may include: Contact data
Indefinitely
Sales and Marketing (service records), which may include: Contact data
Duration of engagement, and 7 years after termination of engagement


The only exceptions to the Standard Retention Period stated above are where:

  • The law requires us to hold your personal information for a longer period, or delete it sooner.

  • You exercise your right to require us to retain your personal information for a period longer than our stated retention period (see Erasing Your Personal Information or Restricting its Processing below).

  • Uou exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law (see Erasing Your Personal Information or Restricting its Processing below).
  • We bring or defend a legal claim or other proceedings during the period we retain your personal information, in which case we will retain your personal information until those proceedings have concluded and no further appeals are possible.

  • In limited cases, existing or future law or a court or regulator requires us to keep your personal information for a longer or shorter period.

AUTOMATED DECISION MAKING

We do not envisage that any decisions will be taken about you using purely automated means, however we will update this policy if this position changes.

YOUR RIGHTS

You have a number of rights in relation to your personal information under data protection law. In relation to certain rights, we may ask you for information to confirm your identity and, where applicable, to help us to search for your personal information. Except in rare cases, we will respond to you within one month from either the date that we have confirmed your identity or, where we do not need to do this because we already have this information, from the date we received your request.

Accessing Your Personal Information

You have the right to ask for a copy of the information that we hold about you by emailing or writing to us at the address at the end of this policy. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.

Correcting and Updating Your Personal Information

The accuracy of your information is important to us and we are working on ways to make it easier for you to review and correct the information that we hold about you.

In the meantime, if you change your name or address/email address, or you discover that any of the other information we hold is inaccurate or out of date, please let us know by contacting us in any of the details described at the end of this policy.

Withdrawing Your Consent

Where we rely on your consent as the legal basis for processing your personal information, as set out under How We Use Your Personal Information, you may withdraw your consent at any time by contacting us using the details at the end of this policy. If you would like to withdraw your consent to receiving any direct marketing to which you previously opted-in, you can do so using our unsubscribe tool. If you withdraw your consent, our use of your personal information before you withdraw is still lawful.

Objecting to Our Use of Your Personal Information and Purely Automated Decisions Made About You

Where we rely on your legitimate business interests as the legal basis for processing your personal information for any purpose(s), as under How We Use Your Personal Information, you may object to us using your personal information for these purposes by emailing or writing to us at the address at the end of this policy. Except for the purposes for which we are sure we can continue to process your personal information, we will temporarily stop processing your personal information in line with your objection until we have investigated the matter. If we agree that your objection is justified in accordance with your rights under data protection laws, we will permanently stop using your data for those purposes. Otherwise we will provide you with our justification as to why we need to continue using your data.

You may object to us using your personal information for direct marketing purposes and we will automatically comply with your request. If you would like to do so, please use our unsubscribe tool.

You may also contest a decision made about you based purely using automated processing by contacting us.

Erasing Your Personal Information or Restricting its Processing

In certain circumstances, you may ask for your personal information to be removed from our systems by emailing or writing to us at the address at the end of this policy. Unless there is a reason that the law allows us to use your personal information for longer, we will make reasonable efforts to comply with your request.

You may also ask us to restrict processing your personal information where you believe it is unlawful for us to continue processing, you have objected to its use and our investigation is pending or you require us to keep it in connection with legal proceedings. In these situations we may only process your personal information whilst its processing is restricted if we have your consent or are legally permitted to do so, for example for storage purposes, to protect the rights of another individual or company or in connection with legal proceedings.

Transferring Your Personal Information in a Structured Data File

If we rely on your consent as the legal basis for processing your personal information or need to process it in connection with your contract, as set out under How We Use Your Personal Information, you may ask us to provide you with a copy of that information in a structured data file. We will provide this to you electronically in a structured, commonly used and machine readable form, such as a CSV file. Where applicable, you can ask us to send your personal information directly to another service provider, and we will do so if this is technically possible. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.

Complaining to a Data Protection Regulator

You have the right to lodge a complaint with a data protection regulator in Europe, in particular in a country you work or live or where your legal rights have been infringed. However, we encourage you to contact us before making any complaint and we will seek to resolve any issues or concerns you may have.

CHANGES TO THIS POLICY

We may review this policy from time to time and any changes will be notified to you by email. Any changes will take effect seven (7) days after the date of our email. We recommend you regularly check for changes and review this policy.

CONTACT US 

Please direct any queries about this policy or about the way we process your personal information to our Data Protection Manager using our contact details below. If you wish to write to us, please write to Hexcel Composites Limited, The Data Protection Manager, Duxford, Cambridge CB22 4QB, United Kingdom. Our email address for data protection queries is GDPR@Hexcel.com. If you would prefer to speak to us by phone, please call +44 (0) 1223 838299.

ABOUT OUR GROUP

Group companies located in Europe

Hexcel Group Company
Country
Registered Address
Registration Number
Hexcel Holding GmbH
Austria
Schardinger Staze 1, 4061, Pashing, AUSTRIA
FN 229351g
Hexcel Composites GmbH & Co KG
Austria
Industriegelaende 2, A-4720, Neumarkt/Hausruck, AUSTRIA
FN 239670g
Hexcel Composites Sprl
Belgium
Parc Industriel, Rue 3 Bourdons, 54, 4840, Welkenraedt, BELGIUM
BE 04 0245 9235
Hexcel Composites SASU
France
45 Rue de la Plaine, CS10027, 01120, Dagneux, CEDEX, FRANCE
410 286 702
Hexcel Fibers SASUFrance45 Rue de la Plaine, CS10027, 01120, Dagneux, CEDEX, FRANCE
493 663 835
Hexcel Holdings SASUFrance
45 Rue de la Plaine, CS10027, 01120, Dagneux, CEDEX, FRANCE
955 508 007
Hexcel Reinforcements SASU
France
45 Rue de la Plaine, CS10027, 01120, Dagneux, CEDEX, FRANCE
410 287 379
Structil SASU
France
45 Rue de la Plaine, CS10027, 01120, Dagneux, CEDEX, FRANCE
331 620 385
Hexcel Composites GmbH
Germany
Sophie-Scholl-Weg 22, 21684, Stade, GERMANY
HRB101120
Hexcel Composites Srl
Italy
Piazza A.De GASPERI, 32, 21047 Saronno, ITALY
02 520 540 127
Hexcel Holding Spain SL
Spain
Poligono Industrial Ciudad, de Parla, C/Bruselas 10-16, 28980, Parla, Madrid, SPAIN
B83438820
Hexcel Composites SL
Spain
Poligono Industrial Ciudad, de Parla, C/Bruselas 10-16, 28980, Parla, Madrid, SPAIN
B78399672
Hexcel Fibers SL
Spain
Curtidores 15, 45200 Illescas, Toledo, SPAIN
B45598463
Hexcel Composites Limited
United Kingdom
Ickleton Road, Duxford, Cambridge, CB22 3QB, UK
03069887
Hexcel UK Reinforcements Limited
United Kingdom
Ickleton Road, Duxford, Cambridge, CB22 3QB, UK
03685736


Group companies located in the U.S.A.

Hexcel Group Company
Country
Principal Place of Business
Registration Number
Hexcel Corporation
USA
281 Tresser Boulevard, 16TH Floor, Stamford, CT 06901-3261, USA
94-1109521