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LEGAL DOCUMENT UPDATE: PRIVACY NOTICE

Please note that our Privacy Notice has been updated as of April 2020


PRIVACY POLICY

© Copyright 2020, Koch Industries, Inc.
All Rights Reserved

Last Updated: April 2020

Privacy Policy in Spanish

Koch Industries, Inc. respects individuals’ concerns about the privacy of their
information. This global Policy applies to the personal information practices of
Koch Industries, its affiliate companies (e.g., Flint Hills Resources, LLC;
INVISTA Equities, LLC; Georgia-Pacific LLC; Molex, LLC; Guardian Industries
Holdings, LLC; Koch Business Solutions, LP; Koch Minerals & Trading, LLC; Koch
Ag & Energy Solutions, LLC; and Koch Engineered Solutions, LLC, ) and their
subsidiaries (together, “Koch Industries”). This Privacy Policy was developed to
explain our practices regarding personal information we collect from you or
about you on our sites online, offline via written or verbal communications with
us, mobile applications (“apps”), social networking presence, or from other
sources. While this Privacy Policy broadly describes the practices we have
adopted across Koch Industries globally, local laws vary and some jurisdictions
may place restrictions on our processing activities. Therefore, our actual
practices in such jurisdictions may be more limited than those described herein
to enable us to comply with local requirements. This Privacy Policy is not a
contract and does not create any contractual rights or obligations.

We recommend that you read this entire Privacy Policy to ensure you are fully
informed. However, if you only want to access a particular section of this
Privacy Policy, you can click on one of the links below to jump to a specific
section:

 * Personal Information We Collect and How We Use It
 * Information We Collect by Automated Means
 * With Whom We Share Your Information
 * Automated Decisions About You
 * User-Generated Content
 * Links to Other Sites 
 * How We Protect Personal Information
 * International Transfers of Personal Information
 * How Long is Personal Information Retained
 * Your Personal Information Rights
 * Children
 * State Required Notices
 * Updates to Our Privacy Policy
 * How to Contact Us

 




PERSONAL INFORMATION WE COLLECT AND HOW WE USE IT

We may collect personal information from individuals through our websites or by
other means (such as email, fax, mail, phone, mobile applications, third-party
applications, our parent, subsidiary, or affiliate companies, business partners,
and other third-parties such as commercial data vendors and public databases).
The principal ways you may provide the information and the types of information
you may submit, as well as the ways we may use the information, are listed
below.

Business Alerts, Newsletters and Other Communications – You may provide personal
information such as your name and contact details to receive business alerts,
newsletters and other communications (including emails).  It is in our
legitimate business interests to use the information you provide to send you the
communications and information you have requested and to communicate with you
about our products and services. If you no longer want us to send you business
alerts, newsletters or other communications, you may unsubscribe at any time by
contacting us via the contact information provided in the “How to Contact Us”
section of this Privacy Policy.

Business Purposes – On our websites and mobile applications you may be able to
register using your personal information to gain access to information related
to your business relationship with or products of Koch Industries. We use these
details to provide you with access to information about your business
relationship with us and to facilitate your use of the websites or mobile
applications. You may also choose to provide, or we may obtain, your personal
information at trade shows or from our distributors. It is in our legitimate
business interests to use this information so that we can manage our business
relationships and carry out marketing and sales activities.

You may also choose to connect to us via social networking services (e.g.,
Facebook or Twitter). When you connect to us via a social networking service, we
may collect personal information that you have provided to that service in
accordance with the service’s applicable Terms of Use and your privacy settings
within that social networking service. We may also choose to supplement
information you have provided to us by obtaining additional demographic
information about you from third-party sources in order to improve our
communications with you, give us better insight into your needs, and improve our
business where permitted under local law.

Careers – IIndividuals from all over the world apply for jobs with Koch
Industries through the Koch Careers or similar websites, third-party job posting
sites, job fairs, or directly to the business locations. The information job
seekers provide through this process is often maintained by third-party service
providers. This information may be maintained in locations within the United
States, accessible to our global recruiting team, and be shared with our
corporate affiliates for the purpose of evaluating you for positions within our
company. The information submitted by job seekers, such as name, contact details
and any other information relevant to the application is used to evaluate their
qualifications for employment and to contact them regarding possible employment
opportunities. It is in our legitimate business interests to use this
information in the selection process and to communicate with you, and it will be
necessary to provide us with this information so that we can assess your
application.

To allow the Company to meet certain government recordkeeping and reporting
obligations (particularly in the U.S.), job seekers may choose to provide
sensitive personal information, such as race, gender, disability status or
ethnic background. This information will not be considered in evaluating
candidates’ qualifications for employment.

Contact – If you contact us with questions, requests or comments through a
“Contact Us” link on our website, by similar means on Koch affiliates’ websites,
or via the contact information provided in the “How to Contact Us” section of
this Privacy Policy, we may process your personal information to verify your
identity or to track the inquiry internally to ensure we respond to your
questions, requests or comments.

Contests, Sweepstakes, Promotions and E-Commerce – We may collect personal
information such as your name, contact details and payment details, if you
request a coupon, or wish to participate in contests, sweepstakes, promotions,
or e-commerce activities related to Koch Industries or our products or services.
If you provide another person’s information to us, you must first obtain
appropriate consent from that individual prior to providing this information to
us and in order for us to use this information in the manner indicated. It is in
our legitimate business interests to use your personal information to
communicate with you and to process your requests and purchases. When we process
personal information to meet our legitimate interests, we put in place robust
safeguards to ensure that your privacy is protected and to ensure that our
legitimate interests do not override your interests or fundamental rights and
freedoms.

Contractual Obligations – If you are a vendor or a contractor, we may ask you to
provide personal information such as your name, photo, contact details or
business and financial details to establish and administer your account, process
payments, and for compliance with internal and legal requirements (which may
include medical testing and monitoring requirements, where applicable).  We use
your information for this purpose so that we can comply with our contractual
obligations to you.

Feedback – You may be able to submit feedback on our websites. If you choose to
give us your feedback, we may ask you for your personal information. We may also
ask you about your experience using our websites. It is in our legitimate
business interests to use the information you provide to enhance our websites,
evaluate the quality of our products, or to communicate with you about products
and services.

Incidents and Allegations – When you provide information about an incident or
allegation, detailed personal information including your name, contact details
and any relevant information about the incident or allegation may be collected.
We use these details to investigate and comply with any applicable company or
legal requirement. We may transfer and disclose your information to third
parties as required in the course of the investigation or to comply with any
legal obligation related to the information you provide.

Information Technology/Physical Security – We may collect personal information
when detecting and defending against security threats in accordance with our
legitimate business interests and our legal obligations. We use various IT tools
to detect and defend against online security threats (e.g., attacks, viruses,
malware, spam, phishing, malicious web content), to promote business continuity
of our information systems and assets, and to maintain optimal performance of
our IT systems. Likewise, to ensure physical security of our facilities we may,
where permitted under local law, document your presence or verify your identity,
utilize surveillance systems and/or location tracking while you are on Company
property.

Other Uses of Information – We may use the personal information you provide to
us for internal general business purposes in accordance with our legitimate
business interests. These purposes include administration of our websites, data
analytics, fraud prevention and compliance with our legal obligations,
standards, policies and procedures (i.e., due diligence checks and sanction
screening where applicable).

Scholarships, Grants and Awards – You may provide personal information such as
your name, contact details, education details, employment details,
qualifications, awards, etc. when applying for scholarships, grants or awards
offered by Koch Industries. It is in our legitimate business interests to use
the information you provide in the selection process, to communicate with you
and to publish a list of the recipients. It is necessary for you to provide us
with the information requested so that we can assess your application.

We may obtain your explicit consent to collect and use certain types of personal
information when we are required to do so by law (for example, in relation to
our direct marketing activities, or when we process sensitive personal
information). If we ask for your consent to process your personal information,
you may withdraw your consent at any time by contacting us using the details at
the end of this Privacy Policy.




INFORMATION WE COLLECT BY AUTOMATED MEANS

When you visit and interact with our websites and applications, we may collect
“Other Information” that does not inherently reveal your specific identity, in
order to learn how to best tailor our websites for our visitors. Examples of
what Other Information we may collect and how we and third-party service
providers may collect this information include:

Aggregation Information – Aggregated user information does not personally
identify you or any other user (for example, we may aggregate user information
to calculate the percentage of our users who have a particular telephone area
code). Aggregated data is treated in accordance with this Privacy Policy.

App Usage Data – When you download and use an app, we and our service providers
may 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.

Browser and Device Information – Certain information is collected by most
browsers or automatically through your device, such as your computer type,
operating system name and version, device manufacturer and model, Internet
browser type and version and the name and version of the online services (such
as the apps) you are using. We use this information to ensure that the online
services function properly.

Cookies – Cookies are pieces of information stored directly on the computer or
mobile device that you are using. Cookies allow us to collect information such
as browser type, time spent on the online services, pages visited, referring
URL, and other aggregated website traffic data. We and our service providers use
the information for security purposes, to facilitate navigation, to display
information more effectively, to collect statistical information, and to
personalize your experience while online.

Cookies further allow us to select which of our advertisements or offers are
most likely to appeal to you and display them while you are on the online
services or to send you advertisements and marketing emails. We may also use
cookies or other technologies to track responses to our online advertisements
and marketing emails. You can opt out of such interest-based advertising using
cookies set by participating NAI members at:
http://optout.networkadvertising.org/#!/. Opting out of interest-based
advertising does not mean you will no longer see advertising online. It does
mean that the company or companies from which you opt out will no longer show
ads that have been tailored to your interests.

If you do not want information collected through the use of cookies, there is a
simple procedure in most browsers that allows you to automatically decline
cookies or be given the choice of declining or accepting the transfer to your
computer of a particular cookie (or cookies) from a particular site. You can
choose whether to accept cookies by changing the settings on your browser or,
depending on your jurisdiction, by managing your tracking preferences as noted
in a separately posted cookie statement or via a posted cookie manager. If,
however, you do not accept cookies, you may experience some inconvenience in
your use of the online services. For example, we may not be able to recognize
your computer, and you may need to log in every time you visit. You also may not
receive advertising or other offers from us that are relevant to your interests
and needs. At this time, we do not respond to browser “Do-Not-Track” signals
except in jurisdictions where we are required to do so by law.

IP Address – 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 a user accesses the online services, along with the time of the visit
and the page(s) that were visited. Collecting IP addresses is standard practice
and is done automatically by many websites, applications and other services. We
use IP addresses for purposes such as calculating usage levels, diagnosing
server problems and administering our online services. We may also derive your
approximate location from your IP address to understand from what regions of the
world our website visitors come.

Geolocation Based Services – We may collect geolocation data (i.e., the physical
location of your device) if you have consented to us doing so, by, for example,
using satellite, cell phone tower, Wi-Fi signals, or other technologies. We may
use your device’s physical location to provide you with location-based services
and content.

For example, some of our apps allow you to enroll to receive location-based
offers by agreeing to the use of technologies that enable us to collect
information about your location through your mobile device. We will collect this
information if you opt-in through the app (either during your initial login or
later) to receive the offers and by enabling these capabilities on your mobile
device. In addition, if you download one of our business apps for use in
performing activities in your occupation, we may collect the geolocation of your
mobile device (if you consent to the collection of this data) to provide
information for the benefit of you and other users. For example, if you are a
driver for a motor carrier, and download one of our business apps designed for
motor carrier logistics, we may collect the geolocation of your mobile device
(if you consent) to track the status of a shipment and provide other logistics
services for customers, shippers or carriers.

Pixel Tags or Similar Technologies – Pixel tags (also known as web beacons and
clear GIFs) may be used in connection with some online services to, among other
things, track the actions of users of the online services (including email
recipients), measure the success of our marketing campaigns and compile
statistics about usage of the online services and response rates. We also use
Google Analytics and Facebook Pixels, which uses cookies and similar
technologies to collect and analyze information about use of our services and
report on activities and trends. These services may collect information
regarding the use of other websites, apps and online resources. You can learn
about Google’s practices by going to www.google.com/policies/privacy/partners/,
and opt-out by downloading the Google Analytics opt-out browser add-on,
available at
https://tools.google.com/dlpage/gaoptout. You can learn about Facebook’s
practices by going to
https://www.facebook.com/ads/about/?entry_product=ad_preferences
and opt-out by visiting http://www.aboutads.info/choices and
http://www.youronlinechoices.eu/.




WITH WHOM WE SHARE YOUR INFORMATION

We do not sell your personal information. We may share your information as
disclosed at the time you provide it and/or in the following circumstances:

Business Transfers – We may disclose your personal information, usage
information, and other information about you to parties acquiring part or all of
our assets, as well as to attorneys and consultants. If we transfer your
information to an acquirer, we will use reasonable efforts to direct the
acquirer to use your information in a manner that is consistent with this
Privacy Policy. Also, if any bankruptcy or reorganization proceeding is brought
by or against us, your information may be considered a company asset that may be
sold or transferred to third parties.

Corporate Affiliates – We may share the information you provide (such as
information about your orders, enquiries, applications or use of our websites)
within Koch Industries and with Koch affiliates for purposes described in this
Privacy Policy. We do this to run our business more efficiently and to have a
better understanding of our customers across business lines.

Law Enforcement Agencies, Courts, Regulators, Government Authorities or other
Third Parties – We may transfer and disclose your information to third parties
(i) to comply with a legal obligation, (ii) when we believe in good faith that
the law requires it, (iii) at the request of governmental authorities conducting
an investigation, (iv) to verify or enforce our policies, Terms of Use and other
agreements or to protect the rights, property, or safety of Koch Industries, our
customers, or others (v) to respond to an emergency, (vi) when we believe
disclosure is necessary or appropriate to prevent physical harm or financial
loss or in connection with an investigation of suspected or actual illegal
activity or (vii) otherwise to protect the rights, property, safety, or security
of third parties, users of our services or the public.

Marketing Partners –– In some cases, we may permit certain network advertising
companies and publishers to collect personal information on our sites. In
addition, and when permitted by law, our business partners may access personal
information about you that we have combined with such business partners’ data.
This collaboration with our business partners using the combined set of
information is to jointly send tailored promotional communications to you. If
you prefer not to receive these joint communications, you can opt out by
following the instructions included in any such communication.

Non-Personal Information – We may share non-personal information, such as
aggregate user statistics, demographic information, and usage information with
third parties.

Sharing With Your Consent – Our services may present you with the opportunity to
opt in to receive information or marketing offers from third parties or to
otherwise consent to the sharing of your information with third parties. If you
agree to have your personal information shared, your personal information will
be disclosed to the third-party subject to the privacy notice and business
practices of that third party.

Third-Party Service Providers – In order to carry out your requests, to make
various features, services and materials available to you through the services,
to respond to your inquiries, and for other purposes described in the “How We
Use Your Information” section of this Privacy Policy, we may share your personal
information or usage information with third parties that perform functions on
our behalf (or on behalf of our partners), such as companies or individuals
that: host or operate our sites; analyze data; provide customer service; mail
product samples or manage payments; advertisers; sponsors or other third parties
that participate in or administer our promotions, e-commerce activities, provide
marketing or promotional assistance (such as in connection with winner
selection, prize fulfillment, and as required by law, such as on a winners
list), or assist with risk management, compliance, legal and audit functions.
These service providers are not authorized by us to use or disclose the
information except as necessary to perform services on our behalf or comply with
legal requirements.

Business to Business Transactions– We make available certain apps that
facilitate transactions between businesses (for example, shipping apps that
assist with load delivery or pickups). If you use one of our business apps, we
may share your information with other users of the app to facilitate
transactions and communications between you and other users.

Because we operate as part of a global business, the recipients referred to
above may be located outside the jurisdiction in which you are located (or in
which we provide the services). See the section on “International Transfers of
Personal Information” below for more information.




AUTOMATED DECISIONS ABOUT YOU

We may make automated decisions about you using your personal information in the
following circumstances:

 * Automated processing may be used when evaluating large numbers of applicants
   for job vacancies. For these purposes we would request that you create a
   profile and answer some job-related questions to evaluate your skills as
   compared to the published job requirements. An algorithm may then be used to
   determine which candidates will be allowed to proceed to the next step within
   the selection process. We consider this data and process to be relevant
   because it will assist us to select the applicant most suitable for our
   vacancies. The outcome of the evaluation may have an impact on whether you
   are offered a role for the vacancy to which you applied.

You can contact us via the contact information provided in the “How to Contact
Us” section of this Privacy Policy to request further information about
automated decision-making, object to our use of automated decision-making, or
request an automated decision to be reviewed by us if required by local law.




USER-GENERATED CONTENT

Some of our services and social networking features may enable you to submit
your own content for public posting. Information you post in this fashion
becomes public information and is not subject to this Privacy Policy. Certain
areas of our websites and our social media pages may enable users to submit
personal information to Koch Industries or its affiliates. Such information will
be used in accordance with the website’s Privacy Policy. Postings, letters, and
other submissions become the property of Koch Industries and may be reproduced
in whole or in part, including your name, for any purpose and in any manner.




LINKS TO OTHER SITES

Our websites and communications may provide links to other websites, including
to social networks or partners that may use our logo(s) as part of a co-branding
agreement. To the extent that any linked services are not provided by Koch
Industries, we are not responsible for the services, or any of the content found
on these websites. If you provide information on and use third-party services or
websites, the privacy policy and terms of service on those sites are applicable.
We encourage you to read the privacy policies of websites that you visit before
submitting personal information.




HOW WE PROTECT PERSONAL INFORMATION

In proportion to the sensitivity of the information, we maintain reasonable
administrative, technical and/or physical safeguards and appropriate security
measures to protect personal information from loss, misuse or unauthorized
access, disclosure, alteration, or destruction of the information you provide.
However, we cannot guarantee the security of your personal information, as no
electronic data transmission or storage of information is completely secure. If
an incident is reported affecting your information, we will investigate and
comply with all required reporting obligations.




INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

Koch Industries is a global organization – headquartered in the United States –
that does business in many countries. We may share your personal information
among Koch Industries, its affiliates, our service providers, and other third
parties that may be located in countries outside of your own. Although the data
protection laws of these various countries may differ from those in your own
country, we have put in place appropriate safeguards (such as contractual
commitments) to ensure that your personal information is handled as described in
this Privacy Policy and in accordance with the law. For transfers of data
outside of the European Union, this includes standard contractual clauses
approved by the European Commission. For more information on the appropriate
safeguards in place, please contact us via the contact information provided in
the “How to Contact Us” section of this Privacy Policy.




HOW LONG IS PERSONAL INFORMATION RETAINED

We will keep your personal information for as long as we have a relationship
with you. Once our relationship with you has come to an end, we will retain your
personal information for a period of time that enables us to:

 * Maintain business records for analysis and/or audit purposes
 * Comply with record retention requirements under the law
 * Defend or bring any existing or potential legal claims
 * Address any complaints regarding the services

We will delete your personal information when it is no longer required for these
purposes. If there is any information that we are unable, for technical reasons,
to delete entirely from our systems, we will put in place appropriate measures
to prevent any further processing or use of the data.




YOUR PERSONAL INFORMATION RIGHTS

You may have certain rights regarding your personal information, subject to
local law. These include the following rights to:

 * access your personal information;
 * correct the information we hold about you;
 * erase your personal information;
 * restrict our use of your personal information;
 * object to our use of your personal information;
 * withdraw your consent for us to use your personal information, if applicable;
 * receive your personal information in a usable electronic format and transmit
   it to a third party (right to data portability); and
 * lodge a complaint with your local data protection authority (if applicable).

We encourage you to contact us to update or correct your information if it
changes or if the personal information we hold about you is inaccurate. Please
note that we will likely require additional information from you in order to
verify your identity and respond to your requests. If you would like to discuss
or exercise your applicable rights, subject to limitations established under
local law, please contact us via the contact information provided in the “How to
Contact Us” section of this Privacy Policy. We will respond to you within a
reasonable time and within the time limits established by applicable law.




CHILDREN

Our services are generally not directed to children under 16. We do not
knowingly collect personal information from anyone under 16 without parental
consent. If you become aware that we have collected personal information from a
child under the age of 16 without parental consent, please let us know so we can
take appropriate action.




STATE REQUIRED NOTICES

California: California consumers can click here to access Georgia-Pacific’s
California Consumer Privacy Notice.




UPDATES TO OUR PRIVACY POLICY

We may modify or update this Privacy Policy from time to time. We will always
indicate at the top of the Policy when it was most recently updated. If we
substantially change this Privacy Policy, we will notify you of the changes. Any
changes will be effective immediately upon the posting unless otherwise
indicated. Where changes to this Privacy Policy will have a fundamental impact
on the nature of processing or otherwise have a substantial impact on you, we
will give you sufficient advance notice so that you have the opportunity to
exercise your rights.




HOW TO CONTACT US

If you have any questions or comments about this Privacy Policy or if you would
like us to remove or update information we have about you or your preferences,
please contact us using our Privacy Intake Webform or write to the following
applicable contact:

Koch Industries, Inc.
Koch Engineered Solutions,
LLC Compliance & Ethics Department
P.O. Box 2256
Wichita, KS 67201-2256, USA Flint Hills Resources,
LLC Compliance & Ethics Department
P.O. Box 2256
Wichita, KS 67201-2256, USA INVISTA Equities,
LLC
Compliance & Ethics Department
P.O. Box 2936
Attn: Compliance & Ethics Office
Wichita KS, 67201-2936, USA Georgia-Pacific LLC
Privacy Office
P.O. Box 105605
Atlanta, GA 30348, USA
Guardian Industries Holdings, LLC
Compliance & Ethics Department
2300 Harmon Road
Auburn Hills, MI 48326, USA Molex, LLC
Compliance & Ethics Department
2222 Wellington Court
Lisle, IL 60532-1682 Koch Ag & Energy Solutions, LLC
Compliance & Ethics Department
P.O. Box 2985
Wichita, KS 67201-2985, USA Koch Minerals, LLC
Compliance & Ethics Department
P.O. Box 2256
Wichita, KS 67201-2256, USA Koch Business Solutions, LP
Compliance &åamp; Ethics Department
Data Protection Officer
P.O. Box 2256
Wichita, KS 67201-2985, USA



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