Privacy Policy

How SL Metals Corporation collects, uses and protects personal information

Effective date: 01 01 2016        Last updated:

1.  Introduction

SL Metals Corporation ("SL Metals", "we", "us" or "our") is an international distributor of secondary aluminum alloys, silicon metal and specialty industrial materials. This Privacy Policy explains what personal information we collect through our website at slmet.com, how we use it, who we share it with, and what rights you have over it.

This policy applies to the website and to enquiries submitted through it. It does not apply to personal information processed under a separate contract of sale, which is governed by the terms of that contract.

Our website is intended for business and professional use. We do not knowingly collect information from consumers acting outside a trade or profession, and we do not knowingly collect information from anyone under 18.

2.  Who we are

For the purposes of the EU and UK General Data Protection Regulation, the data controller is:

SL Metals Corporation

134 South Dixie Highway, Suite 212, Hallandale Beach, FL 33009, United States

Telephone: +1 (305) 320-4433

Email: info@slmet.com

If SL Metals offers goods or services to, or monitors the behaviour of, individuals located in the EU or UK, an Article 27 representative may be required in each of those territories.

3.  Information we collect

3.1  Information you give us

When you submit an enquiry through our contact form, or contact us by email, telephone, WhatsApp, Telegram or WeChat, we collect:

  • Your full name
  • Your company name
  • Your country
  • Your email address
  • Your telephone number, where you provide it
  • The product you are interested in and the content of your message
  • How you heard about us, where you provide it

We may also collect information you provide in the course of a commercial relationship, such as company registration details, shipping and billing addresses, and the names and contact details of your employees involved in a transaction.

3.2  Information collected automatically

When you visit the website, our servers and any analytics tools we use may record:

  • Your IP address and approximate location derived from it
  • Browser type and version, operating system and device type
  • Pages viewed, time spent, and the site or search term that referred you
  • Date and time of your visit

3.3  Compliance screening information

Because our trade is subject to international sanctions and export-control regulations, we screen counterparties and their representatives against government watchlists, including the OFAC Specially Designated Nationals list and the BIS Entity List. This screening may involve processing the names of individuals connected with a prospective or actual customer.

4.  How we use your information, and our legal basis

Where the EU or UK GDPR applies, we rely on the following legal bases:

Purpose Legal basis Notes
Responding to your enquiry and providing quotations Steps taken at your request prior to entering a contract (Art. 6(1)(b)) Without this information we cannot reply to you
Performing a contract of sale and arranging shipment Performance of a contract (Art. 6(1)(b)) Includes sharing with logistics and inspection providers
Sanctions and export-control screening Compliance with a legal obligation (Art. 6(1)(c)) and legitimate interests (Art. 6(1)(f)) Required by US and, where applicable, EU law
Maintaining trade, customs and accounting records Compliance with a legal obligation (Art. 6(1)(c)) Statutory retention periods apply
Improving and securing the website Legitimate interests (Art. 6(1)(f)) Our interest in a functioning, secure site
Analytics and non-essential cookies Consent (Art. 6(1)(a)) You may withdraw consent at any time
Sending commercial updates, where offered Consent (Art. 6(1)(a)) or legitimate interests for existing customers You may unsubscribe at any time

We do not sell personal information, and we do not use it for automated decision-making that produces legal or similarly significant effects.

5.  Cookies

Our website uses cookies and similar technologies. Strictly necessary cookies keep the site functioning and cannot be switched off. Analytics and marketing cookies are used only with your consent, which you may give or refuse through our cookie banner and change at any time.

Most browsers allow you to block or delete cookies through their settings. Blocking strictly necessary cookies may prevent parts of the site from working.

6.  Who we share your information with

We share personal information only where necessary, and only with:

  • Our offices in the United States and Japan, and personnel within our group who need the information to respond to you
  • Service providers acting on our instructions — website hosting, email, IT support, analytics and customer-relationship tools
  • Logistics providers, freight forwarders, customs brokers and port agents, where required to arrange a shipment
  • Independent inspection and testing bodies, such as SGS, where an inspection is arranged
  • Banks, insurers and professional advisers, where required for a transaction
  • Government authorities, regulators and law enforcement, where required by law or to comply with sanctions and export-control obligations
  • A purchaser or successor, in the event of a sale, merger or reorganisation of our business

We require our service providers to process personal information only on our instructions and to keep it secure.

7.  International transfers

SL Metals is based in the United States and operates offices in Miami, New York and Tokyo. Information you provide will be transferred to and processed in the United States, and may be transferred to Japan or to other countries where our service providers operate.

Where personal information is transferred out of the European Economic Area or the United Kingdom, we rely on an appropriate safeguard — in most cases the European Commission's Standard Contractual Clauses, together with the UK International Data Transfer Addendum where the UK GDPR applies. You may request a copy of the relevant safeguard by writing to info@slmet.com.

8.  How long we keep it

We keep personal information only as long as necessary for the purpose for which it was collected, and then delete it or anonymise it. Our current retention periods are:

  • Enquiries that do not lead to a transaction — 24 months from the last contact
  • Customer and transaction records — 7 years after the end of the relationship, to meet accounting, customs and tax obligations
  • Sanctions screening records — 5 years, as required by applicable US recordkeeping rules
  • Website analytics data — 14 months

9.  Security

We maintain technical and organizational measures appropriate to the risk, including encryption of the website in transit using TLS, access controls limiting personal information to personnel who need it, and secure disposal of records at the end of their retention period. No method of transmission over the internet is completely secure, and we cannot guarantee absolute security.

10.  Your rights

Subject to the law that applies to you, you may have the right to:

  • Ask what personal information we hold about you and obtain a copy of it
  • Have inaccurate information corrected
  • Ask us to delete information we no longer need
  • Ask us to restrict how we use your information, or object to our use of it
  • Receive your information in a portable, machine-readable format
  • Withdraw consent at any time, where we rely on consent
  • Complain to a supervisory authority

To exercise any of these rights, write to info@slmet.com. We will respond within one month, or within any shorter period required by applicable law. We may ask you to verify your identity before we act.

If you are in the EU or UK, you may lodge a complaint with your national data protection authority. If you are in Japan, our handling of personal information is also subject to the Act on the Protection of Personal Information, and you may contact the Personal Information Protection Commission. If you are a resident of California or another US state with a comprehensive privacy law, you may have equivalent rights under that law; we do not sell or share personal information as those terms are defined in such laws.

11.  Third-party links and messaging platforms

Our website links to third-party messaging platforms, including WhatsApp, Telegram and WeChat. When you contact us through those platforms, your use of them is governed by their own privacy policies, over which we have no control. We receive only the information you choose to send us. Please do not send sensitive or confidential commercial information through a messaging platform.

12.  Changes to this policy

We may update this policy from time to time. The effective date at the top of this document shows when it was last revised. Where a change is material, we will take reasonable steps to bring it to your attention.

13.  Contact us

Questions about this policy, or about how we handle personal information, should be addressed to:

SL Metals Corporation — Privacy, 134 South Dixie Highway, Suite 212, Hallandale Beach, FL 33009, United States(opens in new tab)

Email: info@slmet.com
Telephone: +1 (305) 320-4433