Privacy Notice for Applicants

Last Updated: August 30, 2023

Any data which relates to you (“Personal Data”) that you provide to Huntsman International LLC, its subsidiaries and/or affiliates (collectively “Huntsman”) as part of the online recruitment process and/or otherwise for potential employment (including any sensitive Personal Data) may be held and/or processed for the purposes of your registration, application and potential selection, and in connection with any subsequent employment or placement at Huntsman, unless otherwise indicated at the time of collection of such data. Huntsman has implemented technical and organizational measures to protect your Personal Data in accordance with applicable privacy laws.

By submitting your application or resume, you declare to have read this Privacy Notice for Applicants (“Notice”).

This Notice explains:

  • what information we collect in the course of the application and recruitment process;
  • how we use this data;
  • what technical means we use to process your data;
  • who has access to your data;
  • how long we keep your data;
  • how you can consult and update the data we collect about you;
  • how we protect your data; and
  • how you can reach us with questions and comments.
  1. Data Privacy Framework for Applicants in the EU, the EEA, the UK and Switzerland.

Huntsman complies with the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”), the UK Extension to the EU-U.S. DPF (“UK DPF Extension”) and the Swiss-U.S. Data Privacy Framework (“Swiss-U.S. DPF”) as set forth by the U.S. Department of Commerce.  Huntsman has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (“EU-U.S. DPF Principles”) with regard to the processing of Personal Data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK DPF Extension.  Huntsman has also certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (“Swiss-U.S. DPF Principles” and together with the “EU-U.S. DPF Principles”, the “Principles”) with regard to the processing of Personal Data received from Switzerland in reliance on the Swiss-U.S. DPF.  If there is any conflict between the terms in this Notice and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. 

In compliance with the EU-U.S. DPF, the UK DPF Extension and the Swiss-U.S. DPF, Huntsman commits to resolve DPF Principles-related complaints about our collection and use of your personal information.  EU, UK and Swiss individuals with inquiries or complaints regarding our handling of Personal Data received in reliance on the EU-U.S. DPF, the UK DPF Extension and the Swiss-U.S. DPF should first contact Huntsman using the contact methods set forth in Section 10 of this Notice. Huntsman also commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities and the Swiss Federal Data Protection and Information Commissioner with regard to unresolved complaints concerning our handling of human resources data received in reliance on the EU-U.S. DPF and the Swiss-U.S. DPF in the context of the employment relationship.

Attached as Appendix A to this Notice is Huntsman’s Data Privacy Framework Addendum.  This Addendum contains additional information about Huntsman’s obligations and your rights under the EU-U.S. DPF, the UK DPF Extension and the Swiss-U.S. DPF including the choices and means Huntsman offers applicants for limiting the use and disclosure of Personal Data, the possibility of invoking binding arbitration in the event of a dispute and Huntsman’s liability to you in the event of an onward transfer of your data to a third party.  To learn more about the Data Privacy Framework program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

  1. What data do we collect?

This Notice covers all Personal Data that we receive from you and collect and process about you in the context of your application and the further recruitment process. This includes Personal Data collected and processed as part of the online interactions you have with Huntsman. After completion of the application process, your Personal Data may be retained and further processed in accordance with this Notice, for the purposes of matching your skills and qualifications to future vacancies (where permitted by applicable law), identifying you as a potential candidate for future suitable vacancies and/or to inform you of such future suitable vacancies. If you are selected for employment by Huntsman, your Personal Data may be used for the purpose of entering into an employment relationship or contract, including sending you correspondence or general information related to the employment relationship or contract.

Personal Data collected and processed includes: identification and contact details, personal characteristics (such as gender and date of birth), education and work experience (including grades, certificates, diplomas, references), job preferences, strengths, areas of interest, hobbies, videos, audio clips, financial data (e.g. current and desired salary, where collection is allowed by law), all data from your resume, all visible data from your LinkedIn profile and other social media or public websites (if such information is collected) and all other information you give us in writing or orally in the context of your application.  Personal Data may be collected by Huntsman or via authorized service providers retained by Huntsman mentioned in Section 5.

Additionally, Huntsman’s online recruitment website (the “Site”) also collects Personal Data about you. Huntsman monitors user traffic patterns throughout the Site according to a user’s domain name, browser type, date and time of access and pages viewed.  Web servers collect the domain names and other technical information associated with visitors to the Site. This information is collected in order to measure the number of visitors to the Site and to determine which areas of the Site users find useful based upon the amount of traffic to particular areas. Huntsman uses this information to enhance users’ experience at the Site and to better prepare future content based on the interests of users.

Cookies are small text files sent to and stored on users’ computers that allow sites to recognize repeat users, facilitate users’ access to sites and allow sites to compile aggregate data that will allow content improvements.  Cookies do not damage users’ computers or files.  Web beacons are transparent graphic images, often just the size of a single pixel, that allow sites to track activity on the Site.

Huntsman uses both cookies and web beacons on our Site to collect aggregate and anonymous usage data so that we can improve the functionality of the Site.  Huntsman may also use cookies which can contain personal information to enhance the user experience.  For example, the Site may permit you to select a language and/or geographic location preference, which will be stored for future visits. 

The Site uses third-party cookies from Huntsman’s service providers to manage your activity during a session. These cookies track sessions, user inputs and user authentication. These service providers also use cookies to determine whether you navigated to the Site from an external one to track the effectiveness of external postings. Huntsman does not “sell” or “share” your Personal Data in a manner which would require the recognition of do-not-track signals under applicable law.

  1. How do we use your data?

Your data will be used within the framework of the application and recruitment process, including for:

  1. assessing your skills, qualifications and interests within the framework of our career prospects;
  2. checking your data, checking references and/or performing background or drug/alcohol checks (where applicable and permitted under applicable laws);
  3. communication concerning the recruitment process and your candidacy; and
  4. making improvements in the recruitment process of Huntsman.

The processing for purposes 1, 2 and 3 above are necessary for the possible conclusion of an employment relationship or contract between you and Huntsman, and the processing for purpose 4 is based on the legitimate interest of Huntsman to improve its recruitment processes, on the basis of the course of the application and recruitment process with you.

Huntsman (or authorized service providers) may use an automated tool to process your Personal Data in order to source, screen and match your profile with a vacancy. This automated tool may be one method used to help identify fitting candidates, which is necessary for the possible conclusion of an employment relationship or contract between you and Huntsman. Other non-automated methods of identifying fitting candidates are also used by Huntsman.

  1. How do we process your data? 

Applications that we receive are stored electronically by our HR staff in a digital file on our central servers or in an online database in the cloud.

  1. Who has access to your data?

Your data can be shared between the Huntsman entities. Within these entities, HR staff and managers have access to your data. In certain cases, technical personnel can access your data, but only to the extent that this is necessary to ensure the proper functioning of our technical systems.

Except as set out in this Notice, your Personal Data will not be disclosed to third parties. Your Personal Data may be disclosed within the Huntsman entities.

When you submit registration information or your resume to Huntsman using a third-party website, your information and your resume will be hosted on the server of that third-party organization. In such case, the handling of your registration information and your resume will be subject to the privacy policies of that provider.

In addition to the above, Huntsman may share your personal information with authorized service providers and third parties to:

  • perform recruiting and candidate identification services on our behalf;
  • perform administrative services on our behalf such as payroll, background check, drug and alcohol testing, resume verification.
  • perform IT services on our behalf such as cloud hosting and IT administration;
  • comply with legal obligations, including in response to a legitimate legal request from law enforcement authorities or other government regulators;
  • maintain the security and integrity of our networks and systems;
  • investigate suspected or actual illegal activity;
  • prevent physical harm or financial loss; or
  • support the sale or transfer of all or a portion of our business or assets (including through bankruptcy).

These service providers are primarily based in the US and the European Economic Area; they may also be based in other locations where Huntsman operates.

Huntsman requires all service providers to use Personal Data only for the purposes identified in this Notice and all service providers will provide services under a contract which restricts use of information to that which is necessary to perform services on our behalf or to comply with legal requirements.

  1. International transfers of data. 

Huntsman may store, transfer or process your Personal Data outside the area in which you reside. If required by law, your Personal Data will be protected by Standard Contractual Clauses or other appropriate data transfer mechanisms including, as far as U.S.-based entities are concerned, adherence to the EU-U.S. DPF, the UK DPF Extension and the Swiss-U.S. DPF.  To the extent Standard Contractual Clauses are used, you may obtain a copy by reaching out via the contact details under Section 10 of this Notice.

  1. How long do we keep your data?

If you do not enter into an employment relationship with Huntsman, your Personal Data provided in connection with your application will be retained by Huntsman for a period of a maximum of two years unless applicable law requires a different retention period.

In case of possible employment, your details will be included in your personnel file and will be subject to the terms and conditions of the applicable employee privacy notice.

  1. Your rights. 

You have the right to view, correct or delete your data; as well as the right to obtain a copy of the specific pieces of Personal Data Huntsman has collected about you or to transfer the Personal Data that you have provided to us to another organization. To this end, please click on the following link to make a Data Subject Access Request (https://www.huntsman.com/privacy/data-request). Please note that these rights are not absolute under applicable law. Should Huntsman decline your request, we will provide you with a reason why such a request was declined.

In addition to the above, you have the right to restrict our use of your Personal Data in certain circumstances, object to the processing of your data where our legal basis for processing your data is our legitimate interests, not to be subject to a decision based on automated processing, including profiling which has legal or similar significant effects and to lodge a complaint with a supervisory authority - for EEA residents, in particular in the EEA member state of your habitual residence, place of work or of an alleged infringement of the GDPR. Please note that these rights may not be exercised in certain circumstances. Please contact us via our contact details set out in Section 10 if you have any questions about any of your rights.

If you are a California resident, California law does not permit Huntsman to discriminate against you because you exercised any of your rights under this Notice. Additionally, California law permits California residents to designate an agent to manage their rights under California law. If you qualify and you would like to designate an agent to manage your privacy preferences, you may do so using the mechanisms noted below under “Contact”.  We will need sufficient personal information about your authorized agent to be able to identify them.  As part of this process, you must have permission from your authorized agent to disclose their personal information to us for the purpose of acting as your agent.  Your designated agent will then be able to contact us using the same mechanisms available to you.  If you submit a Data Subject Access Request, to verify the request, we will match identifying information provided by you to the personal information we have on file, taking into account the type of request as well as the type, risk and value of the personal information involved. 

You remain responsible for the data you provide to us and for the consequences of its use. You may not provide information to us that infringes obligations relating to privacy, confidentiality, intellectual property or trade secrets of others, unless you have the data subject’s explicit consent. By passing on references you also guarantee that you have informed those individuals of the processing of their Personal Data as described here.

  1. Security of your data.

We secure our IT systems against unauthorized access. Only authorized persons have access to your data, based on a personal login and password and only via a secure internet or intranet connection. Consultation of Personal Data by the authorized persons is permitted only to the extent relevant in the context of their specific assignment.

In addition, we have implemented appropriate technical, physical and organizational measures to protect your data against unauthorized or unintentional removal, modification or disclosure and against misuse, damage and theft.

  1. Contact. 

Huntsman International LLC, 10003 Woodloch Forest Drive, The Woodlands, Texas, 77380, USA, is the data controller for the purposes specified in this Notice. If you want to consult, update and/or delete your data, please click on the following link to make a Data Subject Access Request (https://www.huntsman.com/privacy/data-request). For questions, comments or any complaints concerning the processing of your Personal Data, you may also contact:

Huntsman International LLC
Attention: Privacy Officer
10003 Woodloch Forest Drive
The Woodlands, Texas 77380 USA
Phone: (281) 719-6000
Email: privacy@huntsman.com

Huntsman’s representative in the EEA is:

Huntsman International (Germany) GmbH
Attention: Human Resources
Land Au 30
94469 Deggendorf
Email: privacy@huntsman.com

In addition, you may have the right to object to the processing of your Personal Data and the right to data portability under applicable laws. You also have the right to file a complaint with the competent Data Protection Authority. However, you are encouraged to contact us first if you have any concern about the use of your Personal Data.

  1. Changes to this Privacy Notice for Applicants.

Changes are made to this Notice on a regular basis. The most recent version can always be found on this page. The date on which this text was last modified can be found in the head of the document.

  1. Declaration and Consent.

By submitting your Personal Data and application form you:

  • Declare that you have read, understood and accepted the statements set out in this Privacy Notice for Applicants;
  • Declare that the information given by you is complete and accurate;
  • Authorize Huntsman to verify, or have verified on our behalf, all statements contained in your application form and to undertake reference checks. Reference checks will only be carried out where permitted in accordance with applicable law, and may include credit enquiries, work history verification, reference checks, education verification, credential verification, criminal convictions checks, passport verification, directorship searches, driving status reports, right to work verification and residency status verification among other things;
  • Authorize any relevant third parties to disclose to Huntsman or its representatives relevant information (including your Personal Data) in conjunction with your application; and
  • Where required by applicable law, consent to the transfer of your Personal Data (including cross-border transfers) between Huntsman entities and/or third-parties processing your Personal Data on behalf of Huntsman for the purposes and to the extent described in this Notice.

Appendix A

 

Data Privacy Framework Addendum (Applicants)

Last updated: August 30, 2023

This Addendum is intended to supplement the Company’s Privacy Notice for Applicants for Personal Data transfers between the European Union (“EU”), the European Economic Area (“EEA”), the United Kingdom (“UK”) or Switzerland and the United States.

Huntsman International LLC and its U.S. subsidiaries and affiliates, which include:

  • Huntsman Building Solutions (USA) LLC
  • Nanocomp Technologies, Inc.
  • Huntsman Advanced Materials Americas LLC
  • Huntsman Ethyleneamines LLC
  • Huntsman Petrochemical LLC
  • Rubicon LLC

(collectively, “Huntsman” or the “Company”) respect your concerns about privacy. 

Huntsman complies with the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”) and the UK Extension to the EU-U.S. DPF (“UK DPF Extension”), and the Swiss-U.S. Data Privacy Framework (“Swiss-U.S. DPF”) as set forth by the U.S. Department of Commerce. Huntsman has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (“EU-U.S. DPF Principles”) with regard to the processing of Personal Data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK DPF Extension.  Huntsman has also certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (“Swiss-U.S. DPF Principles” and together with the “EU-U.S. DPF Principles”, the “Principles”) with regard to the processing of Personal Data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this Addendum and the Principles, the Principles shall govern.  To learn more about the Data Privacy Framework (“DPF”) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

For purposes of DPF compliance enforcement, Huntsman acknowledges that it is subject to the investigatory and enforcement powers of the United States Federal Trade Commission (FTC).

  1. Definitions.

For purposes of this Addendum:

“Applicants” or “you” means any individual applying for and/or taking part in any recruitment process and/or selection process for potential employment or other kind of working relationship with any subsidiary or affiliate of Huntsman who is located in the EU, the EEA, the UK or Switzerland.  

“Personal Data” means any information, including Sensitive Data, that is transferred to Huntsman in the U.S. from the EU, the EEA, the UK or Switzerland, is recorded in any form, and relates to an identified or identifiable Applicant.

“Sensitive Data” means Personal Data specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, sex life or any other information received from a third party that is identified and treated by that party as sensitive. 

For more information about Huntsman’s processing of Personal Data about Applicants globally, please see the Company’s  Privacy Notice for Applicants, to which this Addendum constitutes an annex.

  1. How Huntsman Obtains and Uses Personal Data.

We obtain, process and use certain Personal Data about Applicants in connection with recruitment and/or selection processes for potential employment or other kinds of working relationships with Huntsman.  This Personal Data includes information such as:

  • identification and contact details
  • personal characteristics (such as gender and date of birth)
  • education and work experience (including grades, certificates, diplomas, references)
  • job preferences and strengths
  • areas of interest and hobbies
  • videos and audio clips
  • financial data (e.g. current and desired salary, where collection is allowed by law)
  • resume data
  • visible data under LinkedIn profiles and other social media or public websites if such information is collected
  • any other information Applicants give us in writing or orally in the context of their application

We process this Personal Data for the following purposes: 

  • assessing Applicants’ skills, qualifications and interests within the framework of our career prospects;
  • checking Applicants’ data, checking references and/or performing background or drug/alcohol checks (where applicable and permitted under applicable laws);
  • communication concerning the recruitment process and Applicants’ candidacy; and
  • making improvements in the recruitment process of Huntsman.

Additionally, Huntsman’s online recruitment website (the “Site”) also collects Personal Data about Applicants. Huntsman monitors user traffic patterns throughout the Site according to a user’s domain name, browser type, date and time of access and pages viewed.  Web servers collect the domain names and other technical information associated with visitors to the Site. This information is collected in order to measure the number of visitors to the Site and to determine which areas of the Site users find useful based upon the amount of traffic to particular areas. Huntsman uses this information to enhance users’ experience at the Site and to better prepare future content based on the interests of users.

Huntsman’s practices regarding the collection, storage, use, transfer and other processing of Personal Data comply, as appropriate, with the principles of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access and recourse, enforcement and liability. 

  1. Third Party Disclosures.

We do not disclose any Personal Data about you collected pursuant to this Addendum to any third parties except as stated in this Addendum, as otherwise permitted by law or authorized by you. 

Generally: Third parties to whom we disclose information are required by law and/or contractual undertakings to keep your Personal Data confidential and secure, and to use and disclose it for purposes that a reasonable person would consider compatible in the circumstances with the purposes for which it was collected, in compliance with all applicable legislation.

Service Providers: We may disclose Personal Data to our services providers to fulfill any of the purposes provided for in this Addendum. These may include service providers that assist Huntsman or other third parties with whom Huntsman shares Personal data for the purposes of (i) performing recruiting and candidate identification services on our behalf; (ii) performing administrative services on our behalf such as payroll, background check, drug and alcohol testing, resume verification; (iii) performing IT services on our behalf such as cloud hosting and IT administration; (iv) complying with legal obligations, including in response to a legitimate legal request from law enforcement authorities or other government regulators; (v) maintaining the security and integrity of our networks and systems; (vi) investigating suspected or actual illegal activity; (vii) preventing physical harm or financial loss; and (viii) supporting the sale or transfer of all or a portion of our business or assets (including through bankruptcy).

Because a number of these service providers and third parties are located in the United States, your Personal Data will be processed and stored inside the United States; the U.S.  government, courts or law enforcement or regulatory agencies may be able to obtain disclosure of your Personal Data under U.S. laws.

  1. Notice.

Huntsman notifies Applicants about the participation of Huntsman in the DPF program, the type of Applicants’ Personal Data collected and the Huntsman US affiliates and subsidiaries who adhere to the Principles,  our commitment to subject to the Principles all Personal Data received from the EU, the EEA, the UK and Switzerland in reliance on the DPF, the purposes for which we collect and use your Personal Data, the types of third parties to whom we disclose the Personal Data and the purposes for doing so, your right to access your Personal Data and the choices and means you have for limiting the use and disclosure of your Personal Data and how to contact Huntsman with any inquiries or complaints about our practices concerning Personal Data and the available redress avenues.  Huntsman also notifies Applicants of the independent dispute resolution body designated by Huntsman to address complaints and provide appropriate recourse free of charge, that we are subject to the investigatory and enforcement powers of the FTC, when you can invoke binding arbitration, that Huntsman must disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements and of our potential liability in cases of onward transfers to third parties.

If Huntsman collects any Personal Data for a purpose outside the purposes specified in this Addendum, we will provide you with notice of such data practices at the time we collect such Personal Data and, where required, obtain your consent.  

  1. Choice.

Huntsman generally does not rely on consent as the basis for processing.  We usually rely on other legal basis to process Personal Data, including where:

  • the transfer or processing is necessary for the possible conclusion of an employment relationship or contract between you and Huntsman; and
  • the transfer or processing is in Huntsman’s legitimate interest of improving its recruitment process.

In the event that Huntsman relies on consent for the fair and lawful processing of Personal Data, you may withdraw consent, and therefore prevent that processing, at any time, in accordance with applicable laws.

Applicants are also entitled to opt-out where their Personal Data are to be disclosed by Huntsman to third parties (unless these third parties act as agents performing tasks on behalf of and under the instructions of Huntsman) in accordance with this Annex or where their Personal Data are to be used for a purpose that is materially different from the purposes for which it was originally collected or subsequently authorized by the relevant Applicant.

Unless otherwise permitted by the law, Huntsman will seek an Applicant’s express consent to proceed with the disclosure to any such third parties or to process Personal Data for any such materially different purpose, if and to the extent that the relevant Personal Data includes Sensitive Data. Certain circumstances where we may not be required to obtain opt-in consent with respect to Sensitive Data could occur when the processing is (i) in the vital interest of the Applicant or another person; (ii) necessary for the establishment of legal claims or defenses; (iii) required to provide medical care or diagnosis; (iv) necessary to carry out our obligations in the field of employment law; or (v) related to Personal Data that has obviously been made public by the Applicant.

If you wish to opt-out or withdraw consent, please refer to the contact information section below.

  1. Onward Transfer of Personal Data.

The Privacy Notice for Applicants – to which this Addendum constitutes an annex – describes the internal sharing or processing of Personal Data for all Applicants globally and further explains when third-party disclosures of Personal Data may be required or permitted by applicable laws.  Huntsman also may share Personal Data with third parties as indicated above. 

Except as permitted or required by applicable law, Huntsman requires third parties to whom it discloses Personal Data and who are not subject to the Regulation (EU) 2016/679 of the European Union, or an adequacy finding by the European Commission, to either subscribe to the DPF program or contractually agree to provide at least the same level of protection for Personal Data as is required by the Principles. 

Except as permitted by the Principles, the Company retains liability for third-party processing of Personal Data in a manner inconsistent with the Principles.

  1. Applicants’ Access Rights.

Where appropriate, Huntsman provides Applicants with access to the Personal Data Huntsman maintains about them to verify its accuracy and lawful uses.  We also provide an opportunity for Applicants to correct, amend or delete that information where it is inaccurate or used inconsistent with the principles of the DPF program.  We may limit or deny access to Personal Data where providing such access is unreasonably burdensome or expensive under the circumstances, or as otherwise permitted by the DPF program.  The right to access Personal Data also may be limited in some circumstances by local law requirements.   

Applicants may request access to their Personal Data by contacting the local HR Department, any local data protection officer (“DPO”) or the Company’s Privacy Officer as indicated below, or as indicated in the Privacy Notice for Applicants.

  1. Security.

We take appropriate technical and organizational security measures to protect Applicant Personal Data from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the Personal Data. 

  1. Data Integrity and Purpose.

Huntsman will use Personal Data only in ways that are compatible with the purposes for which it was collected or consented to by the individual. Huntsman takes reasonable steps to ensure that the Personal Data the Company processes are (i) relevant for the purposes for which they are to be used, (ii) reliable for their intended use and (iii) accurate, complete and current.  In this regard, we depend on Applicants to update and correct their Personal Data to the extent necessary for the purposes for which the information was collected or subsequently authorized by the individuals.

Huntsman will only store Personal Data for as long as it is needed to fulfill the purposes for which it was collected, subject to applicable data retention periods determined by Huntsman as a result of applicable law.

Applicants may contact the local HR representative or the Company’s Privacy Officer as indicated below and in the Privacy Notice for Applicants, to which this Addendum constitutes an annex, to request that Huntsman update or correct relevant Personal Data.

  1. Recourse and Enforcement.

Huntsman has established procedures for verifying implementation of and compliance with the Principles.  We conduct an annual self-assessment of our Personal Data practices to verify that the attestations and assertions the Company makes about its privacy practices are true and that the Company’s privacy practices have been implemented as represented.  In the event we no longer maintain DPF certification, we will continue to adhere to the relevant privacy Principles and requirements for so long as we retain such Personal Data.

In compliance with the EU-U.S. DPF, the UK DPF Extension and the Swiss-U.S. DPF, Huntsman commits to resolve DPF Principles-related complaints about our collection and use of your personal information.  EU, EEA, UK and Swiss individuals with inquiries or complaints regarding our handling of Personal Data received in reliance on the EU-U.S. DPF, the UK DPF Extension and the Swiss-U.S. DPF should first contact Huntsman using the contact methods set forth in Sections 11 and 12 of this Addendum. We will take steps to investigate and to promptly respond within forty-five days (45) to issues arising out of a failure to comply with the Principles. 

If an Applicant’s complaint cannot be resolved or remedied through the internal process, EU/EEA Applicants can share their unresolved complaint about our processing of their Personal Data with their data protection authority (“DPA”) in the jurisdiction where they work. UK Associates can share their unresolved complaint with the UK Information Commissioner’s Office (“ICO”), whereas Swiss Associates can share their unresolved complaint with the Swiss Federal Data Protection and Information Commissioner (“FDPIC”).

For Complaints Involving HR Data

In compliance with the EU-U.S. DPF, the UK DPF Extension and the Swiss-U.S. DPF, Huntsman commits to cooperate and comply respectively with the advice of the panel established by the EU DPAs, the IPO and the FDPIC with regard to unresolved complaints concerning our handling of human resources data received in reliance on the EU-U.S. DPF, the UK DPF Extension and the Swiss-U.S. DPF in the context of the applicant relationship. Huntsman will promptly respond to and cooperate with, at no cost to the Applicant, the relevant authority or DPA panel in the investigation and the resolution of a concern or complaint, as appropriate.  Huntsman will likewise comply with any advice given by the EU DPAs, the IPO and/or the FDPIC where they take the view that we need to take specific action to comply with the Principles, including remedial or compensatory measures for the benefit of individuals affected by any non-compliance with the Principles, and we will provide the EU DPAs, the IPO and/or the FDPIC with written confirmation that such action has been taken. 

For Complaints Involving non-HR Data 

In compliance with the EU-U.S. DPF, the UK DPF Extension and the Swiss-U.S. DPF, Huntsman commits to refer unresolved complaints concerning our handling of non-HR Personal Data received in reliance on the EU-U.S. DPF, the UK DPF Extension and the Swiss-U.S. DPF to JAMS, an alternative dispute resolution provider based in the United States.  If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://www.jamsadr.com/eu-us-data-privacy-framework  for more information or to file a complaint.  The services of JAMS are provided at no cost to you. 

If an Applicant continues to have concerns related to DPF data handling practices, as a last resort, the decisions of the alternative dispute resolution provider may be appealed to a DPF Panel, which will have the authority to arbitrate disputes and to impose individual-specific non-monetary equitable relief to remedy any non-compliance with the Principles.  An Applicant may invoke such binding arbitration for those certain DPF related purposes, subject to the conditions provided by the Principles, by following the procedure provided to the Applicant by the Company at the initiation of the internal complaint. This arbitration option may not be invoked if your same claimed violation (1) has previously been subject to binding arbitration, (2) was the subject of a final judgment entered in a court action to which the Applicant was a party or (3) was previously settled by the Applicant and Huntsman.  In addition, this option may not be invoked where the relevant Data Protection Authority already has jurisdiction to resolve the complaint. 

  1. Access Requests, Inquiries and Questions. 

For access requests, inquiries or questions about this Addendum, you can send an email to privacy@huntsman.com or contact our Privacy Officer at the below address.

  1. Reporting a Complaint.

To report a complaint about the Company’s data handling or processing of Applicants Personal Data, Applicants should contact the Privacy Officer at:  

Huntsman International LLC
            Attention: Privacy Officer
            10003 Woodloch Forest Drive
            The Woodlands, Texas 77380 USA
            Phone: (281) 719-6000
            privacy@huntsman.com

Huntsman’s representative in the EEA is Huntsman International (Germany) GmbH, which you can contact via:

Huntsman International (Germany) GmbH
Attention: Human Resources
Land Au 30
94469 Deggendorf
Email: privacy@huntsman.com 

  1. Updates to this Addendum. 

Huntsman reserves the right to amend this Addendum from time to time to reflect technological advancements, legal and regulatory changes, and Huntsman’s business practices, subject to applicable laws.  If Huntsman changes its privacy practices, an updated version of this Addendum will reflect those changes.  Huntsman will provide notice of such changes by updating the effective date listed on this Addendum.  It is your responsibility to check this Addendum frequently to view any amendments.  Your continued interaction with Huntsman, in the activities covered above, will be subject to the then-current Addendum.