Privacy Policy

Last Updated: 07/12/2021

We are committed to safeguarding your privacy and ensuring that your personal data is protected. This Privacy Policy explains the types of personal data we collect and how we process and protect that data.

It applies to personal data processed by us in connection with the services we offer. This includes information collected directly from you and indirectly from you by means such as cookies. This Privacy Policy does not apply to any personal data collected from or about any of our employers or our subsidiaries’ employees.

This Privacy Policy also applies to our targeted content, including online offers and advertisements for services, which we (or a service provider acting on our behalf) may send to you on third party websites, platforms and applications (“Third Party Websites”) based on your use of the internet. These Third Party Websites may have their own privacy policies and terms and conditions. We encourage you to read them before using those Third Party Websites.

1. WHO IS RESPONSIBLE FOR WHAT HAPPENS WITH YOUR DATA?

The Doe Run Resources Corporation (“Doe Run,” “we,” “us” or “our”) is responsible for processing of your Personal Data (as defined herein). You can contact us via e-mail at privacy@doerun.com if you have any questions.

2. WHO IS THE DATA PROTECTION OFFICER?

The Data Protection Officer of Doe Run is Matt Milter.  You can contact him by email at privacy@doerun.com, by mail at:  1801 Park 270 Drive, Suite 300, Attn: Data Protection Officer, St. Louis, MO 63146 or by telephone at: 1‑833‑690‑0452.

3. WHEN DO WE ASK FOR YOUR CONSENT?

By using the services we provide to you (our “Services”) from www.doerun.com or other Doe Run websites (our “Website”), or otherwise, you acknowledge that we are processing your Personal Data in accordance with this Privacy Policy. If you do not wish that we process your Personal Data in this way, please do not use our Website or otherwise provide our Website with your Personal Data.

We process your data to provide you our Services, whether on our Website or otherwise. In certain instances, we only process your data if you have consented, for example in certain cases where we process your personal data for marketing purposes, or use cookies. Where we process your data on the basis of your consent, we will ask for your consent explicitly but, in some cases and only where permitted by applicable law, we may infer in a transparent manner consent from your actions. We may also ask you to provide additional consent if we need to use your personal data for purposes not covered by this Privacy Policy or before sharing your personal data with the Doe Run group of companies or relevant subsidiaries of Doe Run for the purposes of marketing. You may unsubscribe from our marketing emails by sending such a request to privacy@doerun.com.

4. WHAT HAPPENS IF OUR CUSTOMER IS A CHILD?

Our Website is not intended for children under 16 years of age. No one under age 16 may provide any information to or on the Website. We do not knowingly collect personal data from children under 16. If you are under 16, do not use or provide any information on this Website or on or through any of its features/register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal data from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at privacy@doerun.com.

5. FOR WHICH PURPOSES DO WE PROCESS YOUR PERSONAL DATA?

Personal Data means information that can directly or indirectly identify you or other individuals (“Personal Data”). This typically includes information such as your name, address, email address, and telephone number, but can also include other information such as IP address. Please see details in the following paragraphs.

We collect your Personal Data directly when you provide us with Personal Data so that you can receive information or mailings, use our applications, buy Services from us, complete a survey, make a comment or inquiry or contact our customer services. We may also receive Personal Data about you from other sources, including information from commercially available sources, such as public databases and data aggregators, and information from third parties.
In more detail, we process the following categories of Personal Data for the following purposes:

5.1 Browsing our Website – with or without cookies

Which Personal Data do we collect about you? – For this purpose (browsing our Website – with or without cookies), we process the following Personal Data: your email address, name, home or work address, or telephone number, if provided to our Website; anonymous demographic information, which is not unique to you, such as your ZIP code, age, gender, preferences, interests and favorites, if provided to our Website; your IP address, browser type, domain names, access times and referring website addresses.

What is the Purpose of Processing your Personal Data? – We (and third party service providers acting on our behalf or on their own behalf) use cookies and similar technologies to process data about you when you visit our relevant Website. We use cookies and similar technologies (like pixels, fingerprints and other tools) to improve your experience on our Websites by evaluating your use thereof, and to provide general statistics regarding use of our Website. You can view more information on the Cookies used via our Cookie Policy and adjust your cookie preferences via the Cookie Consent Tool on our Website.

How long do we store your Personal Data? – Please check the Cookie Policy to learn about the storage periods for each cookie.

What is the Basis for Processing your Personal Data? – Your consent.

Additional Comments: It is always possible for you to visit our Website without disclosing your Personal Data. This requires that you have disabled cookies. You can opt out of the processing of such information via the Cookie Consent Tool displayed in the bottom right corner of the relevant Website. Please note, however, that without cookies you may not be able to use all of the features of our Websites or online services.

5.2 Communicating with you or fulfilling or meeting the reason you provided the information; communicating with you and our employees, and marketing our Services

Which Personal Data do we collect about you? – For this purpose (communicating with you or fulfilling or meeting the reason you provided the information; communicating with you and marketing our Services), we process the following Personal Data: your first and last names, your postal address, your email address, and phone number(s).

What is the Purpose of Processing your Personal Data? – We process your Personal Data whenever you contact us and we respond to your inquiries and comments. We process Personal Data to provide you with our Services that you request from us, including marketing communications and responding to your inquiries or comments. We also process Personal Data to administer and review surveys that we send to you.

How long do we store your Personal Data? – We store your Personal Data for the period they are active and ten years therafter, unless we are required by law to store them for a longer period.

What is the Basis for Processing your Personal Data? – Performance of the contract with you, or in order to take steps at your request prior to entering into a contract (i.e. fulfill your contact request), and as applicable (such as a scenario in which you provide to us Personal Data that is considered sensitive (e.g. information on your health or ethnic origin) or otherwise authorize specific contact), your consent.

5.3 Conducting and operating our business and business transactions

Which Personal Data do we collect about you? – For this purpose (conducting and operating our business and business transactions), we process the following Personal Data: your name, signature, physical characteristics or description, address, telephone number, Services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies or other similar identifiers.

What is the Purpose of Processing your Personal Data? – We process your Personal Data whenever we need to provide our Services to you and facilitate business transactions to provide such Services.

How long do we store your Personal Data? – We store your Personal Data while they are part of an active business relationship and for ten years thereafter, unless we are required by law to store them for a longer period.

What is the Basis for Processing your Personal Data? – Our bases for collection of this information is performance of a customer contract with you, our legitimate interests for internal administrative purposes, and as applicable, your consent.

5.4 Performing relevant administrative services, such as payments and fraud prevention

Which Personal Data do we collect about you? – For this purpose (performing relevant administrative services, such as fraud prevention), we process the following Personal Data: your first and last names, your address, your email address, phone number(s), and your criminal or credit history.

What is the Purpose of Processing your Personal Data? – We will process your Personal Data for the purposes of performing administrative services requested or necessary to facilitate our relationship (e.g., facilitating payments or deliveries of services, information or materials) or to fulfill requests you have made.

How long do we store your Personal Data? – We store your Personal Data for six years related to delivery and payment information and, with regard to any customer information, for so long as the relationship is active plus ten years thereafter, unless we are required by law to store the Personal Data for a longer period in which case we store the Personal Data for the period required by applicable law.

What is the Basis for Processing your Personal Data? – Our legitimate interests regarding security and fraud protection; performance of the contract with, or request by, you; if you provide to us Personal Data that is considered sensitive, your consent.

5.5 Considering your job application and communicating with you regarding your job application

Which Personal Data do we collect about you? – For this purpose (considering your job application and communicating with you regarding your job application), we process the following Personal Data: your first, middle, and last names, your mailing address, including city, state, and zip code, your email address, your phone number, including primary and secondary phone numbers, your gender, your ethnic origin, your veteran status, your voluntary self-identification of disability, your work experience, including job titles, company names, and dates of employment, and your education, including the names of the schools you attended, your level of education, your degree, including majors and minors, and the dates of your school attendance. The Personal Data of Doe Run’s European Economic Area (“EEA”), United Kingdom (“U.K.”), and Swiss employees is covered by the EEA, U.K. and Swiss Employee Data Privacy Policy.

What is the Purpose of Processing your Personal Data? – We process your Personal Data in order to make employment decisions.

How long do we store your Personal Data? – We store your Personal Data for three years after you provide the Personal Data to us, unless we are required by law to store the Personal Data for a longer period in which case we store the Personal Data for the period required by applicable law.

What is the Basis for Processing your Personal Data? – Your consent and our legitimate interests in operating our business in a lawful and appropriate manner.

5.6 Maintaining the safety, security, and integrity of our Website, Services, databases and other technology assets

Which Personal Data do we collect about you? – For this purpose (maintaining the safety, security, and integrity of our Website, Services, databases and other technology assets), we process the following Personal Data: your email address, name, home or work address, or telephone number, if provided to our Website; anonymous demographic information, which is not unique to you, such as your ZIP code, age, gender, preferences, interests and favorites, if provided to our Website; your IP address, browser type, domain names, access times and referring website addresses.

What is the Purpose of Processing your Personal Data? – We process your Personal Data in order to maintain security protocol of our Website and protect against malware, phishing, and other hacking attempts.

How long do we store your Personal Data? – We store your Personal Data for so long as we or our processors while they are part of an active process and for ten years thereafter, or for how long we are required by law to store the Personal Data, or for such longer period of time that we may be required to keep the Personal Data in order to protect the public interest.

What is the Basis for Processing your Personal Data? – Our basis for processing is (i) a legal obligation to which we are subject or (ii) the processing is necessary for the purposes of our legitimate interests in protecting our business, Services or a person or property.

5.7 Testing, researching, analyzing, and developing our Services, including providing, supporting, personalizing, developing and improving our Website and Services

Which Personal Data do we collect about you? – For this purpose (testing, researching, analyzing, and developing our Services, including providing, supporting, personalizing, developing and improving our Website and Services), we process the following Personal Data: your email address, name, home or work address, or telephone number, if provided to our Website; anonymous demographic information, which is not unique to you, such as your ZIP code, age, gender, preferences, interests and favorites, if provided to our Website; your IP address, browser type, domain names, access times and referring website addresses.

What is the Purpose of Processing your Personal Data? – We process your Personal Data to improve and test our current Website and Services, and developing future versions of our Website and Services.
How long do we store your Personal Data? – We store your Personal Data for so long as we or our processors while they are part of an active process and for ten years thereafter, or for how long we are required by law to store the Personal Data, or for such longer period of time that we may be required to keep the Personal Data in order to protect the public interest.

What is the Basis for Processing your Personal Data? – Our basis for processing is the processing is necessary for the purposes of our legitimate interests in protecting our business, our Services or a person or property.

5.8 Preventing harm and engaging in legal and regulatory compliance activities, including but not limited to products liabilities, prosecuting and defending against legal claims, and responding to law enforcement requests and as required by applicable law, court order, or governmental regulations

Which Personal Data do we collect about you? – For this purpose (preventing harm and engaging in legal and regulatory compliance activities, including but not limited to products liabilities; prosecuting and defending against legal claims), we process the following Personal Data: your first and last names, your address, your email address, your phone number(s), your criminal or credit history and relevant information about (i) the harm or potential harm, (ii) the claim or potential claim or (iii) the facts, situation, or circumstances giving rise to harm, potential harm, claim or potential claim.

What is the Purpose of Processing your Personal Data? – We will process your Personal Data for the purposes of preventing harm to Doe Run or any of its subsidiaries, their Services or to any person or property (e.g., fraud prevention) and/or in the bringing or prosecution of a claim or potential claim against you. In addition, we may process your Personal Data for the purposes of defending Doe Run and/or its subsidiaries against claims or potential claims made against one or more of them.

How long do we store your Personal Data? – We store your Personal Data for six years after you provide the Personal Data to us, unless (i) we are required by law to store the Personal Data for a longer period in which case we store the Personal Data for the period required by applicable law or (ii) unless we reasonably anticipate litigation with regard to the matter in which case we would retain relevant Personal Data until such time as the litigation and all related processes have been concluded or litigation is no longer reasonably anticipated.

What is the Basis for Processing your Personal Data? – Our basis for processing is (i) a legal obligation to which we are subject or (ii) the processing is necessary for the purposes of our legitimate interests in protecting our business, Services or a person or property or to defend ourselves against claims or potential claims.

5.9 Providing you with support and responding to your inquiries; processing reports of business concerns about our Services, operations, etc.

Which Personal Data do we collect about you? – For this purpose (processing reports of business concerns about our Services, operations, etc.), we process the following Personal Data: your name, signature, physical characteristics or description, address, phone number(s), insurance policy number, education, employment, employment history, health information, records of personal property, Services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies or other similar identifiers.

What is the Purpose of Processing your Personal Data? – We process your Personal Data to investigate and resolve reports, complaints, and other related communications we receive about our Website or Services.
How long do we store your Personal Data? – We store your Personal Data for ten years after we receive them, unless we are required by law to store them for a longer period.

What is the Basis for Processing your Personal Data? – Our bases for collection of this information are performance of a contract with you, our legitimate interests for internal administrative purposes, and, as applicable, your consent.

5.10 Conducting our financial planning processes (i.e., budgeting, forecasting, strategy, and analysis of credit and financial risk)

Which Personal Data do we collect about you? – For this purpose (conducting our financial planning processes (i.e., budgeting, forecasting, strategy, and analysis of credit and financial risk)), we process the following Personal Data: your name, signature, physical characteristics or description, address, telephone number, Services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies, or other similar identifiers, or other purchasing or consuming histories or tendencies or other similar identifiers.

What is the Purpose of Processing your Personal Data? – We process your Personal Data to review our financial history and to analyze patterns of customer purchases and market projections, which then enables us to create accurate financial statements and reports to our various stakeholders.

How long do we store your Personal Data? – We store your Personal Data for ten years after we receive them, unless we are required by law to store them for a longer period.

What is the Basis for Processing your Personal Data? – Our bases for collection of this information are our legitimate interests for internal administrative and business strategic purposes, and as applicable, your consent.

5.11 Evaluating or conducting a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Doe Run’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Doe Run is among the assets transferred.

Which Personal Data do we collect about you? – For this purpose (evaluating or conducting a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Doe Run’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Doe Run is among the assets transferred), we process the following Personal Data: your name, signature, address, telephone number, bank account number, or any other financial information, records of personal property, Services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies, or other similar identifiers.

What is the Purpose of Processing your Personal Data? – We process your Personal Data whenever to evaluate potential mergers or other actions related to Doe Run’s corporate structure and ownership.

How long do we store your Personal Data? – We store your Personal Data while they are part of an active business relationship and for ten years thereafter, unless we are required by law to store them for a longer period.

What is the Basis for Processing your Personal Data? – Our bases for collection of this information is our legitimate interests for internal business strategic purposes, and as applicable, your consent.

6. WHO IS RECEIVING YOUR PERSONAL DATA?

6.1 Our Service Providers

  • Various providers for management of our internal communications activities;
  • Email providers for the purposes of providing emails and communicating with you;
  • Various providers for financial processes (e.g., accounts receivable/payable);
  • Provider for job posting and applicant management;
  • A provider for enterprise resource planning;
  • Various providers for technological security;
  • Various providers for managing employment applicant data and human resources processes related to employment applicants;
  • Various providers for safety and inspection activities; and
  • A provider for biomonitoring and training.

6.2 Other Recipients (controllers)

  • None.

6.3 Sharing your Website Usage Information

  • Providers for providing analytics and personalizing ads to individuals.

7. WHERE DO WE TRANSFER YOUR PERSONAL DATA?

Doe Run may transfer certain personal information across geographical borders to our related legal entities or to outside companies working with us or on our behalf. Doe Run may also store personal information in a jurisdiction other than where you are based and such jurisdiction may not provide the same level of protection for your personal information as your home country. Each member firm is required to safeguard personal data in accordance with its contractual obligations and data protection legislation applicable to its provision of services. Your personal data will only be transferred if appropriate or suitable safeguards are in place. When Doe Run transfers personal information to countries other than the country where it was provided, we do so in compliance with applicable data privacy laws and/or regulations, including, as applicable, the GDPR and/or the E.U. Standard Contractual Clauses.

8. HOW LONG DO WE PROCESS YOUR PERSONAL DATA?

Unless noted otherwise in this Privacy Policy, we will store your Personal Data only until the aforementioned purposes for which we have collected or received your Personal Data are fulfilled and once our statutory obligations to preserve records have expired. In addition, we may retain anonymized personal information (data that is no longer in a form identifying or making identifiable the individual to which the personal information relates).

9. WHAT ARE YOUR RIGHTS?

If certain requirements are fulfilled, you have the right to obtain from us:

  • Confirmation as to whether or not we process Personal Data from you and, where that is the case, access to the Personal Data,
  • Rectification of inaccurate Personal Data,
  • Erasure of Personal Data,
  • Restriction of processing of Personal Data, and
  • Receive the Personal Data which you have provided to us and transmit those data to another data controller without hindrance.

You may exercise any of these rights by contacting us at privacy@doerun.com or writing to us at:  The Doe Run Resources Corporation, Attn: Data Protection Officer, 1801 Park 270 Drive, Suite 300, St. Louis, MO 63146, emailing us at privacy@doerun.com, or calling us at: 1‑833‑690‑0452.

We will respond to your requests in accordance with, and within the appropriate timeframe determined by, the applicable law and/or regulation governing the use of the given personal information. In most cases, we will respond to requests within one month; provided, however, if the request is complex, we may extend its response time in accordance with applicable law and regulation. Please note that we may require additional information from you in order to honor the request, such as to ensure proper authentication or to verify the Doe Run entity to which the information was provided.

California residents may be provided with additional privacy rights under applicable, including including but not limited to California Civil Code Section § 1798.83 and the California Consumer Privacy Act of 2018. For more information, see our Privacy Notice for California Residents.

10. CAN YOU WITHDRAW YOUR CONSENT TO THE PROCESSING OF PERSONAL DATA?

You may withdraw your consent to some of all of our processing of your Personal Data by contacting us at privacy@doerun.com or writing to us at:  The Doe Run Resources Corporation, Attn: Data Protection Officer, 1801 Park 270 Drive, Suite 300, St. Louis, MO 63146, emailing us at privacy@doerun.com, or calling us at: 1‑833‑690‑0452.

We will respond to your requests in accordance with, and within the appropriate timeframe determined by, the applicable law and/or regulation governing the use of the given personal information. In most cases, we will respond to requests within one month; provided, however, if the request is complex, we may extend its response time in accordance with applicable law and regulation. Please note that we may require additional information from you in order to honor the request, such as to ensure proper authentication or to verify the Doe Run entity to which the information was provided.

11. CAN YOU COMPLAIN WITH THE APPLICABLE LEGAL AUTHORITIES?

You also have the right to lodge your complaints with the applicable legal authorities, including, without limitation, the applicable European Union (“E.U.”) supervisory authority(ies) (if you are an E.U. citizen).

12. HOW DO WE PROTECT YOUR PERSONAL DATA?

We maintain appropriate technical and organizational measures to protect the Personal Data you provide to us against accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to your Personal Data.

Our relevant Website may contain links to other websites provided by third parties. We do not control these third party websites or any of the content contained on those websites. Once you have left our relevant Websites, we cannot be responsible for the protection and privacy of any information which you provide. You should exercise caution and look at the privacy statement for the website you visit.

Do Not Track (DNT) is a privacy preference that users can set in their web browsers. At this time, our Website does not support DNT codes.

13. CAN WE CHANGE OUR PRIVACY POLICY?

As we continue to provide additional services and as the privacy laws and regulations evolve, it may be necessary to revise or update this Privacy Policy. If we make any material changes to this Privacy Policy, including, any material changes to how we collect, use, process, and/or share your information, we will prominently post a notice of such changes on our Website covered by this Privacy Policy. To the extent required by applicable law, we will contact you with regard to changes to this Privacy Policy.

14. HOW CAN YOU CONTACT US?

If you have questions about this Privacy Policy or any subject discussed herein, please feel free to contact us at one of the following:

  • By mail at The Doe Run Resources Corporation, Attn: Data Protection Officer, 1801 Park 270 Drive, Suite 300, St. Louis, MO 63146; or
  • By telephone at 1‑833‑690‑0452.

In most cases, we will respond to requests within one month; provided, however, if the request is complex, we may extend its response time in accordance with applicable law and regulation. Please note that we may require additional information from you in order to honor the request, such as to ensure proper authentication or to verify the Doe Run entity to which the information was provided.

Updated: 07/12/2021

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