Privacy Policy

1. Introduction

This privacy policy describes how we collect, use, process, disclose and protect personal information about you. It applies to personal information we collect when you access and use the services and features offered on our websites and mobile applications that link to this policy (collectively the “Sites”).

We may change this policy from time to time. If we make significant changes, we will notify you by email, notice in your account on our Sites or another appropriate method. We encourage you to review this policy whenever you use the Sites. It is important that personal information we hold about you is accurate and current. Please let us know if your personal information changes during your relationship with us.

This policy may be supplemented by other more specific privacy policies on our Sites. For example, if you apply to work for us through our careers Site, you will be provided with access to our Candidate Privacy Policy that will explain how your personal information is used during the recruitment process.

2. What personal information do we collect?

Personal information, or personal data, means any information about an individual from which that person can be identified.

We may collect, store and use, the following categories of personal information about you:

• Identity and contact information. For example, name, telephone number, email, employer name, employer address, industry, occupation, languages, information about authorised users.
• Transaction information. For example, when you purchase or return products, use our services, register a product, contact us for technical support services, we collect information about the transaction, such as product name, purchase price, quantity ordered and services provided.
• Account information. If you create an account on our website, we will collect information associated with you depending on the type of the account that you create.
• Logical identifiers. For example, passwords, usernames and cookies (see below).
• Log information. We log information about your use of the Sites. For example, the type of browser you use, access, times, pages viewed, your IP address and the page you visited before navigating to our Sites.
• Device information. We collect information about the computer or mobile device you use to access our Sites, including the hardware model, operating system and version, unique device identifiers and mobile network information.
• Accreditation information. If you are an installer certified to install products we manufacture, your certifications.
• Financial information. For example, credit or debit card information.
• Complaints data. We collect details of any complaints made by you via our Sites.
• Communications data. We may process information contained in or relating to any communication that you send to us or we send to you. For example, if you contact us using one of the forms on the Sites, we will use that information.

We do not specifically collect special category personal information about you. This includes details about your racial or ethnic origin, political opinions, religion or other beliefs, health, biometric or genetic characteristics, criminal background or trade union membership. We ask you not to share special category personal information with us, unless specifically requested or necessary.

If you are resident in California, we may collect certain categories of sensitive personal information. This is usually limited to your user account login detail.

We also collect, use and share Aggregated Data such as statistical, demographic, aggregated usage and purchasing data for any purpose. Aggregated Data may be derived from your personal information but is not considered personal information in law as this data does not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this privacy policy.

3. How do we collect your personal information?

We collect personal information using different methods:

• Directly from you. For example, when you visit the Sites, we collect information when you request a quote, create an account, participate in any interactive features of the Sites, order products, register you products with us, sign up for newsletters or provide general feedback.
• Automatically when you use our Sites. When you access the Sites, we will automatically collect transaction information, log information, device information and information collected by cookies and other tracking technologies depending on your cookies settings.
• From other sources. For example, if you create or log into an account by using social network credentials, such as LinkedIn or Facebook, we will have access to certain information from that site, in accordance with the procedures determined by such social media site.

4. How and why do we use your personal information?

4.1.Purposes for which we use your personal information

We will use your personal information for the following purposes:

• To register you or the business partner as a customer or end user
• To create a user account for you or a candidate account for you
• To process orders and requests for products, including quoting, tracking orders, delivery, processing returns and exchanges, payment management, processing credit and other forms of payment and collections
• To provide, maintain, improve and protect the Sites
• To personalize and improve your experience using the Sites and provide advertisements, content and features that match user profile or interests and to measure effectiveness of content delivery
• To provide and improve our customer service, including to respond to your comments, questions and requests and provide training and technical support
• To analyze and manage our business, including our relationship with you or a business partner
• To send technical notices, updates, security alerts and support administrative messages
• To improve our Sites, products and services
• To communicate with you about the services, offers, promotions, rewards, and events offered by us and others
• To link or combine with information we get from others to help understand your needs and provide you with better service
• To comply with international trade laws and regulations and other regulatory requirements
• To prevent fraud and to keep our Sites secure

The above purposes for using your personal information will overlap and, therefore, multiple purposes may justify our use of your personal information.

4.2. Lawful bases for processing your personal information

We will only use personal information where the applicable law allows us to do so. Where necessary, we will rely on the following lawful bases:

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where we need to comply with a legal or regulatory obligation.
• We rely on consent as lawful basis for processing in specific circumstances. Where we do rely on consent, the relevant form on the Site will provide information on when consent is sought. Usually, this will be the case in relation to sending direct marketing communications to you. You have the right to withdraw consent to marketing at any time by contacting us or clicking unsubscribe.

Where the applicable law does not require us to only process personal information under a specific lawful basis but imposes other requirements such as ensuring that the purposes for which we use personal information would be considered appropriate, we will comply with such other requirements.

4.3. If you do not provide your personal information

If you do not provide personal information that we request, we may not be able to provide products or services that you or our business partner requests. You will also not be able to receive targeted offers and other relevant communication. If we enter into a contract with you, without personal information that we need, we may not be able to perform that contract.

4.4. Change of purpose

We will only use your personal information for the purposes for which we collected it. If we need to use your personal information for a different purpose, we can use it provided we reasonably consider that such different purpose is compatible with the original purpose.

If we need to use your personal information for an unrelated purpose, we will, where required by law, notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law.

4.5. Marketing

We may use information about how you use the Sites, your identity, the identity of a business partner you represent to form a view on the products and services you may need or be interested in or that may be relevant to you. We may also combine personal information gathered across the Sites and from third parties to bring you products, services, offers, promotions and events that are most relevant to you.

Where permitted by law, we may send marketing communications to you, unless you opt-out or unsubscribe and, where required, we will ask for your consent before sending direct marketing communications to you.

Wherever you are based, you can always ask us or our nominated third parties to stop sending you marketing messages at any time by following the links on any marketing message sent to you or by contacting us at any time.

4.6. Cookies

We use cookies and other tracking technologies to distinguish you form other users of our site. For simplicity, we will refer to these technologies as “cookies”. A cookie is a small text file that is placed on your device by the websites that you visit. On subsequent visits, cookies are sent back by the website that recognizes the cookies, to develop a record of your online activity. To manage your choices, please see our cookie manager].

In addition, most browsers allow you to refuse to accept cookies. You may also delete cookies. This can be found in your browser settings. Please remember that if you block all cookies in your browser, you will not be able to use all features of our Sites.

4.7. Third-party links

The Sites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

5. Who do we share your personal information with?

5.1. Categories of recipients of personal information

We may share your personal information with the following categories of third parties:

XpressConnect Supply

• The information will be shared with XpressConnect Supply, which provide IT and system administration services and e-marketing teams.
• Local sales teams that look after our business partner accounts.
• Other Wesco Group companies that provide shared services, such as accounts payable and receivable and purchasing, may receive personal information.

Service providers and suppliers of goods

• Service providers, who provide IT and administration and hosting services in relation to the Sites, our services, and our internal infrastructure. Personal information may also be shared with providers of analytical services.
• Service providers that provide ancillary services such as outsourced call centers and helpdesks.
• The information may be shared with suppliers of products, transportation companies, payment service providers and other companies involved in fulfilling your or business partner’s orders.

Professional advisers and insurers. We may need to share information with our lawyers, accountants and other consultants, as well as with our insurers and brokers.

Regulators and other authorities. It may be necessary to provide personal information to, for example, tax authorities.

M&A buyers and sellers. The parties to whom we may choose to sell, transfer, or merge parts of our business or assets or where we acquire or seek to acquire other businesses or merge them.

We require third parties to respect security of your personal information and treat it in accordance with the law. Where we disclose personal information to a service provider or other processor, we require them to take adequate security measures to protect your personal information in line with our policies and the law. We only permit such third parties to process your personal information for specified purposes and in accordance with our instructions

5.2. International data transfers

We may share your personal information within XpressConnect Supply. This will involve transferring your personal information to our global HQ in the US and countries where XpressConnect Supply is located. Where required, we use intra-group standard contractual clauses approved by the European Commission or the UK’s Information Commissioner.

External third parties with whom we share personal information may be based outside EEA. In that case, we have processes in place to ensure that your personal information is adequately protected. For example, our contracts with third party processors include provisions that they must follow to ensure adequate protection of your personal information.

If you wish to know about the above contracts, please contact us.

6. How do we protect your personal information?

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. We take reasonable steps to maintain physical, procedural, and technical security in our offices, information systems, and information storage facilities in order to protect your personal information. We restrict access to personal information to those individuals who need access to it in performing our duties and obligations.

7. How long will we keep your personal information?

We will only keep your personal information for as long as is necessary for the purpose for which it was collected. That includes satisfying any legal, accounting, or reporting requirements.

8. What are your rights over your personal information?

8.1. Your rights in general

Your rights will vary depending on your location. These rights may be subjects to exceptions and certain limitations under the applicable law.

In certain circumstances, you have the right to:

• Request access to personal information that we hold about you.
• Request correction of your personal information when incorrect, out of date or incomplete.
• Request erasure of your personal information. You may exercise this right, when there is no good reason for us continuing to process personal information about you. Note that we may not always be able to remove your personal information for specific legal reasons which will be notified to you.
• Object to processing of your personal information where we are relying on a legitimate interest. You also have the right to object where we are processing personal information for marketing purposes. In some cases, we may demonstrate that we have compelling legitimate ground to process your personal information which override your rights and freedoms.
• Request the restriction of processing of your personal information. This allows you to ask us to suspend processing of your personal information. For example, where you wish to establish that personal information that we hold about you is accurate.
• Request the transfer of your personal information to your or to a third party in a commonly used machine-readable format. Note that this right applies in limited circumstances, where personal information is processed by automated means on the basis of consent you provided or contract we entered into with you.
• Stop consent-based processing of your personal information. If we collected personal information on the basis of consent, you have the right to withdraw consent. If you withdraw your consent, we may not be able to provide certain products or services to you and will advise you if that would be the case.

If you are resident outside of the US and want to exercise any of the above rights, please contact us.

8.2. US residents

If you are resident in the US, your rights will depend on the State you reside in.

• California residents have the right to request disclosure of specific and general personal information we collect, right to delete and correct their personal information, and to opt-out of any sharing for cross-context behavior advertising or sale of personal information. These rights are subject to certain restrictions and may be exercised by an agent on behalf of a California resident. If you are resident in California, here is how you can exercise your rights.
• Right to disclosure, correction or deletion. You may exercise your rights to disclose information about you and to delete your personal information by submitting a form here.
• Right to opt-out of the sale of your personal information. The California Consumer Privacy Act (CCPA) requires business to give individuals a right to opt out from “selling” or “sharing” their personal information. The terms “sell” under CCPA captures a broad range of disclosure to third parties for monetary or other valuable consideration. “Selling” may therefore include providing third parties with information about IP addresses, trackers, cookies, devices and browsers and “sharing” of personal information relates specifically to cross-context behavior advertising. Although XpressConnect Supply does not sell your personal information for money, placing third party advertising cookies on your device may qualify as “selling” your personal information. If you wish to opt-out from such advertising cookies simply use our cookie banner [here]. If you decide to only allow the necessary cookies, your personal information will only remain with us.

8.3. Verification and unfounded requests

Please note that you will not have to pay a fee to exercise your rights. However, where allowed by law, we may charge a reasonable fee if your request is clearly unfounded or excessive or we may refuse to comply with your request in such circumstances.

When you exercise your rights, we may request information form you to confirm your identity. This is to ensure your personal information is not disclosed to any person who has no right to receive it.

9. Who to contact?

We hope that this policy has been helpful, but if you have questions or wish to exercise your legal rights or to complaint, please contact our Chief Compliance Officer by submitting a form here.

If you do not have access to an email you may write to us at Chief Compliance Officer:

Global HQ
1601 Feehanville Drive, Suite 500
Mount Prospect, IL 60056
800-325-9473

You also have a right to make a complaint at any time to a supervisory authority in your country.