Koch Industries, Inc. Privacy Policy

©Copyright 2009-2013, Koch Industries, Inc.
All Rights Reserved
Updated July 2013

Koch Industries, Inc. and its affiliates (“Koch Industries”) respect individuals’ concerns about the privacy of their information. This Privacy Policy applies to the personal information (such as name, email and address, telephone number and financial information) Koch Industries may collect about you, both online and offline. This Privacy Policy also describes how we may use that personal information and with whom we may share it, as well as the measures we take to protect your personal information.

This Policy applies to the personal information practices of Koch Industries and its affiliates (specifically including Koch Companies Public Sector, LLC; Koch Company Services, LLC; Koch Agriculture Company; Koch Remediation & Environmental Services, LLC; Market Based Management, LLC; and Koch Financial Corporation), except those affiliates that have implemented their own governing privacy policy. Koch Industries employees may access the Employee Privacy Notice on the corporate DNET or by contacting their Compliance & Ethics office. Non-employees, such as contractors, who have access to information technology and communication tools provided by Koch Industries may also access (or may request access) to the Employee Privacy Notice to learn about the company’s personal information practices that may apply to them through their use of the company’s IT resources.

Information We Collect and How We Use It

Personal Information We Collect About You
We may collect personal information from individuals through our websites or by other means (such as email, fax, mail or phone). The principal ways you may provide the information and the types of information you may submit, as well as the ways we may use the information, are listed below.

Business Alerts, Newsletters and Other Communications
You may provide personal information to receive business alerts, newsletters and other communications (including emails) about our company. We use the information you provide to send you the communications and information you have requested and to communicate with you about our products and services.

Scholarships, Grants and Awards
You may provide personal information when applying for scholarships, grants or awards offered by Koch Industries. We use the information you provide in the selection process, to communicate with you and to publish a list of the recipients.

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

Careers
Individuals from all over the world apply for jobs with Koch Industries through the Koch Careers website and other similar websites or through third-party job posting sites. The information job seekers provide through this process is maintained by a third-party service provider, and may also be maintained in locations within the United States and accessible to our global recruiting team. The information submitted by job seekers is used to evaluate their qualifications for employment and to contact them regarding possible employment opportunities. Job seekers may also choose to provide information such as gender or ethnic background. Providing this data is optional and is not required to apply for a job with Koch Industries. This information will not be considered in evaluating candidates’ qualifications for employment.

Websites for Business Purposes
On our websites you may be able to register using your Personal Information to gain access to information related to your business relationship with Koch Industries. We use these details to provide you with access to information about your business relationship with us and to facilitate your use of the websites.

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

Contact Us
You may contact us with questions, requests or comments through the "Contact Us" link on our websites or by other available means. When you do so, we may ask you for your personal information. We use the information to respond to your questions, requests or comments.

Vendors and Contractors
If you are a vendor or a contractor, we may ask you to provide personal information to establish and administer your account, process payments, and for compliance with internal and legal requirements (which may include medical testing and monitoring requirements, where applicable).

Other Uses of Information
We may use the personal information you provide to us for internal general business purposes. These purposes include administration of our websites, data analytics and compliance with our legal obligations, standards, policies and procedures. 

Information Technology Security
We may collect personal information when detecting and defending against security threats. We use various IT tools to detect and defend against security threats (e.g., attacks, viruses, malware, spam, phishing, malicious web content), to promote business continuity of our information systems and assets, and to maintain optimal performance of our IT systems.

Information We Collect by Automated Means
We collect certain information by automated means when you visit our websites. By collecting this information, we learn how to best tailor our websites to our visitors. We collect this information through various means such as “cookies,” “web beacons”, and “IP addresses” as explained below.

Cookies
Like many companies, we use “cookies” on our websites. Cookies are bits of text that are placed on your computer's hard drive when you visit certain websites. We use the information collected from these cookies to compile reports and help us improve the website. For example, a cookie might tell us whether you have visited us before, the number of visitors to the website, which site a visitor has come from, the pages they visited, and to help us identify site features in which you may have the greatest interest. Cookies may enhance your online experience by saving your preferences while you are visiting a particular site.

Web Beacons
Certain pages on our websites contain “web beacons” (also known as internet tags, pixel tags and clear GIFs). These web beacons allow us to obtain information such as the IP address of the computer that downloaded the page on which the beacon appears, the URL of the page on which the beacon appears, the time the page containing the beacon was viewed, the type of browser used to view the page, and the information in cookies set by the third-party.

IP Addresses
An IP address is a unique identifier that certain electronic devices use to identify and communicate with each other on the Internet. When you visit our websites, we may view and/or store the IP address of the device you use to connect to the Internet. We use this information to determine the general physical location of the device and understand from what regions of the world our website visitors come. We also may use this information to enhance our websites.

Information We Share
We do not sell or otherwise disclose personal information except as described here. We may share the information you provide with our affiliates. We also may share the information with service providers we have retained to perform services on our behalf. These service providers are not authorized by us to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements. In addition, we may disclose information about you: (1) if we are required to do so by law or legal process; (2) to law enforcement authorities or other government officials; (3) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity; or (4) in order to enforce or apply our Terms of Use and other agreements or to protect the rights, property, or safety of Koch Industries, our customers, or others.

We reserve the right to transfer any information we have about you in the event we sell or transfer all or a portion of our business or assets. Should such a sale or transfer occur, we will use reasonable efforts to direct the transferee to use information you have provided in a manner that is consistent with this Privacy Policy.

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

Links to Other Sites
Our websites and communications may provide links to other websites for your convenience and information. These websites may operate independently from Koch Industries and its subsidiaries and affiliates. Linked sites may have their own privacy notices or policies, which we strongly suggest you review if you visit any linked websites. To the extent any linked websites you visit are not part of the Koch Industries family of companies, we are not responsible for their content, any use of the sites, or the privacy practices of the sites.

How We Protect Personal Information 
In proportion to the sensitivity of the information, we maintain reasonable administrative, technical and/or physical safeguards and appropriate security measures to protect personal information from loss, misuse or unauthorized access, disclosure, alteration, or destruction of the information you provide. However, no electronic data transmission or storage of information can be completely secure. Although we will do our best to protect your personal information we cannot ensure or warrant the security of any information you transmit to us or that we acquire. Accordingly, you must use our services at your own risk..

Safe Harbor (European Economic Area and Switzerland)
Laws related to personal information vary by country. For example, personal information collected in the European Economic Area (EEA) is subject to the laws of the European Union. Certain Koch Companies are registered and comply with the Safe Harbor privacy framework as set forth by the United States Department of Commerce regarding the collection, storage, transfer, use and other processing of personal information transferred to the United States from the EEA and Switzerland and relating to consumers, customers, employees (including job applicants and current or former employees), contractors, vendors, and other relevant individuals. Click here to view our Safe Harbor Privacy Policy, including a listing of the Koch Companies which are Safe Harbor certified.

International Transfers of Your Personal Information 
We operate our services in the United States and in other countries and we may transfer your personal information to the United States or other countries for storage and processing. By using the websites, or providing us with any personal information, you consent to the collection, processing, maintenance, and transfer of such information in and to the United States and other countries in which the privacy laws may not be as comprehensive as those in your country of residence.

Access and Correction
You will be provided with reasonable access to personal information you provide to us and the ability to review and correct it, as required by law. As permitted by law, we may request a fee for providing access or correction services. To help protect your privacy and security, we will take reasonable steps to verify your identity, such as requiring a password and user ID for websites or asking you to confirm your provided information, before granting you access to your information. To remove or update your preferences or information we have about you, please contact us as indicated in the “How to Contact Us” section of this Privacy Policy.

Children
Our services are generally not directed to children under 13. We do not knowingly collect personal information from anyone under 13 without parental consent. If you become aware that we have collected personal information from a child under the age of 13 without parental consent, please let us know so we can take appropriate action.

California Residents
If you are a California resident, you may ask us to refrain from sharing your information with our affiliates for their marketing purposes, if the affiliates are separate legal entities. Please tell us your preference by contacting us as indicated in the “How to Contact Us” section of this Privacy Policy.

Updates to Our Privacy Policy
Please review our Privacy Policy periodically as we may change it at any time and without prior notice to you. Any changes will be effective immediately upon the posting unless otherwise indicated. We will post a notice on this site to notify you of any significant changes to our Privacy Policy and indicate at the top of the policy when it was most recently updated.

How to Contact Us
If you have any questions or comments about this Privacy Policy or if you would like us to remove or update information we have about you or your preferences, please email us (kiicompeth@kochind.com) or write to:

Koch Industries, Inc.
Compliance & Ethics Department
P.O. Box 2256 Wichita, KS 67201-2256, USA
 

KOCH INDUSTRIES, INC. SAFE HARBOR PRIVACY POLICY
This Policy outlines our general policy and practices for implementing the Safe Harbor privacy principles for Personal Information that we collect online and offline. Koch Industries, Inc. and the following Koch companies have certified compliance with the Safe Harbor privacy principles, as set forth by the United States Department of Commerce, regarding the collection, storage, transfer, use and other Processing of Personal Information (as these terms are defined below) transferred to the United States from the European Economic Area (EEA) or Switzerland:

  • Koch Companies Public Sector, LLC
  • Koch Company Services, LLC
  • Koch Agriculture Company
  • Koch Remediation & Environmental Services, LLC
  • Market-Based Management, LLC
  • Koch Financial Corporation 

General information about our privacy practices is found in the Koch Industries Privacy Policy on kochind.com or for employees in our Employee Privacy Notice on the corporate intranet. Information may also be provided in specific notices triggered by the collection or submission of specific types of personal information (such as job applications, marketing campaigns, etc.).

Definitions:
“Personal Information” means information that: (1) is transferred to the United States from the EEA or Switzerland; (2) is recorded in any form; (3) is about, or relates to, an identified or identifiable consumer, customer, job applicant, employee (current or former), contractor, vendor or any other relevant individual located in the EEA or Switzerland; and (4) can be linked to that individual.

“Processing” means any operation or set of operations performed upon Personal Information, whether or not by automatic means, such as creating, collecting, procuring, obtaining, accessing, recording, organizing, storing, adapting, altering, retrieving, consulting, using, disclosing, or destroying the information.

“Sensitive Data” means Personal Information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, criminal records, driving records or information concerning health or sexual orientation, or other such information which may be specifically defined by applicable law.

Safe Harbor Privacy Principles
Our practices regarding the collection, storage, transfer, use and other Processing of Personal Information comply with the Safe Harbor principles of notice, choice, onward transfer, access, security, data integrity, and enforcement and oversight.

Notice
We notify relevant individuals located in the EEA or Switzerland about: (1) the purposes for which we collect and use their Personal Information; (2) the types of third-parties to which we disclose the information (for example, service providers that Process Personal Information on our behalf); (3) certain privacy rights the individuals may have (such as the right to request access to their Personal Information and certain choices for limiting the use and disclosure of the information); and (4) how to contact us about our practices concerning Personal Information.

Purpose of Collection and Use of Personal Information
Personal Information may be processed to: (1) respond to individual’s requests; (2) provide, evaluate the quality of and communicate about product and services; (3) notify individuals of and administer scholarships, grants and awards; (4) enable the company’s service providers to perform activities on its behalf; (5) carry out and support human resources functions and activities, including employee benefits, compensation and performance; (6) undertake compliance activities; (7) comply with contractual and legal obligations, standards, policies and procedures; (8) carry out internal and external investigations; (9) undertake administrative activities, including data analytics; and (10) fulfill other purposes described in our Privacy Policy and Employee Privacy Notice, and other privacy related notices as relevant. We also may Process Sensitive Data to the extent necessary or appropriate for compliance with relevant legal or contractual obligations

For EEA and Switzerland Residents 
In some jurisdictions, such as within the EEA or Switzerland, individuals have certain specific rights related to the collection and processing of their personal data, including the right to “opt-out” of having their personal data collected and maintained.

We offer individuals located in the EEA or Switzerland certain choices for limiting the use and disclosure of their Personal Information. To learn about the choices you may have, please review the relevant privacy notice that governs the Processing of your Personal Information by Koch Industries. If you are located in the EEA or Switzerland, you may advise us of your choices concerning your personal data, or direct us not to share your personal information with third-parties (except as specified below). If these rights are applicable to you, and should you wish to pursue them, please Contact Us.

We may disclose or otherwise share Personal Information without offering individuals an opportunity to opt-out, as follows: (1) to service providers we have retained to perform services on our behalf; (2) in the event we sell or transfer all or a portion of our business or assets; (3) if disclosure is required by law or legal process; (4) to law enforcement authorities or other government officials based on an enforceable government request or as may be required under applicable law; or (5) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual illegal activity.

We do not use Personal Information for purposes incompatible with the purposes for which we originally collected the information without notifying the relevant individuals of such uses and offering an opportunity to opt out of the incompatible use, unless such use is permitted or required by applicable law.

Onward Transfer of Personal Information
We may share Personal Information with service providers we have retained to perform services on our behalf and among our subsidiaries and affiliates. We require service providers, affiliates and subsidiaries to whom we disclose Personal Information and who are not subject to the laws of the European Union or Switzerland, as applicable, to either: (1) subscribe to the Safe Harbor principles; or (2) contractually agree to provide at least an equivalent level of protection for Personal Information as is required by the relevant Safe Harbor principles.

Access to Personal Information
Koch Industries provides individuals located in the EEA or Switzerland with reasonable access to the Personal Information we maintain about them. We also provide a reasonable opportunity to correct, amend, or delete that information where it is inaccurate. We may limit or deny access to Personal Information where providing such access is unreasonably burdensome or expensive under the circumstances, As permitted by law, we may impose a fee for providing access or correction services, or as otherwise permitted by the Safe Harbor principles. To obtain access to Personal Information, individuals may contact Koch Industries as specified in the "How to Contact Us" section of this Policy. Employees should submit requests for access to their Personal Information as described in the Employee Privacy Notice.

Security
In proportion to the sensitivity of the information, we maintain reasonable administrative, technical and/or physical safeguards and appropriate security measures to protect Personal Information in accordance with the sensitivity of the information from loss, misuse, or unauthorized access, disclosure, alteration, or destruction. However, no electronic data transmission or storage of information can be completely secure. We cannot ensure or warrant the security of any information you transmit to us or that we acquire.

Data Integrity
Koch Industries takes reasonable steps to ensure that Personal Information the company collects is relevant for the purposes for which it is to be used and that the information is reliable for its intended use and is accurate, complete and current.We depend on individuals to update or correct their Personal Information whenever necessary. Please contact us if you believe your Personal Information is not accurate or current.

Enforcement and Oversight
Koch Industries has established procedures for periodically verifying implementation of and compliance with the Safe Harbor principles. We conduct an annual self-assessment of our practices with respect to Personal Information to verify that the representations we make about our Personal Information privacy practices are true and that related privacy policies have been implemented as represented.

Individuals located in the EEA or Switzerland may file a complaint with the Compliance & Ethics Department at Koch Industries, Inc. in connection with the Processing of their Personal Information under the Safe Harbor principles. We will also cooperate with the following dispute resolution bodies to address individuals’ complaints regarding privacy issues: (1) for complaints submitted by individuals other than our employees, we cooperate with JAMS in the U.S. in accordance with the JAMS International Mediation Rules; and (2) for complaints concerning our handling of employee Personal Information, we cooperate with the relevant EU and/or Swiss data protection authorities. We will take steps to remedy any issues arising out of a failure to comply with the Safe Harbor principles. Please contact us as specified below to address any complaints regarding our Personal Information practices.

Updates to Our Safe Harbor Privacy Policy
Please review our Safe Harbor Privacy Policy periodically as we may change it at any time and without prior notice to you. Any changes will be effective immediately upon the posting unless otherwise indicated. We will post a notice on this site to notify you of any significant changes to our Safe Harbor Privacy Policy and indicate at the top of the policy when it was most recently updated.

How to Contact Us

Contacting us at kiicompeth@kochind.com

Writing to:
Koch Industries, Inc.
Compliance & Ethics Department
P.O. Box 2256
Wichita, KS 67201-2256
USA