The Sherwin-Williams Company Privacy Policy

Effective Date:  April 1, 2018

Sherwin-Williams recognizes that when you choose to provide us with personal information about yourself, you trust us to treat it responsibly.

This Privacy Policy explains the types of personal information that Sherwin-Williams and its affiliated companies collect about you, how we use, share, and protect this personal information, and the choices you can make about how we use and share this personal information.  This Privacy Policy governs personal information collected by any means, including, but not limited to, websites, mobile applications, and other online services that refer or link to this Privacy Policy, as well as information collected by other business functions of Sherwin-Williams, such as through our customer loyalty programs or when you speak with a customer service representative (collectively, the “Services”).

It is important that you read this Privacy Policy carefully, because anytime you use our Services you consent to the practices we describe in this Privacy Policy.  Key jurisdiction-specific information about our privacy practices is available in our policy here.  In the event of any inconsistencies between the English-language version of this privacy policy and any local language version that we make available, the English-language version will prevail.

Information Covered by this Privacy Policy

This Privacy Policy is applicable to information collected by Sherwin-Williams and its affiliated companies.  This includes information collected:

• Through websites, mobile applications, and other online services that refer or link to this Privacy Policy.
• Through the other business functions of Sherwin-Williams, such as through our customer loyalty programs or by customer service representatives.

Our Services may link to third-party websites and services that are outside our control.  In addition, we may have relationships with non-Sherwin-Williams entities that distribute Sherwin-Williams products.  We are not responsible for the security or privacy of any information collected by such third parties.  You should exercise caution, and review the privacy statements applicable to such third parties.

Information We Collect

We may collect information about you and others and, if applicable, the computer or device you use to access our Services in a variety of ways:

• You may provide us information directly.
• We may collect information about you when you use our Services, make purchases, or view our online advertisements.
• We may collect additional information about you in accordance with applicable law.

The manner of our collection and the type of information collected may vary by jurisdiction to accommodate local legal requirements.

Information you provide us directly

We collect information directly from you when you choose to register for our Services (for example, when you register for one of our loyalty programs), make a purchase, sign up to enter a promotion, submit your zip code to learn more about stores near you, or otherwise provide information directly to us.  The following are examples of information you may provide us directly:

• Name.
• E-mail address, physical address and/or zip code, and phone number.
• Username or password.
• Age or birthdate, gender, occupation, and other demographic information.
• Credit card or other payment information.
• Other information about you, your family or others (such as product interests and where you typically shop for paint and coatings products).

You can choose not to provide us with certain types of information, but doing so may affect your ability to use some of the Services.

Information we collect when you use our Services or view our online advertisements

We collect information about your computer or device and your online activity, including through the use of standard Internet technologies, such as cookies, web beacons, and local stored objects.  The following are examples of the types of information that we may collect:

• Your browser type and operating system.
• IP address and/or device ID.
• Your browsing behavior on our Services, such as the amount of time spent viewing our online Services, the links you click within our online Services, and the purchases and transactions you make through the Services.
• Websites you visit before or after our websites.
• Sherwin-Williams e-mails you open and/or forward.
• Sherwin-Williams offers or links you connect to via e-mails.
• Depending on your device settings, location information, such as your mobile device’s GPS signal or information about nearby WiFi access points and cell towers

Additional information we may collect about you

We may receive information about you from publicly and commercially available sources in accordance with applicable law.  In addition, we may collect other information you allow a third party to provide to us.  For example, if you choose to access or use social networking services, we may receive and store information that you allow us to receive through those services, such as your e-mail address.

We also may collect other information about you, your device, or your use of the Services in ways that we describe to you at the point of collection or otherwise with your consent.

All of the information we collect about you may be combined to help us enhance and improve our products and services and tailor our communications to you.

Use of Information

We may use the information we collect about you:

• To provide you with services, products, or other materials you request (for example, completing your registration for a loyalty program and sending you product samples).
• To communicate with you about our products, services, and promotions.
• To customize your experience with our Services, including by providing you with relevant advertising on our Services and elsewhere.
• To manage and improve your shopping experiences and our products, Services and offerings, including analyzing the use of our products and services, and determining the effectiveness of our advertising.
• To protect the security and integrity of our Services.
• To enforce our legal rights.
• Otherwise with your consent.

Please see Your Choices & Rights in Your Information below for information about the choices you may have in relation to our use of your personal information.

Sharing of Information

Sherwin-Williams may disclose your information in the following circumstances:

• Affiliates.   We may share information within Sherwin-Williams among our various businesses and affiliated companies, including, for example, to provide you with our product and service improvements.
• Service Providers.  We rely on third-party service providers to perform a variety of contractual services on our behalf.  To do so, we may need to share your information with them.  For example, we may rely on service providers to fulfill our product and service requests, process your credit card and other payments, answer your questions, send e-mails on our behalf, and analyze data to improve our products and services.
• Other Parties When Required by Law or as Necessary to Protect Our Services.  There may be instances when we disclose your information to other parties:
  • To comply with the law or respond to legal process or a request for cooperation by a government entity.
  • To prevent fraud or verify and enforce compliance with the policies governing our Services.
  • Where permitted by law, to protect the rights, property, or safety of Sherwin-Williams, or any of our respective affiliates, business partners, customers or employees.

• Other Parties In Connection With A Corporate Transaction.  We may disclose your information to a third party in the event we sell or transfer all or a portion of a business or our assets to a third party, such as in connection with a merger or in the event of a bankruptcy reorganization or liquidation.  In certain jurisdictions, consent is required for this sharing of information.  We will collect your consent when required by applicable law.
• Other Parties With Your Consent At Your Direction.  In addition to the disclosures described in this Privacy Policy, we may share information about you with third parties when you consent to or request such sharing.
• Aggregated and Non-Personal Information.  We also may share data in a manner that does not identify you (for example, information that has been aggregated with other records) for general business purposes.  For example, we may disclose the number of visitors to our websites or other Services.

Cookies, Web Beacons, and Other Internet Technologies

We, as well as certain third parties, including those that provide content and other functionality on our Services, may use cookies, web beacons and other similar technologies on our online Services and the information collected from such technologies.  By using our online Services, you are consenting to our use of cookies, web beacons, and other tracking technologies as described in this Privacy Policy.  If you are a U.S. user, click here for information about Do-Not-Track signals and similar mechanisms.

Cookies

A cookie is a small file that may be stored on your computer or other device.  A cookie enables the entity that put the cookie on your device to recognize it across different websites, services, devices, and browsing sessions.

When you use a web browser to access the Services, you may configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent.  Click the “Help” menu of your browser to learn more about how to change your cookie preferences.  The operating system of your device may contain additional controls for cookies.   Please note that disabling cookies may affect your ability to access and use certain features of the Services.

Web Beacons

Web beacons and similar technologies are small bits of code, which are embedded in web pages, ads, and e-mail, that communicate with third parties.  We may use web beacons, for example, to count the number of users who have visited a particular web page, to deliver or communicate with cookies, and to understand usage patterns.  We also may include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

Other Technologies

There are other local storage and Internet technologies, such as Local Shared Objects (also referred to as “Flash cookies”) and HTML5 local storage, that operate similarly to the cookies discussed above in that they are stored on your device and can be used to store certain information about your activities and preferences across different services and sessions.  Please note that these technologies are distinct from cookies, and you may not be able to control them using standard browser tools and settings.  For information about disabling or deleting information contained in Flash cookies, please visit the Flash website operated by Adobe.

How We Use These Technologies

Our online services use these technologies for the following general purposes:

Type of Cookie	What Do They Do	Examples
Technical	Enable our online Service to work correctly.	For example, these cookies remember previous actions (e.g., entered text) when navigating back to a page in the same session and balance website traffic.
Performance	Help us measure and understand how visitors interact with the online Services and our content and any issues encountered to help us improve the performance of the Services.	For example, these cookies gain insight into how visitors use our websites so we can make improvements to usability and content.
Functionality	Allow our online Services to remember choices you make (such as your user name, language, or the region you are in) to provide a more personalized online experience.	For example, these cookies maybe enable you to store your sign-in credentials and preferences so that you don’t have to enter those credentials and preferences each time you log on.
Targeting/Advertising	Help us and third parties provide you with relevant content and advertising by collecting information about your use of our Services and other websites and online services.	These cookies may be used to deliver targeted advertising or to limit the number of times you see an advertisement.  They also help us measure the effectiveness of ad campaigns. We may include web beacons in e-mails, for example, to understand whether messages have been opened, acted on, or forwarded.

Third Parties That Provide Content or Functionality on Our Services

Some of the content and functionality on our Services may be provided by third parties that are not affiliated with us.  For example, we enable you to share certain materials on our Services through social networking services, such as Facebook and Twitter.  Third-party advertisers also may have a presence on some of our Services.  These and other third parties may collect or receive certain information about your use of our Services, including through the use of cookies, web beacons, and Internet technologies, and this information may be collected over time and combined with information collected across different websites and online services.

Some of these companies participate in industry-developed programs designed to provide consumers choices about whether to receive targeted advertising.  Please visit the websites operated by the Network Advertising Initiative and Digital Advertising Alliance to learn more.  (Canadian users may also visit the website operated by the Digital Advertising Alliance of Canada.  Further information in local languages may be available at that site.)

International Transfer of Data

Sherwin-Williams and its service providers may collect, transfer, store and process your information outside of your country of residence, including to the United States.  Please note that other countries’ data protection and other laws may not be as comprehensive as those in your country.  In accordance with applicable law, we implement measures such as standard data protection clauses to ensure that any transferred personal information remains protected and secure.  You may obtain further information about these measures by contacting us using the Global Privacy Portal.

Collection of Information From Children

We do not knowingly collect personal information online from children as defined by local law.  If we learn that a child has provided us with personal information, we will delete it or otherwise comply with applicable law.

Your Choices & Rights in Your Information

Where permitted by law, we may send you offers or promotions.   However, we give you choices about how we communicate with you.

• E-Mail: If you no longer wish to continue receiving commercial emails from a particular Sherwin-Williams brand or group, you may follow the instructions contained in any such message.   You may also contact us at Global Privacy Portal for information about how to remove yourself from any of our mailing lists.

• Postal mail:  If you no longer wish to continue receiving commercial postal mailings from a particular Sherwin-Williams brand or group, you may follow the instructions or use the contact information contained in any such message.   You may also contact us at Global Privacy Portal to remove yourself from our mailing lists.

• Other:  If you no longer wish to continue receiving other commercial communications from a particular Sherwin-Williams brand or group, you may follow the instructions or use the contact information contained in any such message.   You may also contact us at Global Privacy Portal to remove yourself from other types of direct marketing in accordance with local law.

Please note that, despite your opt-out selections, where permitted by applicable laws, we may send you communications regarding transactions or services you have specifically requested or to inform you of important changes to our Services, products or policies.  If you have multiple accounts, you may need to opt-out separately for each account in connection with the privacy choices described above.

You may have certain rights as a data subject under local law.  For example, local law may afford you the right to access, update, restrict, oppose, erase, port and/or correct inaccuracies in your personal information under our control, subject to certain exceptions prescribed by law.  Many of our programs provide you direct access to view, update, correct, and/or delete personal information you provided when you registered online and certain other functionality. Please check where you registered to learn what functionality may be available to you in relation to an applicable program.

If functionality is not available where you registered and you would like to exercise your legal rights, please contact us at the Global Privacy Portal.  We will respond to requests in accordance with applicable law and subject to legal and contractual restrictions.

Information Security & Retention

We have in place various procedures to safeguard your information, including technical, administrative and physical procedures intended to keep your information secure.  However, please note that although we take reasonable steps to protect your information, no website, Internet transmission, computer system or wireless connection is completely secure.

In addition, we take steps to retain personal information about you only for so long as is necessary for the purpose for which it was collected, as required under contract, or as required by or permissible under applicable law.

How to Contact Us

If you have questions or concerns about this Privacy Policy or our privacy practices, please contact Sherwin-Williams.  You may contact us at the Global Privacy Portal.  In addition, you may contact us at the following address:

Sherwin-Williams Company

Global Privacy Compliance

101 W. Prospect Ave.

Cleveland, OH 44115

E-mail via electronic webform:  Global Privacy Portal

Changes to This Privacy Policy in the Future

Privacy laws and guidelines are part of a constantly changing environment. We reserve the right, at our discretion, to change, modify, add, or remove portions of this Privacy Policy at any time. We recommend that you revisit this Privacy Policy periodically to ensure that you are aware of our current privacy practices, although we may also elect to notify you by e-mail or by posting something on some or all of our online services. Your continued use of our Services following any changes signifies your acceptance of these changes.

Jurisdiction-Specific Disclosures

Your California Privacy Rights

California residents are entitled once a year, free of charge, to request and obtain certain information regarding our disclosure, if any, of certain categories of personal information to third parties for their direct marketing purposes in the preceding calendar year.  We do not share personal information with third parties for their direct marketing purposes.

Do-Not-Track Signals and Similar Mechanisms.  Some web browsers may transmit “do-not-track” signals to the websites and other online services with which a user communicates.  There is no industry standard that governs what, if anything, websites should do when they receive these signals.  Sherwin-Williams currently does not take action in response to these signals.  If and when a standard is established and accepted, Sherwin-Williams may revisit its policy on responding to these signals.

Residents of any European Union Member State

The legal bases for our processing activities are as follows:

• For our legitimate business purposes, including:
  • to provide you with services, products, or other materials you request (for example, completing your registration for a loyalty program and sending you product samples) and to customize your experience with our Services;
  • to manage and improve your shopping experiences and our products, Services and offerings, including analyzing the use of our products and services, and determining the effectiveness of our advertising; and
  • to protect the security and integrity of our Services.

• To perform our contract(s) with you, including processing your purchases and transactions,

• To meet our legal obligations, for example:
  • for audit and reporting purposes;
  • to perform accounting and administrative tasks;
  • to respond to requests for information by competent public bodies and judicial authorities; and
  • to enforce our legal rights and to enforce or manage legal claims.

• On the basis of your consent:

• to send you direct marketing messages about our products, services, and promotions; and
• to deliver targeted advertisements to you, both on and off the Services, including by using cookies and similar technologies, as explained below.

 

You can withdraw your consent at any time by contacting us.  If you withdraw certain consents, we may no longer be able to offer related services.

 

• E-Mail: If you wish to unsubscribe or opt out of receiving direct marking from a particular Sherwin-Williams brand or group via email, you may follow the instructions contained in any such message.   You may also contact us at Global Privacy Portal for information about how to remove yourself from any of our mailing lists.

• Postal mail:  If you no longer wish to continue receiving commercial postal mailings from a particular Sherwin-Williams brand or group, you may follow the instructions or use the contact information contained in any such message.   You may also contact us at Global Privacy Portal to remove yourself from our mailing lists.

• Other:  If you no longer wish to continue receiving other commercial communications from a particular Sherwin-Williams brand or group, you may follow the instructions or use the contact information contained in any such message, or by changing the privacy settings in your browser (for example, with respect to cookies).   You may also contact us at Global Privacy Portal to remove yourself from other types of direct marketing in accordance with local law.

You may lodge a complaint with a supervisory authority if you consider that our processing of your personal information infringes applicable law.

Our Services may use web analytics services, such as Google Analytics, which are provided by Google, Inc. and other third party providers. These services use “cookies” to help analyze how visitors use online services. The information generated by the cookies about your use of the online services (including your IP address) will be transmitted to and stored by these providers, including outside the EU in third countries such as the United States which might not have data protection and other laws that are as comprehensive as those in your country.

If your IP address is not truncated through IP-anonymization, then the full IP address may be transferred to third party providers’ non-EU servers. These providers may use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and Internet usage.   You may refuse the use of cookies as described elsewhere in this policy, and some providers offer you the ability to prevent the collection and processing of data generated by cookies and related to your use of the website (including your IP address) by downloading and installing a Browser-Plugin.

Residents of Argentina

If you are an Argentine resident, in accordance with Law No. 25,326, as amended, you can exercise your right of access every 6 months free of any charge, or more often if you have a legitimate interest to exercise such right, by providing us with any proof of your identity. The request shall be answered in accordance with applicable law.

Besides the right of access, any Argentine resident can exercise their amendment, update or cancelation rights at any time free of any charge by providing us with any proof of identity. The request shall be answered in accordance with applicable law. The request can be denied if: (i) there is a third party interested in the conservation of the personal information in its current state by Sherwin-Williams; or (ii) there is a legal obligation to preserve the data in its current state.

The exercise of the rights of access, amendment, update or cancelation can be denied by us if it is needed to: (i) protect the national security, the institutional order, the public safety or third party rights; or (ii) avoid the obstruction of justice in judicial or administrative case files related to tax obligations, social security obligations, public health, criminal investigations and administrative infraction investigations as long as there is an order in the corresponding case file to avoid the exercise of any of the aforementioned rights by the data subject.

For information about how to exercise these rights, please see Your Choices & Rights in Your Information above. Sherwin-Williams can be contacted through the Global Privacy Portal for additional inquiries.

Residents of Australia

Australian residents are hereby notified that you have the option to deal anonymously or by pseudonym if you contact us by telephone and you merely seek information about our Services but you do not wish to enter into any further discussions with us. However, if you wish to deal with us in this way, you will not be able to engage with us in respect of our services. If you wish to engage with us in respect of our services, you may be required to provide us with your personal information.

Sherwin-Williams may transfer your personal information to affiliates, service providers, and other parties described under “Sharing Your Information” outside of Australia including in the United States.

We rely on your consent to send you direct marketing messages about our products, services, and promotions, and to deliver targeted advertisements to you.  You can withdraw your consent at any time.  Please see Your Choices & Rights in Your Information for more information.  You also may change the privacy settings of your browser, for example, with respect to cookies.  If you withdraw consent, we are no longer able to offer these services.

If we become aware of any ongoing concerns or problems concerning our privacy practices, we will take these issues seriously and work to address these concerns. If you have any further queries relating to our privacy policy, or you have a problem or complaint, please contact us at our Global Privacy Portal.  If you are not satisfied with our handling of your problem or complaint you may make a complaint to the Australian Information Commissioner – for further details please visit http://www.oaic.gov.au/

Residents of Canada

Canadian residents are hereby notified that Sherwin-Williams and its service providers may process and store your personal information outside of Canada, including in the United States, and such data may be subject to disclosure to authorized law enforcement, local courts, and national security authorities pursuant to applicable local laws and legal process.  You may contact Sherwin-Williams with questions about our privacy practices, including to receive information regarding our policies and procedures with respect to service providers outside of your jurisdiction.

You are further notified that if you refuse to consent to our collection, use or disclosure of your personal information, we may not be able to provide you with the products or services you request.  Subject to legal and contractual restrictions, you may withdraw your consent to our further collection, use or disclosure of your personal information for such purposes as marketing and delivering surveys at any time by giving us reasonable notice.  You may not be permitted to withdraw your consent to certain necessary collections, uses and disclosures of your information (such as maintaining reasonable business and transaction records).

Please see Your Choices & Rights in Your Information for information about how to exercise your rights to access your personal information.  Our authorized employees, agents and mandataries will have access to your information as required to fulfill their obligations to us.

Residents of India

If you are an Indian resident, you are entitled to request to review your personal information and to update, correct, or delete deficient or inaccurate information, and you have the right to contact us regarding any discrepancies or grievances relating to the processing of personal information by Sherwin-Williams.  Please see How to Contact Us for information on how to contact us.  Please see Your Choices & Rights in Your Information for information about how to exercise these rights.  While we take steps to comply with your requests in a timely manner, we are not responsible for the authenticity of your personal information.

Residents of Malaysia

If you are a resident of Malaysia, please see How to Contact Us for information about how to contact Sherwin-Williams’ Global Privacy Compliance group responsible for global data protection.

Residents of Mexico 

As residents of Mexico, you may object to the processing of your personal information for the following voluntary uses of such personal information:

• To communicate or send you promotions.
• To provide you with relevant advertising on our Services and elsewhere.
• To determine the effectiveness of our advertising.

Also, in addition to your rights of access and rectification, you also may have the right to cancel or oppose the collection and processing of your personal information and to limit the scope of processing and to revoke your consent, in accordance with local law.

Please see Your Choices & Rights in Your Information for information about how to exercise these rights.  Please explain what right you want to exercise and provide proof of identity.  The request shall be answered in accordance with applicable law. If you would like to correct or update your personal information, indicate what the correction should be.

Residents of New Zealand

Under the New Zealand Privacy Act 1993, you have certain rights of access to and correction of personal information we hold about you.  Please see Your Choices & Rights in Your Information for information about how to exercise these rights.

Residents of Singapore

If you are a resident of Singapore, please see How to Contact Us for information about how to contact Sherwin-Williams’ Global Privacy Compliance group responsible for global data protection.

Residents of Sweden

If you are a Swedish resident, you may contact Sherwin-Williams for information about our privacy practices as described under How to Contact Us.

Residents of Uruguay

The legal bases for our processing activities are as follows:

• For our legitimate business purposes, including:
  • to provide you with services, products, or other materials you request (for example, completing your registration for a loyalty program and sending you product samples) and to customize your experience with our Services;
  • to manage and improve your shopping experiences and our products, Services and offerings, including analyzing the use of our products and services, and determining the effectiveness of our advertising; and
  • to protect the security and integrity of our Services.

• To perform our contract(s) with you, including processing your purchases and transactions.

• To meet our legal obligations, for example:
  • for audit and reporting purposes;
  • to perform accounting and administrative tasks;
  • to respond to requests for information by competent public bodies and judicial authorities; and
  • to enforce our legal rights and to enforce or manage legal claims.

• On the basis of your consent:

• to send you direct marketing messages about our products, services, and promotions; and
• to deliver targeted advertisements to you, both on and off the Services, including by using cookies and similar technologies, as explained below.

You can withdraw your consent at any time.  Please see Your Choices & Rights in Your Information for more information.   You also may change the privacy settings of your browser, for example, with respect to cookies.  If you withdraw consent, we are no longer able to offer these services.

Please see Your Choices & Rights in Your Information for information about how to exercise the rights you may have in accordance with Uruguayan Data Protection Act No. 18,331.  You also may contact us with questions and to exercise any rights hereunder as described under How to Contact Us.

Vietnam Residents

The information about you that we collect, store, process, use, disclose to and transfer to third parties includes information in electronic format. References to “sharing” and “disclosure” of personal information in Sharing of Information include any and all of the acts of sharing, disclosing, and transferring your information.  Please see Your Choices & Rights in Your Information for information about how to exercise rights you may have under local law to access, update, correct and/or request removal of your personal information from our databases, request stoppage of the provision of your personal information to a third party or request we not quote or otherwise use contents of such information.  In addition, you may contact us at the following address for questions or information about how to exercise your rights under local laws as described under How to Contact Us.  Upon receipt of your request, Sherwin-Williams will grant you reasonable access to personal information that we hold about you, unless otherwise legally unable to do so. In addition, Sherwin-Williams will take necessary steps to permit you to correct, amend, or delete information demonstrated to be inaccurate or incomplete.

Effective Date:  April 1, 2018