Arcadium Lithium Global Privacy Notice

At Arcadium Lithium, we are committed to respecting data privacy. This Global Privacy Notice (“Notice”) explains how Arcadium Litihium and its subsidiaries, affiliates and related entities (collectively, “we,” “us,” or “our”) protect the personal data collected and otherwise processed by us, and what types of personal data we collect about visitors to our website and others that otherwise engage or interact with us (collectively, “you” or “your”). You may have rights to control the use of your personal data, which you can read about below.

If you have any questions or concerns about this Notice, contact us using the details provided in the “Contact Arcadium Lithium” section of this Notice.

We or our affiliates may provide you with products or services that have additional terms and conditions (including, but not limited to, terms of use or other terms, policies, notices, rules or conditions) that apply in connection with your use of such products or services. In the event of any conflict between this Notice and any such additional terms and conditions, such additional terms and conditions will govern in relation to your use of such products or services.

For the purposes of this Notice, “personal data” has the meaning given to such term (or to terms of similar intent, such as “personal information”) under applicable law, as and to the extent applicable to your rights and our obligations with respect to such information, including (as and to the extent applicable): (i) “personal data” as defined under Data Protection (Jersey) Law 2018; (ii) “personal data” as defined under General Data Protection Regulation (EU) 2016/679 (“GDPR”) or the UK Data Protection Act 2018 and the GDPR as incorporated into the laws of the United Kingdom pursuant to the European Union (Withdrawal) Act 2018 (collectively, “UK GDPR”); and/or (iii) “personal information” as defined under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA”). Personal data excludes anonymous or de-identified data that is not associated with a particular individual.

What Data We Collect

We collect personal data from visitors to this website and from subscribers to our e-mail alerts. For these purposes we may collect your name, contact details (including email address), IP address and other online identifiers/web beacons, device ID, pages viewed prior to landing on our site, browser or e-mail client type, Internet browsing and usage habits (including, but not limited to, services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page), Internet Service Provider (“ISP”), domain name, the time/date of your visit to our website and your time zone settings, the referring URL and your browser type and version, relevant plug-ins, operating system and platform, and any other personal data provided by you or your ISP. Additionally, your personal data may be provided to us by our affiliates. This information is generally used to help us administer the website and other services we offer, to improve our product offerings, and in other ways as described in this Notice.

If you submit personal data on behalf of another individual (e.g., a colleague or family member), you must ensure that they have read and understand the content of this Notice and that you have their consent to share their personal data with us.

Cookie Generated Information

Arcadium Lithium may use cookies and other tracking technologies on its websites. Our website is cookie-enabled in order to give you a more personalized user experience. You may change your cookie settings on your internet browser or delete our cookies at any time. However, please note that if you disable cookies, the functionality offered by our website may be limited as a result. For more information, please refer to our Cookie Policy at the base of this Notice.

We also use web analysis tools, such as Google Analytics, to create usage profiles that help us understand statistical information about the usage of our website, to design it to be user-friendlier and improve our services by evaluating server log files. These tools either do not collect personal data such as IP addresses or anonymize these upon collection. You can generally avoid the creation of usage profiles by deactivating cookie usage in your browser’s settings.

How Data is Used

We will use or otherwise process your personal data in the following circumstances: (i) where we need to perform the contract we are about to enter into or have entered into with you; (ii) 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; (iii) where we need to comply with a legal obligation; or (iv) with your consent.

Generally, we do not rely on consent as a legal basis for processing your personal data, although we will get your consent before sending third-party direct marketing communications to you via email or text message or where we are otherwise required to do so under applicable law before processing your personal data. You can withdraw your consent to such third-party direct marketing communications by using the ‘unsubscribe’ link provided in our emails or contacting us using the details provided in the “Contact Arcadium Lithium” section of this Notice.

We may use your personal data for the following business purposes:

1. To initiate, perform or fulfill a contractual obligation or otherwise provide you with the products or services you have requested, including, without limitation, by:

• providing you with documentation or communications which you have requested;
• fulfilling an order for products or services;
• providing product information you have requested;
• providing technical service and safe handling interviews for use of our products;
• providing after-sales support and customer service, surveys and feedback;
• processing and completing certain transactions involving our website, and more generally transactions involving Arcadium Lithium products and services;
• keeping accounting records and evidence of online sales;
• engaging you about events, promotions, our website and Arcadium Lithium products and services;
• customizing your experience with us to your interests and purchase history;
• sending you promotional materials and marketing communications about our products and services, including price announcements;
• sharing your personal data with manufacturing partners to enable product production, product shipping and auditing; and/or
• corresponding with you to resolve your queries or complaints.

2. To operate and improve our website and services, including, without limitation, by:

• evaluating transactions involving our website or our products and services;
• operating, evaluating, maintaining, improving and developing our website (including by monitoring and analyzing trends, access to, and use of our website and pages for advertising and marketing);
• assessing your use of our website, products and services in order to better meet the needs of all users and to inform our marketing strategy;
• protecting the security of our website and Arcadium Lithium confidential and proprietary information; and/or
• assessing your user experience in order to evaluate, improve and develop our products and services generally, as well as our sales, marketing and promotional efforts.

3. To protect our legitimate interests, including, without limitation, by:

• protecting the safety of Arcadium Lithium employees;
• managing, remediating, protecting against and investigating fraud, credit risk, risk exposure, claims and other liabilities, including violation of our contract terms or laws or regulations;
• administering and protecting our business, our network and our website (including troubleshooting, testing, system maintenance, support, reporting and hosting of data), and other security purposes;
• undertaking internal business administration and record keeping;
• using data analytics to improve our website, products/services, marketing, customer relationships and experiences;
• complying with legal and regulatory obligations, including, for example, as necessary to respond to governmental, regulatory or law enforcement agency requests;
• delivering relevant website content and advertisements to you and to measure or understand the effectiveness of the content we serve to you;
• processing such personal data as necessary to buy, sell, form, or otherwise reorganize, or seek or obtain financing in connection with, one or more of Arcadium Lithium’s businesses (including any stock or assets thereof), for example, as the result of any actual or potential sale, merger, reorganization, restructure, liquidation or any other corporate transaction; and/or
• processing such personal data for purposes otherwise set out in this Notice.

For clarity, Arcadium Lithium and its affiliates may also share personal data amongst themselves.

We do not use or otherwise process your personal data, including “sensitive” personal data, for purposes of automated decision-making, including profiling.

We do not use or otherwise process your “sensitive” personal data other than as described herein. To the extent we collect any sensitive categories of personal data about you, including, for example, certain geolocation information, we will limit use of such information to that which is necessary to perform services or provide goods reasonably expected. To the extent you have any questions or concerns regarding our collection and use of sensitive categories of personal data, please contact us using the details provided in the “Contact Arcadium Lithium” section of this Notice.

We may aggregate, anonymize, or otherwise de-identify your personal data and use it for any purpose permitted by applicable law, and we may use information that does not personally identify you for any purpose, except where we are required to do otherwise under applicable laws. We also may use your information for any other purposes disclosed to you at the time of collection, that you have previously authorized, or with respect to which you subsequently provide your consent.

Do Not Track

Your browser and other mechanisms may permit you to send do-not-track signals or other similar signals via your browser settings to express your preferences regarding online tracking. Due to the lack of any standard for how do-not-track should work on commercial websites, we do not currently respond to such signals.

How Data is Shared

We may share your personal data as described below:

• Within Arcadium Lithium. We may share your personal data with Arcadium Lithium employees and affiliates for the purposes described in this Notice.
• With our service providers. We may share your personal data with companies or organizations, including subsidiaries, affiliates, and non-Arcadium Lithium entities, that perform services on our behalf, such as website support service providers, information technology hosting services providers, legal counsel and other professional advisors, electronic billing providers, shipping companies, distributors, communications services providers, marketing service providers and other third-party vendors.
• Agents, Logistics Companies and Distributors. We may share your personal data with companies or organizations, including agents, logistic trading houses, and distributors who provide targeted support and services as part of our customer relationship and service obligations.
• Business transactions and transfers. Arcadium Lithium may buy, sell, form, or otherwise reorganize, or seek or obtain financing in connection with, one or more of its businesses (including any stock or assets thereof), for example, as the result of any actual or potential sale, merger, reorganization, restructure, liquidation or any other corporate transaction. A transaction of this type may involve the disclosure of your personal data to prospective or actual purchasers, partners, lenders or other relevant persons who have signed a confidentiality agreement with Arcadium Lithium.
• Compliance with laws and protection of our rights and the rights of others. We may disclose personal data when we consider disclosure is necessary or appropriate to comply with any applicable law, legal process, court order or subpoena. We may also disclose personal data to cooperate with a government investigation; to prevent or investigate a possible crime, such as fraud or identity theft; to enforce or apply our online terms of use or other agreements; to comply with any duty to disclose or share your personal data with applicable tax authorities; or to protect our own rights or property or the rights, property or safety or use by others.

We also may disclose your information to any other third party where you have provided consent to such disclosure. We do not sell or offer to sell any personal data about you to third parties or share your personal data with third parties for purposes of cross-context behavioral advertising.

Marketing

If you are a current customer of Arcadium Lithium we may use certain personal data to send you product or promotional advertising, and specifically:

• to send you marketing communications containing news, information and updates about our company, products and services, offers, promotions and special events, customer surveys and feedback and other marketing communications that may be of interest to you;
• to assist us in advertising our products and services on third party websites – please see our Cookie Policy at the end of this Notice for additional information;
• to carry out data analytics, market research and data enrichment, such as by analyzing your product preferences, interests, purchase history and interactions with our website together with data collected from third parties, such as data that you agree to share with us on social networks (e.g., LinkedIn, Instagram, etc.) and/or that we may collect from publicly accessible databases.

We will get your consent before sending third-party direct marketing communications to you via email or text message. You can withdraw your consent to third-party or our direct marketing communications at any time or object to our use of your personal data for third-party or our direct marketing purposes. Please use the ‘unsubscribe’ link provided in our emails or contact us using the details provided in the “Contact Arcadium Lithium” section of this Notice if you wish to do so.

Location of Data

Arcadium Lithium is a global organization with its corporate address in Ireland. As part of the services offered to you through our website, and during our ordinary business operations, the personal data we collect may be transferred to countries outside your home country, including the United States. Our servers, databases, and service providers may be located in the United States. Where required, we will ask you to consent to the collection, use, transfer and other processing of your personal data in or to the United States or other countries for the purposes described in this Notice. We will only transfer your personal data outside of your home country where we are satisfied that adequate levels of protection are in place to protect the confidentiality, integrity and security of your personal data or adequate security measures are adopted in compliance with applicable data protection laws. For additional information regarding such steps, please contact us using the details provided in the “Contact Arcadium Lithium” section of this Notice.

Use of Special Features or Areas of Our Website

This Notice may be supplemented or amended from time to time by privacy notices that are specific to and appear on individual Arcadium Lithium websites, including but not limited to our investor relations and career sites. Generally, these notices provide details about the personal data we collect or do not collect on such pages or areas of a website, why we need that information, and choices you may have about the use of that information.

Children’s Privacy

Our website is not intended for children. Arcadium Lithium does not knowingly or intentionally gather personal data from persons who are under the age of 18. If it comes to our attention that a child under 18 submits personal data to us, we will attempt to delete the information as soon as possible. If you are a parent or guardian of a child who has provided personal data without your knowledge and consent, you may request we remove this information by contacting us using the details provided in the “Contact Arcadium Lithium” section of this Notice.

Security

We take commercially reasonable precautions designed to protect the confidentiality, integrity and security of the personal data we collect. Unfortunately, the storage and transmission of electronic information is not completely secure. Although we strive to protect your personal data, we cannot guarantee the security of information stored on our or our vendors’ servers or transmitted via email or through our website; you transmit personal data to us at your own risk.

Retention of Your Personal Data

We keep personal data for as long as required to fulfill the purposes for which it was collected. In general, we retain your personal data for a period of time corresponding to a statute of limitation, for example to maintain an accurate record of your dealings with us, such as pursuant to a supplier, vendor or customer contract so that we can raise or defend a legal claim. However, in some circumstances we may retain personal data for other periods of time, for instance where we are required to do so in accordance with legal, tax and accounting requirements, or if required to do so by a legal process, legal authority, or other governmental entity having authority to make the request, for so long as required.

Links to Other Websites

For your convenience, this website may contain certain hyperlinks to other Arcadium Lithium websites or to websites outside Arcadium Lithium. By visiting a linked website from a Arcadium Lithium website, you acknowledge that Arcadium Lithium is providing these links to you only as a convenience and you agree that we do not control, and that we are not responsible for, the content, nature, reliability or information handling practices of such linked websites. Data collection on the hyperlinked pages and sites is governed by the privacy policies posted on those websites. We therefore recommend that you read the privacy policy, statement or notice for each site you visit. We are not responsible for any linked websites.

Your Choices and Rights

Depending on where you reside, you may have one or more rights, such as those set forth below, relating to our processing of your personal data under applicable law (for example, the Data Protection (Jersey) Law 2018, the GDPR and the UK GDPR, as applicable). These rights are not absolute and some of these rights will be subject to specific requirements or limitations under applicable law.

Your Rights

• Opt-out: You may have the right to withdraw your consent for us to collect, use, disclose or otherwise process your personal data. For example, if you wish to opt out of receiving electronic marketing communications, you can use the ‘unsubscribe’ link provided in our emails or otherwise contact us directly and we will stop sending you such communications.
• Access, correction and erasure: You may have the right to request access to and obtain a copy of any of your personal data that we may hold, to request correction of any inaccurate data relating to you and to request the deletion of your personal data under certain circumstances.
• Data portability: Where we are relying upon your consent as the justification for processing your personal data, or the fact that such processing is necessary to perform a contract to which you are party or to take steps at your request prior to entering a contract, and the personal data is processed by automated means, you may have the right to receive all such personal data which you may have provided us in a structured, commonly used and machine-readable format, and also to require us to transmit it to another controller where this is technically feasible.
• Objection or restriction of processing: You may have the right to object to or restrict our processing of your personal data under specific circumstances. Where your personal data is subject to restriction we will only process it with your consent or as permitted under applicable law.
• Complaints: Please contact us using the details provided in the “Contact Arcadium Lithium” section of this Notice if you have any questions or complaints. You also have the right to lodge a complaint with the supervisory authority of your habitual residence, place of work or place of alleged infringement, if you consider that the processing of your personal data infringes applicable law. For example, in Jersey you should contact the Jersey Office of the Information Commissioner (https://jerseyoic.org/) and in the UK you should contact the Information Commissioner’s Office (https://ico.org.uk/global/contact-us/ or 0303 123 1113).
• Right to object to processing (including profiling) based on legitimate interest grounds: You may have the right to object to the processing of your personal data where we are relying upon legitimate interests to process personal data. If you object, we must stop such processing unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms, or that such processing is otherwise permitted by applicable law.
• Right to object to direct marketing (including profiling): You may have the right to object to our use or processing of your personal data (including profiling) for direct marketing purposes, such as when we use your personal data to invite you to our promotional events that we believe may be of interest to you. If you wish to opt out of receiving direct marketing communications, you can use the ‘unsubscribe’ link provided in our emails or otherwise contact us directly and we will stop sending you such communications.

Fees

You will not have to pay a fee to access your personal data (or to exercise any of the other above-listed rights). In some cases, we may charge a reasonable fee if your request for access is clearly unfounded or excessive, or if you request multiple copies of the relevant information. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you

To access your personal data (or to exercise any of the other above-listed rights), we may need to request specific information from you to help us confirm your identity and ensure your right to access the personal data (or to exercise any of your other above-listed rights). This is another appropriate security measure designed to ensure that personal data is not disclosed to any person who is not entitled to receive it.

Contact Us

Please contact us using the details provided in the “Contact Arcadium Lithium” section of this Notice if you wish to exercise any of your rights, or if you have any enquiries or complaints regarding the processing of your personal data.

Changes to this Notice

This Notice is subject to change. As we add new features and functionality to our websites or Arcadium Lithium policies or as applicable laws evolve, we may need to update or revise this Notice accordingly. We reserve the right to do so, at any time, by posting a revised version on our website prior to any such change taking effect. It is important for you to review this Notice regularly. These changes will be effective and will supersede all prior versions of any Arcadium Lithium privacy policy or privacy notice as of the date we post a revised version on our website. We will seek your consent to these changes where required to do so by applicable law.

Additional Information for Individuals Whose Personal Information is Subject to the CCPA

Residents of the state of California have certain rights with respect to their personal information pursuant to the CCPA and as further described in this section. Please note that the rights under the CCPA do not apply to personal information collected, processed, sold or disclosed subject to the Gramm-Leach-Bliley Act (Public Law 106-102), the Fair Credit Reporting Act (12 CFR 1022) and/or the California Financial Information Privacy Act.

Under certain circumstances, under the CCPA, you may have the right to:

• request, up to twice in a twelve-month period, that we disclose, free of charge, the categories and specific pieces of personal information we collect about you (and, if applicable, sell or otherwise disclose to a third party and the categories of such third parties), the sources from which such personal information was collected, and the business purpose for collecting, selling or disclosing such personal information;
• opt out of the sale of your personal information (as noted above, we do not currently sell your personal information or share your personal information with third parties for purposes of cross-context behavioral advertising);

• request that we delete the personal information we have collected about you, except in circumstances where we are legally entitled to retain personal information regardless of any such request; and

• request that we correct any inaccurate or outdated personal information we have collected about you.

We will not discriminate against or, except as permitted by applicable law, deny services to any California resident who seeks to exercise the rights set forth in this section.

You have the right to appoint an authorized agent to exercise these rights on your behalf. If you want to exercise any of these rights, or have your authorized agent exercise any of these rights on your behalf, then please contact us using the details set forth at the end of this Notice. To exercise any of these rights, we may need to request specific information from you or your authorized agent to help us confirm your identity and ensure your right to exercise these rights.

These rights are not absolute and each is subject to certain exceptions or qualifications.

For California residents with disabilities who need to access this Notice in an alternative format, please contact us using the details provided in the “Contact Arcadium Lithium” section of this Notice.

Contact Arcadium Lithium

Arcadium Lithium’s corporate address is at Suite 12, Gateway Hub, Shannon Airport House, Shannon, Co., Clare V14 E370, Ireland. Please address any questions, comments and requests regarding our data processing practices to us:

By post at our corporate address.

By email at [email protected]

Arcadium Lithium Cookie Policy

What are Cookies?

Cookies are files or pieces of information that may be stored on your computer (or other internet-enabled devices, such as a smartphone or tablet) when you visit a website. A cookie will usually contain the name of the website from which the cookie has come from, the “lifetime” of the cookie (i.e., how long it will remain on your device) and a value, which is usually a randomly generated unique number.

How we use cookies

Our website uses technologies that enhance user friendliness and engagement, to keep our website operating as smoothly as possible and to provide web services and functionalities for each visitor. Examples of these technologies are cookies, pixel tags, local storage objects and scripts. We may use cookies for a variety of purposes. For example, to calculate web statistics, or improve your experience when you visit our website.

Each browser accessing the Arcadium Lithium website is given a unique cookie, which is then used to determine the extent of repeat usage, usage by a registered user versus by an unregistered user, and to help develop content based on user interests and behavior. We also aggregate and anonymize the information collected to measure certain traffic patterns, which areas of our websites you have visited, and your visiting patterns. We use this research to understand our users’ habits so that we can make your experience on our website a better one. We may use this information to better personalize the content, banners, and promotions on our sites.

Cookies we use

We may use the following cookies on our website:

• Functional cookies: using these cookies is essential in order to ensure that our website operates properly. They are used to save your user preferences, detect misuse of our website and services and to distribute the load on our servers, which keeps our website available. Certain services you may request cannot be provided without these cookies.
• Web statistics cookies: we use these cookies to determine which parts of our website interest our visitors. This enables us to make the structure, navigation, and content of our website as user friendly as possible for you. These cookies are used to (i) keep track of the number of visitors to our web pages; (ii) keep track of the amount of time each user spends on our web pages; (iii) determine the order in which a visitor visits the various pages of our website; (iv) assess which parts of our website need to be changed; and (v) optimize our website.
• Google Analytics: Our website uses Google Analytics, a web analytics service provided by Google Inc. Google Analytics uses cookies to analyze how you use our website. The information generated by the cookie is usually transmitted to a Google server in the USA and stored there. However, Google Analytics provides an IP masking feature, which can be activated by us. IP masking is activated on our website, which means that your IP address will be shortened by Google (IP masking/truncating) before it is collected, within member states of the European Union or other parties to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be sent to a Google server in the US and shortened there. Google will use this information on behalf of Arcadium Lithium to evaluate your use of our website, to compile reports on website activity and to provide other services related to website activity and internet usage to us.

The IP address provided by Google Analytics will not be merged with other Google data. You may refuse the use of these cookies by selecting the appropriate settings on your browser as described in this Notice. However, please note that if you do this, you may not be able to use the full functionality of our website. In addition, you can find more information about Google’s collection and use of data (cookies and IP address) and how to prevent such use and collection here: https://support.google.com/analytics/answer/181881?hl=en.

Please note that on our website, Google Analytics code is supplemented by “gat._anonymizeIp();” to ensure an anonymized collection of IP addresses (so called IP-masking).

We or our third-party service providers also may use collected information to establish connections among related web browsers and devices (such as smartphones, tablets, computers, and TVs) for targeted advertising, analytics, attribution, and reporting purposes. These third parties may match your browsers or devices if you log into the same online service on multiple devices or if your devices share similar attributes that support an inference that they are used by the same person or household. This means that information about your activity on our website or apps on your current browser or device may be combined with information collected from your other browsers or devices.

How to manage your cookies

If you do not want our website to store cookies on your device, you can change your browser settings so that you receive a warning before certain cookies are stored. Most web browsers allow some control of most cookies through the browser settings, which means that you can adjust your settings so that your browser refuses most of our cookies or only certain cookies from third parties. You can also withdraw your consent to cookies by deleting the cookies that have already been stored. Please refer to your browser instructions or help screen to learn more about how to adjust or modify your browser settings.

Please be aware that if you do not want to accept any cookies and change your browser settings accordingly, you may not be able to use all the features of our website to the fullest extent possible or you will be unable to view certain parts of our website. Please note that you will have to change your settings for each browser and device you use. Such methods will not work with respect to certain non-cookie online tracking technologies.

If you use different devices to view and access our website (e.g., your computer, smartphone, tablet, and television), you will need to ensure that each browser on each device is adjusted to suit your cookie preferences.