EEA, UK, And Switzerland Privacy Notice

Last Updated and Effective Date: May 21, 2024

This EEA, UK, and Switzerland Privacy Notice supplements the Southwestern Privacy Notice and includes additional information and disclosures we are required to provide to individuals located in the European Economic Area (including the European Union) (“EEA”), United Kingdom (“UK”), or Switzerland. You should read them both carefully.

To make it simple, we use the same terms as defined in our Privacy Notice. Any new terms will be defined below. This EEA, UK, and Switzerland Privacy Notice should be read together with our Privacy Notice.

Effective Date and Changes to this EEA, UK, and Switzerland Privacy Notice

This EEA, UK, and Switzerland Privacy Notice is effective as of the “Last Updated and Effective Date” above and will remain in effect except with respect to any provisions that are changed in the future. Southwestern may make changes to this EEA, UK, and Switzerland Privacy Notice from time to time and will notify you by posting a revised version on the Site.

Our Relationship with You

If you are using Southwestern products or services where you enrolled in such products or services as a user (or an individual enrolled you on your behalf), then Southwestern is the controller of your Personal Information because we determine the means and purposes of processing this information.

If you are receiving a Southwestern product or service through another entity, such as one of our customers, dealers, or wholesalers, then that entity is the controller of your Personal Information, and Southwestern processes that Personal Information on behalf of the controller.

Our Lawful Bases for Processing Your Personal Information

Southwestern’s lawful bases for processing your Personal Information are to perform a contract with you or at your request prior to entering into a contract with you, with your consent, or to comply with a legal obligation. We also process your Personal Information for our legitimate interest in our business needs, balanced against the rights and freedoms of all individuals affected by that need. These interests incorporate considerations of the risks present in our processing, your likely response to those risks, and what benefits you are likely to receive from our processing.

We process Personal Information for several legitimate interests, including:

fulfilling our contract with our customers based upon our legitimate interest as a business in providing the products and services we offer;
in response to communications initiated by you based upon our legitimate interest as a business in responding to inquiries or suggestions about our business and the corresponding benefit you will receive in our response;
for direct marketing based upon our legitimate interest as a business in sharing information about our products and services and the corresponding benefit you will receive in learning about our products and services;
to protect against fraud based upon our legitimate interest as a business in protecting our business, products, and services; and
to ensure network and information security based upon our legitimate interest as a business in maintaining the confidentiality, security, and integrity of the information in our network and the corresponding benefit you will receive in the maintenance of the security of your Personal Information.

Your EEA,UK, and Swiss Privacy Rights

Under certain circumstances and in accordance with EU, UK, Swiss, or other applicable data protection laws, you may have the following rights:

Right to be Informed

Individuals have a right to be informed of how your Personal Information is collected and used. We provide that through the Southwestern Privacy Notice.

Right of Access

Individuals may have the right to access this Personal Information we have collected about you.

Right to Rectification

Individuals may have the right to request correction of any inaccurate Personal Information that we maintain about you.

Right to Erasure

Individuals may have the right to request that we delete any of your Personal Information that you have provided or that we have collected or obtained about you, subject to certain exceptions.

Right to Restrict Processing

Individuals may have the right to ask us to restrict the processing of your Personal Information in certain circumstances.

Right to Object to Processing

Individuals may have the right to object to the processing of your Personal Information in certain circumstances, and at any time where the processing takes place for the purposes of legitimate interests pursued by us or a third party. Note that the right to object under legitimate interests is absolute for direct marketing but is not absolute for other processing. We will be allowed to continue to process your Personal Information if we can demonstrate “compelling legitimate grounds for the processing which override your interests, rights and freedoms” or we need this for the establishment, exercise, or defense of legal claims.

Right to Data Portability

Individuals may have the right to ask that we transfer the Personal Information you gave us to another organization or to you in certain circumstances.

Right to Withdraw Consent

Individuals may have the right to withdraw previously given consent to process your Personal Information.

Right to Object to Automated Processing

Southwestern does not generally engage in automated processing of the information we collect about you, except to the extent that our use of cookies for targeted advertising qualifies as automated processing under applicable law. Therefore, please review our Cookie Notice and Your Cookie Rights and Choices regarding cookies.

Individuals may have the right to object to decisions being made with your Personal Information solely based on automated decision making or profiling.

Exercising Your Rights

You are not required to pay any charge for exercising your rights. If you make a request, we will respond to you as required under the applicable data protection law.

Please note that we may still use any aggregated and/or anonymized Personal Information that does not identify any individual, and may also retain and use Personal Information as necessary to comply with our legal obligations.

If you are using a Southwestern product or service where you enrolled in such products or services as a user (or an individual enrolled you on your behalf), to exercise your rights, please contact us at:

Form: here

If you are receiving a Southwestern product or service through another entity, that entity is the controller of your Personal Information, and Southwestern is not permitted to respond directly to requests related to processing of Personal Information from such users. Requests must be directed to the entity that controls the Personal Information.

The deletion or cessation of collection of information may result in cancellation of programs and subscriptions or other services initially provided to you.

Please note that if you are one of our customer’s employees and you unsubscribe from receiving promotional or marketing communications from us, we may continue to send you transactional or service-related emails.

International Transfers

We are a global business which results in your Personal Information likely being transferred to, stored, and processed in the U.S. and other countries outside of where you live. When we conduct such transfers, we rely on various legal bases to lawfully transfer Personal Information around the world, including fulfillment of our agreements with you, your prior consent, adequacy decisions for relevant countries, or other transfer mechanisms as may be available under applicable law, such as the European Union Commission approved standard contractual clauses.

Contact Us

If you have any questions or concerns about our EEA, UK, and Switzerland Privacy Notice, you can contact us at:

Form: here

Phone: (888) 551-5901

Postal Address:

c/o the Vice President of I.T. of the Southwestern Family of Companies
2451 Atrium Way
Nashville, Tennessee 37214

If you are in the EU/UK, you may address privacy-related inquiries to our EU/UK representatives at:

EU:

Osano International Compliance Services Limited
ATTN: KP4S
3 Dublin Landings
North Wall Quay
Dublin 1
D01C4E0

UK:

Osano UK Compliance LTD
ATTN: KP4S
42-46 Fountain Street
Belfast
Antrim
BT1 – 5EF

We will respond to requests, inquiries, or concerns within 30 days. If you make a request to exercise one of your rights, we will respond according to the applicable data protection law.

You may also lodge a complaint with the data supervisory authority competent for your country or region if you feel unsatisfied with our treatment of your Personal Information.