Privacy Policy

LAST UPDATED: May 6, 2025

Tempel Steel Company, LLC and its subsidiaries (collectively, “Company,” “we,” or “us,”) want you to be familiar with how we collect, use, and disclose information. This Privacy Policy describes our practices in connection with information that we collect through:

• Websites operated by us from which you are accessing this Privacy Policy (the “Websites”);
• Our social media pages that we control (collectively, our “Social Media Pages”);
• HTML-formatted email messages that we send to you that link to this Privacy Policy or other communications with you; and
• Offline business interactions you have with us.

Collectively, we refer to the Websites, Social Media Pages, emails, and offline business interactions as the “Services.”

PERSONAL INFORMATION

“Personal Information” is information that identifies you as an individual or relates to an identifiable individual. The Services collect Personal Information, including:

• Name
• Postal address
• Telephone number
• Email address
• Business contact information
• Purchase and transaction history
• User feedback you choose to provide
• Your CV and other job application materials, if you choose to apply for a position with us
• IP address (we may also derive your approximate location from your IP address)

Collection of Personal Information

We and our service providers collect Personal Information in a variety of ways, including:

• Through the Services.

• We collect Personal Information through the Services, for example, when you make a purchase, apply for a position with us, provide feedback, or contact us with inquiries. We may also collect Personal Information automatically as described in the “Information Collected Automatically” section below.

• From Other Sources.

• We receive your Personal Information from other sources, for example: joint business partners, third-party data providers, social media platforms, marketing partners, and publicly available websites and databases.

We need to collect Personal Information in order to provide the requested Services to you. If you do not provide the information requested, we may not be able to provide the Services. If you disclose any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

Use of Personal Information

We and our service providers use Personal Information for the following purposes:

• Administering the Services and fulfilling your requests.

• To administer the Services, respond to your inquiries, fulfill your requests, and provide you with customer service.
• To complete your transactions and verify your information.
• To fulfil our contract with your business and verify your information.
• To process your job application, if you choose to apply for a position with us.
• To send administrative information to you, such as changes to our terms, conditions, and policies.

We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.

• Providing you with our newsletter and/or other marketing materials and facilitating social sharing.

• To send you marketing related emails, with information about our services, new products, and other news about our Company.
• To facilitate social sharing functionality that you choose to use.

We will engage in these activities with your consent or where we have a legitimate interest.

• Analyzing Personal Information for business reporting and providing personalized services.

• To analyze or predict our users’ preferences in order to prepare aggregated trend reports on how our digital content is used, so we can improve our Services.
• To better understand your interests and preferences, so that we can personalize our interactions with you and provide you with information and/or offers tailored to your interests.
• To better understand your preferences so that we can deliver content via our Services that we believe will be relevant and interesting to you.

We will provide personalized services based on our legitimate interests, and with your consent to the extent required by applicable law.

• Aggregating and/or anonymizing Personal Information.

• We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose, as it no longer identifies you or any other individual.

• Accomplishing our business purposes.

• For data analysis, for example, to develop and improve the efficiency of our Services;
• For audits, to verify that our internal processes function as intended and to address legal, regulatory, or contractual requirements;
• For fraud prevention and fraud security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft;
• For developing new products and services;
• For enhancing, improving, personalizing, repairing, maintaining, or modifying our current products and services, as well as undertaking quality and safety assurance measures;
• For identifying usage trends, for example, understanding which parts of our Services are of most interest to users;
• For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users; and
• For operating and expanding our business activities, for example, understanding which parts of our Services are of most interest to our users so we can focus our energies on meeting our client’s interests.

We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or based on our legitimate interest.

Disclosure of Personal Information

We disclose Personal Information:

• To our corporate affiliates for the purposes described in this Privacy Policy.
  • You can consult the list and location of our affiliates here: https://www.worthingtonsteel.com/our-company/who-we-are/locations.
• To our third-party service providers, to facilitate services they provide to us.
• These can include providers of services such as website hosting, data analysis, fraud prevention, credit risk reduction, personalization, information technology and related infrastructure provision, customer service, email delivery, auditing, and other services.
• To our distributors or sellers who facilitate the sale of our products.
• To our business partners who may provide products or services you are interested in.
• By using the Services, you may elect to disclose Personal Information.
• On message boards, chat, profile pages, blogs, and other services to which you are able to post information and content (including, without limitation, our Social Media Pages). Please note that any information you post or disclose through these services will become public and may be available to other users and the general public.

Other Uses and Disclosures

We also use and disclose your Personal Information as necessary or appropriate, in particular when we have a legal obligation or legitimate interest to do so:

• To comply with applicable law and regulations
• This may include laws outside your country of residence.
• To cooperate with public and government authorities
• To respond to a request or to provide information we believe is necessary or appropriate.
• These can include authorities outside your country of residence.
• To cooperate with law enforcement
• For example, when we respond to law enforcement requests and orders or choose to provide information that we believe is important.
• For other legal reasons
• To enforce our terms and conditions; and
• To protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others.
• In connection with a sale or business transaction
• We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

INFORMATION COLLECTED AUTOMATICALLY

We and our service providers may collect information automatically in a variety of ways, including:

• Your browser or device.
• Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services you are using. We use this information to ensure that the Services function properly.
• Cookies are pieces of information stored directly on your computer. Cookies allow us to collect such information as browser type, time spent on the Services, interactions with our Websites, pages visited (including sites or services you interacted with before or after interacting with our Websites), content interactions, language preferences, and traffic data. We use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalize your experience. We also gather statistical information about use of the Services in order to continually improve their design and functionality, understand how they are used, and assist us with resolving questions regarding them.
• Cookies further allow us to select which of our advertisements or offers are most likely to appeal to you and display them while you are on the Services or reach out to you directly with personalized marketing communications. We may also use cookies or other technologies in online advertising to track responses to our ads.
• We do not currently respond to browser do-not-track signals.
• If you do not want information collected through the use of cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting particular cookies from a particular website. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Services. You also may not receive advertising or other offers from us that are relevant to your interests and needs. 
• Pixel tags and other similar technologies.
• Pixel tags. Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns, and compile statistics about usage of the Services and response rates.
• Analytics. We use third-party analytics services, such as Google Analytics, which use cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends. These services may also collect information regarding the use of other websites, apps, and online resources. You can learn about Google’s practices by going to google.com/policies/privacy/‌partners/, and exercise the opt-out provided by Google by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
• IP Address
• Your IP Address is a number that is automatically assigned to your computer by your Internet Service Provider. An IP Address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the pages visited. We use IP Addresses for purposes such as calculating usage levels, diagnosing server problems, and administering the Services. We may also derive your approximate location from your IP Address.
• Physical Location
• We may collect the physical location of your device by, for example, using satellite, cell phone tower or WiFi signals. We may use your device’s physical location to provide you with personalized location-based services and content. You may be permitted to allow or deny such uses and/or sharing of your device’s location, but if you do, may not be able to provide you with the applicable personalized services and content.

Uses and Disclosures of Information Collected Automatically

We may use and disclose information collected automatically for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat the information as Personal Information under applicable law, we may use and disclose it for the purposes for which we use and disclose Personal Information, as detailed in this Privacy Policy. In some instances, we may combine information collected automatically with Personal Information. If we do, we will treat the combined information as Personal Information so long as it is combined.

SECURITY

We seek to use reasonable organizational, technical, and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.

CHOICES AND ACCESS

Your choices regarding our use of your Personal Information

You may opt out from receiving marketing-related emails from us. If you no longer want to receive marketing related emails from us on a going-forward basis, you may opt out by clicking on the opt-out or unsubscribe link in each such email or contact us at legalcompliance@worthingtonsteel.com.

We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt out of receiving marketing related emails from us, we may still send you important administrative messages, from which you cannot opt out.

How you can access, change, restrict, or delete your Personal Information

If you would like to request to access, correct, update, suppress, restrict, or delete Personal Information, object to or opt out of the processing of Personal Information, or if you would like to request to receive a copy of your Personal Information for purposes of transmitting it to another company (to the extent these rights are provided to you by applicable law), you may contact us in accordance with the “Contacting Us” section below. We will respond to your request consistent with applicable law.

In your request, please make clear what Personal Information you would like to have changed or whether you would like to have your Personal Information suppressed from our database. We may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion.

If you are a resident of the EEA, please see the section at the end of this policy entitled “ADDITIONAL INFORMATION REGARDING THE EEA” for further information on your privacy choices.

If you are a resident of California, please see the section at the end of this policy entitled “ADDITIONAL INFORMATION REGARDING CALIFORNIA” for further information on your privacy choices.

RETENTION PERIOD

We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was collected. The criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you and provide services to you, for example, for as long as you have an account with us or keep using our Services, and the length of time thereafter during which we may have a legitimate need to reference your Personal Information to address issues that may arise;
• Whether there is a legal obligation to which we are subject, for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them; or
• Whether retention is advisable in light of our legal position, such as in regard to applicable statutes of limitations, litigation or regulatory investigations.

THIRD PARTY SERVICES

This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any website or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.

In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as Facebook, Twitter, Instagram, YouTube, Pinterest, LinkedIn, Apple, Google, Microsoft, RIM, or any other app developer, app provider, social media platform, operating system provider, wireless service provider, or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with our Social Media Pages.

USE OF SERVICES BY MINORS

The Services are not directed to individuals under the age of eighteen (18), and we do not knowingly collect Personal Information from individuals under 18.

JURISDICTION AND CROSS-BORDER TRANSFER

We are located in the United States. We may store and process your Personal Information in any country where we have facilities or in which we engage service providers. By using the Services, you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.

Some countries outside of the European Economic Area (the “EEA”) are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these “specified countries” is available at https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en. For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures where necessary, such as standard contractual clauses adopted by the relevant authority to protect your Personal Information. You may obtain a copy of these measures by contacting us in accordance with the “Contacting Us” section below.

SENSITIVE INFORMATION

Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) on or through the Services or otherwise to us.

UPDATES TO THIS PRIVACY POLICY

The “Last Updated” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on the Services.

CONTACTING US

Tempel Steel Company, LLC, located at 5500 North Wolcott Avenue, Chicago, Illinois, 60640-1020 U.S.A., is the company responsible for the collection, use, and disclosure of your Personal Information under this Privacy Policy.

If you have any questions about this Privacy Policy, please contact us at legalcompliance@worthingtonsteel.com or 100 West Old Wilson Bridge Road, Columbus, OH43085 U.S.A., Attn: General Counsel – Privacy Matter.

Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.

ADDITIONAL INFORMATION REGARDING THE EEA

You may lodge a complaint with an EEA data protection authority for your country or region where you have your habitual residence or place of work or where an alleged infringement of applicable data protection law occurs.  A list of EEA data protection authorities is available at https://edpb.europa.eu/about-edpb/about-edpb/members_en.  

You may also contact our Data Protection Officer (DPO) responsible for your country or region, if applicable, at legalcompliance@worthingtonsteel.com.

ADDITIONAL INFORMATION REGARDING CALIFORNIA

Pursuant to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA”), we are providing the following additional details regarding the categories of Personal Information about California residents that we collect, use, and disclose. This section supplements the information provided in the Privacy Policy, above. This Privacy Policy does not apply to the Personal Information we collect about our former or current employees.

Categories of Personal Information Collected and Disclosed

The following chart details which categories of Personal Information about California residents we collect, as well as which categories of Personal Information we have collected and disclosed for our operational business purposes in the preceding 12 months.

We do not “sell” or “share” your Personal Information, including your Sensitive Personal Information, as defined under the CCPA. We have not engaged in such sales or sharing in the 12 months preceding the date this Privacy Policy was last updated. Without limiting the foregoing, we do not “sell” or “share” the Personal Information, including the Sensitive Personal Information, of minors under 16 years of age.

Rights and Requests

If you are a California resident, you may request:

1. That we disclose to you the following information:
   1. The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
   2. The business or commercial purpose for collecting Personal Information about you;
   3. The specific pieces of your Personal Information, including a copy of your Personal Information in a portable format; and
   4. The categories of Personal Information about you that we otherwise disclosed, and the categories of third parties to whom we disclosed such Personal Information.
2. To correct inaccuracies in your Personal Information.
3. To have your Personal Information deleted.

You have the right not to be unlawfully discriminated against for exercising your privacy rights.

We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the Personal Information subject to the request. We may need to request additional Personal Information from you, such as mailing address, telephone number and/or email address, in order to verify your identity and protect against fraudulent requests. If you maintain a password-protected account with us, we may verify your identity through our existing authentication practices for your account and require you to re-authenticate yourself before disclosing or deleting your Personal Information. If you make a deletion request, we may ask you to verify your request before we delete your Personal Information.

To make a request, please contact us at legalcompliance@worthingtonsteel.com.

Authorized Agents

If an agent would like to make a request on your behalf as permitted by the CCPA, the agent may use the submission methods noted in the section entitled “Rights and Requests.” As part of our verification process, we may request that the agent provide, as applicable, proof concerning their status as an authorized agent. In addition, we may require that you verify your identity as described in the section entitled “Rights and Requests” or confirm that you provided the agent permission to submit the request.

De-Identified Information

Where we maintain or use de-identified information, we will continue to maintain and use the de-identified information only in a de-identified fashion and will not attempt to re-identify the information.