Wesco Privacy Policy

Quick Read

If you are short on time, the following three bullet points may help you understand how we use your personal information. If you wish to know the details of how we use your personal information, feel free to read this policy in full.

• If you visit our sites, we will collect your personal information to make our sites work. We may also track your behavior on our websites and mobile applications (collectively, the “Sites”) depending on your location and your cookie choices.
• If you have a user profile, we will also link information about you to that profile. We will collect your username, password, company name, and other information that may be required for a user profile.
• We typically collect information through various forms on the Sites if you participate in our events or request information about our products and services.

This is not all we do with your personal information, nor is it a complete list of how we collect your personal information, but these are the typical user stories we feel you should know about.

1. Introduction

This privacy policy describes how we collect, use, process, retain, disclose, protect, and dispose of your personal information. It applies to personal information we collect when you visit our Sites, use services and features on our Sites or engage with us in a business capacity. It also applies to personal information about you we may collect from other sources, such as financial institutions and credit reporting agencies.

We may change this policy from time to time. If we make significant changes, we will notify you by email, notice in your account on our Sites or another appropriate method. We encourage you to review this policy whenever you use the Sites. The personal information we hold about you must be accurate and up-to-date. Please let us know if your personal information changes during your relationship with us.

This policy may be supplemented by other more specific privacy policies on our Sites. For example, if you apply to work for us through our careers Site, you will be provided with access to our Candidate Privacy Policy, which will explain how your personal information is used during the recruitment process.

The Wesco group of companies consists of all Wesco International, Inc. and its subsidiaries. For simplicity, throughout this policy, “we” and “us” mean the Wesco group.

If you are located in the UK or the European Economic Area (EEA) and are using the Sites, Wesco Distribution, Inc. is the data controller. Its representative in the UK is Anixter Limited; in the EU, it is Anixter Distribution Ireland Limited.

2. What personal information do we collect?

Personal information, or personal data, means any information relating to an identified or identifiable person.

We may collect, store and use the following categories of personal information about you:

• Identity and contact information. For example, name, telephone number, email, employer name, employer address, industry, occupation, languages, and information about authorized users.
• Transaction information. For example, when you purchase or return products, use our services, register a product, or contact us for technical support services, we collect information about the transaction, such as product name, purchase price, quantity ordered and services provided.
• Account information. If you create an account on our website, we will collect information associated with you depending on the type of account that you create.
• Logical identifiers. For example, passwords, usernames and cookies (see below).
• Log information. We log information about your use of the Sites. For example, the type of browser you use, access, times, pages viewed, your IP address and the page you visited before navigating to our Sites.
• Device information. We collect information about the computer or mobile device you use to access our Sites, including the hardware model, operating system and version, unique device identifiers and mobile network information.
• Accreditation information. If you are an installer certified to install products we manufacture, we may retain information related to your certifications. Financial information. For example, credit or debit card information.
• Complaints data. We collect details of any complaints made by you via our Sites.
• Communications data. We may process information contained in or relating to any communication that you send to us or we send to you. For example, if you contact us using one of the forms on the Sites, we will use that information.

We do not generally collect special category personal information about you, such as details about your racial or ethnic origin, political opinions, religion or other beliefs, health, biometric or genetic characteristics, criminal background or trade union membership, except in specific circumstances such as candidate or business partner background screening as may be described in applicable Privacy Policies. Please do not share special category personal information with us unless specifically requested or necessary, such as when we conduct background checks on job applicants or new suppliers.

If you are a resident of California, we may collect certain categories of sensitive personal information. This is usually limited to your user account login details.

We also collect, use and share Aggregated Data, such as statistical, demographic, aggregated usage and purchasing data, for any purpose. Aggregated Data may be derived from your personal information but is not considered personal information by law as this data does not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal information that will be used in accordance with this privacy policy.

3. How do we collect your personal information?

We collect personal information using different methods:

• Directly from you. For example, when you visit the Sites, we collect information when you request a quote, create an account, participate in any interactive features of the Sites, order products, register your products with us, sign up for newsletters or provide general feedback.
• Automatically when you use our Sites. When you access the Sites, we will automatically collect transaction information, log information, device information and information collected by cookies and other tracking technologies depending on your cookies settings.
• From other sources. For example, if you create or log into an account by using social network credentials, such as LinkedIn or Facebook, we will have access to certain information from that site in accordance with the procedures determined by such social media site.

4. How and why do we use your personal information?

4.1. Purposes for which we use your personal information

We will use your personal information for the following purposes:

• To register you or the business partner as a customer or end-user
• To create a user account for you or a candidate account for you
• To process orders and requests for products, including quoting, tracking orders, delivery, processing returns and exchanges, payment management, processing credit and other forms of payment and collections
• To provide, maintain, improve and protect the Sites
• To personalize and improve your experience using the Sites and provide advertisements, content and features that match user profiles or interests and to measure the effectiveness of content delivery
vTo provide and improve our customer service, including requesting your feedback, responding to your comments, questions and requests and provide training and technical support
• To analyze and manage our business, including our relationship with you or a business partner
• To send technical notices, updates, security alerts, and support administrative messages
• To improve our products and services
• To communicate with you about the services, offers, promotions, rewards, and events offered by us and others
• To link or combine with information we get from others to help understand your needs and provide you with better service
• To comply with international trade laws and regulations and other regulatory requirements
• To prevent fraud and to keep our Sites secure

The above purposes for using your personal information will overlap; therefore, multiple purposes may justify our use of your personal information.

4.2. Lawful bases for processing your personal information

We will only use personal information where the applicable law allows us to do so. Where necessary, we will rely on the following lawful bases:

• 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.
• Where we need to perform a contract we are about to enter into or have entered into with you.
• Where we need to comply with a legal or regulatory obligation.
• We rely on consent as a lawful basis for processing in specific circumstances. Where we rely on consent, the relevant form on the Site will provide information on when consent is sought. This is usually the case when sending direct marketing communications to you. Even when your consent has been lawfully obtained, you have the right to withdraw consent to marketing at any time by contacting us or clicking unsubscribe.

Where the applicable law does not require us only to process personal information under a specific lawful basis but imposes other requirements, such as ensuring that the purposes for which we use personal information would be considered appropriate, we will comply with such other requirements.

4.3. If you do not provide your personal information

If you do not provide the personal information we request, we may be unable to provide the products or services you or our business partner request. You will also be unable to receive targeted offers and other relevant communication. If we enter into a contract with you without the personal information that we need, we may not be able to perform that contract.

4.4. Change of purpose

We will only use your personal information for the purposes for which we collected it. If we need to use your personal information for a different purpose, we can use it provided we reasonably consider that such other purpose is compatible with the original purpose.

If we need to use your personal information for an unrelated purpose, we will notify you or obtain your consent when required by law and explain the legal basis that allows us to do so.

Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law.

4.5. Marketing

We may use information about how you use the Sites, your identity, and the identity of a business partner you represent to form a view on the products and services you may need or be interested in or that may be relevant to you. We may also combine personal information gathered across the Sites and from third parties to bring you products, services, offers, promotions and events that are most relevant to you.

Where permitted by law, we may send marketing communications to you unless you opt out or unsubscribe, and where required, we will ask for your consent before sending direct marketing communications to you.

Wherever you are based, you can always ask us or our nominated third parties to stop sending you marketing messages at any time by following the links on any marketing message sent to you or by contacting us at any time.

4.6. Cookies

We use cookies and other tracking technologies to distinguish you from other users of our site. For simplicity, we will refer to these technologies as “cookies.” A cookie is a small text file that is placed on your device by the websites that you visit. On subsequent visits, cookies are sent back by the website that recognizes the cookies to develop a record of your online activity.

In addition, most browsers allow you to refuse to accept cookies. You may also delete cookies. This can be found in your browser settings. Please remember that if you block all cookies in your browser, you will not be able to use all features of our Sites.

4.7. Third-party links

The Sites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

5. Who do we share your personal information with?

5.1. Categories of recipients of personal information

We may share your personal information with the following:

• Wesco Group
• The information will be shared with Wesco Group companies, which provide IT and system administration services and e-marketing teams.
• Local sales teams that look after our business partner accounts.
• Other Wesco Group companies that provide shared services, such as accounts payable, accounts receivable, human resources administration and support services and purchasing, may receive personal information.
• Third-party service providers and product suppliers
• Service providers who provide IT or administration and hosting services concerning the Sites, our services, and our internal infrastructure. Personal information may also be shared with providers of analytical services.
• Service providers that provide ancillary services such as outsourced call centers and helpdesks.
• Product suppliers, transportation companies, payment service providers and other companies involved in fulfilling your or a business partner’s orders.
• Other third-party agents, consultants, vendors, and service providers who require such information to meet their obligations as part of their mandate or contractual obligations to us.
• Professional advisers and insurers. We may need to share information with our lawyers, accountants and other consultants, as well as with our insurers and brokers.
• Regulators and other authorities. It may be necessary to provide personal information to, for example, tax authorities.
• M&A buyers or sellers. The parties to whom we may choose to sell, transfer, or merge parts of our business or assets or where we acquire or seek to acquire or merge other businesses.

We require third parties to respect the security of your personal information and treat it in accordance with the law. Where we disclose personal information to a service provider or other processor, we require them to take adequate security measures to protect it in accordance with our policies and the law. We only permit such third parties to process your personal information for specified purposes and in accordance with our instructions.

5.2. International data transfers

We may share your personal information within Wesco Group. This will involve transferring your personal information to our global headquarters in the US and other countries where Wesco Group companies are located. Where required, we use intra-group standard contractual clauses approved by the European Commission, the UK’s Information Commissioner, or other contract clauses or contracts as required by applicable laws.

External third parties with whom we share personal information may be based outside of the country, state or province where you reside. In that case, where required by law, we have processes in place to ensure that your personal information is adequately protected. For example, our contracts with third-party processors include provisions that they must follow to ensure adequate protection of your personal information.

If you wish to know about the above contracts, please contact our privacy officer at privacyinquiry@wescodist.com.

6. How do we protect your personal information?

We are responsible for protecting personal information in our possession, whether it is held by us or by a third party, regardless of its form. Therefore, we have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. We take reasonable steps to maintain physical, procedural, and technical security in our offices, information systems, and information storage facilities in order to protect your personal information. We restrict access to personal information to those individuals who need access to it when performing our duties and obligations. When we share personal information with third parties, where applicable, we require those third parties to adopt robust contractual safeguards to ensure the protection of the transferred personal information through (i) technical, physical, and organizational security measures to safeguard the information, (ii) limiting the use of the personal information to the purpose of the transfer, and (iii) retention limitations that prohibit the retention of the personal information by the third party longer than necessary to fulfill contractual obligations.

7. How long will we keep your personal information?

We will only keep your personal information for as long as necessary for the purpose for which it was collected. That includes satisfying any legal, accounting, or reporting requirements.

8. What are your rights over your personal information?

8.1. Your rights in general

Your rights will vary depending on your location. These rights may be subject to exceptions and certain limitations under the applicable law.

In certain circumstances, you have the right to:

• Request access to personal information that we hold about you.
• Request correction of your personal information when incorrect, out of date or incomplete.
• Request the erasure of your personal information. You may exercise this right when there is no good reason for us continuing to process personal information about you. Note that we may not always be able to remove your personal information for specific legal reasons, which we will notify you of.
• Object to processing of your personal information where we are relying on a legitimate interest. You also have the right to object where we are processing personal information for marketing purposes. In some cases, we may demonstrate that we have compelling, legitimate grounds to process your personal information, which overrides your rights and freedoms.
• Request the restriction of processing of your personal information. This allows you to ask us to suspend the processing of your personal information. For example, where you wish to establish that personal information we hold about you is accurate.
• Request the transfer of your personal information to your or a third party in a commonly used machine-readable format. Note that this right applies in limited circumstances, where personal information is processed by automated means on the basis of consent you provided or the contract we entered into with you.
• Stop consent-based processing of your personal information. If we collected personal information on the basis of consent, you have the right to withdraw consent. If you withdraw your consent, we may be unable to provide certain products or services. We will notify you if that is the case.

If you wish to exercise any of the above rights, please contact our privacy officer at privacy@wesco.com.

8.2. US residents

If you are a resident of the US, your rights will depend on the state in which you reside.

• California residents have the right to request disclosure of specific and general personal information we collect, to delete and correct their personal information, and to opt out of any sharing for cross-context behavior advertising or sale of personal information. These rights are subject to certain restrictions and may be exercised by an agent on behalf of a California resident. If you are a resident of California, here is how you can exercise your rights.
• Right to disclosure, correction or deletion. You may exercise your rights to disclose information about yourself and to delete your personal information by contacting us.
• Right to opt out of the sale of your personal information. The California Consumer Privacy Act (CCPA) requires businesses to give individuals a right to opt out from “selling” or “sharing” their personal information. The term “sell” under the CCPA captures a broad range of disclosure to third parties for monetary or other valuable consideration. “Selling” may therefore include providing third parties with information about IP addresses, trackers, cookies, devices and browsers and “sharing” of personal information related specifically to cross-context behavior advertising. Although Wesco does not sell your personal information for money, placing third-party advertising cookies on your device may qualify as “selling” your personal information. If you wish to opt out of such advertising cookies, you may do so by contacting us.

8.3. Quebec Residents

Quebec residents have the right to access or obtain a copy of their personal information. If you would like us to amend any inaccurate personal information we have about you, you may do so by sending us a written request. You may also inquire as to how this information is used, ensure that it is accurate and complete, and update it, if necessary, to the extent permitted by law.

8.4. Verification and unfounded requests

Please note that you will not have to pay a fee to exercise your rights. However, where allowed by law, we may charge a reasonable fee if your request is clearly unfounded or excessive, or we may refuse to comply with your request in such circumstances.

When you exercise your rights, we may request information from you to confirm your identity. This is to ensure your personal information is not disclosed to any person who has no right to receive it.

9. Who to contact

We hope this policy has been helpful, but if you have questions or wish to exercise your legal rights, please contact our Chief Ethics and Compliance Officer at ethics@wesco.com, by sending an email to privacyinquiry@wescodist.com, or by writing to us at:

For Quebec residents. Any person concerned about personal information collected, used, communicated, or retained by us may file a complaint with the Privacy Officer. Complaints must be made in writing and must indicate the nature of the facts complained about, the date on which the incident occurred, and the expectations regarding the outcome of the complaint. The Privacy Officer will acknowledge receipt of the complaint and process it within 30 days. We investigate all privacy complaints and take appropriate steps to resolve them. For further information about how we handle personal information, please contact the Privacy Officer at privacyinquiry@wescodist.com.

You also have a right to submit a complaint to a supervisory authority in your country at any time.