The Sherwin-Williams Company (“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 the 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 the Privacy Policy carefully because anytime you use our Services, you consent to the practices we describe in this Privacy Policy.  If you do not agree to the practices described in the Privacy Policy, you should not use our Services.

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, 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 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, for example, 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), 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 online Services or view our online advertisements

We use standard Internet technologies, such as cookies, web beacons, and local stored objects, to collect information about your computer or device and your online activity.  The following are examples of the types of information that we may collect with these technologies:
• 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 and the links you click within our online 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.

Additional information we may collect about you

We may receive information about you from publicly and commercially available sources.  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 a social networking service, we may receive and store information that you allow us to receive through those services.

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 websites and elsewhere.
• To manage and improve 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.

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 and 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.
• 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 that is not linkable to a particular consumer or device (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 that provide content and other functionality on our Services, may use cookies, web beacons and other similar technologies on our online Services.  Click here for more information about cookies, web beacons and other Internet technologies.  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 click here.

How We Use These Technologies

Our websites use these technologies for the following general purposes:
• Administering and improving our Services, including helping us measure and research the effectiveness of our content, features, advertisements, and other communications.  For example, we measure which pages and features website visitors are accessing and how much time they are spending on our web pages.  We may include web beacons in e-mails, for example, to understand whether messages have been opened, acted on, or forwarded.
• Storing your sign-in credentials and preferences so that you don’t have to enter those credentials and preferences each time you log on to a Service.
• Helping us and third parties provide you with relevant content and advertising by collecting information about your use of our Services and other websites.
Please see “How We Use Your Information” for details about how we use the information that we collect.  By continuing to use the Sherwin-Williams websites and online services, you consent to our use of cookies, web beacons, and other Internet technologies as described above.

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 websites through social networking services, such as Facebook and Twitter.  Third-party advertisers also may have a presence on some of our sites.  These third parties may collect or receive certain information about your use of our Services, including through the use ofcookies, 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 Digital Advertising Alliance of Canada.  Further information in local languages may be available at Your Online Choices.)

Consent to 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.  By providing us with your information or using any Service, you consent to the transfer and processing of your information outside your country of residence.

Collection of Information From Children

We do not knowingly collect information from children under the age of thirteen (13).  If we learn that a child under the age of 13 has provided us with information, we will delete it in accordance with applicable law.

Your Choices & Access to Your Information

Choices.  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:  You may contact us at Global Privacy Portal to remove yourself from our mailing lists.

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.

Access to Your Information.  The accuracy of your information is important to us.  Many Sherwin-Williams online programs allow you to view or update your information online.  Check the program you registered with to learn if you can view or update your information online.   If information access and correction is not available where you registered and you would like to make a request to access, correct, or delete your information or otherwise object to our processing of such information, please contact us at  Global Privacy Portal.  We will respond to reasonable 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 reasonable steps to ensure that we retain personal information about you only for so long as is necessary for the purpose for which it was collected, or as required under any contract or by 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 by e-mail at Global Privacy Portal In addition, you may contact us at the following address:

Sherwin-Williams Company
Enterprise Risk Management
101 W. Prospect Ave.
Cleveland, OH 44115
E-mail: 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 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.

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 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).

We may establish and maintain a file of your personal information for the purposes described in this Privacy Policy, which will be accessible at our Global Privacy Portal Our authorized employees, agents and mandataries will have access to your information as required to fulfill their obligations to us.

Residents of Italy

The information in this Privacy Policy is being provided pursuant to Section 13 of Legislative Decree no. 196/2003.

Data subjects are entitled at any time to obtain confirmation of the existence of personal data concerning them and be informed of their contents and origin, verify their accuracy, or else request that such data be supplemented, updated or rectified pursuant to Section 7 of Legislative Decree no. 196/2003.  The foregoing also provides for the right to request erasure, anonymisation or blocking of any data that is processed in breach of the law as well as to object in all cases, on legitimate grounds, to processing of the data.

Residents of Germany

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 the site. The information generated by the cookies about your use of the website (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 Malaysia

If you are a resident of Malaysia, you may contact Sherwin-Williams’ Data Protection Officer at the following:
The Sherwin-Williams Company
Enterprise Risk Management
101 W. Prospect Ave.
Cleveland, OH 44115
Phone: +1 216 515 5463
Fax:     +1 216 774 1865
E-mail: Global Privacy Portal

Residents of Mexico

If you are a resident of Mexico, in addition to your rights of access and rectification, you also have the right to cancel or oppose the processing of your personal information, limit the scope of processing or revoke your consent in accordance with local law.

These rights include your right to oppose the processing or transfer of your personal information for secondary purposes, different from those which are essential for your legal relationship with The Sherwin Williams Company.

Should you wish to assert any of your rights, please contact us at Global Privacy Portal, attaching: (i) a copy of your official ID, or the documentation supporting the identity of your representative, and (ii) a description of the right you wish to exercise. We will respond your request by email, within the applicable terms as provided by local laws.

You also have the right to record your telephone number with the Public Registry to Avoid Advertising, of the Federal Bureau of Consumers (http://rpc.profeco.gob.mx/).

If you consider that any of your rights of protection of personal data has been affected, you have the right to file a complaint with the National Institute of Transparency, Access to Information and Personal Data Protection (www.inai.org.mx).

Residents of Singapore

If you are a resident of Singapore, you may contact Sherwin-Williams’ Data Protection Officer at Global Privacy Portal

Residents of Sweden

If you are a Swedish resident, you may contact Sherwin-Williams for information about our privacy practices at +1 216 515 5463.

Effective Date:  August 1, 2014