Privacy Statement

1. INTRODUCTION 

Tenneco is committed to protecting your privacy and making sure that we handle your personal data with integrity always and in accordance with applicable data protection laws.  

When you visit our Sites and use our services, you entrust us with your personal information.  In this Privacy Statement, we describe what information we collect, how we use it and the rights you have. We hope you take some time to read our Privacy Statement carefully.  Please contact us if you have any question about our privacy practices.  If there are any terms in this Privacy Statement that you do not agree with, please discontinue use of our Site and our services.  You may contact us by writing to PrivacyOffice@Tenneco.com.  

For the purposes of this Privacy Statement, references to “we”, “us” or “our”, “Tenneco” shall refer to Tenneco Incorporated and its worldwide entities and affiliates. 

 

2. WHO WE ARE  

Tenneco is a leading designer, manufacturer and marketer of Aftermarket, Ride Performance, Clean Air and Powertrain products and technology solutions for diversified markets.  Our principal place of business is located at 500 N Field Drive, Lake Forest, Illinois, 60045, USA.  Tenneco is the provider of the website www.tenneco.com and is responsible for the personal data processing in connection with the use of the website.  Each Tenneco entity and affiliate covered by this Privacy Statement is responsible for the personal information it collects and processes on its site.    

 

3. WHAT THIS PRIVACY STATEMENT APPLIES TO

Summary: This Privacy Statement applies to personal information collected through our websites (such as https://www.tenneco.com and/or any related services, sales, marketing or events websites, microsites, brand sites or applications (we refer to them collectively in this Privacy Statement as the "Site").  



4. THE PERSONAL INFORMATION WE COLLECT ABOUT YOU 

Summary: We collect personal information that enables us to identify you, such as your name, postal address, e-mail address, or telephone number.  We collect other information about you, such as information about your internet connection, the browser you use to access our Site and usage details.

  • Information you provide to us 

    Summary: We collect personal information that you provide to us, such as name, mailing address, email, telephone number, payment information, and correspondence.
    • Information that you provide by filling in forms on our Site.  This includes information provided at the time of registering to use our Site, subscribing to our service, uploading documents, or requesting further services;
    • Information in connection with an application for employment.  We may ask for your employment history, and other qualifications required by applicable laws;  
    • Information you provide when you enter a contest or promotion sponsored by us;
    • Records and copies of your correspondence with us;
    • Your responses to surveys we send out;
    • Details of transactions you carry out through our Site including payment information; 
    • Information such as your name, user ID, company and email that you provide when you register with us;
    • User contributions you provide to us for publication or transmission to other users. 

  • Information we collect through automatic data collection technologies

    Summary: We automatically collect information such as IP address and/or browser and device characteristics when you visit our Sites. 

    As you navigate through and interact with our Site, we may use automatic data collection technologies such as cookies to collect certain information about your equipment, browsing actions, and patterns, including:
    • Details of your visits to our Site, including traffic data, location data, logs, and the resources that you access and use on the Site.
    • Information about your computer and internet connection, including your IP address, operating system, and browser type.
    • International Mobile Equipment Identity (IMEI);
    • International Mobile Subscriber Identity (IMSI).

  • Information collected from other sources

    Summary: We may collect limited data from public databases, marketing partners, social media platforms, and other outside sources. 

    We may obtain information about you from sources such as public databases, joint marketing partners, social media platforms, as well as from other third parties.  Examples of the information we receive from these sources include: 
    • Social media profile information (your name, email, current city, state and country, user identification numbers for your contacts, profile picture, URL and any other information that you choose to make public); 
    • Marketing leads, search results and links containing information such as your name, contact information and interests. 

 

5. WHY WE USE YOUR PERSONAL INFORMATION AND THE LAWFUL BASIS FOR PROCESSING 

Summary: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, protection of vital interest and/or consent.

We use the information we collect or receive:  

  • To facilitate account creation and logon process. To register an account to use our services, we process your personal information for registration and profile setup purposes. 
    • Our lawful legal bases are Legitimate Business Interest and/or Consent.
  • To send you marketing and promotional communications. We and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences.  See the section entitled Your Rights below. 
    • Our lawful legal bases are Legitimate Business Interest and/or Consent. 
  • To send administrative information to you. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
    • Our lawful legal bases are Legitimate Business Interest, Performance of a Legal Obligation, and/or Fulfilment of a Contractual Obligation.
  • Fulfill and manage your orders. We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Site. 
    • Our lawful legal bases are Legitimate Business Interest, Performance of a Legal Obligation, and/or Fulfilment of a Contractual Obligation.
  • To improve your user-experience and for statistical purposes. We may use the information to estimate our audience size and usage patterns, as well as to store your preferences, which allows us to customize our Site according to your interests and to recognize you when you return to our Site. 
    • Our lawful legal basis is Legitimate Business interest.
  • Deliver targeted advertising to you. We may use your information to develop and display content and advertising tailored to your interests and/or location and to measure its effectiveness, or we may work with third parties who do so.
    • Our lawful legal bases are Legitimate Business Interest and/or Consent.
  • Administer prize draws and competitions. We may use your information to administer prize draws and competitions when you elect to participate in competitions.
    • Our lawful legal bases are Legitimate Business Interest and/or Consent.
  • Request feedback. We may use your information to request feedback and to contact you about your use of our Site. 
    • Our lawful legal bases are Legitimate Business Interest and/or Consent.
  • To protect our Site. We may use your information as part of our efforts to keep our Site safe and secure (for example, for fraud monitoring, prevention and protection from cybersecurity threats).
    • Our lawful legal bases are Legitimate Business Interest, Performance of a Legal Obligation, or Protection of Vital Interest.
  • To enforce our terms, conditions and policies.
    • Our lawful legal bases are Legitimate Business Interest, Performance of a Legal Obligation, and/or Performance of a Contract.
  • To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
    • Our lawful legal basis is the Performance of a Legal Obligation.
  • To process job applications. Our Site may contain job listings that you may apply to.  The personal information you provide as part of a job application will be used for recruitment purposes only. 
    • Our lawful legal bases are Legitimate Business Interest, Performance of a Legal Obligation and/or Consent.

 

6. COOKIE STATEMENT

Summary: We use cookies and similar technologies to collect and store your information.

  • What are cookies? 

    Cookies are text files containing small amounts of information, which are downloaded to your hard disk or to your web browser's memory when you visit our Site.  Cookies are useful for arranging the content and layout of our Site and allow us to recognize those computers or other devices that have visited our Site before.  Cookies allow our Site to remember your preference settings and help us to enhance your experience and the usability of our Site.

    Our Site may also contain electronic images known as web beacons – sometimes known as single-pixel gifs – that allow us to count the number of visitors on specific web pages.

  • Categories of cookies and similar technologies that we use 

    We have four categories of cookies or similar technologies that may be used on our Site.  We categorize them as follows: Strictly Necessary cookies, Performance cookies, Functionality & Profile cookies and Advertising cookies.

    Below, we explain each one of the categories to help you understand what they are.

    1. Strictly necessary cookies

    These cookies are essential for basic functionalities of the Site.  They enable you to move around our Site and use the features, particularly in connection with information searches and order placement.  Without these cookies, services you have asked for cannot be provided.  These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet. 

    Some examples of strictly necessary cookies are: 
  • A shopping basket cookie, which is used to remember the products you wish to purchase when you add products to your shopping basket or proceed to checkout;
  • A login cookie, which allows you to login and manages your login to the Site.  This cookie helps to identify you after logging in and before you logout (single session);
  • A session cookie, which is required to carry out the data transmission and provide the Site to you; and
  • A security cookie that detects repeat failed login attempts or similar abuses of the Sites. 
  • Strictly necessary cookies are generally stored only as long as required for their purpose.

2. Performance cookies

These cookies collect information about how you use our Site such as the pages you go to most often and if you get any error messages from certain pages.  These cookies collect information that are used for improving how the Site works.  Without these cookies, we cannot learn how our Site is performing and make relevant improvements that could enrich your browsing experience. 

An example of a performance cookie is Google Analytics:  

Google Analytics is a web analytics service provided by Google, Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA (“Google”), to collect information about the use of our Site such as how often you visit our Site, the pages you go to and actions you take on the Site.  We do not combine the information collected through the use of Google Analytics with personal information. 

You can prevent Google Analytics from recognizing you on return visits to this Site by disabling their cookies on your browser through downloading and installing the following Browser-Plug- in: https://tools.google.com/dlpage/gaoptout?hl=en.

3. Functionality & profile cookies

These cookies allow our Sites to store information that you provide, such as preferences, and they help us to store technical information useful for your interactions with our Sites.  For instance, they remember your user ID and elements of your user profile.  They also ensure that your experience using the Site is relevant to you.  They may also be used to provide services you have requested such as watching a video or commenting on a blog.  These cookies are not used to track your browsing activity on other websites.

Without these cookies, our Site cannot remember your choices or personalize your browsing experience. 

4. Advertising cookies and similar technologies

We may use these cookies or similar technologies to deliver advertisements that are more relevant to you.  They may be used to limit the times you see an advertisement as well as to help measure the effectiveness of the advertising campaign.  These cookies may track your visits to other websites.  Without these cookies or other technologies, online advertisements you encounter will be less relevant to you and your interests.

An example of an advertising cookie or similar technology we use is called Flashtalking. 

Flashtalking is a tool that enables us to deliver ads suited to our user’s interests. The tool is provided by Flashtalking Inc., 1101 W Fulton Market, Suite 200, Chicago, Illinois 60607, USA. 

Flashtalking collects information on websites the user visits and the user’s interaction with ads.  In order to be able to identify the user’s computer, Flashtalking stores a cookie on your computer.  Furthermore, it stores user IPs on the Flashtalking servers.  The cookies used by Flashtalking expire after two years.

Flashtalking may combine your user information with other information gathered from other sources such as publicly accessible sources.

Users have the ability to opt-out of our Flashtalking cookies via these links:

http://www.youronlinechoices.com/
https://www.networkadvertising.org/choices
http://www.flashtalking.com/uk/privacypolicy/

 

7. HOW WE SHARE YOUR INFORMATION 

Summary: We only share information when we have Legitimate business interest, or Consent (if consent is the appropriate legal basis), or when we have to comply with a Legal obligation, or when we have to protect your rights and others or when we have to perform a contract that you are part of.  We restrict access to your information to only those persons who need to use it for the relevant purpose.

We only share and disclose your information in the following situations:

  • Compliance with laws. We may disclose your information where we are legally required to do so in order to comply with applicable laws, governmental requests, a judicial proceeding, court order or legal process, such as in response to a court order or a subpoena. 
  • Protect vital interests and legal rights. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding situations involving potential threats to the safety of any person, potential violations of our policies, suspected fraud, illegal activities or as evidence in litigation in which we are involved.  
  • Vendors, consultants and other third-party service providers. We may share your information with third-party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do the work.  Examples include payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts.  Unless described in this Statement, we do not share, sell, rent or trade any of your personal information with third parties for their promotional purposes. 
  • Business transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
  • Third-party advertisers. We may use third-party advertising including social media companies to serve ads when you visit our Site.  These companies may use information about your visits to our Site and other websites that are contained in web cookies and other tracking technologies in order to provide advertisements about goods and services of interest to you.  Please read our Cookie Statement above for more information. 
  • Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor the policies described in this Privacy Statement.  Affiliates include any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
  • Business partners. We may share your information with our business partners to offer you certain products, services or promotions. 
  • Other purposes. We may disclose your personal information for any other purpose with your consent.
  • Public users of our site. When you share personal information (for example, by posting comments, contributions or other content to our Site) or otherwise interact with public areas of the Site, such personal information may be viewed by all users and may be publicly distributed outside the Site. 

 

8. HOW LONG WE KEEP YOUR DATA  

Summary: We will retain your personal data for the duration the applicable law requires us or as long as is reasonably necessary to fulfill the relevant purposes for which we obtained it, as set out in this Privacy Statement. 

Our retention period is determined by applicable legal and regulatory obligations, duration of our business relationship with you, your employer or another associated party and legitimate business interest.  For example, if you submit an employment application through our Site, we may be required by law to retain the information for a specific period of time such as three years or longer depending on the country. 

When your information is no longer needed for business purposes or a law does not require us to keep your information, we either irreversibly anonymize or destroy the data securely.  In some cases, however, we may retain your personal information for longer periods of time if we reasonably believe there is a likelihood of litigation, in the event of any complaints or there is another valid business reason to believe the information will be needed in the future.   

9. INTERNATIONAL TRANSFERS  

Summary: In the course of doing business, we may collect, transmit, and store your personal information in the United States of America and transfer to our affiliates in other countries in which we operate, including countries outside the European Economic Area (EEA).

We are a global company with a number of legal entities in different jurisdictions.  Each entity is responsible for the personal information it collects and processes.  From time to time, we may need to share your personal information with our entities, affiliates, vendors or partners who may be located outside of the country or region your personal information was originally collected.  We may allow our service providers, who may be located outside the country you are located, to access your personal information in order to perform a service on our behalf.  We may also make other disclosures of your personal information overseas, for example if we receive a legal request from a foreign law enforcement body. 

We will always take steps to ensure that any international transfer of personal information is carefully managed to protect your rights and interests: 

  • For individuals within the European Union, we will only transfer your personal information to countries, which are recognized as providing an adequate level of legal protection or where we can be satisfied that alternative arrangements are in place to protect your privacy rights. 
  • Transfers within our entities/affiliates and their overseas offices will also be covered by an approved transfer mechanism such as Standard Contractual Clauses, adopted by the European Commission.  This transfer mechanism has specific contractual protections designed to ensure that your personal information receives an adequate and consistent level of protection. 
  • Transfers to service providers and other third parties will always be protected by contractual commitments and where appropriate further assurances. 
  • Any requests for information we receive from law enforcement or regulators will be carefully reviewed before personal data is disclosed. 

 

10. Data Transfer and Privacy Shield Framework

Tenneco is a global organization with legal entities and business processes in operation across borders.  Tenneco complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal data transferred from the European Union (EU), and the United Kingdom (UK) to the United States, respectively.

Tenneco has certified to the Department of Commerce that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, Recourse, Enforcement and Liability.  Tenneco is accordingly subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).

If there is any conflict between the terms of this Privacy Statement and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification, please visit the Department of Commerce’s Privacy Shield Website at https://www.privacyshield.gov/.

With respect to any sharing of EU and UK Business Contact Information for the purposes of marketing Tenneco products and services, Tenneco obtains assurances from its affiliates, subsidiaries and business partners that such entities will use and disclose such EU and UK Business Contact Information for purposes of marketing Tenneco’s products and services only.

In cases of onward transfer of EU or UK Business Information to third parties pursuant to Privacy Shield, Tenneco is potentially liable in the event of an improper disclosure.  In certain situations, individuals may seek to opt-out of disclosures of their EU and UK Business Contact Information by contacting Tenneco at PrivacyOffice@Tenneco.com

With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Tenneco is subject to the regulatory enforcement powers of the United States Federal Trade Commission.  In certain situations, Tenneco may disclose EU and UK personal data in connection with the sale or transfer of all or part of its business, where required or permitted by law, where Tenneco believes that such disclosures are appropriate in connection with a law enforcement request, or as otherwise permitted by the Privacy Shield Principles, or in order to investigate, prevent or take action regarding illegal activities or suspected fraud, or in order to comply with, enforce Tenneco agreements.

In compliance with the Privacy Shield Principles, Tenneco commits to resolve complaints about our collection or use of your personal data at no cost to the individual.  European Union and United Kingdom individuals with inquiries or complaints regarding our Privacy Shield policy should contact our Privacy Office at PrivacyOffice@Tenneco.com.  Tenneco will respond to your inquiry within 45 days.

In the event of a reported complaint that Tenneco does not resolve itself, Tenneco commits to cooperate with the EU Data Protection Authorities (DPAs), and UK Information Commissioner Office (ICO) and comply with the advice given by the EU DPA panel, or UK ICO with regard to human resources and non-human resources data transferred from the EU and UK to Tenneco in the United States (US).

Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

 

11. SECURITY

Summary: We are committed to ensuring that your personal data is secure.  In order to prevent unauthorized access, alteration or disclosure, we put in place appropriate technical and organisational measures to protect your personal data.

We apply reasonable and appropriate administrative, technical and organizational measures such as industry-standard encryption, authentication tools, access controls, firewalls, contractual commitments, and intrusion detection and prevention systems to protect the security of personal data.  Because of the nature of Internet communication, we cannot guarantee against the loss or misuse of personal data transmitted.  If, despite all our efforts, a data breach occurs, we will take all appropriate and expedient steps to limit the damage. 

In case of a data breach, which is likely to result in a high risk, and depending on the circumstances, we will inform you about remedial actions to prevent any further damage.  We will also inform the relevant supervisory authority or authorities without undue delay.

 

12. YOUR RIGHTS  

Summary: In some regions, such as the European Economic Area, you have rights that allow you greater access to and control over your personal information.  For other users, the rights that apply to you will depend on the laws of your country of residence.  We will assist you in exercise the rights that apply to you in accordance with applicable law. 

Depending on the country or region you are located, you may have certain rights as an individual, which you may exercise in relation to the personal data we hold about you.  If you make a request to exercise any of your rights, we reserve the right to ask you for a proof of your identity.  We do this to protect your rights and privacy. 

In general, you have the following rights:  

  • The right to access. You have a right to receive confirmation whether we are processing your data, a copy of your data, where applicable, and information about purposes of processing.  You may have a right to know whom we disclose your data to, whether we transfer your data internationally, how we protect it, how long we keep it, the rights you have, where we got your data from and how you can make a complaint.  
  • The right to rectification. If the personal information we hold about you is inaccurate or incomplete you can request for it to be corrected.  
  • The right to erasure. If you withdraw your consent (where consent was the legal basis we used to process your personal information), terminate a contract with us or you believe the personal information is no longer necessary for the purposes they were collected, you may request your data to be deleted.  We will strive to honor your request but there are times we will need to balance your request against other factors such as certain regulatory obligations, which may prevent us from deleting the data.  
  • The right to restrict processing. You can ask us to restrict your personal data in certain situations.  This means that we may still keep your personal information, but that we will no longer be able to use it.  You can ask us to restrict your personal data where: 
    • The accuracy of the data is contested; this will allow us to verify its accuracy; 
    • The processing is unlawful, but you do not want it erased;  
    • The data is no longer needed for the purposes for which it was collected; we need the data to establish, exercise or defend legal claims; or
    • You have exercised the right to object to processing, and we are in the process of verifying if there are justifiable reasons to comply or not to comply with the request. 

    It is important to point out that we may continue to use your personal information following a request for restriction, where we have a valid legal basis such as your consent or where we need to establish, exercise or defend legal claims or where we need to protect the rights of another individual. 

  • The right to data portability. If we relied on your consent to collect your personal data or if we relied on a contractual agreement to process your personal data, you can request from us to transfer your personal data, where feasible, to you or another third party of your choice.  
  • The right to object. You have the right to object to the processing of your personal information where the processing is necessary for the purposes of our legitimate interests, especially where your interest or fundamental rights and freedoms override our interest.  You have a right to object where we process your personal information for direct marketing purposes or share it with third parties for their own direct marketing purposes. 
  • The right to not be subjected to automated-decision making. You have a right not to be subject to a decision based solely on automated processing, which can affect your legal rights, such as profiling.  We do not carry out automated decision-making on our Site. 
  • The right to withdraw consent. You have the right to withdraw your consent at any time if we relied on your consent to process your personal information. You may write to us at PrivacyOffice@Tenneco.com to communicate your withdrawal of consent.  Even though we will do our best to honor your right, there are instances where we may have to balance your request against the rights and freedoms of others who may be adversely affected to determine if we can comply with your request. 
  • The right to complain. If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information or if you are not satisfied with our responses to you, you have the right to complain to your local data protection supervisory authority.  You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm
  • How to exercise your rights. Please contact us by using the information in the Contact Us section below.  We will respond to your request as soon as possible and address your inquiry within one month of receipt of the request.  There are instances where we may not be able to address your inquiry within one month.  We will communicate such instances to you but in any event, we will address your inquiry no longer than three months.

    Users with registered accounts may update their user settings, profiles, organization settings and event registrations by logging into their accounts and editing their settings or profiles. 

 

13. CHILDREN

Summary: We are committed to protecting children's privacy on the Internet.  We comply with the Children’s Online Privacy Protection Act in the United States, and similar laws around the world.

Our Site is not intended for children.  The definition of “children/child” is subject to the laws and regulations in the jurisdiction in which you are located.  No child may provide any information to us on the Site.  We do not knowingly collect personal information from children.  If we learn that we have collected the personal information of children, we will take steps to delete the information as soon as possible.

 

14. LINKS TO SOCIAL MEDIA AND OTHER WEBSITES

Summary: We use social media to communicate with the public.  Some of the accounts we currently maintain include LinkedIn, Twitter, Facebook, Instagram, and WeChat.  We have placed buttons or links to these social media platforms on our Site to facilitate the sharing of content and promote brand awareness. 

Each of these social media services has its own data protection policy.  When you click on a link or button to access a social media site, you will leave our Site and the social media company you clicked on will process your data. 

Our Site may contain links to other third-party websites, products and services.  We have no liability or responsibility for those websites, products and services, and their policies.  We also have no liability or responsibility for their collection or other processing of your personal information.  The practices of those third parties with respect to information collected through their websites, products or services is governed by their own privacy policies.  We strongly encourage you to read and understand the privacy policies of those third parties.


15. CALIFORNIA PRIVACY RIGHTS

California Civil Code Section 1798 allows California residents to ask companies with whom they have an established business relationship to provide certain information about the companies’ sharing of personal data with third parties for direct marketing purposes.  We do not share any California consumer personal data with third parties for their direct marketing purposes without the consent of the consumers. 

 

16. CONTACT US   

If you have any questions relating to this Privacy Statement, concerns about how we are handling your personal information, or to exercise your rights regarding your personal data, please contact us at:  

Tenneco Privacy Office  
Attention: Privacy Officer 
500 N Field Drive, Lake Forest, IL 60045, USA

Email: PrivacyOffice@Tenneco.com   

 

17. Changes to this Privacy Statement

We may modify or update this Privacy Statement from time to time.  If we change this Privacy Statement, we will notify you of the changes by publishing an updated statement on our Site.  Where changes will have a fundamental impact on the nature of the processing or otherwise have a substantial impact on you, we will give you sufficient advance notice so that you have the opportunity to exercise any rights you may have (e.g. to object to the processing).
Privacy Notice:  Agency Page 2 of 9