The Sherwin-Williams Company Privacy Policy

Last Updated: July 1, 2024

To view our California Privacy Notice, please click here.

Sherwin-Williams recognizes that when you choose to provide us with information about yourself, you trust us to treat it responsibly.

This Privacy Policy explains the types of information that Sherwin-Williams and its affiliated companies collect about you; how we use, share, and protect this information; and the choices you can make about how we use and share this information. This Privacy Policy governs information collected by Sherwin-Williams or its Affiliates (as hereinafter defined), 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 stores, customer loyalty programs or when you speak with a customer service representative (collectively, the “Services”).

It is important that you read this Privacy Policy carefully because anytime you use our Services you consent to the practices we describe in this Privacy Policy. Key jurisdiction-specific information about our privacy practices is available in our policy here.  In the event of any inconsistencies between the English-language version of this Privacy Policy and any local language version that we make available, the English-language version will prevail.

As permissible by law, Sherwin-Williams reserves the right to make changes to this Privacy Policy. If changes are made, updates will be reflected by the Last Updated date at the top of this Privacy Policy. These changes will take effect immediately upon posting. By continuing to use the Services following such changes, you will be deemed to have agreed to such changes.

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.

We may collect information about you in a variety of ways:

• You may provide us with information directly.
• We may collect information about you when you use our Services, make purchases, or view our online advertisements.
• We may collect additional information about you in accordance with applicable law.

The manner of our collection, the type of information collected, and the processing of such information may vary by jurisdiction to accommodate local legal requirements.

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), make a purchase, sign up to enter a promotion, submit your zip/postal 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/postal code, and phone number.
• Username or password.
• Age or birthdate, gender, occupation, organization name, job title and other demographic information.
• Credit card, billing address 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).
• Purchase history or coupon history.
• Other information provided when you contact us for customer support purposes.

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.

We collect information about your computer or device and your online activity, including using standard Internet technologies, such as cookies, pixels, web beacons, software development kits, local stored objects, and other similar technologies. The following are examples of the types of information that we collect, track, analyze, and use:

• Your browser type, operating system and your push notification token.
• IP address and/or device ID.
• Your browsing behavior on our Services, such as when and how you visit our websites or other Services, the amount of time spent viewing our online Services, the buttons and links you click, videos you watch, and where you scroll within our online Services, the search terms that you enter into our website, and the form submissions, purchases and transactions you make through the Services.
• Websites you visit before or after our websites, including but not limited to, any websites or advertisements that referred you to our websites or Services.
• Sherwin-Williams e-mails you open and/or forward.
• Sherwin-Williams offers or links you connect to via e-mails.
• Depending on your device settings, location information, such as your mobile device’s GPS signal or information about nearby Wi-Fi access points and cell towers
• Marketing identifiers, device identifiers, or other similar unique identifiers.
• Text or other messages sent or shared through chat or chatbot services.

We may receive information about you from publicly and commercially available sources in accordance with applicable law. In addition, we collect other information you allow a third party to provide to us. For example, if you choose to access or use social networking services, we may receive and store information that you share with us through those services.

All 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.

We use the information we collect about you:

• To provide you with services, products, or other materials you request (for example, completing a purchase, completing your registration for a loyalty program and sending you product samples).
• To communicate with or advertise to you, including about our products, services, policies, and promotions.
• To customize your experience with our Services, including by providing you with relevant advertising on our Services and elsewhere, such as on other websites and social media services and networks.
• To manage and improve your shopping experiences and 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, as well as address information security and/or privacy issues, debug and detect security incidents or abnormalities, fulfill, respond to, and document privacy rights requests, network functioning, and troubleshooting.
• To enforce our legal rights.
• To conduct internal analyses, such as surveys, studies, market research, monitoring or analyzing trends, usage and activities.
• To comply with Sherwin-Williams' policies, industry standards and applicable laws, regulations or legal processes.
• Otherwise with your consent.

Please see Your Choices & Rights in Your Information below for information about the choices you may have in relation to our use of your information.

Sherwin-Williams may disclose or share your information in the following circumstances:

• Affiliates. We share information within Sherwin-Williams among our various businesses and companies with which we share common control (together, our “Affiliates”), 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, process your credit card and other payments, 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.
  • To comply with corporate governance functions such as audits.
• Other Parties In Connection With A Proposed or Completed 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 in a manner that does not identify you (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.

We, as well as certain third parties, including those that provide content and other functionality on our Services, may use cookies, pixels (i.e., through a Meta/Facebook pixel), web beacons and other similar technologies on our online Services (referred to collectively as “Cookies”) and the information collected from such technologies. We also share information about your use of our websites with third parties, including our social media, advertising, and analytics partners. For more information on the information we collect through the use of Cookies, and how we use the information we collect, please see the Information We Collect and Use of Information sections of this Privacy Policy. For more information regarding third-party use of cookies, pixels, web beacons, and other similar technologies on our websites, please see the Third Parties That Provide Content or Functionality on Our Services section of this Privacy Policy. By using our online Services, you are consenting to our use of tracking technologies as described in this Privacy Policy.

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 and services.

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. 

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. If you are a U.S. user, click here for information about Do-Not-Track signals and similar mechanisms.

Pixels, 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 pixels, 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 pixels in e-mails to understand whether messages have been opened, acted on, or forwarded.

There are a variety of tracking technologies that may be included in mobile applications that are not browser-based like cookies and cannot be controlled by browser settings. Some use “SDKs” to associate app user activity to a particular app and to track user activity across apps and/or devices. SDKs are blocks of code that may be installed in our mobile application by third party companies with which we work. SDKs help us understand how you interact with our mobile application and collect certain information about the device and network you use to access our application, such as the advertising identifier associated with your device and information about how you interact with our application.

Our online Services use these technologies for the following general purposes:

Cookies vary in how long they last. “Session Cookies” terminate shortly after you terminate your internet session. “Persistent Cookies” are stored on your device until a set expiration date. We use both Session Cookies and Persistent Cookies on our websites.

Some of the content and functionality on our Services is provided by third parties that are not affiliated with us. For example, we enable you to share certain materials on our Services through social networking services, such as Facebook and Twitter. These and other social networking services may automatically collect information from or about your use of our Services when you use our Services while logged into the social networking services. We also offer online chat features that are supported by vendors - when you use these features, you are sharing information you provide in the chat with the vendor as well as with us. Third-party advertisers, including but not limited to session replay vendors and social media services, also may have a presence on some of our Services. These and other third parties collect or receive certain information about your use of our Services, including through the use of Cookies, pixels, and similar 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 website operated by the Digital Advertising Alliance of Canada. Further information in local languages may be available at that site.)
 

Our Services, including our websites, use analytics technology provided by Google Analytics to understand how users interact with the sites, improve our web experience, and better market our products. You may exercise choices regarding the use of Cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout or downloading the Google Analytics Opt-out Browser Add-on.

Sherwin-Williams and its service providers may collect, transfer, store and process your personal 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.  In accordance with applicable law, we implement measures such as standard data protection clauses to ensure that any transferred personal information remains protected and secure.  You may obtain further information about these measures by contacting us using the Global Privacy Portal.

We do not knowingly collect personal information online from children as defined by local law.  If we learn that a child has provided us with personal information, we will delete it or otherwise comply with applicable law.

Where permitted by law, we may send you offers or promotions. However, we give you some 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:  If you no longer wish to continue receiving commercial postal mailings from a particular Sherwin-Williams brand or group, you may follow the instructions or use the contact information contained in any such message. You may also contact us at Global Privacy Portal to remove yourself from our mailing lists.
• Text messaging: You have the choice to opt in to receiving text messages and alerts on the mobile phone number(s) you share with us. You do not have to opt-in to text messages and alerts to use and enjoy our Service or products. If you opt-in, standard text messaging charges may apply. If you no longer wish to receive text messages from a particular Sherwin-Williams brand or group, you may opt-out of our text messages and alerts at any time. To directly opt-out, follow the instructions or use the contact information contained in any such message. Please see our Text Message Program Terms and Conditions for more information.

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.
 

You may have certain rights as a data subject under local law. For example, local law may afford you the right to access, update, restrict, oppose, erase, port and/or correct inaccuracies in your personal information under our control, subject to certain exceptions prescribed by law. Many of our programs provide you direct access to view, update, correct, and/or delete personal information you provided when you registered online. Please check where you registered to learn what functionality may be available to you in relation to an applicable program.

If functionality is not available where you registered and you would like to exercise your legal rights, please contact us at the Global Privacy Portal. We will respond to requests in accordance with applicable law and subject to legal and contractual restrictions.

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 steps to retain information about you only for so long as is necessary for the purpose for which it was collected, as required under contract, or as required by or permissible under applicable law.

If you have questions about this Privacy Policy or our privacy practices, please contact Sherwin-Williams through our Global Privacy Portal or at the following address:
 

The Sherwin-Williams Company

Global Privacy Compliance

101 W. Prospect Ave.

Cleveland, OH 44115

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. Our Privacy Policy is posted at this link. 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 Services. Your continued use of our Services following any changes signifies your acceptance of these changes.

This Notice supplements the other parts of our Privacy Policy, and provides additional information for US consumers (“Consumers”) as well as California residents who interact with us in the course of their work for another company (“B2B Contacts”). This Notice applies to “Personal Information” or “PI” which means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you.

In the past 12 months, we have collected PI about US Consumers and California B2B Contacts, and may have disclosed such PI with our affiliates, service providers, and contractors as described in the table below.

Among the categories of personal information listed above, the following categories of personal information we collect may be considered “sensitive” under some state privacy laws:

HOW LONG WE KEEP YOUR PERSONAL INFORMATION

We keep the categories of PI described above for as long as is necessary for the purposes described in this Policy or otherwise authorized by law. This generally means holding the information for as long as one of the following apply:

• Your PI is reasonably necessary to manage our operations, to manage your relationship with us, or to satisfy another purpose for which we collected the information;
  
• Your PI is reasonably necessary to carry out a disclosed purpose that is reasonably compatible with the context in which the PI was collected;
• The information is reasonably required to protect or defend our rights or property (which will generally relate to applicable laws that limit actions in a particular case); or
• We are otherwise required or permitted to keep your information by applicable laws or regulations.

Where PI is used for more than one purpose, we will retain it until the purpose with the latest period expires. For more information about our retention policies, please contact us using the contact details below.

TARGETED ADVERTISING, SELLING, AND SHARING OF PERSONAL INFORMATION

The categories of PI that we disclose for a business or commercial purpose and the categories of recipients are listed in the chart above. The chart below summarizes the categories of PI we used for targeted / cross-context behavioral advertising in the past 12 months. Although we do not sell Personal Information in exchange for money, some of the ways in which we share PI for targeted advertising may be considered “sales” or “sharing” under some US state privacy laws. We do not have actual knowledge that we sell or share the PI of people under 16 years of age. Our uses of Personal Information are not considered “sales” under Nevada law.

Under the California Consumer Privacy Act (California Civil Code Section 1798.100, et seq.), as amended by the California Privacy Rights Act (California Civil Code Section 1798.100, et seq.) (“CCPA”), California residents have certain rights they may exercise either independently or through an authorized agent. Your California privacy rights are described below. For purposes of this Notice, in some places we have abbreviated or summarized CCPA terms or language. Terms defined under the CCPA that are used in this Notice shall have the same meanings as under the CCPA.

To make a request to delete, request to correct, or request to know, you can submit a case through our Global Privacy Portal or by calling 1-844-835-4134. Please follow the instructions on our Global Privacy Portal and promptly respond to any follow-up inquires so that we may confirm your identity. If you would like to opt out of sales and sharing of PI, click the Do Not Sell or Share My Personal Information link on the homepage of the Sherwin-Williams website(s) you visit and move the “Do Not Sell or Share My Personal Information / Targeting Cookies” toggle to “off”.

If you submit a request to know, request to delete or request to correct, you will be asked to log into your account or to provide 2-3 pieces of PI that we will match against our records to verify your identity. Authorized Agents may submit requests on behalf of Consumers by following these steps and providing appropriate documentation. If you submit a request through an authorized agent, you will still need to verify your identity directly with us before your request can be processed.

Right to Know

You have the right to request that we provide you with the following information. Requests of this nature may be made no more than twice in a 12-month period.

• The categories of PI we have collected about you, including:
  • The categories of sources from which the PI was collected
  • Our business or commercial purposes for collecting, selling, or sharing PI
  • The categories of third parties to which we disclose PI
  • The categories of PI that we sold, and for each category identified, the categories of third parties to which we sold that particular category of PI
  • The categories of PI that we disclosed for a business purpose, and for each category identified, the categories of recipients to which we disclosed that particular category of PI
• The specific pieces of PI we have collected about you.

Right to Opt Out of Sales and Sharing of PI

You have the right to opt out of the sale of your PI, and to request that we do not share your PI for cross-context behavioral advertising. Although we do not sell Personal Information in exchange for money, some of the ways in which we share PI for advertising or marketing may be considered “sales” or “sharing” under the CCPA. To opt-out, please click on the “Do Not Sell or Share My Personal Information” link on the homepage of the Sherwin-Williams website(s) you visit and move the indicated toggle to “off.” If you choose to use a browser-based opt-out signal (such as the Global Privacy Control (GPC)), you will be opted out of cookie-based sales and sharing of Personal Information for each of our websites you visit with the signal enabled. Because we are unable to recognize you across different websites, visiting one of our sites with the signal enabled will have the effect of opting you out of sales and sharing with respect to that specific site, but will not impact sales and sharing for our other websites. Additionally, you will need to turn on the opt-out signal for each browser that you use. Please note that the GPC signal may block our websites’ cookie banners and preference centers from appearing or otherwise interfere with our Do Not Sell or Share My Personal Information links. If this occurs, your preferences have been recognized, even if the banner and preference center are no longer visible.

Deletion Rights

You may request that we delete your PI that we have collected directly from you. Under the CCPA, we may decline to delete your PI under certain circumstances—for example, if we need the PI to complete transactions or provide services you have requested or that are reasonably anticipated, for security purposes, for legitimate internal business purposes, to comply with law, or to exercise or defend legal claims. Where we use deidentification to satisfy a deletion request, we commit to maintaining and using the information in deidentified form and will not attempt to reidentify the information.

Correction Rights

If you believe that PI we maintain about you is inaccurate, you have the right to request that we correct that information.

Right to Limit Use and Disclosure of Sensitive Personal Information

We do not use or disclose Sensitive Personal Information for purposes to which the right to limit use and disclosure applies under the CCPA.

Right to Non-Discrimination for the Exercise of Your Privacy Rights

If you choose to exercise any of your privacy rights under the CCPA, you also have the right not to receive discriminatory treatment by us.

NOTICE OF FINANCIAL INCENTIVE

Our PaintPerks rewards program provides benefits such as rewards points and discounts to those who choose to participate. Participation requires you to provide some PI, such as Identifiers, Customer Records, and Commercial Information. The incentives associated with our rewards program are designed to reward loyal customers based on the volume of products and services they purchase from us. For the full terms and conditions applicable to our rewards program, please click here.

We have made a good faith estimate that the value of PI provided in connection with our rewards program is equivalent to the relevant expenses related to the collection and retention of that PI. Any difference in price or benefits provided to customers who participate in our rewards program is reasonably related to the value of the PI provided. By joining our rewards program, you consent to any financial incentive associated with the program. You have the right to withdraw from the financial incentive at any time by cancelling your participation in the rewards program. To cancel your rewards membership, please click here. Please note that if you submit a request to delete, that will delete PI associated with any rewards account you may have.

Privacy Rights for Residents of Additional U.S. States

This section supplements the other parts of our Privacy Policy and provides additional information for consumers who reside in US States other than California. If you are a resident of California, please review our California-specific disclosures, above.

MAKING A PRIVACY RIGHTS REQUEST

If you would like to make a request relating to your Personal Information, please use our Global Privacy Portal or call 1-844-835-4134. Please note that we will need to authenticate your identity before your request can be processed. For authentication, you will be asked to log into your account or to provide 2-3 pieces of Personal Information that we will match against our records.

• Access and Data Portability. You can use this type of request to confirm whether we are processing your Personal Information, access your Personal Information, and to obtain a copy of your Personal Information in a portable format.
• Correction. You may request that we correct inaccuracies in your Personal Information, taking into account the nature of the Personal Information and our purposes for processing it.
• Deletion. You may request that we delete your Personal Information. Under the state privacy laws, we may decline to delete your PI under certain circumstances—for example, if we need the PI to complete transactions or provide services you have requested or that are reasonably anticipated, for security purposes, for legitimate internal business purposes, to comply with law, or to exercise or defend legal claims.
• Opt-Out Requests. You may opt out of the following uses of your Personal Information: (a) targeted advertising; (b) the sale of Personal Information; and (c) profiling in furtherance of decisions that produce legal or similarly significant effects concerning your economic situation, health, personal preferences, interests, reliability, behavior, location, or movements. We do not sell Personal Information in exchange for money or engage in practices that qualify as profiling producing legal or similarly significant effects under applicable state privacy law. To opt out of targeted advertising / non-monetary “sales” of Personal Information, please click on the “Do Not Sell or Share My Personal Information” link on the homepage of the Sherwin-Williams website(s) you visit and move the Targeting Cookies toggle to “off.” If you are an authorized agent submitting an opt-out request on behalf of a Colorado consumer, please click the Do Not Sell or Share My Personal Information link on the homepage of the Sherwin-Williams website(s) you visit and move the “Do Not Sell or Share My Personal Information / Targeting Cookies” toggle to “off.” We use commercially reasonable efforts to authenticate the identity of the consumer and the authorized agent's authority to act on the consumer's behalf.
• Appeals. Sometimes we are unable to process requests relating to your Personal Information, in which case, your request will be denied. If your privacy rights request has previously been denied by us and you believe we denied it in error, you may appeal for reconsideration of your request using our Global Privacy Portal.

Please note that if you make a privacy rights request, we will retain the Personal Information submitted in connection with your request for recordkeeping purposes.

LOYALTY PROGRAM DISCLOSURES FOR COLORADO RESIDENTS

The purpose of this section is to notify Colorado consumers of how we use Personal Information in connection with your participation in our PaintPerks loyalty program. You have the right to delete your Personal Information associated with your PaintPerks account; however if you delete your Personal Information, we will be unable to link your rewards to your account, and therefore you will be unable to receive benefits from the program. The chart below identifies the categories of Personal Information collected through our loyalty program that we sell, or process for targeted advertising, and the third parties who receive each category of Personal Information.

For more information about how we process your Personal Information, please see the other sections of our Privacy Policy.

The legal bases for our processing activities are as follows:

• For our legitimate business purposes, including:
  • 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) and to customize your experience with our Services;
  • to manage and improve your shopping experiences and our products, Services and offerings, including analyzing the use of our products and services, and determining the effectiveness of our advertising; and
  • to protect the security and integrity of our Services.
• To perform our contract(s) with you, including processing your purchases and transactions,
• To meet our legal obligations, for example:
  • for audit and reporting purposes;
  • to perform accounting and administrative tasks;
  • to respond to requests for information by competent public bodies and judicial authorities; and
  • to enforce our legal rights and to enforce or manage legal claims.
• On the basis of your consent:
  • to send you direct marketing messages about our products, services, and promotions; and
  • to deliver targeted advertisements to you, both on and off the Services, including by using cookies and similar technologies, as explained below.

You can withdraw your consent at any time by contacting us.  If you withdraw certain consents, we may no longer be able to offer related services.

• E-Mail: If you wish to unsubscribe or opt out of receiving direct marking from a particular Sherwin-Williams brand or group via email, 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:  If you no longer wish to continue receiving commercial postal mailings from a particular Sherwin-Williams brand or group, you may follow the instructions or use the contact information contained in any such message.   You may also contact us at Global Privacy Portal to remove yourself from our mailing lists.
• Other:  If you no longer wish to continue receiving other commercial communications from a particular Sherwin-Williams brand or group, you may follow the instructions or use the contact information contained in any such message, or by changing the privacy settings in your browser (for example, with respect to cookies).   You may also contact us at Global Privacy Portal to remove yourself from other types of direct marketing in accordance with local law. 

You may lodge a complaint with a supervisory authority if you consider that our processing of your personal information infringes applicable law.

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 online services. The information generated by the cookies about your use of the online services (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 websites, 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.

If you are an Argentine resident, in accordance with Law No. 25,326, as amended, you can exercise your right of access every 6 months free of any charge, or more often if you have a legitimate interest to exercise such right, by providing us with any proof of your identity. The request shall be answered in accordance with applicable law.

Besides the right of access, any Argentine resident can exercise their amendment, update or cancelation rights at any time free of any charge by providing us with any proof of identity. The request shall be answered in accordance with applicable law. The request can be denied if: (i) there is a third party interested in the conservation of the personal information in its current state by Sherwin-Williams; or (ii) there is a legal obligation to preserve the data in its current state.

The exercise of the rights of access, amendment, update or cancelation can be denied by us if it is needed to: (i) protect the national security, the institutional order, the public safety or third party rights; or (ii) avoid the obstruction of justice in judicial or administrative case files related to tax obligations, social security obligations, public health, criminal investigations and administrative infraction investigations as long as there is an order in the corresponding case file to avoid the exercise of any of the aforementioned rights by the data subject.

For information about how to exercise these rights, please see Your Choices & Rights in Your Information above. Sherwin-Williams can be contacted through the Global Privacy Portal for additional inquiries.

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.

Sherwin-Williams may transfer your personal information to affiliates, service providers, and other parties described under “Sharing Your Information” outside of Australia including in the United States.

We rely on your consent to send you direct marketing messages about our products, services, and promotions, and to deliver targeted advertisements to you.  You can withdraw your consent at any time.  Please see Your Choices & Rights in Your Information for more information.  You also may change the privacy settings of your browser, for example, with respect to cookies.  If you withdraw consent, we are no longer able to offer these services.

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 https://www.oaic.gov.au/.

In addition to the purposes set forth in this Consumer Privacy Policy, we also process your personal data in order to manage your orders internally, for the protection and security of your personal data and to manage your participation in trainings, presentations and events that we or our representatives may offer related to our products and services.

By participating in trainings, presentations, and other events, you agree that you are interested in our products and services, including our marketing materials.  We observe all your rights set forth in this policy and applicable law, including your right to opt-out.

Regardless of additional provisions set forth in this Privacy Policy, you may be entitled to the following rights in connection with your personal data before Sherwin-Williams at any time and upon request:

• confirmation of the processing;
• access to the personal data;
• rectification of incomplete, inaccurate or out-of-date personal data;
• anonymization, restriction/blocking or deletion of unnecessary or excessive personal data or data processed in breach of the provisions set forth in the Law No. 13,709/18 or “Brazilian Data Protection Law”;
• portability of personal data to another service provider or product supplier, upon explicit request, subject to commercial and industrial secrecy, pursuant to regulation of the National Data Protection Authority (as defined in the Brazilian Data Protection Law);
• erasure of personal data processed based on the consent of the data subject, except for cases where the Brazilian Data Protection Law authorizes Sherwin-Williams to keep such data;
• information about public and private entities which Sherwin-Williams shared data subject’s personal data with;
• information about the possibility of denying consent and the consequences of such denial; and
• revocation of consent. 

In addition to the exercise of the rights above, it is your responsibility to keep your information duly updated and accurate with us.

You may contact Sherwin-Williams, the controller of personal data subject to processing, at the Global Privacy Portal, to exercise any of your rights and comply with obligations set forth in this Privacy Policy.

Pursuant to article 41 of the Brazilian Data Protection Law, Sherwin-Williams has appointed its Global Privacy Manager – LATAM as its Data Protection Officer. You may contact her at the Global Privacy Portal.

Additional information regarding our personal information practices in Canada:

• When you join our PaintPerks loyalty program in-store or online, we collect information such as your first and last name, phone number, and either mailing address, email address or postal code in order to create and administer your PaintPerks account and provide you with benefits, such as tracking your purchase history, saving colors, creating shopping lists. If you have a retail charge account, you will automatically be enrolled in the Preferred Customer Program with PaintPerks benefits.  Please note that our PaintPerks program is not available to residents of Quebec. 
• You may be able to create a personal, paint professional or PRO+ (for architects, designers, and design students) and profile on our website. To do so, we may collect personal information such as first and last name, country, postal code, mobile phone number, and home anniversary month. 
• If you sign-up to receive our email newsletters, we will send you emails with sale alerts, color videos and online magazine inspiration. You can withdraw your consent any time by clicking “unsubscribe” in any of our email communications. 
• If you sign-up for our Mobile Alerts program, we will send you text messages with special offers, colour tips, announcements and sale alerts. You can withdraw your consent any time by replying STOP to any text message. 
• If you book a virtual session via text, email, phone or video chat with a Sherwin-Williams Color Consultant, we may collect your first and last name, email address, mobile phone number, mailing address (excluding residents of Quebec). We use this information to communicate with you about and during your consultation, including to send you confirmation and reminder emails. We also collect any images of your space that you share with us. Please do not send us any photos that contain images of individuals or any other personal information. 
• To receive a military discount in our stores, you will be required to present your military ID card. Similarly, if you return merchandise without a receipt, we view a copy of your government-issued photo ID for fraud prevention purposes. We do not record or retain any information from the ID card provided.

Sharing of Information: Legal and Compliance

Our authorized employees, agents and Service Providers will have access to your information on a need-to-know basis as required to fulfill their obligations to us for the purposes set out in this Privacy Policy.

Sherwin-Williams (and its Canadian, U.S. and other foreign service providers) may access, process and store your personal information outside your province (including, for Quebec residents, outside Quebec)  and internationally, including in the United States. We will obtain your consent prior to disclosing your personal information to our affiliates for their own marketing or other purposes.

We and our service providers may provide your personal information in response to a search warrant or other legally valid inquiry or order, or to another organization for the purposes of investigating a breach of an agreement or contravention of law, suppressing or preventing fraud, or as otherwise may be required or permitted by applicable Canadian, U.S. or other law or legal process, which may include lawful access by U.S. or foreign courts, law enforcement, or other government authorities.  

Interest-Based Advertising

We work with third parties such as ad networks and other advertising companies that use their own tracking technologies (including cookies, web beacons and pixel tags) on our Website in order to provide you with tailored advertisements across the Internet. This is a common marketing practice referred to as interest-based or online behavioral advertising. These companies may collect information about your activity on our Website and third-party websites (such as web pages you visit and your interaction with our advertising and other communications) and use this information to make build a profile of your interests, make predictions about your preferences, develop personalized content and deliver ads that are more relevant to you on third-party websites. This information may also be used to evaluate the effectiveness of our online advertising campaigns.

Opting-out of Interest-Based Advertising: To adjust your preferences or exercise control over the third parties who collect data on our Website for interest-based advertising purposes, please click “Cookie/Consent Preferences” or the “Do Not Sell or Share My Personal Information” link on the homepage of the Sherwin-Williams website(s) you visit to visit our Manage Consent Preferences page where you can adjust your preferences.  For more information about interest-based advertising and to understand your options, including how you can opt-out of receiving behavioural ads from third-party advertising companies participating in the Digital Advertising Alliance of Canada, please visit the Digital Advertising Alliance of Canada website at http://youradchoices.ca/choices. 

• Please note that even if you opt-out of interest-based advertising by a third-party, these tracking technologies may still collect data for other purposes including analytics and you will still see ads from us, but the ads will not be targeted based on behavioural information about you and may therefore be less relevant to you and your interests. 
• To successfully opt out, you must have cookies enabled in your web browser (see your browser’s instructions for information on cookies and how to enable them). Your opt-out only applies to the web browser you use so you must opt-out of each web browser on each computer you use. Once you opt out, if you delete your browser’s saved cookies, you will need to opt-out again.

Custom Audience

We may use services provided by third-party platforms (such as social media and other websites) to serve targeted advertisements on such platforms to you or others, and we may provide a hashed version of your email address or other information to the platform provider for such purposes. To opt-out of the sharing of your information for such purposes, please send a request through our Global Privacy Portal (select “Other”) or contact us as described under “How to Contact Us" above.

Your Choices & Rights in Your Information

You may contact Sherwin-Williams’ Chief Information Security Officer with questions about our privacy practices, including to receive information regarding our policies and procedures with respect to service providers outside of your jurisdiction. Subject to legal and contractual restrictions, you may request access, updating, rectification and corrections of inaccuracies in your personal information in our custody or control, or withdraw your consent to our further collection, use or disclosure of your personal information (subject to legal or contractual restrictions) by contacting our Chief Information Security Officer.  If you withhold or withdraw consent to our collection, use or disclosure of your personal information, we may not be able to provide you with all of the products or services you request. Please see Your Choices & Rights in Your Information for additional information about how to exercise your rights and choices.

Our Chief Information Security Officer can be contacted using the contact details under “How to Contact Us" above, or through our Global Privacy Portal. 

Information about our Privacy Governance Policies and Practices

We have designated our Chief Information Security Officer as responsible for overseeing the company’s compliance with privacy legislation. Depending on your activities, Sherwin Williams Company or its Canadian affiliate, Sherwin Williams Canada Inc., will be responsible for your personal information.

We are committed to protecting personal information and have implemented a comprehensive set of policies and practices that govern our treatment of personal information. These policies and procedures include, among other things, the following:

• policies and procedures to protect personal information in our custody and control from unauthorized access, use or disclosure.
• a privacy framework that defines the roles and responsibilities for our employees with respect to the treatment of personal information.
• a framework for the retention and destruction of personal information to ensure compliance with legal obligations, and to securely destroy personal information once no longer required. 
• processes to respond to data subject requests and complaints in a timely and effective manner.
• regular privacy training and awareness for our employees.

If you are an Indian resident, you are entitled to request to review your personal information and to update, correct, or delete deficient or inaccurate information, and you have the right to contact us regarding any discrepancies or grievances relating to the processing of personal information by Sherwin-Williams.  Please see How to Contact Us for information on how to contact us.  Please see Your Choices & Rights in Your Information for information about how to exercise these rights.  While we take steps to comply with your requests in a timely manner, we are not responsible for the authenticity of your personal information.

This section supplements the other parts of our Privacy Policy and provides additional information for residents of Jamaica. 

LEGAL BASES FOR PROCESSING

The legal bases for our processing activities are as follows:

• To perform our contract(s) with you, for instance, providing you with services, products or other materials you request including processing your purchases and transactions, completing your registration for a loyalty program or sending you product samples.
• To pursue our legitimate interests as a business, including:
  • To manage and improve your shopping experiences and our products, services and offerings including analysing the use of our products and services, and determining the effectiveness of our advertising; and
  • To enforce our legal rights and to enforce or manage legal claims.
• To meet our legal obligations including:
  • Performing accounting and administrative tasks
  • Auditing and reporting; and 
  • Responding to requests for information by public and judicial authorities.
• On the basis of your consent.

DIRECT MARKETING

On the basis of your consent, we may send you direct marketing messages about our products, services, and promotions or deliver targeted advertisements to you, both on and off the Services.

If you are a Sherwin Williams customer, we may send you direct marketing messages without your consent but will give you an opportunity to opt out.

If you wish to opt out of receiving direct marking communications from a particular Sherwin-Williams brand or group, you may follow the instructions contained in such messages or contact us through our Global Privacy Portal.  To change your preferences relating to online targeted advertisements from Sherwin-Williams, please use the cookie management tool provided on our website or adjust your cookie settings within your browser. More information about our use of cookies can be found here.

YOUR LEGAL RIGHTS

You have the following rights under the Data Protection Act:

• The right to request a copy of the personal data that we hold about you. 
• The right to ask us to rectify inaccuracies in the personal data we hold about you.
• The right to erasure, in certain circumstances.
• The right to object or to prevent the processing (or further processing) of your personal data in certain circumstances.
• The right to withdraw consent to marketing.
• Rights related to solely automated decision-making including profiling. We do not use automated decision-making processes that would significantly affect you. But, if we did, you have the right to human intervention, to be informed of the logic of the decision and to have the decision reconsidered.
• The right to data portability to transfer your data to another controller.

If you wish to exercise any of the rights set out above, please submit your request through our Global Privacy Portal.  Should you have any questions about our data privacy practices, you may contact our Data Protection Representative for Jamaica via our Global Privacy Portal.  You may lodge a complaint with the Office of the Information Commissioner (OIC) if you consider that our processing of your personal information infringes the Data Protection Act.

If you are a resident of Malaysia, please see How to Contact Us for information about how to contact Sherwin-Williams’ Global Privacy Compliance group responsible for global data protection.

As residents of Mexico, you may object to the processing of your personal information for the following voluntary uses of such personal information:

• To communicate or send you promotions.
• To provide you with relevant advertising on our Services and elsewhere.
• To determine the effectiveness of our advertising.

Also, in addition to your rights of access and rectification, you also may have the right to cancel or oppose the collection and processing of your personal information and to limit the scope of processing and to revoke your consent, in accordance with local law.

Please see Your Choices & Rights in Your Information for information about how to exercise these rights.  Please explain what right you want to exercise and provide proof of identity.  The request shall be answered in accordance with applicable law. If you would like to correct or update your personal information, indicate what the correction should be.

Under the New Zealand Privacy Act 1993, you have certain rights of access to and correction of personal information we hold about you.  Please see Your Choices & Rights in Your Information for information about how to exercise these rights.

If you are a resident of Singapore, please see How to Contact Us for information about how to contact Sherwin-Williams’ Global Privacy Compliance group responsible for global data protection.

If you are a Swedish resident, you may contact Sherwin-Williams for information about our privacy practices as described under How to Contact Us.

The legal bases for our processing activities are as follows:

• For our legitimate business purposes, including:
  • 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) and to customize your experience with our Services;
  • to manage and improve your shopping experiences and our products, Services and offerings, including analyzing the use of our products and services, and determining the effectiveness of our advertising; and
  • to protect the security and integrity of our Services.
• To perform our contract(s) with you, including processing your purchases and transactions.
• To meet our legal obligations, for example:
  • for audit and reporting purposes;
  • to perform accounting and administrative tasks;
  • to respond to requests for information by competent public bodies and judicial authorities; and
  • to enforce our legal rights and to enforce or manage legal claims.
• On the basis of your consent:
  • to send you direct marketing messages about our products, services, and promotions; and
  • to deliver targeted advertisements to you, both on and off the Services, including by using cookies and similar technologies, as explained below.

You can withdraw your consent at any time.  Please see Your Choices & Rights in Your Information for more information.   You also may change the privacy settings of your browser, for example, with respect to cookies.  If you withdraw consent, we are no longer able to offer these services.

Please see Your Choices & Rights in Your Information for information about how to exercise the rights you may have in accordance with Uruguayan Data Protection Act No. 18,331.  You also may contact us with questions and to exercise any rights hereunder as described under How to Contact Us.

The information about you that we collect, store, process, use, disclose to and transfer to third parties includes information in electronic format. References to “sharing” and “disclosure” of personal information in Sharing of Information include any and all of the acts of sharing, disclosing, and transferring your information.  Please see Your Choices & Rights in Your Information for information about how to exercise rights you may have under local law to access, update, correct and/or request removal of your personal information from our databases, request stoppage of the provision of your personal information to a third party or request we not quote or otherwise use contents of such information.  In addition, you may contact us at the following address for questions or information about how to exercise your rights under local laws as described under How to Contact Us.  Upon receipt of your request, Sherwin-Williams will grant you reasonable access to personal information that we hold about you, unless otherwise legally unable to do so. In addition, Sherwin-Williams will take necessary steps to permit you to correct, amend, or delete information demonstrated to be inaccurate or incomplete.

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