Customer Privacy Notice
(last updated May 2018)
We are committed to your right to privacy and will only process personal information you provide to us in accordance with applicable data protection laws.
If you have any questions about how we collect, store and use your personal information, please contact us by post at
7 Westwood House
The personal information we collect
The personal information that we may collect about you broadly falls into the following categories:
- Your name;
- Company Name;
- Payment processing information;
- Company or business postal address;
- Company or business email address;
- Business landline or mobile telephone number;
- Delivery details;
- As well as other non-sensitive personal information;
- Your industry interests
- Your job title or job role
- Company business information
- Top level demographic information
If you use our websites, we may also collect information about you or your computer when you browse to allow you to use the services available, and also collect anonymous information about you or your computer for analysis to support continual improvements to our products and services.
How we use your personal information
We use the personal information that we collect about you to respond to your enquiries for payment processing, for the provision of goods and services to you or to the company that you represent, and for providing continuing product care such as warrant and technical support. We also process your personal information where we are required to do so by law, and for the exercise or defence of legal claims.
From time to time, we may contact you for research purposes, or to tell you about our special offers and other services in accordance with your contact preferences. Where appropriate, we will obtain your consent to do so. If you no longer wish to receive communications from us, please follow the “unsubscribe” instructions provided in any of those communications.
If we intend on using your personal information for any other purpose, we will let you know how we intend to use it when it is captured.
We will only process your personal information for the specific purposes listed above or for any other purposes specifically permitted by law. Your personal information will only be processed to the extent that it is necessary for the specific purposes listed above.
Our legal basis for processing your personal information
We will only process your personal information where you have consented (which you may withdraw after giving it if we are relying on consent as a legal basis), in order to perform a contract with you, or where the processing is necessary for our legitimate interests or the legitimate interests of others, for example, for market research purposes or, where you are an existing customer or user, to promote our goods and services.
How long we retain your personal information
We will only retain personal information if it is required for a specific purpose. We have a statutory duty to keep certain records for a specified minimum period, for example, personal information in relation to the purchase of a product or service from Wynn Oil a Division of ITW Ltd. We will not retain any data that is not connected to the purchase of a Wynn Oil a Division of ITW Ltd product or service for longer than 6 years. We will also retain and use your personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Information that is no longer required for any valid business purpose, and that we are not required to keep pursuant to any applicable law, will be routinely destroyed by secure means.
Who we share your personal information with
We may share your personal information with the following categories of recipients:
- Our group companies, third party services providers and partners who provide data processing services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our Website), or who otherwise process personal information for purposes that are described in this Privacy Notice or notified to you when we collect your personal information.
- Any competent law enforcement body, regulatory, government agency, court or other third parties where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
- A potential buyer (and its agents and advisers) in connection with any proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Notice;
- Any other person with your consent to the disclosure.
We may transfer your personal information to our associated entities and other members of our group of companies (including our parent company, Illinois Tool Works Inc., in the US).
Please be aware that countries outside of the European Economic Area (EEA) may not offer the same level of data protection as a country within the EEA. We ensure that we have a relevant data processing agreement in place with each third party outside the EEA to ensure they are compliant with privacy and data protection laws. We will make sure that any transfer of your personal information by us will be secured and/or encrypted for its protection.
How we protect your information
We use reasonable and appropriate administrative, technical, and organisational measures to safeguard personal information against loss, theft and unauthorised uses, access, disclosure, modifications or destruction. Certain areas of our websites may be password protected. If you are a user of our websites and have a password, you can help to preserve your privacy by ensuring that you do not share your password with anyone else.
Choices you have about how we use your information
You have the following rights under data protection laws:
- If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided under the “How to contact us” heading below.
- In addition, you can object to the processing of your personal information, ask us to restrict the processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided under the “How to contact us” heading below.
- You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under the “How to contact us” heading below.
- Similarly, if we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
- You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.
These rights may not apply in some cases, including where we must comply with legal requirements, where it would violate the rights of someone other than the individual requesting access, or (in the case of your right to request access to your personal information) where the request is manifestly unfounded or excessive.
If you would like to request access to, correction, amendment, or deletion of your personal information, please contact us using one of the methods below. We may request specific information from you to confirm your identity. In certain circumstances, for instance, if you request substantial copies of documents, we may charge a reasonable fee.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
Updates to this Privacy Notice
We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Notice changes if and where this is required by applicable data protection laws.
You can see when this Privacy Notice was last updated by checking the “last updated” date displayed at the top of this Privacy Notice.
How to contact us
If you have any questions or concerns about our use of your personal information, please contact using the following details: firstname.lastname@example.org
The data controller of your personal information is Wynn Oil a Division of ITW Ltd.
ITW Modern Slavery and Human Trafficking Statement
Revised June 2020
Illinois Tool Works Inc.
155 Harlem Avenue // Glenview, Illinois 60025 // itw.com
ITW Modern Slavery and Human Trafficking Statement
This Statement relates to our fiscal year ended December 31, 2019. It describes the activities of
Illinois Tool Works Inc. and its consolidated subsidiaries (the “Company,” “ITW,” “we,” “us” and
“our”) to eliminate slavery and human trafficking from its business and supply chains.
ITW recognizes that our impact extends far beyond our own walls. To further our positive impact
on our shared world, we are committed to fostering responsibility across our value chain,
through the impact of our products, as well as via our global supplier network.
The Company is a global manufacturer of a diversified range of industrial products and
equipment with 84 divisions in 53 countries. The ITW Culture is one of the key drivers of our
enterprise strategy and encompasses our Core Values of Integrity, Respect, Trust, Shared Risk
and Simplicity. We integrate into our Core Values, the principles of the United Nations Global
Compact, Universal Declaration of Human Rights and the International Labor Organization’s
Declaration on Fundamental Principles and Rights at Work. Our Core Values, communicated
throughout the Company, call for the highest ethical standards in all interactions with all
We have prepared this Statement on a combined basis to comply with both the California
Transparency in Supply Chains Act and the UK Modern Slavery Act and for our entire company,
because our Core Values, Statement of Principles of Conduct, Human Rights Policy, Supplier
Code of Conduct, Supplier Expectations and Conflict Minerals Policy Statement, together
provide the over-arching compliance framework relating to slavery and human trafficking across
our entire enterprise (which we sometimes refer to herein collectively as “modern slavery”).
However, not all of the entities that are part of the Company are subject to the California
Transparency in Supply Chains Act or the UK Modern Slavery Act.
We believe that the risks of modern slavery in our own businesses are remote given the nature
of our businesses and workforce coupled with our internal policies and procedures. Where we
have identified risks inherent in suppliers, as further discussed below, we have established
procedures to mitigate the risks of modern slavery in our supply chains for products from those
Where practicable, we seek to maintain long-term relationships with local suppliers, to help us
source more responsibly and reduce the risk of sourcing from an unethical supplier.
Codes of Conduct
The ITW Statement of Principles of Conduct mandates compliance with human rights
requirements around the globe, including environmental, health and safety laws that protect the
well-being of employees, and laws against slavery, human trafficking and child labor. The ITW
Statement of Principles of Conduct applies to all of our employees and internal business
In addition, ITW’s Supplier Code of Conduct holds our suppliers accountable to the same
standards of conduct set forth in our Statement of Principles of Conduct. The Supplier Code of
Conduct specifically prohibits our suppliers from employing workers that are younger than
minimum age (and in any case, under the age of 15) or from knowingly sourcing from suppliers
associated with human trafficking. The Supplier Code of Conduct also requires our suppliers to
make reasonable efforts to ensure that their suppliers comply with our policies. We expect our
suppliers to be in compliance with the Supplier Code of Conduct, and we do not knowingly do
business with suppliers who violate laws for the protection of human rights or human health and
We also have published Supplier Expectations. Among other things, our Supplier Expectations
indicate that we expect suppliers to comply with all applicable laws and regulations around the
globe, including those pertaining to human rights and laws against slavery, human trafficking
and child labor.
Furthermore, we have published a Human Rights Policy. Our Human Rights Policy indicates
that we are committed to human rights in the workplace. Among other things, this includes
providing a workplace that protects employee well-being and safety and compliance with all
applicable laws regarding slavery, human trafficking and child labor.
Steps to Mitigate Slavery and Human Trafficking Risk
We engage in the activities discussed below to mitigate the risk of modern slavery in our supply
Consistent with our decentralized operating structure, our individual businesses are responsible
for assessing and addressing risks of modern slavery in their supply chains, based on their
particular business and risk profile. In recognition of the different risk profiles of our businesses,
we have elected not to take a prescriptive approach to this area of compliance as we believe
that enabling individual businesses to take a thoughtful, tailored approach to addressing modern
slavery risk is more effective than a prescriptive approach, and our business units are expected
to operate in accordance with our Core Values, the ITW Statement of Principles of Conduct, the
Supplier Code of Conduct, the Supplier Expectations, the Human Rights Policy and other ITW
Supplier and Risk Assessments; Supply Chain Verification. Our businesses evaluate
prospective suppliers during supplier selection and periodically thereafter based on their
business and risk profile and role in our supply chain. The evaluation may include steps to
assess risks of modern slavery. The steps taken to assess modern slavery risk typically include
a request that suppliers complete a supplier questionnaire detailing supplier capabilities related
to manufacturing processes, quality control, delivery, and technology, and requesting other
information relative to overall management of the supplier company.
ITW also conducts internal research relating to modern slavery risk using U.S. government and
non-governmental organization resources, conducts supplier outreach in connection with our
conflict minerals country of origin inquiries and participates in industry groups and engagement
with other stakeholders. As part of our supplier risk assessment process, we also use a
proprietary supply chain risk checklist that guides us in identifying suppliers with the highest
risks of modern slavery in their operations. In addition, as discussed below, we require
certifications from the highest risk suppliers.
Audits. Prior to placing business with a supplier, an onsite supplier visit may be made by ITW
personnel for purposes of confirming supplier overall capabilities related to manufacturing,
quality, delivery, and technology, and assessing overall supplier risk. Additionally, after business
has commenced with a supplier, onsite supplier visits may be performed periodically by ITW
personnel. Although the specific purpose of onsite visits is not typically to assess modern
slavery, compliance with Company standards for modern slavery is covered within the overall
supplier assessment, and we believe that onsite supplier visits by ITW personnel discourage
abusive working conditions.
Contract Terms. Our standard Terms and Conditions of Purchase provide that direct suppliers
must comply with all applicable laws against slavery, human trafficking and child labor. Terms
and Conditions of Purchase also require direct suppliers to comply with our Supplier Code of
Supplier Certifications. We evaluate our purchased products against the U.S. Department of
Labor’s List of Goods Produced by Child Labor or Forced Labor for likely countries and industries
prone to modern slavery to help identify high-risk suppliers ITW may utilize. Based on this
evaluation, we provide education on our Supplier Code of Conduct to identified possible high-risk
suppliers and ask them to sign a declaration that they are aware of and comply with our Supplier
Code of Conduct, including its provisions regarding slavery and human trafficking. We have
obtained certification of compliance from 100 percent of these identified possible high-risk
We require annual re-certifications from any identified high-risk suppliers. In addition, we require
substantial suppliers who sell us product that contains so-called “conflict minerals” to certify as to
the origin of the minerals or other requested material to determine whether such minerals or
materials may be supporting conflict in central Africa. These certifications are in part intended to
help identify and mitigate the risk of modern slavery, human trafficking, child labor and other
violations of human rights.
Grievance Mechanism. The Company maintains a confidential whistleblower help line by which
all employees, suppliers and other third parties may report compliance failures by employees,
suppliers or contractors, including with respect to modern slavery. The contact information for our
helpline is http://www.itwhelpline.ethicspoint.com.
Internal Accountability and Training
Compliance Team. At the corporate level, we have a Responsible Sourcing Committee that
meets regularly on human rights and other topics related to responsible sourcing. Employees at
our decentralized business units also are involved in compliance efforts and are responsible to
ensure they are sourcing appropriately, including consideration of the risks related to modern
slavery in the supply chain.
Training and Knowledge Management. Our sourcing personnel are trained in overall supplier
expectations, including the requirement to act ethically and according to our Supplier Code of
Conduct. In addition, we require our global sourcing employees, global employees who work with
suppliers and customers on conflict minerals requests, and our Responsible Sourcing Committee
members to undergo specific modern slavery training intended to generate awareness and
examples of best practices, particularly with respect to mitigating risks within our product supply
chains, and to enable our sourcing professionals to better recognize the signs of modern slavery
and act to address any identified issues. In 2018, we enhanced the content of our modern
slavery training and expanded the group of employees required to undergo such training to the
groups mentioned above. In 2019, we continued providing enhanced training to all new
employees in those groups. We also host an internal website that contains this training and
additional materials on this topic. To date, no issues of concern have been identified by our
personnel regarding any potential modern slavery at our suppliers.
Employee Certifications. Employees are periodically required to certify to their compliance
with the ITW Statement of Principles of Conduct. In addition, our modern slavery training,
mentioned above, also requires the employee groups described above to undergo periodic
certification of compliance.
Additional Corporate Social Responsibility Efforts
For more information on our efforts and our achievements relating to corporate social
responsibility, see our Corporate Social Responsibility Report, which is available at
Solely for purposes of compliance with the UK Modern Slavery Act, this Statement was approved
by the Board of Directors of ITW Limited on June 24, 2020 and signed by a director of that entity
as indicated below.
Giles Hudson, Director
June 24, 2020
Staying COVID-19 Secure in 2020
Wynn’s UK can confirm we have complied with the Government’s guidance on managing the risk of COVID-19
5 Steps to Safer Working Together
- We have carried out a COVID-19 risk assessment and shared the results with the people who work here
- We have cleaning, handwashing and hygiene procedures in line with guidance
- We have taken all reasonable steps to help people work from home
- We have taken all reasonable steps to maintain a 2m distance in the workplace
- Where people cannot be 2m apart, we have done everything practical to manage transmission risk
dated JULY 2020
for the following premises
Wynn’s UK, Unit 7 Westwood House I Westwood Way I Westwood Business Park I Coventry I CV4 8HS I United Kingdom
Signed document here: