Privacy Policy – Berlin Packaging L.L.C.

Effective Date
12/05/23

At Berlin Packaging, we care about your privacy and personal information. This Privacy Policy (the “Policy”) applies to the websites, applications, and electronic communications where it appears, as well as all software, services, extensions, subdomains, and application programming interfaces related thereto (the “Platform”). The Policy describes how Berlin Packaging L.L.C. and our affiliated companies (“Berlin Packaging,” “we,” or “us”), uses Personal Information that we collect, receive, maintain, use, treat, and store about you in connection with your use of our services and the Platform. IF YOU DO NOT ACCEPT THIS PRIVACY POLICY, PLEASE DO NOT ACCESS, USE, OR BROWSE OUR PLATFORM.

“Personal Information” means any information relating to an identified or identifiable natural person. When we combine Personal Information with other information (i.e. information that does not, on its own, identify you), we treat the combined information as Personal Information.

You may choose whether or not to provide or disclose Personal Information in connection with your use of our Platform. If you choose not to provide the Personal Information we request, you may still visit and use parts of our Platform, but may be unable to access or use certain features, options, programs, products, and services.

Notice at Collection
At or before the time of collection, California residents may have a right to receive notice of our practices, including the categories of personal information to be collected, the purposes for which such information is collected or used, whether such information is sold or shared and how to opt-out of such uses, and how long such information is retained. You can find those details by clicking on the above links.

Categories of Personal Information We Collect
We and our service providers collect a range of Personal Information. We may collect contact information when you connect with us on the Platform through email or our web form, or when you choose to join our mailing list, fill out one of our surveys, or register an account on the Platform. For instance, we may collect your name, email address, phone number, and address. When you communicate with us, such as through email or our web chat tool, we and our service providers collect the information you communicate to us.

We may collect financial information if you make a purchase on the Platform. Payment information includes your bank account information and/or credit and/or debit card number including your CVV code and expiration date.

We may also collect professional details and other information about your business, such as company name and website, and annual packaging budget, in order to respond to your inquiry more accurately by providing you with more detailed and targeted information.

If you are applying for a job, we may collect information you provide to us in connection with the application or interview process, including, but not limited to, information about your education and employment history and other demographic information. This may include the schools you attended and previous employers. It may also include your gender, ethnicity, disability status, and veteran status, as well as the contents of your resume.

We may also collect usage and device information when you visit our Platform. This may include information about the browser and operating system, as well as the device you are using. This includes information such as Internet Protocol (IP) address, ISP, browser type, date and time of visit, referral page, the website pages you visit, and other information.

How We Collect Your Personal Information
We collect information in a variety of ways.  We collect information directly from you, for instance when you register an account, make a purchase, or communicate with us through our Platform.  Similarly, we collect information directly from you when you apply for a position that we post.

We also collect information from you passively.  Our Platform uses tracking tools like cookies, pixels, and web beacons.  We do this both on our Platform and in emails that we send to you.  Through these tools we collect information about users over time when you use our Platform.  This collection includes usage and browser information.  We may also have third parties collect Personal Information this way.  For more information about the trackers that we use, please see the “Cookies and Other Web Technologies” section below.

Combining Information
We may combine Personal Information we obtain.  For example, we may combine information that we have collected online with information that we have collected offline, for instance during calls between you and our support team.  We may also combine information that we have collected across other third party sites or from other third parties with information we already have.  Finally, we combine information across devices.

How We Use Your Personal Information
We use Personal Information in a number of ways.  For instance, we use the personal information we collect about you to respond to your questions or to provide you with the products, services, or information that you request. We may also use your personal information to keep you informed about our new products and services offerings or to tell you about upcoming events. If you wish to opt-out of receiving promotional or marketing materials from us, please see the “Your Choices” section below.

In addition, we may use the personal information we collect about you to:

• • Create and manage your online account, including access to your purchase history
  • Assist with product selection and replenishment
  • To tailor ads displayed to you on our Platform and elsewhere to your interests and history with us
  • Operate, evaluate and improve our business (including by developing new services and offering additional products; performing data analytics; improving technical performance and functioning of our Platform; managing our communications; and performing accounting, auditing and/or other internal functions)
  • For security purposes and to identify and protect against fraud and other misuse of our Platform
  • Comply with applicable legal requirements, industry standards and other policies
  • Process your employment application and evaluate your candidacy if you apply for a position that we post
  • Carry out activities otherwise permitted by applicable laws

How We Disclose Your Personal Information
We may share your information among our affiliates, subsidiaries, employees, service providers, contractors, or consultants.

Generally, we will not sell, distribute, publish, disclose, or share your personal information to any unaffiliated third parties without your consent. In limited situations, though, we may disclose your personal information to unaffiliated third parties, including:

1. 1. Our Service Providers. We may share your Personal Information with third-party service providers that provide products or services to us (examples of these service providers include entities that process credit card payments, provide marketing services, host our web chat, and website optimization services).
   2. Business Partners. We may share Personal Information with our trusted third party partners. For example we may share information with partners when we co-sponsor a promotion. These partners may use your information to, among other things, send you information or contact you about services and products.
   3. Advertising Services. On occasion, we may engage advertising services to assist us in promoting our Platform and brand. Those services may target advertisements on third party websites based on cookies or other information indicating previous interaction with our Platform.
   4. Law Enforcement, Government Agencies, and Courts. We may disclose Personal Information in order to comply with law or respond to a legally valid inquiry or order, subpoena or search warrant, or otherwise protect ourselves, our employees, our customers, or members of the public. We may also disclose such information to exercise our rights or to defend against a legal claim or as otherwise required or allowed by law;
   5. Companies Involved in Mergers and Acquisitions Transactions. If we are involved in a corporate transaction, such as a merger, or sale of assets we may provide your Personal Information as a part of that transaction. Any information collected through the Platform, including Personal Information, may be among the items sold or transferred as part of such a deal
   6. Fraud and Other Investigations. We may share your Personal Information in order to enforce our Terms & Conditions and other agreements or policies. We may also share your Personal Information in the course of an investigation or to prevent a violation related to fraud, illegal, or harmful activity, or other contractual violation.

We may transfer your personal information to recipients in countries other than the country in which the information was originally collected, and your personal information may be stored and processed outside of your country of residence. Those countries may not have the same data protection laws as your country of residence, and your personal information may be subject to applicable foreign laws.

Your Choices
You have certain choices about how we use your Personal Information.  If you wish to opt-out of receiving promotional or marketing materials from us, request to update or change your personal information, or request to delete personal information you provided to us, please let us know by either calling our toll free number1-800-223-7546 sending us an email at info@berlinpackaging.com. Please provide us with your full name and email address (or other applicable contact information) when contacting us. You can also always opt out of receiving promotional emails by clicking the unsubscribe link at the bottom of each marketing email.

Please note that it may take several days to process your opt-out request and that you may continue to receive promotional or marketing materials during this time. Also, please note that opting-out of receiving will not preclude us from sending you other types of non-promotional messages, such as emails about your registered account or orders.

Cookies and Other Web Technologies
Our Platform uses cookies and other web technologies, such as pixels, web beacons, flash cookies, and web server logs.  We may also have third parties collect Personal Information this way on our behalf and for their purposes.  A cookie is a small text file that is stored on your computer or device by a website’s server. When you visit or interact with our Platform, we may use cookies to determine whether you’ve visited our Platform before, deliver personalized content, improve your experience on our Platform, tailor ads displayed to you, and for data analytics. For example, cookies help us understand whether or not you are already logged in as you click throughout our Platform. You may use your browser settings to choose what cookies can be placed on your computer and to delete or disable cookies, but setting a browser to reject cookies may affect and limit your experience on our Platform. For more information about cookies visit: http://www.allaboutcookies.org/. Web beacons, pixels, and other tracking technologies may operate independent of cookies.

We use third party analytics service providers, such as Google Analytics and BigCommerce, to administer such web technologies and help us analyze how visitors use our Platform. The information collected through these means (including IP addresses) is disclosed to these service providers. To learn more about Google Analytics uses your personal information, please visit Google Analytics’ Privacy Policy. To learn more about how to opt-out of Google Analytics’ use of your information, please click here.

We may also use Hotjar’s session replay analytics services. This allows us to record and replay an individual’s interaction with the Services. For more information about how Hotjar uses your personal information, please visit the “Personal Data collected from a visitor of a Hotjar Enabled Site” section of Hotjar’s Privacy Policy. To learn more about how to opt-out of Hotjar’s use of your information, please click here.

We may also use LinkedIn Analytics. For more information about how LinkedIn uses your personal information, please visit LinkedIn Analytics’ Privacy Policy. To learn more about how to opt-out of LinkedIn’s use of your information, please click here.

Text Messaging
If you elect to receive marketing text messages from us, either via our website or by sending a text message indicating your consent, you are providing your express written consent to receive recurring marketing or promotional and support text messages from us (each, a “Marketing Text Message”) which may be sent through an automatic telephone dialing system. These may include cart abandon messages. Message frequency varies. To the extent you voluntarily opt to have text notifications sent directly to your mobile phone, we receive and store the information you provide, including your telephone number or when you read a text message. You can opt out of receiving any further Marketing Text Messages from us at any time by replying “STOP” to any Marketing Text Message you receive from us. For help, reply “HELP” to any Marketing Text Message you receive from us or email info@berlinpackaging.com. In addition to any fee of which you are notified, your mobile provider’s message and data rates may apply to our confirmation Marketing Text Message and all subsequent Marketing Text Message correspondence according to your individual rate plan provided by your wireless carrier. Under no circumstances will we or our affiliates be responsible for any text messaging or wireless charges incurred by you or by a person that has access to your wireless device or telephone number.

Supplemental Notice for California Residents
This Supplemental Notice for California Residents supplements our Privacy Policy and only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (as amended from time to time) (“CCPA”).

The CCPA provides California residents with the right to know what categories of personal information Berlin Packaging has collected about them, whether Berlin Packaging disclosed that personal information for a business purpose (e.g., to a service provider), whether Berlin Packaging “sold” that personal information, and whether Berlin Packaging “shared” that personal information for “cross-context behavioral advertising” in the preceding twelve months. California residents can find this information below:

The categories of sources from which we collect personal information and our business and commercial purposes for using and disclosing personal information are set forth in “Categories of Personal Information We Collect”, “How We Collect Your Personal Information”, “How We Use Your Personal Information”, and “How We Disclose Your Personal Information” above, respectively. We will retain personal information in accordance with the time periods set forth in “Data Retention.”

If you visit our websites that use advertising cookies or pixels, we may “sell” and “share” your personal information to provide you with “cross-context behavioral advertising” about Berlin Packaging’s products and services.

Additional Privacy Rights for California Residents

1. 1. Privacy Rights. California residents may have the right to:
      • Confirm Whether We Are Processing Your Personal Information.(the right to know);
      • Request Access to and Portability of Your Personal Information,including: (i) obtaining access to or a copy of your personal information; and (ii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company in a readily useable format (also known as the “right of data portability”);
      • Request Correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information; and
      • Request Deletion of your personal information
      
      
      • If you would like to exercise any of these rights, please contact us as set forth in “Questions or Comments” below. We will process such requests in accordance with applicable laws.
   2. Disclosure Regarding Individuals Under the Age of 16. Berlin Packaging does not have actual knowledge of any “sale” of personal information of minors under 16 years of age. Berlin Packaging does not have actual knowledge of any “sharing” of personal information of minors under 16 years of age for “cross-context behavioral advertising.”
   3. Opting Out of “Sales” of Personal Information and/or “Sharing” for Cross-Context Behavioral Advertising under the CCPA. California residents have the right to opt out of the “sale” of personal information and the “sharing” of personal information for “cross-context behavioral advertising.” California residents may exercise these rights by contacting us as set forth in “Questions or Comments” below.
   4. Disclosure Regarding Sensitive Personal Information.Berlin Packaging only uses and discloses sensitive personal information for the following purposes
      • To perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services
      • To prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, and or confidentiality of stored or transmitted personal information.
      • To resist malicious, deceptive, fraudulent, or illegal actions directed at Berlin Packaging and to prosecute those responsible for those actions.
      • To ensure the physical safety of natural persons.
      • To verify or maintain the quality or safety of a product, service, or device that is owned, manufactured, manufactured for, or controlled by Berlin Packaging, and to improve, upgrade, or enhance the service or device that is owned, manufactured by, manufactured for, or controlled by Berlin Packaging.
      • For purposes that do not infer characteristics about individuals.
   5. Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.
   6. Verification. To protect your privacy, we will take steps to reasonably verify your identity before fulfilling requests submitted under the CCPA. These steps may involve asking you to provide sufficient information (e.g., the email address or full name we have associated with you) that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. Please note that if we cannot initially verify your identity, we may request additional information to complete the verification process.
   7. Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. To authorize an agent, provide written authorization signed by you and your designated agent using the information found in “Questions or Comments” below and ask us for additional instructions.

Children’s Privacy
Our Platform is not directed to children under the age of 16 and we do not knowingly collect personal information from children. If you are under the age of 16, please stop using our Platform. It is our policy not to knowingly solicit or permit children under the age of 16 to provide their personal information for any purpose. If you are a parent or legal guardian and think your child has given us information you can email us at info@berlinpackaging.com.  You can also write to us at the address listed in the “Contact Us” section of this Policy.  Please mark your inquiries “COPPA Inquiry.

Third Party Websites and Social Networks
Our Platform may link to websites that are not under our control, and we are not responsible for the privacy practices of any linked site not controlled by us. For example, we provide a number of links to associations and institutes that are part of the packaging industry, as well as other industries. We also provide links to social networks, such as Facebook, Twitter, and LinkedIn. We are not responsible for the privacy practices at these external websites or their use of your information. We encourage you to review the privacy policies for these websites.

Targeted Advertising
We may contract with third party advertising networks (e.g., Google) that collect IP addresses and other information through the use of cookies and web server logs on our Platform and emails, on third party websites, social media networks, and emails, and on our advertising placed on third party websites and social media networks. These advertising networks use this information to provide advertisements about products and services tailored to your interests (including for companies not affiliated with us). You may see these advertisements on our Platform or other third party websites. These processes also help us test and track the effectiveness of our marketing efforts.

Some of the advertising networks we work with may include Facebook. For more information about Facebook’s use of your personal information, please visit Facebook’s Data Policy. To learn more about how to opt-out of Facebook’s use of your information, please click here while logged in to your Facebook account.

Data Retention
We keep the personal information that we collect for the duration of our relationship, plus a reasonable period of time thereafter in order to comply with our legal obligations, resolve disputes, enforce our agreements, protect our legal rights, and carry out business purposes. We also collect and maintain aggregated, anonymized or pseudonymized information, which we may retain indefinitely to protect the safety and security of our Platform, improve our services or comply with legal obligations. If you wish to receive marketing communications from us, we will keep the information necessary to send you these communications following the end of our customer relationship or following their collection, if you are a prospective customer.

To determine the appropriate retention period for personal information, we may consider applicable legal requirements, the amount, nature, and sensitivity of the personal information, certain risk factors, the purposes for which we process your personal information, and whether we can achieve those purposes through other means.

Changes to this Privacy Policy
We may update our privacy policy at any time by posting updated text on this webpage. We display an Effective Date at the top of this policy so that it will be easier for you to know when there has been a change. Accordingly, we recommend that you check this privacy policy from time to time so that you are aware of our most current privacy practices. Each time you access, use, or browse one of our Platform, you signify your acceptance of the then-current version of this privacy policy.

Questions or Comments
If you have any questions or comments about the information in this privacy policy, please let us know by either calling our toll free number 1-800-223-7546 sending us an e-mail at info@berlinpackaging.com or by writing to us at the mailing address below.

Berlin Packaging L.L.C.
525 W. Monroe Street
Chicago, IL 60661