BERLIN PACKAGING US APPLICANT PRIVACY NOTICE

Last Updated
08/28/2024

Thank you for your interest in Berlin Packaging! This US Applicant Privacy Notice covers all US applicants and prospective employees (collectively, “Applicants,” “you,” or “your”) of Berlin Packaging LLC, its subsidiaries and affiliate companies (collectively, “Berlin Packaging,” “us,” “our,” or “we”).

This US Applicant Privacy Notice explains the kinds of information we may collect via our Careers page at https://www.berlinpackaging.com/careers/ (the “Careers Site”) or on our premises during the Berlin Packaging application and recruitment process, how we intend to use and disclose that information, and how you may be able to opt out of a use or correct or change such information. We are committed to complying with all data privacy laws in the jurisdictions in which we collect personal information of Applicants.

Applicants with disabilities may access this US Applicant Privacy Notice in an alternative format by contacting HRSupport@berlinpackaging.com.

Disclosure FOR CALIFORNIA RESIDENTS regarding the California consumer privacy act (NOTICE AT COLLECTION)

For information on our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (as amended from time to time) (“CCPA”), please see Annex A – Supplemental CCPA Privacy Notice.

CHANGES TO THE US APPLICANT PRIVACY NOTICE

We may update this US Applicant Privacy Notice from time to time in our sole discretion. If we do, we’ll let you know by posting the updated US Applicant Privacy Notice on our website, and/or we may also send other communications.

WHAT PERSONAL INFORMATION BERLIN PACKAGING COLLECTS

The personal information we may collect from Applicants includes:

- General HR Information. This may include personal information you submit to us in your CV or other documentation as part of your application with us.
  - - Examples: name, nickname or alias, postal address, phone number, unique personal identifier, online identifier, email address, date of birth, age, passport number, driver’s license number, Social Security number or other government-issued identification number, information that may be recorded on a resume/CV or application form (such as education history and employment history).
- Protected classification characteristics (as defined under California or federal law)
  - - Examples: Age, national origin, citizenship, marital status, gender (including sexual orientation, gender identity, gender expression).
    - We also collect optional demographic information such as race or ethnicity to help ensure we are building an equitable workplace.
    - If you interview remotely or on our premises, we may collect photographs and videos of you.
- Internet or other electronic network activity information
  - - Examples: your Internet protocol (IP) address, inferred location based on your IP address or activities, device identifiers associated with your computer or device.
- Audio or visual information
  - - We may collect audio and visual information such as through photographs used for identification purposes. You agree that Berlin Packaging (or our vendors) may record you if conducting interviews via a video conference call (e.g., Zoom).
- Professional or employment-related information
  - - Examples: employment history, information recorded on your resume/CV or application form, language abilities, professional qualifications.
    - We may collect or receive information about you from other sources, including through third-party services and organizations to supplement information provided by you. For example, where permitted by law, we may look at your publicly accessible social media pages (e.g., your LinkedIn profile) or conduct background and/or credit checks on you prior to your employment with Berlin Packaging. This supplemental information allows us to verify information that you have provided to Berlin Packaging.
- Education information
  - - Examples: Education history (as part of a resume/CV or application form).
- Inferences drawn from any of the personal information identified above to analyze your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
- Berlin Packaging may also collect personal information from Applicants as follows:
- Communications with Us. We may collect personal information, such as personal contact information and any personal information you use to contact us, when an Applicant communicates with us.
- Legal Information. We also collect contractual information, such as personal information necessary to comply with our legal and contractual obligations, exercise our legal and contractual rights, and initiate or respond to legal claims.
- Information from Other Sources. We may collect or receive information about you from other sources, including through publicly available sources (e.g., your LinkedIn profile) and through third-party services and organizations to supplement information provided by you. For example, where permitted by law, we may conduct background checks on you prior to your employment with Berlin Packaging or contact the references you provided to verify your previous work history and performance. This supplemental information allows us to verify information that you have provided to Berlin Packaging.
- Miscellaneous Information. We may receive or collect other miscellaneous information (for example, information you choose to disclose during the interview process, whether in verbal or written form, and opinions generated during the interview process).

Apart from personal information we directly collect from you, Berlin Packaging may collect personal information from you automatically and may also collect personal information about you from third-party sources. For example:

- Device Information. We may collect personal information about your device, such as your internet protocol (IP) address, user settings, cookie identifiers, other unique identifiers, browser or device information, Internet service provider, and location information (including, as applicable, approximate location derived from IP address and precise geo-location information) when you apply for a job through our Careers Site.
- Usage Information: We may collect personal information about your use of the Berlin Packaging Careers Site, such as the pages that you visit, items that you search for, the types of content you interact with, information about the links you click, the frequency and duration of your activities, and other information about how you use our website.
- CCTV Footage. If you visit our offices for an on-site interview, Berlin Packaging may monitor its premises using CCTV cameras and may capture your image.
- Cookie Notice (and Other Technologies). We, as well as third parties, may use cookies, pixel tags, and other technologies (“Technologies”) to automatically collect personal information through your use of the Careers Site.
  - - Cookies. Cookies are small text files stored in device browsers.
    - Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the Careers Site that collects personal information about use of or engagement with the Careers Site. The use of a pixel tag allows us to record, for example, that a user has visited, a particular web page or clicked on a particular advertisement. We may also include web beacons in emails to understand whether messages have been opened, acted on, or forwarded.

See “Your Privacy Choices and Rights” below to understand your choices regarding these Technologies.

HOW BERLIN PACKAGING USES YOUR PERSONAL INFORMATION

We process personal information for a variety of business purposes including:

- - To assess your suitability, aptitude, skills, qualifications, and interests for employment with Berlin Packaging;
  - To communicate with you about the application process and/or your application;
  - To take steps at your request prior to entering into an employment contract with you (for example, after we have sent you an offer, we need to process certain personal information in order to enter into and then perform the contract of employment);
  - To pursue our legitimate interests as a company (for example, improving our application or recruitment process, fraud prevention, enforcement of legal claims, and research purposes);
  - Human resources operations administration and communication;
  - Where it is necessary for the establishment, exercise, or defense of legal claims;
  - Diversity and inclusion initiatives;
  - To comply with our legal obligations;
  - Acquisitions, divestitures, and integrations; and
  - As you otherwise agree or consent.

HOW BERLIN PACKAGING DISCLOSES YOUR PERSONAL INFORMATION

We may disclose your personal information as described in this US Applicant Privacy Notice or with your permission.

Vendors and Service Providers. We may disclose any information we receive to our vendors and service providers. The types of service providers to whom we entrust personal information may include service providers for: (i) the provision of IT and related services; (ii) the provider of our job application platform; and (iii) processing for the purposes of verification or background checks.

Some of the service providers we may use include:

- - 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.
  - Hotjar (Session Replay Analytics). We use Hotjar’s session replay analytics services. This allows us to record and replay an individual’s interaction with the Careers Site. 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.

Building Management and Security. In some cases, we are required to disclose your personal information to building management and/or security at Berlin Packaging properties to facilitate your access to the building.

Affiliates and Subsidiaries. Berlin Packaging may disclose personal information to our corporate affiliates and subsidiaries for our and our affiliates’ and subsidiaries’ internal business purposes.

Disclosures to Protect Us or Others. We may access, preserve, and disclose your personal information if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal processes, such as court orders or subpoenas; (ii) protect your, our, or others’ rights, property, or safety; (iii) enforce our policies or contracts; (iv) collect amounts owed to us; or (v) assist with an investigation or prosecution of suspected or actual illegal activity.

Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, receivership, sale of Berlin Packaging assets, transition of service to another entity, or other similar corporate transaction, your information may be disclosed, sold, or transferred as part of such a transaction.

Advertising Partners. We may share your personal information with third-party advertising partners. These third-party advertising partners may set Technologies and other tracking tools on our Careers Site to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising”, “personalized advertising”, or “targeted advertising.”

YOUR PRIVACY CHOICES AND RIGHTS

Your Privacy Choices. The privacy choices you may have about your personal information are described below.

- Email Communications. If you receive an unwanted email from us, you can use the unsubscribe functionality found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails. We may also send you certain non-promotional communications regarding Berlin Packaging and the Careers Site, and you will not be able to opt out of those communications (e.g., communications regarding the Careers Site or updates to this US Applicant Privacy Notice).
- “Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
- Cookies. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, the Careers Site may not work properly.
- Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of certain tracking on some mobile applications by following the instructions for Android, iOS, and others.
- The online advertising industry also provides mechanisms that may allow you to opt out of receiving targeted ads from organizations that participate in self-regulatory programs. To learn more, visit the Network Advertising Initiative, the Digital Advertising Alliance, and the European Digital Advertising Alliance.
- Please note you must separately opt out in each browser and on each device.

Your Privacy Rights. In accordance with applicable law, you may have the right to:

- Confirm Whether Berlin Packaging Is Processing Your Personal Information (aka the “right to know”);
- Request Access to or Portability of Your Personal Information, including: (i) obtaining access to or a copy of your personal information; and (ii) obtaining an electronic copy of personal information that you have provided to us, or asking us to send that information to another company in a structured, commonly used, and machine readable format (also known as the “right of data portability”);
- Request Correction of Your Personal Information;
- Request Deletion of Your Personal Information;
- Request Restriction of or Object to Our Processing of Your Personal Information;
- Request to Opt-Out of Certain Processing Activities including, as applicable, if we process your personal information for “targeted advertising” (as “targeted advertising” is defined by applicable privacy laws), if we “sell” your personal information (as “sell” is defined by applicable privacy laws), or if we engage in “profiling” in furtherance of certain “decisions that produce legal or similarly significant effects” concerning you (as such terms are defined by applicable privacy laws).

If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.

Only you, or someone legally authorized to act on your behalf in certain jurisdictions, may make a request to exercise the rights listed above regarding your personal information. If your personal information is subject to a law that allows an authorized agent to act on your behalf in exercising your privacy rights and you wish to designate an authorized agent, please provide written authorization signed by you and your designated agent using the information found in “Contact Us” below and ask us for additional instructions.

To protect your privacy, we will take steps to verify your identity before fulfilling requests submitted under applicable privacy laws. These steps may involve asking you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. Examples of our verification process may include asking you to confirm the email address we have associated with you.

Some laws may allow you to appeal our decision if we decline to process your request. If applicable laws grant you an appeal right, and you would like to appeal our decision with respect to your request, you may do so by informing us of this and providing us with information supporting your appeal.

RETENTION OF PERSONAL INFORMATION

We store the personal information we collect as described in this US Applicant Privacy Notice for as long as necessary to fulfill the purpose(s) for which it was collected, carry out our human resources operations, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

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.

THIRD-PARTY WEBSITES/APPLICATIONS

Various resources and sites at Berlin Packaging may contain links to third party websites/applications and other websites/applications may reference or link to Berlin Packaging. These third-party services are not controlled by us. We encourage Applicants to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.

CONTACT US

If you have any questions about our privacy practices or this US Applicant Privacy Notice, or to exercise your rights as detailed in this US Applicant Privacy Notice, please contact us using the information set forth below:

Berlin Packaging LLC
525 W. Monroe Street
Chicago, IL 60661
Email: info@berlinpackaging.com
Toll Free Number: 1-800-223-7546

ANNEX A - SUPPLEMENTAL CCPA PRIVACY NOTICE

This Supplemental CCPA Privacy Notice supplements our US Applicant Privacy Notice and only applies to our processing of Applicants’ personal information that is subject to the CCPA.

Notice at Collection

At or before the time of collection, California residents have a right to receive notice of our privacy practices. California residents can find this information below.

- Personal Information Collected. See the section of this Supplemental CCPA Privacy Notice titled “Overview of Personal Information Collected, Disclosed, Sold and/or Shared” for a list of personal information that may be collected. If we have previously collected personal information in the past 12 months, we may collect that personal information from you.
- Uses of Personal Information. See the section of this Supplemental CCPA Privacy Notice titled “Uses of Personal Information” for a list of the purposes for which we use personal information.
- Is Personal Information “Sold” or “Shared” for “Cross-Context Behavioral Advertising”? Yes. We “share” your personal information with the third-party advertisers whose cookies are placed on the Careers Site. See the section of this Supplemental CCPA Privacy Notice titled “Overview of Personal Information Collected, Disclosed, Sold and/or Shared” for more details. If we have previously “sold” personal information or “shared” personal information for “cross-context behavioral advertising” in the past 12 months, we may “sell” or “share” that personal information if collected from you. See the section of this Supplemental CCPA Privacy Notice titled “Right to Opt Out of ‘Sales’ of Personal Information and/or ‘Sharing’ for ‘Cross-Context Behavioral Advertising’ for instructions on how to opt-out of these activities.
- How Long Is Personal Information Retained for? 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.
- Additional Information. For more information on our privacy practices, please review this Supplemental CCPA Privacy Notice and our US Applicant Privacy Notice. Importantly, the section of our US Applicant Privacy Notice titled “Your Privacy Rights” includes important details about how you can exercise some of the rights that you have under the CCPA.

CATEGORIES OF SOURCES FROM WHICH PERSONAL INFORMATION IS COLLECTED

We collect personal information that you provide to us, personal information we collect automatically when you use the Careers Site, and personal information from third-party sources.

Overview of Personal Information Collected, Disclosed, Sold, and/or Shared

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:

Category of Personal Information Collected by Berlin Packaging	Category of Third Parties to Whom Personal Information is Disclosed for a Business Purpose	Category of Third Parties To Whom Personal Information is Sold and/or Shared
Identifiers	Vendors and Service Providers Building Management and Security	Advertising Partner
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	Vendors and Service Providers Building Management and Security	Advertising Partner
Protected classification characteristics under California or federal law	Vendors and Service Providers Building Management and Security	N/A
Commercial information	Service Providers	Advertising Partner
Internet or other electronic network activity	Vendors and Service Providers	Advertising Partner
Sensory data	Vendors and Service Providers Building Management and Security	N/A
Professional or employment-related information	Vendors and Service Providers Building Management and Security	N/A
Inferences drawn from other personal information to create a profile about a consumer	Vendors and Service Providers	N/A
Personal information that reveals a consumer’s social security, driver’s license, state identification card, or passport number	Vendors and Service Providers Building Management and Security	N/A
Personal information that reveals a consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account	Vendors and Service Providers	N/A
Personal information that reveals a consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership	Vendors and Service Providers Building Management and Security	N/A
Personal information collected and analyzed concerning a consumer’s health	Vendors and Service Providers	N/A
Personal information collected and analyzed concerning a consumer’s sex life or sexual orientation	Vendors and Service Providers	N/A

USES OF PERSONAL INFORMATION

We may use and disclose the personal information that we collect for the following business and commercial purposes:

- Carrying out the purposes described in the Applicant Privacy Notice;
- Helping to ensure security and integrity to the extent the use of personal information is reasonably necessary and proportionate for these purposes;
- Debugging to identify and repair errors that impair existing intended functionality;
- Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of your current interaction with Berlin Packaging;
- Maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying Applicants’ information, providing analytic services, providing storage, or carrying out other business purposes;
- Undertaking internal research for technological development and demonstration.

RIGHT TO OPT OUT OF “SALES” OF PERSONAL INFORMATION AND/OR “SHARING” FOR “CROSS-CONTEXT BEHAVIORAL ADVERTISING”

We “sell” your personal information or “share” your personal information for “cross-contextual behavioral advertising” to provide you with “cross-context behavioral advertising” about Berlin Packaging’s products and services.

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 clicking on the “Do Not Sell or Share My Personal Information” link on our Careers Site and filling out the necessary information.

Disclosure Regarding Opt-Out Preference Signals

California residents may opt out of “sales” of personal information and “sharing” of personal information for “cross-context behavioral advertising” that are carried out on the Careers Site by broadcasting the opt-out preference signal known as the Global Privacy Control (GPC) (on the browsers and/or browser extensions that support such a signal). To download and use a browser supporting the GPC browser signal, visit the Global Privacy Control website. If you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use to visit the Careers Site.

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.”

Disclosure Regarding Sensitive Personal Information

Berlin Packaging only uses and discloses sensitive personal information for the purposes set forth in Section 7027(m) of the CCPA regulations:

- To perform the HR functions set forth in this Applicant Privacy Notice.
- 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 Berlin Packaging products, services, or devices, and to improve, upgrade, or enhance Berlin Packaging’s services or devices.
- To perform services on behalf of Berlin Packaging.
- 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.

Non-Discrimination

California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.