“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.
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.
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 non-personal 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 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 submit a job application through the Platform.
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 Section 8 of this Policy.
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
- When legally permitted, 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
The information collected is necessary for the purposes set for above. Without this information, you may not be able to take advantage of some of our services.
How We Disclose Your Personal Information
We may share your information among our affiliates, subsidiaries, employees, service providers, contractors, or consultants so that they may perform their duties and so that we can provide you with our products and services.
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:
- Our Service Providers. We may share your Personal Information with third parties to the extent such information is necessary to deliver these services on our behalf (examples of these service providers include entities that process credit card payments, provide marketing services, and website optimization services).
- 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.
- Advertisers. 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.
- 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;
- 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
- 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 affiliates and service providers 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 will be subject to applicable foreign laws.
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, update or change your personal information, or 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 firstname.lastname@example.org. 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.
Subject to applicable law, you may also have the right to access and receive details about the personal information we maintain about you. You may access this right by contacting us as indicated above.
Cookies and Other Web Technologies
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 and to exercise your choice with respect to their collection on our Platform, please visit http://www.google.com/intl/en/analytics/privacyoverview.html.
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”) 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 email@example.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.
You may elect to receive text messages from us. When you sign up to receive text messages, we will send you information about promotional offers and more. These messages may use information automatically collected based on your actions while on our sites and may prompt messaging such as cart abandon messages (IE Cookies). 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 may opt out of receiving text messages at any time by texting “STOP” to our text messages. For more information about text messages, see our Terms and Conditions.
California Privacy Rights
If you are a California resident, California Civil Code Section 1798,83 permits you to, one time annually request certain information regarding the types of information we share with third parties for direct marketing purposes and the identities of those third parties. If you are a California resident, you may make such a request by sending an email to us at firstname.lastname@example.org write to us at the address listed in the “Contact Us” section of this Policy. In your request, please indicate that you are a California resident and that you are making a “Shine the Light” request. Please be aware that not all information sharing is covered under California Civil Code Section 1798.83.
In addition, pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), California residents have certain other rights concerning their personal information. This section describes (1) the categories of personal information, collected and disclosed by Berlin Packaging, subject to California privacy law, (2) your privacy rights under California privacy law, and (3) how to exercise your rights.
When we use the term “personal information” in this section, we mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
A. Personal Information we Collect.
If you are a California consumer, please be aware that we collect, process, and maintain personal information to fulfill certain business purposes related to our Platform. We will not collect additional categories of personal information or use personal information collected for additional purposes without providing you notice. Within the preceding twelve (12) months we and our service providers have and may collect, and you may consent to provide, the categories of personal information set forth below. We disclose each of these categories of personal information with our service providers for our business purposes (to enable the service providers to provide their services) and as otherwise described in the “How We Disclose Personal Information” section above.
- Identifiers (for example, name, postal address, date of birth, email address, IP address, and online identifiers);
- Categories of personal information as defined by Cal. Civ. Code § 1798.80 (for example, name, signature, Taxpayer Identification Number, telephone number, passport number, driver’s license number, insurance policy number, account numbers);
- Protected classifications under California or federal law (for example, age, citizenship status, national origin or ancestry);
- Commercial information (for example, transaction history);
- Internet or other electronic network activity information, including information on your usage of our Sites;
- Geolocation data;
- Sensory data (for example, audio from call recordings);
- Inferences drawn from any information identified above to create a profile
B. Your Privacy Rights.
In accordance with the CCPA, California consumers may exercise under certain conditions the following four (4) categories of privacy rights with respect to their personal information. Please note: you will not be discriminated against in any way by virtue of your exercise of the rights listed below, which means we will not deny goods or services to you, provide a different prices or rates for goods or services to you, or provide a different level or quality of goods or services to you.
|Notice||You have the right to be notified of what categories of personal information will be collected at or before the point of collection and the purposes for which they will be used and shared.|
|Access||You have the right to request the categories of personal information that we collected in the previous twelve (12) months, the categories of sources from which the personal information was collected, the specific pieces of personal information we have collected about you, and the business purposes for which such personal information is collected and shared. You also have the right to request the categories of personal information which were disclosed for business purposes, and the categories of third parties in the twelve (12) months preceding your request for your personal information.|
|Data Portability||You have the right to receive the personal information you have previously provided to us.|
|Erasure||You can request to have your personal information deleted from our servers and we will direct our service providers to do the same. However, please be aware that we may not fulfill your request for deletion if we (or our service provider(s)) are required to retain your personal information for one or more of the following categories of purposes: (1) to complete a transaction for which the personal information was collected, provide a good or service requested by you, or complete a contract between us and you; (2) to ensure our website integrity, security, and functionality; (3) to comply with applicable law or a legal obligation, or exercise rights under the law (including free speech rights); (4) to otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.|
C. How to Exercise Your Rights.
If you would like to exercise your rights listed above, please send (or have your authorized agent send) an email to email@example.com or call us toll-free at: 1-800-223-7546. You have a right not to receive discriminatory treatment by any business when you exercise your CCPA rights.
While we take measures to ensure that those responsible for receiving and responding to your request are informed of your rights and how to help you exercise those rights, when contacting us to exercise your rights, we ask you to please adhere to the following guidelines:
- Tell Us Which Right You Are Exercising: Specify which right you want to exercise and the personal information to which your request relates (if not to you). If you are acting on behalf of another consumer, please clearly indicate this fact and your authority to act on such consumer’s behalf;
- Help Us Verify Your Identity: Provide us enough information to verify your identity. For example, provide us (at a minimum) your full name and email address, and email address. Please note that if we cannot initially verify your identity, we may request additional information to complete the verification process. Any personal information you disclose to us for purposes of verifying your identity will solely be used for the purpose of verification.
- Direct Our Response Delivery: Inform us of the delivery mechanism with which you prefer to receive our response. You may specify, for example, email, mail, or through your account (if you have one with us).
Please note that you don’t need to create an account with us in order to make a request to exercise your rights hereunder.
D. How We Respond to Your Requests.
In all cases, we will respond to your request within 45 days. However, where reasonably necessary, we may extend our response time by an additional 45 days, provided we send you notice of such extension first. We will provide the information to you via your preferred delivery mechanism. If the information is provided to you electronically, we will provide you the information in a portable format and, to the extent technically feasible, in a machine readable, readily useable format that allows you to freely transmit this information without hindrance.
Please note that we will not charge you for making a request, provided that you make no more than two (2) requests per year. If you make three (3) or more requests in any given twelve (12) month period, we may refuse to respond to such requests, if determined by us to be unfounded or excessive (e.g. repetitive in nature), or we may charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested. If we refuse to act on the request, we will provide you notice and the reason for our refusal to act.
Our Platform is not directed to children under the age of 13 and we do not knowingly collect personal information from children. If you are under the age of 13, please stop using our Platform. It is our policy not to knowingly solicit or permit children under the age of 13 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 firstname.lastname@example.org. 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.
Protecting Your Data
We maintain appropriate administrative, technical and physical safeguards designed to protect the personal information you provide to us against accidental, unlawful or unauthorized access, alteration, loss, destruction, disclosure or use. Unfortunately, no security system is perfect, and we cannot promise that your personal information will remain secure in all circumstances, including the security of data on your mobile device.
We keep the information you provide to us 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 and protect our legal rights. 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.
Questions or Comments
Berlin Packaging L.L.C.
525 W. Monroe Street
Chicago, IL 60661