Introduction

This privacy policy (“Policy”) describes how Emerald Packaging (“we”, “us” or “our”) collects, protects, and uses the personally identifiable information (“Personal Information”) you (“User”, “you” or “your”) may provide on the website and any of its products or services (collectively, “Website” or “Services”).

It also describes the choices available to you regarding our use of your Personal Information and how you can access and update this information. This Policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage.

This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).

The California Consumer Privacy Act of 2018 (“CCPA”) is a California law that gives California consumers the right to learn about and control certain aspects of how a business handles the personal information that a business collects about them.

In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning Services or the collection and processing of Personal Data upon request.

The information collected through our website will be under the responsibility and charge of:

 Website Details:

This policy concerns all users of the website

Information We Collect

Collection & Processing of Personal Information

You can choose not to provide us with certain information, but then you may not be able to take advantage of some of the website’s features. Users who are uncertain about what information is mandatory are welcome to contact us.

We and our Third Parties/Service Providers may have collected and processed the following categories of Personal Information about you in the preceding 12 months:

Types of Personal Information

Personal identifiers

  • IP addresses,
  • contact numbers
  • Beacons
  • Referral URLs
  • cookies
  • Email
  • Name

Protected classified information

  • gender
  • age

Geolocation data

  • City
  • Country

Other

  • Personal information classifications contained in the California Customer Records Statute
  • Inferences made from profiling
  • Professional information
  • Website usage information

Sources of Personal Information

We collect personal information directly from our users and from our web interactions with them. Here are the primary sources from which we collect this information:

  • Consumer-Provided Information:
    • This includes any information provided directly by you, the consumer. This could be through forms such as newsletters, enquiry forms and job applications, or any other direct interactions you have with us or our website.
  • Cookies and Web Analytics:
    • We use cookies and related technologies to collect information about your use of our website and to distinguish you from other users. For more information about our use of these technologies, please see our Cookie Policy.

How We Use Your Information

Any of the information we collect from you may be used to personalize your experience; improve our website; improve customer service and respond to queries and emails of our customers; send newsletters; send notification emails such as password reminders, updates, etc; run and operate our Website and Services.

Non-Personal Information collected is used only to identify potential cases of abuse and establish statistical information regarding website usage. This statistical information is not otherwise aggregated in such a way that would identify any user of the system.

We may process Personal Information related to you if one of the following applies: (i) You have given your consent for one or more specific purposes. Note that under some legislations we may be allowed to process information until you object to such processing (by opting out), without having to rely on consent or any other of the following legal bases below.

This, however, does not apply, whenever the processing of Personal Information is subject to European data protection law; (ii) Provision of information is necessary for the performance of an agreement with you and for any pre-contractual obligations thereof; (iii) Processing is necessary for compliance with a legal obligation to which you are subject; (iv) Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in us; (v) Processing is necessary for the purposes of the legitimate interests pursued by a third party or by us.

In any case, we will be happy to clarify the specific legal basis that applies to the processing, and whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Non-personal User Data is also collected for advertising and analytics purposes.

Some of the reasons why businesses collect information include;

  • Identification and verification
  • Customising experiences for consumers
  • Internal operations
  • Product and service development
  • Recruit and evaluate job applicants and candidates for employment.
  • Marketing and advertising
  • To respond to user questions and requests
  • To send users samples, premiums, products and information
  • Legal compliance
  • Data Profiling
  • Communicating with consumers
  • Perform workforce analytics, data analytics, and benchmarking.
  • Otherwise accomplish our business purposes and objectives.
  • Categories of Information Disclosed for Business Purposes

The CCPA requires you to list user information categories shared for business reasons in the previous year.

Section 1798.140 of the CCPA clarifies activities considered ‘business purposes.’ They include;

  • Debugging to establish and rectify errors
  • System Logs and Maintenance
  • Exercise and defend legal claims
  • Internal research for technological development and demonstration
  • Service delivery
  • Short-term uses
  • Manage and monitor employee access to company facilities, equipment, and systems.
  • Conduct internal audits and workplace investigations.
  • Investigate and enforce compliance with and potential breaches of Company policies and procedures.
  • Engage in corporate transactions requiring review of employee records, such as for evaluating potential mergers and acquisitions of the Company.
  • Maintain commercial insurance policies and coverages, including for workers’ compensation and other liability insurance.
  • Administer and maintain the Company’s operations, including for safety purposes.
  • During a merger or acquisition
  • For client marketing purposes.
  • Exercise or defend the legal rights of the Company and its employees, affiliates, customers, contractors, and agents.
  • Operate, manage, and maintain our business.
  • Perform accounting, audit, and other internal functions, such as internal investigations.
  • Comply with laws and regulations, including (without limitation) applicable tax, health and safety, anti-discrimination, immigration, labour and employment, and social welfare laws
  • Monitor, investigate, and enforce compliance with and potential breaches of Emerald Packaging’s policies and procedures and legal and regulatory requirements;
  • Comply with civil, criminal, judicial, or regulatory inquiries, investigations, subpoenas, or summons; and
  • Exercise or defend the legal rights of Emerald Packaging and its employees, affiliates, customers, contractors, and agents.

How We Share Your Information

Categories of Personal Information Shared with Third Parties: As a business compliant with the California Consumer Privacy Act (CCPA), we believe in transparency and the importance of informing our users about their personal information that we share. We disclose the categories of personal information that we have shared with third parties over the past 12 months, the reasons for sharing it, and the third parties with whom we have shared it.

Categories of Personal Information Shared: The personal information we might share with third parties includes, but is not limited to, your device location, gender, age, name, address, email,  job title, number, location ,session data, web activity, user demographics, interests, device and browser information, IP address, user behaviour data, site search data, referral source, event tracking, and conversion data.

Purpose for Sharing: We share this information with the intent of monitoring user activity, enhancing user experience, benchmarking, improving our services, conducting insightful data analysis, and other business purposes.

Third Parties with Whom Information is Shared:

  • External Web Developer: We engage the services of an external web developer to manage our website. This third party has access to certain personal data like name, address, job title, city, number, and email from our enquiry forms. Their sole purpose is to enhance our website’s functionality. They’re bound to not disclose or misuse this data.
  • Contractors: We also share personal information with international contractors who perform data analysis services on our behalf. This includes comprehensive data from Google Analytics and Google Search Console such as user demographics, interests, device and browser information, IP address, user behavior data, site search data, referral source, event tracking, and conversion data. These contractors are provided with the information they need to perform their functions and are not permitted to share or use such information for any other purposes. All data and information used for analytics purposes is aggregated so that  the user’s identity cannot be identified.

Our commitment is to respect and protect your privacy. We assure you that the sharing of personal information is performed solely to improve our business operations and to provide you with our services.

Emerald Packaging does not sell consumer personal information.

Your California Privacy Rights

As a consumer, under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA), you have several rights regarding your personal information. These include:

  1. Right to Know: You have the right to request that we disclose what personal information we collect, use, disclose, and sell about you.
  2. Right to Delete: A consumer may request that Emerald Packaging delete the consumer’s information. We will delete this information upon request unless the request to delete falls within one of the exceptions listed in CCPA 1798.105. (d). The consumer may send a request via our contact form. Our contact information can be found at the bottom of this page.
  3. Right to Opt-Out: You have the right to direct us not to sell your personal information. For consumers under the age of 16, we will not sell personal information unless we receive affirmative authorization.
  4. Right to Non-Discrimination: We will not discriminate against you for exercising your CCPA rights. This means we will not deny you goods or services, charge you different prices or rates, provide a different level or quality of goods or services, or suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
  5. Right to Correct (CPRA): You have the right to request that we correct inaccurate personal information held about you.
  6. Right to Data Portability (CPRA): You have the right to request specific pieces of personal information that we have collected about you in a format that is easily used and shared.
  7. Right to Restrict Use of Sensitive Personal Information (CPRA): You have the right to direct us to limit the use of your sensitive personal information.

Some information may remain in our private records after your deletion of such information from your account. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally. Once the retention period expires, Personal Information shall be deleted.

Therefore, the right to access, the right to erasure, the right to rectification, and the right to data portability cannot be enforced after the expiration of the retention period.

What information may a consumer request?

A consumer may request: (1) the categories of personal information the business has collected about them; (2) the sources from which the personal information is collected; (3) the business or commercial purpose for collecting personal information; (4) the categories of third parties with whom the business shares the personal information; and (5) the specific pieces of personal information it has collected about that consumer.

Emerald Packaging does not sell consumer personal information.

How to Exercise Your Rights

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner, or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to Exercise These Rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

Opting out of certain services

Newsletters opt out

We offer electronic newsletters to which you may voluntarily subscribe at any time. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails or by contacting us. However, you will continue to receive essential transactional emails.

Push Notifications

We use push notifications to send you notifications related to our website. We will only use push notifications if you consent to receive them. At any time, you can manage your push notification preferences or deactivate them in the notification settings of your browser or in the Device Settings of your mobile device.

Google Remarketing Tag

You can opt out of Google Marketing Platform’s use of cookies by visiting the Google Marketing Platform opt-out page or the Network Advertising Initiative opt-out page.

What will Emerald Packaging do after receiving an information request?

Upon receipt of a verifiable consumer request, we will promptly take steps to disclose and deliver, free of charge to the consumer, the personal information. We will endeavour to provide the information within 45 days of the request.

Retaining Personal information

We retain the information collected from our users as long as it’s required to satisfy business needs or adhere to legal obligations, resolve disputes, and enforce our agreements. A significant portion of this data, particularly from website visitors, is collated into aggregate form, providing a layer of anonymity to individual users.

Children’s Privacy

We do not knowingly collect any Personal Information from children under the age of 13. If you are under the age of 13, please do not submit any Personal Information through our website or Service.

We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide Personal Information through our website or Service without their permission.

If you have reason to believe that a child under the age of 13 has provided Personal Information to us through our website or Service, please contact us. You must also be at least 16 years of age to consent to the processing of your personal data in your country (in some countries we may allow your parent or guardian to do so on your behalf).

Third-Party Websites/Services

Do Not Track Signals

Some browsers incorporate a Do Not Track feature that signals to websites you visit that you do not want to have your online activity tracked. Tracking is not the same as using or collecting information in connection with a website.

For these purposes, tracking refers to collecting personally identifiable information from consumers who use or visit a website or online service as they move across different websites over time.

Our website does not track its visitors over time and across third-party websites. However, some third-party services that we use may keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you.

To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Cookies

The website uses “cookies” to help personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer.

Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you. We may use cookies to collect, store, and track information for statistical purposes to operate our website and Services.

To learn more about cookies and how to manage them, visit internetcookies.org.

Visit this link to read our Cookie Policy.

Links to Other Websites

Our website contains links to other websites that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of such other websites or third parties.

We encourage you to be aware when you leave our website and to read the privacy statements of each website that may collect Personal Information.

Security of Your Information

Information Security

We secure the information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure. We maintain reasonable administrative, technical, and physical safeguards to protect against unauthorized access, use, modification, and disclosure of Personal Information in its control and custody.

However, no data transmission over the Internet or wireless network can be guaranteed. Therefore, while we strive to protect your Personal Information, you acknowledge that (i) there are security and privacy limitations of the Internet which are beyond our control; (ii) the security, integrity, and privacy of any and all information and data exchanged between you and our website cannot be guaranteed; and (iii) any such information and data may be viewed or tampered with in transit by a third party, despite best efforts.

 Data Breach

In the event, we become aware that the security of the website has been compromised or users Personal Information has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with law enforcement authorities.

In the event of a data breach, we will make reasonable efforts to notify affected individuals if we believe that there is a reasonable risk of harm to the user as a result of the breach or if notice is otherwise required by law. When we do, we will post a notice on the website, and send you an email.

Information Transfer and Storage

Depending on your location, data transfers may involve transferring and storing your information in a country other than your own. You are entitled to learn about the legal basis of information transfers to a country outside the European Union or to any international organisation governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by us to safeguard your information

If any such transfer takes place, you can find out more by checking the relevant sections of this document or inquiring with us using the information provided in the contact section.

Changes to This Privacy Policy

This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).

We reserve the right to modify this Policy relating to the website or Services at any time, effective upon posting of an updated version of this Policy on the website. When we do, we will revise the updated date at the bottom of this page. Continued use of the Website after any such changes shall constitute your consent.

We commit to updating our Privacy Policy in compliance with the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA) rules at least once every 12 months.

Acceptance of This Policy

You acknowledge that you have read this Policy and agree to all its terms and conditions. By using the website or its Services you agree to be bound by this Policy. If you do not agree to abide by the terms of this Policy, you are not authorized to use or access the Website and its Services.

Owner and Data Controller