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EPL Limited Privacy Notice

Introduction

EPL Ltd., is the largest specialty packaging global company, manufacturing laminated plastic tubes catering to the FMCG and Pharma space. Employing over 2852 people representing 25 different nationalities, EPL Ltd. functions through 20 state of the art facilities and in eleven countries, selling circa 8 billion tubes and continuing to grow every year.

This Privacy Notice describes the usage of information provided or collected, disclosed or transferred of your information by EPL Ltd. and EPL Deutschland GmbH & Co. KG (hereinafter referred to as "EPL", “We”, “Us”, “Our”) and/ or its subsidiary (ies) and / or affiliate(s)(collectively referred to as the "Company"). We follow this privacy policy in accordance with applicable law in the places where we operate. In some cases, we may provide additional data privacy notices specific to certain services or regions.

It is important that you read this Privacy Notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are fully aware of how and why we are using your information. This Privacy Notice supplements the other notices and is not intended to override them.

What data is collected?

The following provides the types of personal information that we collect, use, store and transfer about you:

Context

Types of Data and Purpose for Collection

Customer Connect

We collect name, contact information like email, phone number and business specific information along with customer queries/messages for delivering our demo/support services.

Employment

If you apply for a job posting, or become an employee, we collect personal information necessary to process your application. This may include, your name, email, postal address, phone number, resume among others.

Data entered on the online application form of EPL Deutschland GmbH & Co. KG is processed on the basis of your consent (Art. 6 (1) a GDPR). You have the right to withdraw your consent regarding further processing of your data at any time. Any use or disclosure of your application data to third parties beyond this does not occur.

Feedback/Support

If you provide us feedback, require technical support, or if contact us for other assistance, we will collect your name and e-mail address, contact number and possibly other personal information, as well as any other content you send to us in order to reply.

Subscription

When you sign up for one of our mailing lists we collect your email address or postal address basis your sign up data provided.

Newsletter

If you subscribe to the Newsletter of EPL Deutschland GmbH & Co. KG, we collect your email address as well as information (first and last names) which allows us to verify that you are the owner of the email address supplied and consent to receiving the Newsletter.

Contact form

Data that you personally enter in our contact form (e.g. company, name, address, email address etc.) can be collected on the EPL Deutschland GmbH & Co KG website. This personal data, which is processed in the context of the contact form, is merely used for processing according to Art. 6 (1) b GDPR. There is no additional data processing or transmission. As soon as this data has fulfilled the purpose of the request and no further collection is necessary, this data is deleted. You can object to any further processing of your data at any time. Any further use of your contact data or disclosure to third parties does not occur.

Technical User Data

IP address, IP browser user agent, and other browser information such as browser location data received from GPS coordinates, browser fingerprints, etc., to deliver relevant website content to you.

How collected data is used?

 

Purposes and Lawfulness of processing

We will only collect, store and use personal data about you where we have lawful basis. Lawful basis on which we would store and use your personal information includes obtaining consent from you for "legitimate interests" or “legitimate purpose” where processing is necessary by us to provide you with services and/or business purpose. We use information to provide, analyse, administer, enhance and personalize our service and business efforts, to process your registration, to provide or obtain services, and to communicate with you related to below mentioned points. For example, we use information to:

  • Notify you about changes in terms of service or privacy policy
  • Allow you to participate in interactive features offered through our Services
  • Sharing with our customer support team to resolve your queries/concerns related to your

Information use by EPL

The Information supplied by you enables us to improve our services and provide you the most user-friendly experience(s). In some cases for e.g. provision of certain service(s) or utility (ies), we may require your contact information as well. All required information is service dependent and the Company may use the above said user Information to, maintain, protect, and improve the services provided.

Any personally identifiable information provided by you will not be considered as sensitive if it is freely available and / or accessible in the public domain like any comments, messages, blogs, scribbles available on social platforms like Facebook, Twitter, LinkedIn, etc.

Any posted / uploaded conveyed / communication by users on the public sections of the websites / social media pages/s" becomes published content and is not considered personally identifiable information subject to this Privacy Notice.

In case you choose to decline to submit personally identifiable information on the website, we may not be able to provide certain services on the website to you. We will make reasonable efforts to notify you of the same at the time of opening your account. In any case, we will not be liable and / or responsible for the denial of certain services to you for lack of you providing the necessary personal information.

When you register with our services, we may contact you from time to time about updating your personal information to provide you features that we believe may benefit / interest you.

Retention and Disposal of Personal Data

We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including the fulfillment of the contract, the initiation of a contract, or for the purposes of satisfying any legal, accounting, or other regulatory reporting requirements.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

We do not sell or distribute the personal information in general or marketing purpose. We collect, store and use the personal information for business and service purpose for which the same is intended and as referred in this Notice.

Your Rights

Access to Personal Data. You have the right to access, review and request a physical or electronic copy of information held about you. You also have the right to request information on the source of your Personal Data.

These rights can be exercised by sending us an e-mail at epl-deutschland@ifdds.de  by attaching a copy of your ID or equivalent details (where requested by us and permitted by law). If the request is submitted by a person other than you, without providing evidence that the request is legitimately made on your behalf, the request will be rejected. Please note that any identification information provided to us will only be processed in accordance with, and to the extent permitted by applicable laws.

Additional rights (e.g. modification, deletion of Personal Data). Where provided by law, you can (i) request deletion, correction or revision of your Personal Data; (ii) limit the use and disclosure of your Personal Data; and (iii) revoke consent to any of our data processing activities.

Please note that, in certain circumstances, we will not be able to delete your Personal Data without also deleting your user account. We may be required to retain some of your Personal Data after you have requested deletion, to satisfy our legal or contractual obligations. We may also be permitted by applicable laws to retain some of your Personal Data to satisfy our business needs.

We hope that we can satisfy queries you may have about the way we process your Personal Data. However, if you have unresolved concerns you also have the right to complain to competent data protection authorities.

Cookies/Similar Technologies, Log Files and Web Beacons

Cookies/Similar Technologies. We use cookies and basis the permission provided and we define the purposes for which we use them.

Logdateien. We collect information in the form of log files that record website activity and gather statistics about browsing histories. These entries are generated automatically, and help us to troubleshoot errors, improve performance and maintain the security of our Websites.

Web Beacons. Web beacons (also known as "web bugs") are small strings of code that deliver a graphic image on a web page or in an email for the purpose of transferring data back to us. The information collected via web beacons will include information such as IP address, as well as information about how you respond to an email campaign (e.g. at what time the email was opened, which links you click on in the email, etc.). We will use web beacons on our Websites or include them in e-mails that we send to you. We use web beacon information for a variety of purposes, including but not limited to, site traffic reporting, unique visitor counts, advertising, email auditing and reporting, and personalization. The detailed cookie policy is located here.

Children’s Privacy

EPL Limited is not intentionally designed for or directed at persons less than 18 years of age. EPL Limited does not knowingly permit any person who is under 18 years of age to register with the services or to provide any other personally identifying information. EPL Limited does not seek or intend to seek or receive any personal information from children. Should a parent or guardian have reasons to believe that a minor has provided EPL Limited with personal information without their prior consent, please contact our customer support team to ensure that the personal information is removed from the EPL Limited services.

Data Security

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used, or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and business associates who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach. In the event that we are required by law to inform you of any unauthorized access to your personal information we may notify you electronically, in writing, or if permitted by law, by telephone. We will also notify any applicable regulator of a breach where we are legally required to do so. However, no method of transmission over the Internet, or method of electronic storage, is fully secure.

We use and apply all reasonable efforts to protect your personal information from unauthorized access, use, or disclosure. However, we could not rule out seepage or breach which beyond control or human error or technology hindrance.

Data Transfer, Storage & Processing Globally

We operate globally and may transfer your personal information to individual companies of the EPL Limited affiliated companies or third parties in locations around the world for the limited purposes described in this privacy policy. Wherever your personal information is transferred, stored or processed by us, we will take reasonable steps to safeguard the privacy of your personal information. Additionally, when using or disclosing personal information transferred from the European Union, we use standard contractual clauses approved by the European Commission, adopt other means under European Union law for ensuring adequate safeguards.

Communication via Newsletter

EPL Deutschland GmbH & Co. KG only sends out Newsletters with the recipients’ consent. If you would like to receive the Newsletter offered on the website, we require your email address as well as information (first and last names) which allows us to verify that you are the owner of the email address supplied and consent to receiving the Newsletter. For subscriptions to our Newsletter, a so-called double opt-in procedure is used. This means that after subscribing via our website, you will receive an email in which we ask you to confirm your subscription. After confirmation has been received, only the email address is added to the mailing list. All subscriptions to the Newsletter are recorded for legal reasons. Stored are: subscription data, times of subscription, confirmation and cancellation, IP address as well as changes to the stored data.

You can withdraw the consent given to the data and the email address being stored as well as to these being used to send out the Newsletter. You will find a link at the end of every Newsletter to unsubscribe to the Newsletter. The lawfulness of data processing that already occurred prior to the withdrawal is not affected by this. The data supplied by you in order to receive the Newsletter is stored until you unsubscribe from the Newsletter and then deleted after the Newsletter has been cancelled.

The Newsletter is sent out by “CleverReach”, a company in Germany – CleverReach GmbH & Co. KG, Mühlenstrasse 43, 26180 Rastede. The data you entered in order to receive the Newsletter is stored on a CleverReach server in Germany or Ireland. CleverReach does not independently use the data, possibly to make contact, nor does it disclose the data to third parties. CleverReach is certified under the EU Data Protection Regulation “GDPR” and thus undertakes to comply with the EU data protection specifications. Furthermore, we have concluded an “Order Processing Contract” with CleverReach. CleverReach undertakes to protect our recipients’ data, to process it for us in accordance with their data protection provisions and especially, not to disclose it to third parties.

By sending out the Newsletter, we are able to analyze user behavior. The Newsletters contain a pixel-sized file called “web beacon” that is retrieved by the CleverReach server when the Newsletter is opened. In the context of this retrieval, technical information such as data about the browser and your system is collected first and then also your IP address and time of access.

Sending our Newsletter with CleverReach allows us to analyze the Newsletter recipients’ behavior. Amongst other things, this analysis can include whether the Newsletters are opened, when they are opened and which links are clicked. With the help of so-called conversion tracking, it is also possible to analyze whether a pre-defined action is performed after clicking the link in the Newsletter. Details about the data analysis by CleverReach are available at:https://www.cleverreach.com/de/funktionen/reporting-und-tracking/.

We would like to point out that the CleverReach websites use cookies and thus personal data is processed by CleverReach, their partners and service providers (e.g. Google Analytics). We have no influence on this data collection.

Additional information about the CleverReach data protection provisions are available at: https://www.cleverreach.com/de/datenschutz/ Legal basis: Art. 6 (1) a GDPR

Use of Matomo (formerly Piwik)

This EPL Deutschland GmbH & Co KG website uses the open source web analytics service Matomo, formerly Piwik, so that we can analyze the use of our website. Legal basis for the use of Matomo is your consent, Art. 6 (1) a GDPR. Matomo uses “cookies”. These are text files that are stored on your computer and make an analysis of the use of the website possible. In addition, the information on the use of this website generated by the cookie is stored on our server. The IP address is rendered anonymous before being stored.

The information generated by the cookie regarding the use of this website is not disclosed to third parties. You can prevent the storage of cookies with an appropriate setting of your browser software; however, we would like to point out that in this case you might not be able to fully use all the functions of this website. If you delete your cookies, this will mean that the Piwik opt-out cookie will also be deleted. Opt-out must then be reactivated at your next visit to our site.

You can decide whether a unique web analysis cookie may be stored on your browser to enable the operator of the website to collect and analyze various statistical data. If you would like to decide against this, click the following link so that the Matomo deactivation cookie is stored in your browser.

Your visit to this website is captured by Matomo web analysis in real time. Click here to stop your visit being captured.

Links to other websites

Our Website has links that redirects you to our social networking pages of Facebook, Twitter, LinkedIn, XING, Google +, and YouTube and other sites where we may have pages in future. These pages are hosted on separate sites that are governed by their own privacy policies. Please go through their privacy policies to get information on their Privacy Practices.

Changes to Privacy Notice

The internet is an ever evolving medium. We may alter our privacy policy from time to time to incorporate necessary changes in technology, applicable law or any other variant. In any case, we reserve the right to change (at any point of time) the terms of this Privacy Policy or the Terms of Use. Any changes we make will be effective immediately on notice, which we may give by posting the new policy on the “Site”. Your use of the Site or services offered through the Site after such notice will be deemed acceptance of such changes. We may also make reasonable efforts to inform you via electronic mail. In any case, you are advised to review this Privacy Policy periodically on the “Site”) to ensure that you are aware of the latest version.

Contact Us

Support
If you require any information or clarification regarding the use of your personal information or this privacy policy or grievances with respect to use of your personal information, please contact infosec@eplglobal.com

Complaints
If you have any queries, complaints regarding the collecting, processing, transfer of personal data/information or regarding this policy please do contact our Data Protection Officer. For EPL Deutschland GmbH & Co. KG is that:

Robert Schmock
Institut für Datenschutz und Datensicherheit
Strehlener Straße 14
01069 Dresden
Fon: +49 351 27 57 90 57
Email:epl-deutschland@ifdds.eu

Redressal Mechanism
Any complaints, abuse or concerns with regards to the processing of information provided by you or breach of these terms shall be immediately informed to the designated Grievance Officer as mentioned below via in writing or through email signed with the electronic signature to infosec@eplglobal.com

We request you to please provide the following information in your complaint:

  1. Identification of the information provided by you;
  2. Clear statement as to whether the information is personal information or sensitive personal information;
  3. Your address, telephone number or e-mail address;
  4. A statement that you have a good-faith belief that the information has been processed incorrectly or disclosed without authorization, as the case may be;
  5. A statement, under penalty of perjury, that the information in the notice is accurate, and that the information being complained about belongs to you;
  6. You may also contact us in case you have any questions / suggestions about the Privacy Policy using the contact information mentioned above.

EPL Limited shall not be responsible for any communication, if addressed, to any non-designated person in this regard.

Cookie-Policy

EPL Limited and EPL Deutschland GmbH & Co. KG (“we”, “us”, “EPL”) understands that your privacy is important to data subject (“you”, “your”, “user”, “subscriber”) and we are committed for being transparent about the technologies we use. This Cookie Policy explains how and why cookies and other similar technologies may be stored on and accessed from your device when you use or visit EPL Limited website or application that posts a link to this Policy (collectively, “the Sites”). This Cookie Policy should be read together with our Privacy Policy and Terms of Use.

What are cookies and Other Tracking Technologies?

A cookie is a small text file that a website saves on your computer or mobile device when you visit the site. It enables the website to remember your actions and preferences (such as login, language, font size and other display preferences) over a period of time, so you don’t have to keep re-entering them whenever you come back to the site or browse from one page to another. The other tracking technologies work similarly to cookies and place small data files on your devices or monitor your website activity to enable us to collect information about how you use our websites. This allows our websites to recognize your device from those of other users of the websites. The information provided below about cookies also applies to these other tracking technologies.

How do our sites use cookies and other tracking technologies?

We use cookies to collect and store information when you access our website and use other EPL Limited services. We use cookies for various purposes such as:

  • To provide you EPL Limited Services
  • To provide non-personalized or personalized advertisements
  • To identify your location
  • To identify your browser and device.
  • For analytics and research

Measure and analyze the audience for each page in order to subsequently improve the ergonomics, browsing, or visibility of content; Measure the reliability of Website by analyzing the number of visits to its pages in real time, and offer varied ads that are adapted to users’ areas of interest; Cookies may also be saved by social media tools if you use these functionalities (e.g. Facebook, Twitter).

Type of Cookies

„First-Party-Cookies“ these are the cookies that belong to us and which we place on your device or are those set by a website that is being visited by the user at the time (e.g., cookies placed by EPL Limited).

„Third-party cookies“ are cookies that another party places on your device through our site (For e.g. advertising agencies may place their cookies on our website which will collect tracking information and serve you with advertisements).

We use the following types of cookies

Persistent Cookies. We use persistent cookies to improve your experience of using the sites. This includes recording your acceptance of our Cookie Policy to remove the cookie message which first appears when you visit the site.

Session Cookies. Session Cookies are temporary and deleted from your machine when your web browser closes. We use session Cookies to help us track i­nternet usage as described above.

You may refuse to accept browser Cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of the Sites. Unless you have adjusted your browser setting so that it will refuse Cookies, our system will check if Cookies can be captured when you direct your browser to our Sites.

The data collected by the websites and/or through cookies that may be placed on your computer will not be kept for longer than is necessary to fulfill the purposes mentioned above. In any event, such information will be kept in our database until we get explicit consent from you to remove all the stored cookies.

We categorize cookies as follows

Strictly Necessary/Technical
These Cookies are necessary to allow us to operate our Sites so you may access them as you have requested. These Cookies, for example, let us recognize that you have created an account and have logged in/out to access Site content. They also include Cookies that enable us to remember your previous actions within the same browsing session and secure our Sites.

Analytical/Performance
These Cookies are used by us or third-party service providers to analyse how the Sites are used and how they are performing. For example, these Cookies track what content are most frequently visited, watch history and from what locations our visitors come from. If you subscribe to a newsletter or otherwise register with the Sites, these Cookies may be correlated to you. These Cookies include, for example, Google Analytics cookies, Matomo former Piwik, Comscore cookies.

Functionality
These Cookies let us operate the Sites in accordance with the choices you make. These Cookies permit us to “remember” you in-between visits. For instance, we will recognize your user name and remember how you customized the Sites and services, for example by adjusting text size, fonts, languages and other parts of web pages that are alterable, and provide you with the same customizations during future visits.

Targeting or Advertising Cookies
These cookies are used to deliver content that is more relevant to you and your interests. They are also used to deliver targeted advertising or limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaigns on EPL and other websites. They remember that you have visited one of our websites and this information is shared with other parties, including advertisers and our agencies. These cookies may also be linked to site functionality provided by third-parties such as Google DFP and Affinity. Do these cookies collect personal data/identify me? Most types of these cookies track consumers via their Device ID or IP address therefore they may collect personal data. Based on the type of cookies used by the relevant third-party, the information these cookies collect may include personal data but they would not be able to directly identify you as an individual or have any of your personal information such as Name, E-mail id or mobile number

Managing advertising cookies
Please note that if you want to opt out from receiving targeted advertising, this does not mean that you will receive less advertising when you use our Website. This just means that the advertising you see will not be as customized to you. However if you still want to switch off third-party advertising cookies, you can turn do this by visiting the Internet Advertising Bureau’s consumer advice site, Youronlinechoices.com This will give you a list of all cookies that are currently set on your device and how to opt out of each of them. For more information about and to opt out of interest based ads from many ad networks, go to: European Union: www.youronlinechoices.eu

How do I refuse or withdraw my consent to the use of Cookies?

If you do not want cookies to be dropped on your device, you can adjust the setting of your Internet browser to reject the setting of all or some cookies and to alert you when a cookie is placed on your device. For further information about how to do so, please refer to your browser ‘help’ / ‘tool’ or ‘edit’ section for cookie settings w.r.t your browser that may be Google Chrome, Safari, Mozilla Firefox etc.

Please note that if your browser setting is already setup to block all Cookies (including strictly necessary Cookies) you may not be able to access or use all or parts or functionalities of our Sites.

If you want to remove previously-stored Cookies, you can manually delete the Cookies at any time. However, this will not prevent the Sites from placing further Cookies on your device unless and until you adjust your Internet browser setting as described above.

For more information on the development of user-profiles and the use of targeting/advertising Cookies, please see www.youronlinechoices.eu if you are located in Europe or www.aboutads.info/choices if in the United States.

Cookie Consent Banner

You may see a “cookie banner” on our websites and dashboards. When you consent in this manner, we and our advertising partners may set advertising cookies on the site you are visiting and on other of our websites, dashboards, and services. We’ll display the banner to you periodically, just in case you change your mind.

Cookie Banner

WE RESPECT YOUR PRIVACY!!

We use cookies on our website performance to offer you the optimal website performance and user friendly experience. This includes cookies that are necessary for the operation of this site, as well as those that are collected for anonymous statistical purposes only. Further information about our use of cookies and the processing of your personal data can be found in our Privacy Policy. You decide which category you want to allow.