Effective and last updated date: January 1, 2023
If you are a California resident and a current or former employee, job applicant, or independent contractor of ours, please see our privacy notice available here for more information on our collection and use of your Personal Information in that capacity.
Notice at Collection of Personal Information
- Identifiers (name, postal address, online identifier, Internet Protocol address, email address).
- Unique personal identifiers (device identifier; cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology).
- Username and password (if you have an account with us).
- Telephone number.
- Internet or other electronic network activity information (i.e., actions you have taken in the applications on the platform, such as record creation, changes, input, responses, analysis, and approvals, and tickets filed on your behalf related to our platform).
- Commercial information (records of products or services purchased, obtained or considered)
- Professional or employment-related information (e.g., job title, company name, company size, company financial information).
- Visual information (i.e., video surveillance of our premises).
We collect Personal Information directly from California residents and from advertising networks, internet service providers, data analytics providers, business intelligence providers, and operating systems and platforms. We do not collect all categories of Personal Information from each source.
- Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
- Helping to ensure security and integrity to the extent the use of your Personal Information is reasonably necessary and proportionate for these purposes.
- Debugging to identify and repair errors that impair existing intended functionality.
- Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, or providing similar services.
- Advancing our commercial or economic interests, such as by inducing another person to buy goods or services, or enabling or effecting, directly or indirectly, a commercial transaction.
Sale, Sharing, and Disclosure of Personal Information
The CCPA defines “sale” as the transfer of Personal Information for monetary or other valuable consideration. Although we do not “sell” Personal Information as that term may be commonly interpreted, we engage in online activities that may constitute a sale or a share of Personal Information under California law. This may include showing you advertisements on other websites.
Category of Personal Information
Categories of Third Parties
Unique personal identifiers (device identifier; cookies, beacons, pixel tags, mobile ad identifiers)
Advertising networks and data analytics providers
We sold or shared Personal Information to third parties to advance our commercial or economic interests, such as by inducing another person to buy goods or services, or enabling or effecting, directly or indirectly, a commercial transaction.
Category of Personal Information
Categories of Recipients
Name, postal address, telephone number
Shipping companies; business partners to provide services to you; software as service providers; payment processors.
Internet Protocol address
Internet service providers.
Email service providers; marketing providers; software as a service providers.
We disclosed Personal Information for all business and commercial purposes described above.
We do not knowingly collect or sell or share the Personal Information of consumers under 16 years of age. We do not collect or process sensitive personal information for the purpose of inferring characteristics about individuals.
Retention of Personal Information
We retain your Personal Information for as long as necessary to fulfil the purposes for which we collect it, such as to provide you with the service you have requested, and for the purpose of satisfying any legal, accounting, contractual, or reporting requirements that apply to us.
If you are a California resident, you have the following rights with respect to your Personal Information:
- The right to know what Personal Information we have collected about you, including the categories of Personal Information, the categories of sources from which we collected Personal Information, the business or commercial purpose for collecting, selling or sharing Personal Information (if applicable), the categories of third parties to whom we disclose Personal Information (if applicable), and the specific pieces of Personal Information we collected about you;
- The right to delete Personal Information that we collected from you, subject to certain exceptions;
- The right to correct inaccurate Personal Information that we maintain about you;
- If we sell or share Personal Information, the right to opt out of the sale or sharing;
- If we use or disclose sensitive Personal Information for purposes other than those allowed by the CCPA and its regulations, the right to limit our use or disclosure; and
- The right not to receive discriminatory treatment by us for the exercise of privacy rights the CCPA confers.
How to Submit a Request to Know, Delete, and/or Correct
You may submit a request to know, delete, and/or correct through our interactive webform available here or by calling us toll free at 1-888-526-3723.
If you are submitting a request on behalf of a California resident, please submit the request through one of the designated methods discussed above. After submitting the request, we will require additional information to verify your authority to act on behalf of the California resident.
Our Process for Verifying a Request to Know, Delete, and/or Correct
We will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request. We will verify your identity either to a “reasonable degree of certainty” or a “reasonably high degree of certainty” depending on the sensitivity of the Personal Information and the risk of harm to you by unauthorized disclosure, deletion, or correction as applicable.
For requests to access categories of Personal Information and for requests to delete or correct Personal Information that is not sensitive and does not pose a risk of harm by unauthorized deletion or correction, we will verify your identity to a “reasonable degree of certainty” by verifying at least two data points that you previously provided to us and which we have determined to be reliable for the purpose of verifying identities.
For requests to access specific pieces of Personal Information or for requests to delete or correct Personal Information that is sensitive and poses a risk of harm by unauthorized deletion or correction, we will verify your identity to a “reasonably high degree of certainty” by verifying at least three pieces of Personal Information you previously provided to us and which we have determined to be reliable for the purpose of verifying identities. In addition, you must submit a signed declaration under penalty of perjury stating that you are the individual whose Personal Information is being requested.
Right to Opt Out of Sale or Sharing of Personal Information
If you are a California resident, you have the right to direct us to stop selling or sharing your Personal Information.
You may submit a request to opt out of sales or sharing through our interactive webform available by clicking on this link: “Do Not Sell or Share My Personal Information.” If you have enabled privacy controls on your browser (such as a plugin), we will also treat that as a valid request to opt out.
Shine the Light Law
We do not disclose personal data obtained through our websites to third parties for their direct marketing purposes. Accordingly, we have no obligations under California Civil Code § 1798.83.
How to contact us
Please contact us at 1-888-526-3723 or at email@example.com if you any questions or would like to exercise your privacy rights. You can also submit written inquiries to:
Orora Packaging Solutions
6600 Valley View Street
Buena Park, CA 90620, USA
We may update this policy from time to time. We will provide notice of any material changes to our Policy as required by law. We will also post an updated copy on our website. Please check our site periodically for updates.