California Privacy Policy

Effective and last updated date: January 1, 2023

The California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020 (“CCPA”), requires that we provide California residents with a privacy policy that contains a comprehensive description of our online and offline practices regarding the collection, use, disclosure, sale, sharing, and retention of personal information and of the rights of California residents regarding their personal information. This California Privacy Policy is intended solely for, and is applicable only as to, California residents. If you are not a California resident, this California Privacy Policy does not apply to you, and you should not rely on it.

The CCPA defines “personal information” to mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Personal information does not include publicly available, deidentified or aggregated information or lawfully obtained, truthful information that is a matter of public concern. For purposes of this California Privacy Policy, we will refer to this information as “Personal Information.”

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.

For more information as to our general privacy practices, please see our Privacy Policy.

Notice at Collection of Personal Information

We currently collect and, in the 12 months prior to the Last Updated Date of this California Privacy Policy, have collected the following categories 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.

In addition to the purposes stated above in the Section “Why do we collect and process personal data?” of our Privacy Policy, we currently collect and have collected the above categories of Personal Information for the following business or commercial purposes:

• • 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.

The following table identifies the categories of Personal Information we sold or shared to third parties in the 12 months preceding the last updated date of this California Privacy Policy and, for each category, the categories of third parties to whom we sold or shared Personal Information:

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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.

The following table identifies the categories of Personal Information we disclosed for a business purpose in the 12 months preceding the last updated date of this California Privacy Policy and, for each category, the categories of recipients to whom we disclosed Personal Information.

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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.

Your Rights

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 1-888-682-2807.

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.

Accessibility

We are committed to ensuring this privacy policy is accessible to individuals with disabilities. If you wish to access this privacy policy in an alternative format, please contact us as described below.

How to contact us

Please contact us at 1-888-682-2807 or at privacy@ororagroup.com if you any questions or would like to exercise your privacy rights. You can also submit written inquiries to:

Privacy Officer

Orora Packaging Solutions

6600 Valley View Street

Buena Park, CA 90620, USA

Privacy Policy Updates

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.