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This privacy policy describes the privacy practices of Orora Limited and its affiliates, subsidiaries, international and associated entities which includes but is not limited to (“Orora” “our,” “we”) for our websites (“Website”) or any website or mobile application that we own, operate or control that links to this Privacy Policy.

At Orora, we are committed to protecting your privacy and using your data carefully. In this policy, we outline what personal data we collect, why we collect it and what we do with it. Our goal is to make sure you know how we collect, use, share and store your personal data when you create an Orora account, interact with our customer support specialists and visit www.ororagroup.com or other Orora websites and apps covered by this privacy policy.

This Privacy Policy applies to our websites, mobile applications, marketing content, advertisements, and communications regarding Orora’s products and services. This Policy applies to anything we send to you (or a service provider sends acting on our behalf) on third-party websites, platforms and applications based on your site usage information. We encourage you to read the privacy policies of these third-party websites before using those websites.

In certain jurisdictions, including Australia, there are exemptions which apply to particular “employee records”. In such circumstances, Orora is not required to comply with relevant privacy laws in relation to such employee records. While Orora makes every effort to treat your personal information in accordance with this Privacy Policy, Orora is entitled to rely on any “employee records” or other exemptions available under applicable local laws.

What personal information?

The data we collect and process about you depends on who you are and how we interact with you. Personal information is data that identifies you or that makes you identifiable. It includes data that could be used to identify, locate, track or contact you.

If you are a customer, business partner, or express interest in our solutions:
If you visit the websites and online properties we provide:

We process personal information about you that we collect either directly, through forms or data entry fields on our website, or through passive collection by cookies and other data collection technologies. The types of personal data we collect and process in each of these contexts is further explained in the following four categories:

If you are an employee, contractor, job applicant, temporary hire or former employee:

We will not collect, use or disclose sensitive information about you unless it is necessary to operate our business and we have your consent or unless we are legally required to collect, use or disclose that information. Sensitive information includes any information about a person’s race, ethnic origin, political opinions, religious or philosophical beliefs or affiliations, membership of a professional, trade or political association or union, sexual preferences or practices, criminal record, health information or genetic information about an individual that is not otherwise health information.

We also operate video surveillance devices in our premises and may monitor and record your communications with us (including email and telephone) for legitimate business and security purposes.

Why do we collect and process personal information?

The reasons that we collect and process information about you depends on who you are and how we interact with you.

If you are a customer, business partner, or express interest in our solutions:

If you have a contract or other agreement in place with us, we collect and process personal information about you in order to fulfil the following obligations to you under that contract or agreement to:

Our legitimate interests: We process personal information about you based on our legitimate business interests, including for the following purposes, to which you may exercise Your Rights to object as described below:

Statistical and research purposes: We may further analyse use of our solutions, and characteristics of the companies that use our solutions (e.g., by size and industry sector) to help us understand and make decisions about customer and market needs, to improve our solutions, to design new solutions, and to inform partnership and business development decisions.

If you visit the websites and online properties we provide:

If you have provided your consent, we process personal information about you to:

You may withdraw your consent at any time by clicking the “unsubscribe” link in the email communications we send to you. You may also withdraw consent by exercising Your Rights as described below, including through our rights management solution.

Our legitimate interests: We process personal information about you based on our legitimate business interests, including for the following purposes, to which you may exercise Your Rights to object as described below:

Statistical and research purposes: We may further analyse information we gather online to improve the online experience and resources we provide to our users

If you are an employee, contractor, job applicant, temporary hire or former employee:

If you have a contract or other agreement with us, we process personal information about you to fulfil the specific obligations we have to you under the applicable contract or agreement such as:

Our legitimate interests: we process personal information about you based on our legitimate interests, including to establish and manage our relationship with and responsibilities to you and for effective operation of our business, such as to:

Statistical and research purposes: We may further analyse information to evaluate and understand employee engagement and to develop plans to continuously improve our workplace culture.

How do we protect your personal data?

We take the security of your personal data very seriously. Accessing your personal data is only permitted among our team members on a need-to-know basis and subject to strict contractual confidentiality obligations when processed by third-parties.

International Data Transfers

If you are accessing our websites from outside the United States of America, please note that your data may be transferred to, stored or processed in the United States. We do take steps to protect your privacy and afford the rights to opt-in, request changes to or delete your data. However, please note that by accessing our websites you consent to the transfer of your information to our data processing facilities and third-party tools that we utilize as described throughout this Privacy Policy.

We may transfer, access, or store personal information about you outside of your country.  This may include but is not limited to, transferring, accessing, or storing personal information about you outside the European Economic Area (“EEA”), Switzerland, Australia, New Zealand,  Mexico, Canada, the United States or another country that requires legal protections for international data transfer. When we do, we will ensure that an adequate level of protection is provided for the information by using one or more of the following approaches:

How do we share data about you?

At Orora, we only share personal information in ways that we tell you about.

We do not sell or rent personal information to third parties and we do not share personal information with third parties that are not owned by us or under our control or direction except as described in this Policy.

Keeping and Securing Your Data

We will keep personal information about you for as long as we provide solutions to you, as long as you work for or with us, or as long as we are addressing a concern, question, complaint, or request you have made to us, as applicable to our interactions with you. If we have a contract or other agreement with you, we will follow the retention obligations of that agreement.

We may keep data longer if we have a legal obligation to keep it or to maintain necessary records for legal, financial, compliance, or other reporting obligations, and to enforce our rights and agreements. We also may keep data about you for statistical analysis or research purposes.

We take appropriate security measures to protect personal information against loss, misuse, and unauthorized access, alteration, disclosure or destruction. We also have implemented measures to maintain the ongoing confidentiality, integrity and availability of the systems and services that process personal information, and will restore the availability and access to data in a timely manner in the event of a physical or technical incident.

What are your rights?

You have the right to object to certain uses of your personal data.  To exercise those rights, please contact us at the relevant address below. You have rights under privacy and data protection laws related to the data we process about you. You do not have to pay a fee, and we will aim to respond to your request within 30 days, unless otherwise stated in this Policy or required by law. We will honour the requests you make related to your rights as the relevant regional law allows, which means in some cases there may be legal or other official reasons that we may not be able to address the specific request you make related to your rights. Subject to applicable regional laws, you may have the:

California residents may additionally:

Orora will not discriminate against anyone who exercises their legal rights.

Privacy for Children

Orora is committed to protecting the privacy of children. Our websites are intended for use by adults. We do not knowingly collect information about children or sell products to children. If you are a child, we kindly ask that you do not use our website. If we discover that we have collected personal data from a child, we will delete that data as soon as we are able.

How to contact us about your information or request to opt-out

If you wish to obtain access to your personal information held by us, or to request us to correct any errors in that information, please contact us by:

United States

Please contact us at 1-888-526-3723 or at privacy@ororagroup.com if you any questions or would like to review, access, delete, correct or update your personal information. You can also submit written inquiries to:

Privacy Officer
Orora Packaging Solutions
6600 Valley View Street
Buena Park, CA 90620, USA

Australia

Please contact us at +61 3 9811 7111 or at privacy@ororagroup.com if you any questions or would like to, access, delete, correct or update your personal information. You can also submit written inquiries to:

Privacy Officer
Orora Limited
109 Burwood Road
Hawthorn, Victoria 3122, Australia

If you are not satisfied with how Orora has dealt with your enquiry, you may contact the Office of the Australian Information Commissioner at enquiries@oaic.gov.au or by calling 1300 363 992.

New Zealand

Please contact us at +61 3 9811 7111 or at privacy@ororagroup.com if you any questions or would like to, access, delete, correct or update your personal information. You can also submit written inquiries to:

Privacy Officer
Orora Packaging New Zealand Limited
239 Cavendish Drive
Manukau, New Zealand

If you are not satisfied with how Orora has dealt with your enquiry, you may contact the Office of Privacy Commissioner at investigations@privacy.org.nz or by calling 0800 803 909.

European Economic Area

The nominated Representative for data protection matters within the European Union is:

Email

privacy@ororagroup.com

Privacy Officer
Orora Landsberg
15 Hill Street Edinburgh
EH2 3JP UK

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.

This Privacy Policy was last updated January, 2020.