If you are an employee of Soft-Pak or as Environmental Solutions Group™ Affiliate, you should refer to the Employee Privacy Notice provided by your employer. If you are intending to apply for a job with us or to join our talent network, you should refer to the Privacy Notice on our Careers Portal.
- Who we are and contact details
- What personal data we collect
- What we do with the personal data we gather
- Data Sharing
- Lawful Bases
- Security and Confidentiality
- How long will we hold your personal data
- Transfers of personal data
- Links to other websites
- Rights to your personal data
- Persons under 16
- Any concerns?
1. WHO WE ARE AND CONTACT DETAILS
This is the website of:
8525 Gibbs Drive #300
San Diego, California 92123
You can contact us via e-mail at email@example.com or you can call us at 1-619-283-2338.
If you require this notice in an alternative accessible format, please contact us at 1-619-283-2338 or firstname.lastname@example.org.
2. WHAT PERSONAL DATA WE COLLECT
We collect the following personal data through the Soft-Pak website:
(i) Contact information — that is, information such as your full name, email address, mailing address, telephone number;
a. This information is collected on various forms on the website and is completely voluntary.
(ii) Information related to customer surveys, promotions, and/or offers (e.g., preferences, demographics, interests, etc.), and
(iii) Information about the device you use to access the Soft-Pak website (e.g. IP address)
3. WHAT WE DO WITH THE PERSONAL DATA WE GATHER
We use the personal data we gather about you for the following purposes:
(i) to understand your needs, provide you with a better service, and respond to your inquiries;
(ii) for internal record keeping;
(iii) for internal analysis to see how many unique visitors visit the Soft-Pak website;
(iv) to administer promotions, services (e.g., registration for webcasts, etc.) and offers which you register for;
(v) Subject to the provisions below, we will also use your personal data for other marketing-related purposes;
(vi) To improve the products and services offered through the Soft-Pak website, and
(vii) To measure the number of visitors to the Soft-Pak website and the areas of the website that are of most interest to visitors and to customize the Soft-Pak website.
We do not use the personal data that you provide through the Soft-Pak website to make automated decisions about you.
In the past 12 months, we have not sold your Personal Information to any other entity; and we do not and will not sell Personal Information to third parties.
We do not respond to browser / do not track signals.
To the extent permitted by applicable law, Soft-Pak may also use your personal data as we believe to be necessary or appropriate:
(i) under applicable law, including laws outside your country of residence;
(ii) to comply with legal process;
(iii) to respond to requests from public and government authorities including public and government authorities outside your country of residence;
(iv) to enforce our terms and conditions;
(v) to protect our operations or those of any of our affiliates;
(vi) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others, and
(vii) to allow us to pursue available remedies or limit the damages that we may sustain.
Where required by local law, we will obtain your prior consent:
(i) in order to send you marketing communications about Soft-Pak;
(ii) in order to provide your personal data to Soft-Pak Affiliates for their marketing purposes, and
(iii) in order to provide your personal data to third parties and other partners for joint marketing efforts or their own marketing efforts.
Please note that you always have the right to withdraw your consent.
Otherwise we may contact you by email, phone, fax, mail, or other means unless you direct us not to do so.
We may use your personal data for our own marketing purposes, including, but not limited to notifying you of new services, offers or other information via mail, email, telephone, text message, and other means.
If you do not want us to use your personal data for marketing purposes or to provide your personal data to Soft-Pak Affiliates or to third parties for their marketing purposes, you may opt-out of such uses by notifying us in accordance with the procedure set forth below under the heading, “Rights to your Personal Data.”
5. DATA SHARING
We may share your personal data with our affiliates (i.e., affiliated businesses and operating companies) (collectively, “Soft-Pak Affiliates”) in furtherance of the purposes set out in section 3 above.
We may share your personal data with third-party service providers (including contractors who provide services to us) to assist with any of the uses of personal data described above.
We may share or transfer your personal data to a third party if Soft-Pak enters into, or is involved in, a business transaction such as a merger, acquisition, reorganization, or sale of some or all of its assets.
6. LAWFUL BASES
Under the laws in the EU, we are required to identify the lawful bases for which we use your personal data. These are:
(i) Legitimate Interest — we have a legitimate interest in contacting you where you provide us with your details, to manage our relationship with you and to monitor and improve the use of the Soft-Pak website and to send you marketing communications.
(ii) Consent — where we are required by local law to collect consent in order to send you marketing communications
(iii) Compliance with a legal obligation — where we are required to collect and disclose your personal data because we are subject to a legal or regulatory obligation
We do not intend to collect any sensitive personal data (which is defined under EU law to include, for example, personal data on ethnicity, racial origin and health) through the Soft-Pak website.
Where we rely on the legitimate interest lawful basis to use your personal data, you always have the right to object to such use by contacting us using the details above.
Where we rely on your consent to use your personal data, you always have the right to withdraw your consent at any time by contacting us using the details above.
7. SECURITY AND CONFIDENTIALITY
We are committed to ensuring that your personal data is secure. In order to prevent unauthorized access or disclosure, we have put in place suitable physical, electronic, and managerial procedures to safeguard and secure the personal data we collect online. However, we are not able to guarantee the confidentiality of non-confidential data such as feedback, questions, comments or ideas that you voluntarily provide to us (e.g., via the “Contact” tab or similar features on the Soft-Pak website). We reserve the right to use and disclose such non-confidential information as we deem appropriate in compliance with applicable law.
There is no perfect security, and reasonable security is a process that involves risk management rather than risk elimination. While we are committed to developing, implementing, maintaining, monitoring, and updating a reasonable information security program, no such program can be perfect; in other words, all risk cannot reasonably be eliminated. Data security incidents and breaches can occur due to vulnerabilities, criminal exploits, or other factors that cannot reasonably be prevented. Accordingly, while our reasonable security program is designed to manage data security risks and thus help prevent data security incidents and breaches, it cannot be assumed that the occurrence of any given incident or breach results from our failure to implement and maintain reasonable security measures.
8. HOW LONG WILL WE HOLD YOUR PERSONAL DATA
We will retain your personal data for as long as:
(i) we have a relationship with you;
(ii) we are required by law, or
(iii) we need to in order to protect ourselves as a business or protect any other third party.
If you have any questions about our retention policy, please contact us using the details set out above.
9. TRANSFERS OF PERSONAL DATA
As a global organization, we will transfer your personal data across borders. Soft-Pak is based in the US although our Soft-Pak Affiliates are located in countries worldwide. Where a transfer of personal data across borders is required to comply with applicable laws, we will implement appropriate or suitable safeguards (such as EU Commission approved Standard Contractual Clauses) to protect that personal data. Please contact us using our details above should you require further information.
10. LINKS TO OTHER WEB SITES
11. RIGHTS TO YOUR PERSONAL DATA
Under certain laws, you have the right to seek access to your personal data, seek rectification or erasure of your personal data, restrict our use of your personal data, object to our use or request data portability. Please contact us if you wish to exercise any of these rights.
In any event, you can always ask us for more information about the people who will be able to see and access your personal data.
In accordance with applicable laws, you may choose to restrict the collection or use of your personal data by us by emailing us at email@example.com. This includes where you:
(i) have previously not objected to us using your personal data for our direct marketing purposes but now wish to opt-out of receiving future marketing emails from us;
(iii) do not want us to share your personal data with Soft-Pak Affiliates and/or our business (and other) partners for marketing purposes;
(iv) believe that personal data we are holding on you is incorrect or incomplete so that we can consider your concern and, where appropriate, we will promptly correct any personal data found to be incorrect. Or, you may contact us if you wish to review or change your personal data by using the “Contact” tab on our home page, or
(v) do not want to be contacted by us in the future (unless you initiate the contact).
Individuals who are residents of California have certain consumer rights under applicable California privacy laws, which are subject to certain limitations and/or restrictions. Specifically, under California law you may have the right to:
- Request that we disclose information about the personal information collected, used, disclosed, or sold;
- Request that we delete personal information collected or maintained by us;
- Opt-out of the sale of your personal information, if there are any sales of personal information; and
- Not receive discriminatory treatment for exercising your privacy rights.
Note that if you make such a request, we must verify your request before we can respond. Whenever feasible, we will match at least two data points in the identifying information provided by the consumer to the Personal Information already maintained by us, but it may require more data points depending on the information requested. We will avoid collecting highly sensitive pieces of personal information, unless necessary. If we cannot verify your identity, we may need to deny your request. We will generally respond within 45 days. A consumer may use an authorized agent to submit a request on the consumer’s behalf. When using an authorized agent, we require that you provide the authorized agent written permission to do so and verify their own identity and agent status with us. If you are placing a request on behalf of a household, we will need a verified request on behalf of each member of the household.
12. PERSONS UNDER 16
We do not knowingly collect or allow the collection of personal data from persons under the age of 16. If you are the parent or guardian of a person under the age of 16 and believe that the person has provided personal data to us, please contact us at firstname.lastname@example.org.
When you visit the Soft-Pak website, we may use “cookies” and similar technologies to help us recognize and serve you better. Cookies are small files that contain information sent by a website that is saved on your computer’s hard drive. You may delete cookies from your computer or set your browser to reject cookies. However, doing so may limit some functionalities of our site. Please see our Cookies Policy for more information about our use of these technologies on the Soft-Pak website. Learn more.
14. ANY CONCERNS?
You have the right to complain about our use of your personal data. Please contact us using the contact details set out above.
Depending on where you are located, you may also have a right to complain to your local data protection regulator.