Privacy Policies

Notice of Collection of Information for California Employees and/or Applicants

C-P Flexible Packaging, Inc.

Updated February 20, 2023

This Notice provides information required under the California Consumer Privacy Act of 2018 and California Privacy Rights Act of 2020 (collectively, the “CCPA”). The Notice provides information about CP’s (“we,” “us,” “our”) practices regarding the collection, use, and disclosure of Personal Information about you (for example, employees, independent contractors, job applicants) when you interact with us in an employment-related capacity.

A. Definitions

Personal Information: As used in this Policy, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or household. Personal Information includes Sensitive Personal Information.

Sensitive Personal Information: As used in this Policy, “Sensitive Personal Information” includes Personal Information that reveals, among other things, social security number, driver’s license number, state identification card number, passport number, racial or ethnic origin, union membership, or the contents of a Consumer’s mail, email, and text messages, unless CP Flexible Packaging, Inc is the intended recipient of the communication. Sensitive Personal Information also includes information concerning the Applicant or Employee’s health, sex life, or sexual orientation.

“Service Providers” and “Third Party” have the meanings afforded to it in the CCPA.

To the extent other terms used in this Notice are defined terms under the CCPA, they shall have the meanings afforded to them in those statutes, whether or not capitalized herein.

B. Collection & Processing of Personal Information

We and our Third Parties/Service Providers may have collected and processed the following categories of Personal Information about you in the preceding 12 months:

Identifiers, such as name, email address, accounts number, Social Security number (“SSN”), driver’s license number, passport number or similar identifier;
Financial information, medical information, health insurance information;
Characteristics of protected classifications under state or federal law, such as age, gender, race, physical or mental health conditions, and marital status;
Commercial information, such as transaction information and purchase history;
Biometric information;
Internet or other electronic network activity information, such as browsing history and interactions with our websites or advertisements;
Geolocation data, such as device location;
Audio, electronic, visual and similar information, such as call and video recordings;
Professional or employment-related information, such as work history and prior employer;
Education information, as defined in the federal Family Educational Rights and Privacy Act, such as student records and directory information; and
Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s preferences, characteristics, trends, abilities, and aptitudes.
Sensitive Personal Information, including:
- Personal Information that reveals:
  - - Social security, driver’s license, state identification card, or passport number;
    - Account log-in, financial account number, debit card number, or credit card number in combination with any required security or access code, password, or credentials for allowing access to an account;
    - Precise geolocation;
    - Racial or ethnic origin, religious or philosophical beliefs, or union membership;
    - Contents of a Consumer’s email and text messages, unless the business is the intended recipient thereof; or
- Biometric data processed for the purpose of uniquely identifying a Consumer;
- Personal Information Collected and analyzed concerning a Consumer’s health.

C. Categories of Personal Information We Disclose to our Service Providers/Third Parties

We may disclose the following categories of Personal Information to our Service Providers/Third Parties:

Identifiers, such as name, email address, accounts number, Social Security number (“SSN”), driver’s license number, passport number or similar identifier;
Financial information, medical information, health insurance information;
Characteristics of protected classifications under state or federal law, such as age, gender, race, physical or mental health conditions, and marital status;
Commercial information, such as transaction information and purchase history;
Biometric information;
Internet or other electronic network activity information, such as browsing history and interactions with our websites or advertisements;
Geolocation data, such as device location;
Audio, electronic, visual and similar information, such as call and video recordings;
Professional or employment-related information, such as work history and prior employer;
Education information, as defined in the federal Family Educational Rights and Privacy Act, such as student records and directory information; and
Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s preferences, characteristics, trends, abilities, and aptitudes.
Sensitive Personal Information, including:
- Personal Information that reveals:
  - Social security, driver’s license, state identification card, or passport number;
  - Account log-in, financial account number, debit card number, or credit card number in combination with any required security or access code, password, or credentials for allowing access to an account;
  - Precise geolocation;
  - Racial or ethnic origin, religious or philosophical beliefs, or union membership;
  - Contents of a Consumer’s email and text messages, unless the business is the intended recipient thereof; or
- Biometric data processed for the purpose of uniquely identifying a Consumer;
- Personal Information Collected and analyzed concerning a Consumer’s health.

D. Sources From Which We Collect Applicant and Employee Personal Information

We collect Personal Information from:

Applicants and Employees when they complete recruiting and employment forms;
Service Providers and Third Parties that help us screen and onboard individuals for hiring purposes, and when they share the information with us.

E. Purposes for Processing Personal Information

We and our Service Providers and Third Parties collect Personal Information to use or disclose as appropriate to:

Comply with all applicable laws and regulations.
Recruit and evaluate job applicants and candidates for employment.
Conduct background checks.
Manage your employment relationship with us, including for:
- onboarding processes;
- timekeeping, payroll, and expense report administration;
- employee benefits administration;
- employee training and development requirements;
- the creation, maintenance, and security of your online employee accounts;
- reaching your emergency contacts when needed, such as when you are not reachable or are injured or ill;
- workers’ compensation claims management;
- employee job performance, including goals and performance reviews, promotions, discipline, and termination;
- other human resources purposes
Manage and monitor employee access to company facilities, equipment, and systems.
Conduct internal audits and workplace investigations.
Investigate and enforce compliance with and potential breaches of Company policies and procedures.
Engage in corporate transactions requiring review of employee records, such as for evaluating potential mergers and acquisitions of the Company.
Maintain commercial insurance policies and coverages, including for workers’ compensation and other liability insurance.
Perform workforce analytics, data analytics, and benchmarking.
Administer and maintain the Company’s operations, including for safety purposes.
For client marketing purposes.
Exercise or defend the legal rights of the Company and its employees, affiliates, customers, contractors, and agents.
Operate, manage, and maintain our business.
Perform accounting, audit, and other internal functions, such as internal investigations.
Exercise and defend legal claims.
Otherwise accomplish our business purposes and objectives.

In addition to the purposes identified above, CP may use and disclose any and all Employee Personal Information that we Collect as necessary or appropriate to:

Comply with laws and regulations, including (without limitation) applicable tax, health and safety, anti-discrimination, immigration, labor and employment, and social welfare laws;
Monitor, investigate, and enforce compliance with and potential breaches of CP’s policies and procedures and legal and regulatory requirements;
Comply with civil, criminal, judicial, or regulatory inquiries, investigations, subpoenas, or summons; and
Exercise or defend the legal rights of CP and its employees, affiliates, customers, contractors, and agents.

F. Service Providers. We may disclose your Personal Information to our Service Providers for the purposes described in Section E of this Notice, to provide:

Applicant selection and related hiring services, benefits and wellness services, website services, as well as other products and services, such as web hosting, data analysis, customer service, infrastructure services, technology services, email delivery services, legal services, and other similar services.

We grant our Service Providers access to Personal Information only to the extent needed for them to perform their functions, and require them to protect the confidentiality and security of such information.

Third Parties. We may disclose your Personal Information to our Third Parties for the purposes described in Section E of this Notice:

- At Your Direction. We may disclose your Personal Information to any Third Party with your consent or at your direction.
- Business Purpose. We may disclose your Personal Information to a Third Party for a business purpose.
- Legal and Regulatory. We may disclose your Personal Information to government authorities, including regulatory agencies and courts, as reasonably necessary for our business operational purposes, to assert and defend legal claims, and otherwise as permitted or required by law.

G. Your Data Subject Rights as a California Resident Applicant or Employee

As an Applicant or Employee, you have the following rights regarding our Collection and use of your Personal Information, subject to certain exceptions:

Right to Receive Information on Privacy Practices. We have provided such information in this Policy, and you may request further information about our privacy practices by contacting us as at the contact information provided below.
Right to Deletion: You may request that we delete any Personal Information about you we that we collected from you.
Right to Correction: You may request that we correct any inaccurate Personal Information we maintain about you.
Right to Know: You may request that we provide you with the information about how we have handled your Personal Information in the 12 months preceding your request.
Right to Receive Information About Onward Disclosures: You may request that we disclose to you the categories of Personal Information that we have disclosed or shared about you, the categories of persons to whom we disclosed your Personal Information, and the categories of Third Parties to whom the Personal Information was shared. CP does not sell your personal information.
Right to Opt-Out of the Sharing of Your Personal Information and to Limit the Use of Your Sensitive Personal Information: You have the right to opt-out of the Sharing of your Personal Information. You also have the right to limit the use of your Sensitive Personal Information to the purposes authorized by the CCPA.
- We do not Sell or Share Personal Information. Further, we do not use Sensitive Personal Information for purposes beyond those authorized by the CCPA. Relatedly, we do not have actual knowledge that we Sell or Share Personal Information of California Consumers under 16 years of age. For purposes of the CCPA, a “Sale” is the disclosure of Personal Information to a Third Party for monetary or other valuable consideration, and a “Share” is the disclosure of Personal Information to a Third Party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration.
Right to Non-Discrimination: You have the right not to be discriminated against for exercising your data subject rights. We will not discriminate against you for exercising your data subject rights.

H. Other Disclosures

Retention of Personal Information: We retain each of the above-listed categories of Personal Information for the duration of your Applicant and/or Employee relationship with us, as applicable, and longer as may be required by applicable laws or necessary for our legitimate business purposes.
Changes to our Notice. We reserve the right to amend this Notice at our discretion and at any time. When we make material changes to this Notice, we will notify you by updating the information on CP’s website.
Contacting Us. If you have any questions, comments, requests, or concerns related to this Notice, CP’s information practices, or how to access this policy in another format, please contact us at CP Flexible Packaging, Inc. 15 Grumbacher Rd., York, PA 17406, at 1-800-815-0667 or at hr@cpflexpack.com for assistance. You may also authorize an agent to make a data subject request on your behalf, and the authorized agent may do so via the above-listed submission methods.

We may ask you to provide information that will enable us to verify your identity in order to comply with your data subject request. In particular, if you authorize an agent to make a request on your behalf, we may require the agent to provide proof of signed permission from you to submit the request, or we may require you to verify your own identity to us or confirm with us that you provided the agent with permission to submit the request. In some instances, we may decline to honor your request if an exception applies under the CCPA. We will respond to your request consistent with applicable law.

Cookies Policy

Introduction
1. We are committed to safeguarding the privacy of our website visitors and service users.
2. This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.
3. We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.
4. The cookies on our site do not collect Personally Identifiable Information (PII).
5. In this policy, “we,” “us” and “our” refer to C-P Flexible Packaging. For more information about us, see Section 16.
How We Use Your Personal Data
1. In Section 2 we have set out:
  1. the general categories of personal data that we may process;
  2. in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
  3. the purposes for which we may process personal data; and
  4. the legal bases of the processing.
2. We may process data about your use of our website and services(“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is Google Analytics. This usage data may be processed for the purposes of analyzing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
3. We may process information contained in any inquiry you submit to us regarding goods (“inquiry data“). The inquiry data may be processed for the purposes of offering, marketing and selling relevant goods to you. The legal basis for this processing is consent.
4. We may process information relating to our customer relationships, including customer contact information (“customer relationship data“). The customer relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer. The source of the customer relationship data is you or your employer. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products to customers. The legal basis for this processing is our legitimate interests, namely the proper management of our customer relationships.
5. We may process information contained in or relating to any communication that you send to us (“correspondence data“) via our website’s contact forms. The correspondence data may include the communication content and data associated with the communication. Our website will generate the data associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
6. We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
7. In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
8. Please do not supply any other person’s personal data to us, unless we prompt you to do so.
Providing Your Personal Data to Others
1. We may disclose data collected by Google Analytics and Google Tag Manager to our website developer, insofar as reasonably necessary for assurance that our contact forms, website pages and email templates are functioning properly, to help us make sure our website content meets the needs of our website visitors, and to serve ads about our products to people who have visited our website.
2. We may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
Retaining and Deleting Personal Data
1. This Section 4 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
2. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
3. We will retain your personal data as follows: personal contact information, including name, address, telephone, email address, company or organization will be retained for a minimum period of one year following the date the data was received, and for a maximum period of 20 years following the date it was received.
4. In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:
  1. the period of retention of contact information will be determined based on your activity with our business.
5. Notwithstanding the other provisions of this Section 4, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
Security of Personal Data
1. We will take appropriate technical and organizational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
2. We will store any of your personal data on secure servers.
Amendments
1. We may update this policy from time to time by publishing a new version on our website. This version was written on October 25, 2019.
2. We may notify you of changes to this policy by email or notice on our website.
Your Rights
1. In this Section 7, we have summarized the rights that you have under the European Union data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the European Union regulatory authorities for a full explanation of these rights.
2. Your principal rights under data protection law are:
  1. the right to access;
  2. the right to rectification;
  3. the right to erasure;
  4. the right to restrict processing;
  5. the right to object to processing;
  6. the right to data portability;
  7. the right to complain to a supervisory authority; and
  8. the right to withdraw consent.
3. You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
4. You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
5. In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims.
6. In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
7. You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.
8. You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
9. To the extent that the legal basis for our processing of your personal data is:
  1. consent; or
  2. that the processing isnecessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
  and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
10. If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
11. To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
12. You may exercise any of your rights in relation to your personal data by written notice to us.
Third Party Websites
1. Our website includes hyperlinks to, and details of, third party websites.
2. We have no control over, and are not responsible for, the privacy policies and practices of third parties.
Personal Data of Children
1. Our website and services are targeted at persons over the age of 18.
2. If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
Updating Information
1. Please let us know if the personal information that we hold about you needs to be corrected or updated.
About Cookies
1. A cookie is a file containing an identifier (a string of letters and/or numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
2. Cookies may be either “persistent” cookies or “session” cookies; a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
3. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
Cookies That We Use
1. We use cookies for the following purposes: (a) analysis – we use cookies to help us to analyze the use and performance of our website. Cookies used for this purpose are: Google Analytics: _ga, _gid, _gat. (b) remarketing – we use cookies for remarketing promotional campaigns that serve ads based on a person’s past visits to our website. Cookies used for this purpose are: Google Tag Manager: _ga, _gid, _gat.
Cookies Used by Service Providers
1. We use Google Analytics to analyze the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/. The relevant cookies are: _ga, _gid, _gat.
2. We use Google Tag Manager to support remarketing campaigns. Google Tag Manager gathers information about website use by means of cookies and then serves ads based on a person’s past visits to our website. The relevant cookies are: _ga, _gid, _gat.
Managing Cookies
1. Information about how to opt out of Google’s use of cookies can be learned by visiting Google’s Ads Settings. Alternatively, you can opt out of athird-party vendor’s use of cookies by visiting the Network Advertising Initiative opt-out page.
2. Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
  1. Chrome
  2. Firefox
  3. Opera
  4. Internet Explorer
  5. Safari
  6. Edge
3. Blocking all cookies will have a negative impact upon the usability of many websites.
4. If you block cookies, you might not be able to use all the features on our website.
Cookie Preferences
1. You can learn how to manage your preferences relating to the use of cookies on our website by visiting:
  https://support.google.com/analytics/answer/181881?hl=en
Our Details
1. This website is owned and operated by C-P Flexible Packaging.
2. Our principal place of business is at 15 Grumbacher Rd, York, PA 17406 USA .
3. You can contact us:
  1. by mail, to the postal address given above;
  2. using our website contact forms;
  3. or by telephone, on the contact number published on our Contact Us page.
Data Protection Officer
1. Our data protection officer’s contact details are: Amanda Dahlby, Director of Marketing, adahlby@cpflexpack.com.