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Overview

This Privacy Policy describes how we collect, use, disclose and otherwise process personal information in connection with our Services from individuals who visit and/or engage with our website (the “Site”), use our products or services. The policy also explains the rights and choices available to individuals with respect to their personal information.

In this Privacy Policy, we refer to this personal information as “Personal Information” a term equivalent to “personal data” under Article 4 of the Regulation (EU) 2016/679 (General Data Protection Regulation), i.e. any information relating to an identified or identifiable natural personal information governed by European data protection legislation.

TerraCycle respects the privacy of individuals and is committed to protecting the personal information we hold about you.

1. Who We Are

TerraCycle is headquartered in the United States and partner with individual consumers, as well as major consumer product companies, retailers, manufacturers, municipalities, and small businesses across 20 different countries.  At TerraCycle, we provide recycling solutions for traditionally hard to recycle materials, including snack bags, coffee capsules, writing utensils and pre-consumer plastic packaging (the “Services”).

TerraCycle Ireland. (“TerraCycle”, “Company” “we”, or “us”)

Europe Office: Sabichi House, 5 Wadsworth Rd. Perivale, Middlesex. United Kingdom. UB6 7JD

Lead Data Protection Authority for Europe: The Information Commissioner’s Office (ICO), United Kingdom.

More information about TerraCycle, our recycling solutions, and our global subsidiaries can be found here.

2. What Personal Information do we collect?

2.1 Personal Information you give us

TerraCycle collects personal Information that you may provide through the Services or otherwise communicate with us, which includes:

  • Account information, we collect information from you, such as your first name, last name, shipping address, email address, and telephone when you register for an account (“Account”) on the Site ;
  • Recruitment information, such as information you provide when you apply for a job directly or through a third-party company;
  • Transaction information, such as details regarding your subscriptions, the products you select, your shipments, shipping and billing details;
  • Feedback and correspondence, such as information you provide when you contact us, in your responses to surveys, when you register for a free recycling programme, participate in market research activities, sweepstakes, contest or giveaway, report a problem, receive customer support, register for or otherwise correspond with us;
  • Usage information, such as information about how you use the Services and interact with us;
  • Marketing information, such as your preferences for receiving marketing communications and details about how you engage with them;
  • Charity information, such as  collection of charity details to redeem your TerraCycle points and make payments to the recipients of the contributions allocated by the collector;
  • Demographic information such as age, gender and organisation.

The specific kind of user data collected will depend on the Services used. 

2.2 Information automatically collected (Cookies)

When you visit the Site or use our Services, we may automatically collect certain information about your device that could be considered as Personal Information, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site.  

We collect Personal Information using the following technologies:

We may collect Personal Information using “cookies.” Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Site.

We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which we use to recognise your computer or mobile device when it revisits our Site; and (2) third party cookies, which are served by service providers on our Site, and can be used by such service providers to recognise your computer or mobile device when it visits other websites.

Cookies we use

Our Site uses the following types of cookies for the purposes set out below:

Essential Cookies

These cookies are essential to provide you with services available through our Site and to enable you to use some of its features. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.

Functionality Cookies

These cookies allow our Site to remember choices you make when you use our Site. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-select your preferences every time you visit our Site.

Analytics and Performance Cookies

These cookies are used to collect information about traffic to our Site and how users use our Site. The information gathered may include the number of visitors to our Site, the websites that referred them to our Site, the pages they visited on our Site, what time of day they visited our Site, whether they have visited our Site before, and other similar information.  We use this information to help operate our Site more efficiently, to gather broad demographic information, monitor the level of activity on our Site, and improve the Site.

We use Google Analytics for this purpose. Google Analytics uses its own cookies. You can find out more information about Google Analytics cookies here and about how Google protects your data here.  You can prevent the use of Google Analytics relating to your use of our Site by downloading and installing the browser plugin available here.

Social Media Cookies

These cookies are used when you share information using a social media sharing button or “like” button on our Site or engage with our content on or through a social networking website such as Facebook or Twitter. The social network will record that you have done this.

Collecting this Personal Information enables us to better understand the visitors who come to our Site or use our Service, where they come from, and what content and functionality is of interest to them.

We use this Personal Information for our internal analytics purposes and to improve the quality and relevance of our Site and/or Services to our visitors and users.

Disabling Cookies

You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help” “tools” or “edit” facility).  Many browsers are set to accept cookies until you change your settings.

Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org.

If you do not accept our cookies, you may experience some inconvenience in your use of our Site. For example, we may not be able to recognise your computer or mobile device and you may need to log in every time you visit our Site.

2.3 Personal information shared with us by a third party

We may be provided access to or receive your personal information from a third party. For example data shared during events organised by TerraCyle or a third party. This may include a list of attendees, photos and video recordings.

2.4 Personal information where we act as a data processor

We also process personal information on behalf of our customers in the context of supporting our products and services. Where a customer subscribes to our Services (whether this is using a TerraCycle developed frontend or a proprietary interface), they will be the ones who are responsible for what data is collected and stored on the systems.

You will need to refer to the Privacy Policies of our customers to find out more about how such information is handled by them.

2.5 Children

Our Services are not directed to children under 16. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us. If we learn that we have collected Personal Information from a child under age 16, we will delete such information from our files as soon as reasonably practicable.

2.6 Sensitive Personal Information

We ask that you do not send us, and do not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Site or otherwise to us.

If you send or disclose any sensitive Personal Information to us when you use the Site, you must consent to our processing and use of such sensitive Personal Information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive Personal Information, you must not submit such sensitive Personal Information to our Site.

3. How do we use Personal Information?

To provide our Services

If you have an Account or use our Services, we may use your Personal Information to:

  • operate, maintain, administer and improve the Services;
  • manage and communicate with you regarding your Account, if you have one, including by sending you service announcements, technical notices, updates, security alerts, and support and administrative messages;
  • process and manage subscriptions you purchase via the Services, including to track and administer your shipments;
  • better understand your needs and interests, and personalise your experience with the Services;
  • provide support and maintenance for the Services;
  • communicate with you regarding a job which you may have applied for and
  • respond to your service-related requests, questions and feedback.

To communicate with you

If you request information from us, register for an Account, or participate in our surveys, promotions or events, we may send you Company-related marketing communications as permitted by law.

By default, you should not receive marketing communications. If we want to send you marketing communication, you will need to first provide an expressed interest in “opting in” to communications. This can be done by the following way:

  • After you register an account or sign up to receive email offers, you have option to tick a box to opt in to receive updates and important information about TerraCycle programmes and related promotional activities. You can opt out at any time.

For research and development

We use Personal Information automatically collected to analyse trends, administer the Services, analyse users’ movements around the Site, gather demographic information about our user base as a whole, improve the Services and develop new products and services.

To comply with law

We use your Personal Information as we believe necessary or appropriate to comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities.

With your consent

We will request your consent to use your Personal Information where required by law, such as where we use certain cookies or similar technologies or would like to send you certain marketing messages.  If we request your consent to use your Personal Information, you have the right to withdraw your consent any time in the manner indicated when we requested the consent or by contacting us, using our contact details below.

To create anonymous data

We may create anonymous data from your Personal Information and other individuals whose Personal Information we collect.  We make Personal Information into anonymous data by excluding information that makes the data personally identifiable to you, and use that anonymous data for our lawful business purposes.

For compliance, fraud prevention and safety

We use your Personal Information as we believe necessary or appropriate to (a) enforce the terms and conditions that govern the Service; (b) protect our rights, privacy, safety or property, and/or that of you or others; and (c) protect, investigate and deter against fraudulent, harmful, unauthorised, unethical or illegal activity.

Use for new purposes

We may use your Personal Information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it.  If we need to use your Personal Information for an unrelated purpose, we will notify you and explain the applicable legal basis.

Changes to your Personal Information

It is important that the Personal Information we hold about you is accurate and current.  Please let us know if your Personal Information changes during your relationship with us by updating your Account or contacting our customer service team ([email protected]).

4. Legal basis for processing

We only use your Personal Information as permitted by law.  We are required to inform you of the legal basis of our processing of your Personal Information, which are described below.  

Contract

Processing is necessary to perform a contract governing our provision of the Services or to take steps that you request prior to signing up for the Services.

Legitimate Interests

Processing is necessary for our legitimate interests (or those of a third party and your interests and fundamental rights do not override those interests), Our legitimate interests include: 

·       Customer relations

·       Supplier management

·       Product development

·       Operational management

·       legal obligations including compliance with anti-money laundering regulations

We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Legal obligations

Processing is necessary to comply with our legal or regulatory obligation.

Consent

Where you have given your consent to the processing of your personal data for purposes, such as; direct marketing and registration of free recycling programmes. Where we rely on your consent you have the right to withdraw it anytime in the manner indicated in the Service or by contacting us.

5. Sharing your Personal Information

5.1 Affiliates

We may disclose your Personal Information to our subsidiaries and corporate affiliates for purposes consistent with this Privacy Policy.

5.2 Brand Partners

We may share your information with our brand partners when you register for a free recycling programme and if they are required to contact you in order to complete the registration process. We may also share your information with brand partners if you have won a contest sponsored by brand partners and they need to send the prizes directly to the contestants. We will always notify you when your information is collected for this purpose.

5.3 Service Providers

IT Services

We may employ third party companies and individuals to administer and provide the Services on our behalf (such as customer support, hosting and storage, analytics, email delivery, marketing/advertising and database management services) or to follow-up on your enquiries. For example, we use Shopify to power our online store--you can read more about how Shopify uses your Personal Information here. We use Google Analytics to help us understand how our customers use the Site -- you can read more about how Google uses your Personal Information here. You can also opt-out of Google Analytics here. We also use the Amazon Web Services (AWS) for the hosting of our websites. The Personal Data outlined in section 2.1 collected by TerraCycle for use in our Services is stored in database services offered by AWS that are encrypted and continually backed up. 

These third parties may use your Personal Information only as directed by Company and in a manner consistent with this Privacy Policy, and are prohibited from using or disclosing your Personal Information for any other purpose. You can find more information about AWS’s security practices here.

We also use your Personal Information to provide you with targeted advertisements or marketing communications that you have given consent for. Find out more about how targeted advertising works on the Network Advertising Initiative’s (“NAI”) educational here.

Other Services

We may employ the services of third party fulfilment agencies that will have access to data of customers that make purchases or sample requests. This information is required in order to prepare orders ready for shipping.

We employ a number of third party shipping agencies that will have access to the data of customers that make purchases or sample requests. This information is required for the delivery of ordered items.

We may also employ the services of registered carriers that will have access to the data of customers that are registered on any of our waste recycling services. This information is required for the collection of the items.

5.4 Professional advisors

We may disclose your Personal Information to professional advisors, such as lawyers, bankers, auditors, and insurers, where necessary in the course of the professional services that they render to us.

5.5 Compliance with Laws and Law Enforcement; Protection and Safety

Company may disclose Personal Information about you to government or law enforcement officials or private parties as required by law, and disclose and use such information as we believe necessary or appropriate to (a) comply with applicable laws and lawful requests and legal process, such as to respond to subpoenas or requests from government authorities; (b) enforce the terms and conditions that govern the Service; (c) protect our rights, privacy, safety or property, and/or that of you or others; and (d) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

5.6 Business Transfers

Company may sell, transfer or otherwise share some or all of its business or assets, including your Personal Information, in connection with a business deal (or potential business deal) such as a merger, consolidation, acquisition, reorganization or sale of assets or in the event of bankruptcy, in which case we will make reasonable efforts to require the recipient to honor this Privacy Policy.

5.7 Social Network Services (SNSs)

The Services may enable you to post content to SNSs.  If you choose to do this, we will provide Personal Information to such SNSs in accordance with your elections.  You acknowledge and agree that you are solely responsible for your use of those websites and that it is your responsibility to review the terms of use and privacy policy of the applicable website or service. We will not be responsible or liable for: (i) the availability or accuracy of such website or service; (ii) the content, products or services on or availability of such website or service; or (iii) your use of any such website or service.

6. Transfer of Personal Information outside the European Economic Area

Please note that some TerraCycle entities and some partners and service providers are located outside of the European Economic Area (EEA), in particular the countries in which TerraCycle has an office. An overview of TerraCycle's global presence can be found here.

Whenever we transfer your Personal Information out of the EEA to countries not deemed by the European Commission to provide an adequate level of Personal Information protection, the transfer will be based on one of the following safeguards recognised by the European Commission as providing adequate protection for Personal Information, where required by EU data protection legislation:

  • the country to which we send the Personal Information may be approved by the European Commission
  • the recipient may have signed a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect your Personal Information, or
  • where the recipient is located in the US, it may be a certified member of the EU-US Privacy Shield scheme.

In other circumstances, the law may permit us to otherwise transfer your Personal Information outside Europe. In all cases, however, any transfer of your Personal Information will be compliant with the applicable data protection law.

7. Your Choices

Access, update, correct or delete your Personal Information

All Company Account holders may review, update, correct or delete the Personal Information in their Account by logging into their Account. Company Account holders may also contact us to accomplish the foregoing or if you have additional requests or questions.

Testimonials
If you gave us consent to post a testimonial on our Sites, but wish to update or delete it, please contact us.

Choosing not to share your Personal Information

Where we are required by law to collect your Personal Information, or where we need your Personal Information in order to provide the Services to you, if you do not provide Personal Information when requested (or you later ask to delete it), we may not be able to provide you with the Services and may need to close your account.  We will tell you what Personal Information you must provide to receive the Services by designating it as required in the Services or through other appropriate means. Similarly, you may be required to provide certain Personal Information if you want to enter a contest, participate in a survey, or if you contact our Customer Services team ([email protected]) with a query or complaint.  We will inform you where such Personal Information is required.

8. Security

We take a number of organisational, technical and physical measures designed to protect the Personal Information we collect, both during transmission and once received. These include but are not limited to:

  • Forcing APIs (REST and Pub/Sub) to operate over encrypted ports (HTTPS and TLS).
  • Data encryption between services within the cloud based systems used by TerraCycle.
  • File encryption over file servers.
  • Highly restricted access to Production Environments.

However, no security safeguards are 100% secure and we cannot guarantee the security of your Personal Information. We will comply with applicable laws and regulations requiring that we notify you in the event your Personal Information is compromised as a result of a breach of our security measures.

9. Other Important Privacy Information

Third party sites and services

The Services may contain links to other websites and services.  These links are not an endorsement, authorisation or representation that we are affiliated with that third party. We do not exercise control over third party websites or services, and are not responsible for their actions. Other websites and services follow different rules regarding the use or disclosure of the Personal Information you submit to them. We encourage you to read the privacy policies of the other websites you visit and services you use.

User generated content

We may make available on our Sites, or link to, features that allow you to share information online (e.g., on message boards, in chat areas, in file uploads, through events, etc.). Please be aware that whenever you voluntarily disclose Personal Information online, that information becomes public and can be collected and used by others. We have no control over, and take no responsibility for, the use, storage or dissemination of such publicly-disclosed Personal Information. By posting Personal Information online in public forums, you may receive unsolicited messages from other parties.

10. Data retention

We do not store the personal data for longer than is legally permitted and necessary for the related processing purposes. The storage period depends on the type of personal data, the purposes and the applicable law and therefore varies per use.

Typically, we store your personal data for as long as you are using our Services or for as long as we have another purpose to do so and, thereafter, for no longer than is required or permitted by law. 

We erase personal data after the above described storage period or when you request us to erase your personal data, if applicable.

11. Your rights

Right to access. You have the right to obtain from us confirmation as to whether or not personal data concerning you are processed, and, where that is the case, you have the right to request and get access to that personal data.

Right to withdraw consent. Where we have asked for your consent to process your information, you can withdraw this consent at any time by contacting us using the details below. If you wish to opt out of receiving our commercial messages, you can also do so by at any time using the "unsubscribe" link at the bottom of such e-mail. Withdrawing a consent may lead to fewer possibilities to use our Services. 

Right to rectification. You have the right to obtain from us the rectification of inaccurate personal data and you have the right to provide additional personal data to complete any incomplete personal data.

Right to object. In certain cases, you have the right to object to processing of your personal data, including data relating to profiling. You have the right to object at further processing of your personal data in so far as such data have been collected for direct marketing purposes. We shall then no longer process your personal data unless we demonstrate other compelling legitimate grounds for our processing that override your interests, rights and freedoms or for legal claims.

Right to restriction of processing. You have the right to request from us restriction of processing, applicable for a certain period and/or for certain situations e.g. to allow our verification of accuracy of personal data after your contesting of accuracy or to prevent us from erasing personal data when personal data are no longer necessary for the purposes but still required for your legal claims or when our processing is unlawful. Restriction of processing may lead to fewer possibilities to use our Services. 

Right to data portability. You have the right to receive from us in a structured format your personal data and you have the right to (let) transmit such personal data to another controller.

Right to erasure. You have the right to have personal data we process about you erased from our systems if the personal data are no longer necessary for the related purposes, if we have unlawfully processed the personal data or if you object to processing for direct marketing. Furthermore, you have the right to erasure if you withdraw consent or object to our processing as meant above, unless we have a legitimate ground to not erase the data. We may not immediately be able to erase all residual copies from our servers and backup systems after the active data have been erased. Such copies shall be erased as soon as reasonably possible.

Right to be Not Subject to Automated Individual Decision-Making. You have the right to not be subject to a decision based solely on automated processing.

Right to Filing Complaints

We hope that we can satisfy queries you may have about the way we process your data. If you have any concerns about how we process your data, you can get in touch with us, using the details below.  In the event you have unresolved concerns, you also have the right to contact your local data protection authority. We hope this will not be necessary and would like to assure you we will do our best to resolve any dissatisfaction you may have. Go to www.dataprotection.ie to find out more.

11. Contact Details

If you would like to exercise one of your rights as set out above, or you have a question or a complaint about this policy or the way your personal information is processed, please contact us by one of the following means:

Post:

Data Protection Officer
TerraCycle (Europe)
Sabichi House, 5 Wadsworth Rd.
Perivale, Middlesex.
United Kingdom UB6 7JD

Email: [email protected]

12. Policy Update

This Privacy Policy was most recently updated in January 2019.