TERRACYCLE, INC.

Privacy Policy

Last Updated: November 12, 2020

 

This “Privacy Policy” describes the privacy practices of TerraCycle, Inc (together with our affiliates, “TerraCycle”, “Company” “we”, or “us”).  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”).

 

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

 

Office address: 121 New York Avenue, Trenton, NJ 08638, USA

 

This Privacy Policy describes how we collect, use, disclose and otherwise process personal information in connection with our Services, and explains the rights and choices available to individuals with respect to their information. This Privacy Policy governs any of the Services on which the Privacy Policy is posted.

 

Individuals who are Californian residents should be sure to read the important information provided in Notice to Californian residents – your California privacy rights.

 

1. Personal Information We Collect

2. Changes to your personal information

3. Cookies and Similar Technologies

4. How We Use Your Personal Information

5. How We Share your Personal Information

6. Your Choices

7. Security

8. Children

9. Sensitive Personal Data

10. Other Important Privacy Information

11. International Transfer

12. Changes to this Privacy Policy

13. Contact Us

 

 

1. Personal Information We Collect

Information you give us

Personal information that you may provide through the Services or otherwise communicate with us includes:

  • Account information, we collect information from you when you register for an account (“Account”) on the Site, such as your first name, last name, shipping address, billing address, email address, and telephone.
  • Profile information, such as your password;
  • Recruitment information, such as information you provide when you apply for a job directly or through a third-party company;
  • Feedback and correspondence, such as information you provide in your responses to surveys, when you participate in market research activities, sweepstakes, contest or giveaway, report a problem with the Services, receive customer support or otherwise correspond with us;
  • Transaction information, such as details regarding your subscriptions, such as the Goods you select, your shipments and shipping and billing details;
  • Usage information, such as information about how you use the Services and interact with us;
  • Marketing information, such 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.

 

Information we get from others. We may also get information about you from other sources, for example from Google, if you are signed into Google, we may get demographic data (e.g. gender, age), if you are not signed in, we may receive geographical and technical data (e.g. browser type, location) and we may add this to information we get from the Services.

We may combine other publicly available information, such as information related to the organization for which you work, with the personal information that you provide to us through our Services.

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.

Information automatically collected

We may automatically log information about you and your computer or mobile device when you access our Site. For example, we may log your computer or mobile device operating system name and version, manufacturer and model, browser type, browser language, screen resolution, the website you visited before browsing to our Sites, pages you viewed, how long you spent on a page, access times and information about your use of and actions on our Sites.  We collect this information about you using cookies. Please refer to the Cookies and Similar Technologies section for more details.

2. 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 contact our customer support indicated below.

3. Cookies and Similar Technologies

What are cookies?

We may collect information using “cookies” or similar technologies (altogether, “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 recognize 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:

Type of cookie: Local Storage

Purpose: This technology allows our Site to remember choices you make when you use our Site. The purpose of this 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.

Type of cookie: Analytics and Performance Cookies

Purpose: 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.

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 recognize your computer or mobile device and you may need to log in every time you visit our Site.

Pixel tags

We may also use pixel tags (which are also known as web beacons and clear GIFs) on our Site to track the actions of users on our Site. Unlike Cookies, which are stored on the hard drive of your computer or mobile device by a website, pixel tags are embedded invisibly on webpages. Pixel tags measure the success of our marketing campaigns and compile statistics about usage of the Site, so that we can manage our content more effectively.

Do Not Track Signals

Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not currently respond to do not track signals. To find out more about "Do Not Track," please visit http://www.allaboutdnt.com.

4. How We Use Your Personal Information

To provide our Services

If you have an Account or use our Services, we 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 personalize your experience with the Services;
  • provide support and maintenance for the Services; 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. You will have the ability to opt out of such communications as described below.

For research and development

We use information automatically collected and other information to analyze trends, administer the Services, analyze 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 provide you with advertising

We may use your personal information to serve ads on the Services or on third party sites and to tailor ads to your interests and browsing history.  Please refer to the Cookies and Similar Technologies section for more details.

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 at privacy@terracycle.com or +1 (609) 656-5150.

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, unauthorized, 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.

5. How We Share your Personal Information

Affiliates

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

Service Providers

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). These third parties may use your information only as directed by Company and in a manner consistent with this Privacy Policy, and are prohibited from using or disclosing your information for any other purpose.

Third Party Payment Processing

For online payments, we use the payment services of Authorize.net (https://www.authorize.net/). The personal information collected is encrypted. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. For more information on how payments are handled, or to understand the data security and privacy afforded such information, please refer to https://www.authorize.net/about-us/privacy/.

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.

Compliance with Laws and Law Enforcement; Protection and Safety

Company may disclose 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.

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.

SNSs

The Services may enable you to post content to SNSs.  If you choose to do this, we will provide 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.

Third parties partners/organizations  

We may disclose your personal information to third parties that act as agents, consultants, and contractors to perform tasks on behalf of and under our instructions. Such third parties must agree to use such personal information only for the purposes for which they have been engaged by us and they must agree to provide adequate protections for the personal information.

We also may disclose personal information to third parties when you have consented to or requested such disclosure.

We are liable for appropriate onward transfers of personal data to third parties.

However, such sharing may link to third-party websites and services that are outside our control. We are not responsible for the security or privacy of any information collected by these third parties, which operate pursuant to their respective privacy policies.

6. Your Choices

Access, update, correct or delete your 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 at privacy@terracycle.com or +1 (609) 656-5150 to accomplish the foregoing or if you have additional requests or questions.

Marketing communications

You may opt out of marketing-related emails by logging in and changing your account settings, by clicking on a link at the bottom of each such email, or by contacting us at privacy@terracycle.com or +1 (609) 656-5150.  You may continue to receive service-related and other non-marketing emails.

Testimonials

If you gave us consent to post ratings/comments or a testimonial on our Sites, but wish to update or delete it, please contact us at privacy@terracycle.com or +1 (609) 656-5150.

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 this 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 information you must provide to receive the Services by designating it as required in the Services or through other appropriate means.

7. Security

The security of your personal information important to us.  We take a number of organizational, technical and physical measures designed to protect the personal information we collect, both during transmission and once we receive it.  

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 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.

8. Children

Our Services not directed to children under 16. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at privacy@terracycle.com or +1 (609) 656-5150. If we learn that we have collected personal information from a child under age 16, will delete such information from our files as soon as reasonably practicable.

9. Sensitive Personal Data

We ask that you not send us, and you not disclose, any sensitive personal data (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 data to us when you use the Site, you must consent to our processing and use of such sensitive personal data in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal data, you must not submit such sensitive personal data to our Site.

10. 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, authorization 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.

California Privacy Rights

We may share your personal information with third parties (and in some cases, affiliates) for their direct marketing purposes. Under California Civil Code sections 1798.83- 1798.84, California residents are entitled to request certain information regarding such disclosures within the immediately preceding calendar year. To make such a request, email us at privacy@terracycle.com. You must put the statement “Your California Privacy Rights” in the subject field of your e-mail or include it in your writing if you choose to write to us at the designated mailing address. You must include your name, street address, city, state, and ZIP code. We are not responsible for notices that are not labelled or sent properly, or do not have complete information. BECAUSE WE DO NOT CONTROL THE PRIVACY PRACTICES OF THESE THIRD PARTY COMPANIES, YOU SHOULD READ AND UNDERSTAND THEIR PRIVACY POLICIES.

NOTICE TO CALIFORNIAN RESIDENTS – YOUR CALIFORNIA PRIVACY RIGHTS

 The California Consumer Privacy Act (“CCPA”) provides you with specific rights regarding your personal information. This section describes your CCPA rights and explain how to exercise those rights.

Access, data portability, deletion rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. You also have the right to request that we delete some or all of your personal information.

If requested as described below, we will disclose to you

-       The categories of personal information we collected about you

-       The categories of sources for the personal information we collected about you

-       Our business or commercial purpose for collecting or selling that personal information

-       The categories of third parties with whom we share the personal information

-       The specific pieces of personal information we collected about you (also called a data portability request)

-       If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:

·       Sales, identifying the personal information categories that each category of recipient purchased, and

·       Disclosure for a business purpose, identifying the personal information categories that each category of recipient obtained.

To exercise the access, data portability and deletion rights described above, please submit a verifiable consumer request to us by contacting us at privacy@terracycle.com or +1 (609) 656-5150. You must put the statement “Your California Privacy Rights” in the subject field of your e-mail or include it in your writing if you choose to write to us at the designated mailing address.

You may only make a verifiable consumer request for access or data portability twice within a 12 months periods. The verifiable consumer request must:

-        Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative

-        Describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information related to you. We are not responsible for notices that are not labelled or sent properly, or do not have complete information. BECAUSE WE DO NOT CONTROL THE PRIVACY PRACTICES OF THESE THIRD PARTY COMPANIES, YOU SHOULD READ AND UNDERSTAND THEIR PRIVACY POLICIES.

Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates personal information associated with this specific account.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make a request.

Non discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

-       Deny you goods and services

-       Charge you different prices or rates for goods or services

-       Provide you a different level or quality of goods or services

-       Suggest that you may receive a difference price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates or quality levels. Any CCPA permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

Sharing personal information – Right to opt out of the sale of personal information

We may share the following personal information with third parties (and in some cases, affiliates): name, email address, mailing address.

 

11. International Transfer

Company is headquartered in the United States and has affiliates and service providers in other countries. We work with trusted third-party service providers to provide website, application development, hosting, maintenance, backup, storage, virtual infrastructure and other services for the Company. These service providers may have access to or process your information for the purpose of providing those services for us. Any sharing of information will be in accordance with the purposes set out in this Privacy Policy and applicable local laws.

Such third parties must agree to use such personal information only for the purposes for which they have been engaged by us. Whenever your personal information is transferred to the United States or other locations outside of your jurisdiction where privacy laws may not be as protective as those in your jurisdiction, the transfer will be based on one of the following mechanisms:

  • Ad hoc contracts
  • Standard contractual clauses
  • Codes of conduct/self-certification mechanisms

 

12. Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. We encourage you to periodically review this page for the latest information on our privacy practices. If we make changes to this Privacy Policy we will post them on the Site and update the Last Updated date above. If we make material changes to this Privacy Policy you will be notified via e-mail (if you have an Account where we have your contact information) or another manner through the Services that we believe reasonably likely to reach you. We will obtain your consent to any material Privacy Policy changes if and where this is required by applicable data protection laws.

Any modifications to this Privacy Policy will be effective upon our posting of the new terms and/or upon implementation of the new changes on the Service (or as otherwise indicated at the time of posting). In all cases, your continued use of the Service after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.

 

13. Contact Us

If you have any questions or concerns at all about our Privacy Policy, please feel free to contact us at privacy@terracycle.com or +1 (609) 656-5150., or write to us at:

 

TERRACYCLE, Inc.

121 New York Avenue, Trenton, NJ 08638, USA