PRIVACY POLICY

Why is there a privacy policy?

This Privacy Policy describes how C–Pack Creative Packaging S/A strives to respect Your privacy, when We, as data controllers, collect, process and store personal information about you, as our customer, potential customer, supplier, applicants and/or user of the C–Pack Creative Packaging S/A website (“You”) in connection with Your relationship with C–Pack Creative Packaging S/A and the C–Pack Creative Packaging S/A website (the "Site") accessible at "www.c-pack.com.br" (the "Personal Data").

This Privacy Policy has been designed and implemented to describe our practices in relation to the collection, use, processing, storage, disclosure, and transfer of your personal data, considering the requirements of the General Data Protection Regulation (Regulation (EU) 2016/ 679) (“GDPR”) and applicable laws and regulations.

CUSTOMER AND SUPPLIERS

PURPOSES AND LEGAL BASIS - How and why do we process your personal data?

C–Pack Creative Packaging S/A collects and processes Your Personal Data with the purpose of allowing us to manage the relationship with the customer and/or supplier, including in particular for:

– Managing relationships with customers, potential customers and/or suppliers;
– Measuring customer satisfaction and supplier compliance with legal standards by sending out surveys;
– Prospecting and direct marketing;
– Supervising and monitoring offers and orders;
– Proceeding with the records before the competent authorities;
– Administering invoice payments; and
– Handling contract signing and contract database;

The collection and processing of personal data is necessary to enable us to comply with our legal obligations and / or for the conclusion and / or execution of a contract with you, and / or, as the case may be, for our legitimate interests, to promote our products and services and manage relationships with customers, potential customers, and suppliers on a global scale, based on art. 6 pair. 1 lit. b), c) and / or f) of the GPDR.

PURPOSES AND LEGAL BASIS - How and why do we process your personal data?

C–Pack Creative Packaging S/A collects and processes Your Personal Data with the purpose of allowing us to manage the relationship with the customer and/or supplier, including in particular for:

– Managing relationships with customers, potential customers and/or suppliers;
– Measuring customer satisfaction and supplier compliance with legal standards by sending out surveys;
– Prospecting and direct marketing;
– Supervising and monitoring offers and orders;
– Proceeding with the records before the competent authorities;
– Administering invoice payments; and
– Handling contract signing and contract database;

The collection and processing of personal data is necessary to enable us to comply with our legal obligations and / or for the conclusion and / or execution of a contract with you, and / or, as the case may be, for our legitimate interests, to promote our products and services and manage relationships with customers, potential customers, and suppliers on a global scale, based on art. 6 pair. 1 lit. b), c) and / or f) of the GPDR.

PERSONAL DATA CATEGORIES - What do we collect about you?

C–Pack Creative Packaging S/A may collect Your Personal Data, mainly during Your interaction with C–Pack Creative Packaging S/A, as in the course of business, during a trade show or through the use of Our Website, either ( i) directly, from You or Your employer, or (ii) indirectly, from authorized third parties, such as agents, distributors, etc.

C–Pack Creative Packaging S/A collects, processes and uses the following categories of Personal Data about you for the purposes set out above:

– Identification information (mainly surname, first name, gender);
– Contact information, such as business email, phone number, fax, business address, title, role, seniority in the role, contact type (direct marketing contact, customer research contact, etc.), interest in the product, CRM / SRM information, such as who is your primary contact at C–Pack Creative Packaging S/A and/or who is our primary contact at your organization;
– Purchasing, billing and tax information to manage orders with suppliers;
– Survey ratings and comments;
– IP address.

RECIPIENTS - Who has access to your personal data?

When necessary, C–Pack Creative Packaging S/A may disclose Your Personal Data to:

– C–Pack Creative Packaging S/A personnel from relevant entities within C–Pack Creative Packaging S/A, according to product lines and geographic regions, as well as sales and purchasing functions, project management functions, technical functions, communications functions, information technology department, regulatory affairs functions;

– C–Pack Creative Packaging S/A personnel from relevant entities within C–Pack Creative Packaging S/A managing orders and suppliers, such as buyers, approvers, and accountants;

– Processors of C–Pack Creative Packaging S/A providing services to C–Pack Creative Packaging S/A for relationship management with customers, potential customers and/or suppliers, including processors that host Your Personal Data;

Regarding the disclosure of Personal Data described above, C–Pack Creative Packaging S/A:

Following processes and procedures ensures that disclosures are made only to internal personnel who are authorized to receive this information and who need the information to fulfill their job responsibilities; will only provide Personal Data to third party suppliers authorized to receive and process this information and who have contractually agreed to (i) use technical and other appropriate measures to protect this information and (ii) process this information as instructed by C–Pack Creative Packaging S /A and as necessary to perform its services to C–Pack Creative Packaging S/A; and will comply with applicable laws and regulations.

In the event that we are sold or all or part of our business is transferred to a third party, the personal data we collect and maintain about you may be transferred to that third party, subject to applicable legal requirements.

We may also disclose information about you in cases where we have a good faith belief that we are required to do so by law, including pursuant to a court order or in circumstances where we believe such action is necessary to prevent fraud or cybercrime or to protect the rights, property or our safety or the safety of any person, in each case, as required or permitted by applicable laws and regulations.

RETENTION PERIODS - How long will we keep your personal data?
We will retain Your Personal Data for the period of Our relationship with You and as necessary to comply with our legal and regulatory obligations, resolve disputes, enforce our agreements and similar records management purposes, and to the extent permitted or required by law.

CANDIDATES

PURPOSES AND LEGAL BASIS - How and why do we process your personal data?

C–Pack Creative Packaging S/A collects and processes Your Personal Data in order to allow us to review and evaluate your application and manage the recruitment process.

This Privacy Policy has been designed and implemented to describe our practices in relation to the collection, use, processing, storage, disclosure, and transfer of your personal data, considering the requirements of the General Data Protection Regulation (Regulation (EU) 2016/ 679) (“GDPR”) and applicable laws and regulations.

The collection and processing of Personal Data is necessary to allow C–Pack Creative Packaging S/A to prepare the execution and/or execution of the employment contract with You and, as the case may be, for Our legitimate interests and for the legitimate interests from other C–Pack Creative Packaging S/A companies for a global and efficient management of recruitment processes, based on art. 6 pair. 1 lit. b), c) and / or f) of the GPDR.

Unless otherwise specified at the time of collection, the provision of Your Personal Data is therefore mandatory. If you do not provide personal data, we will not be able to carry out the recruitment processes for you.

PERSONAL DATA CATEGORIES - What do we collect about you?

C–Pack Creative Packaging S/A may collect Your Personal Data during Your job interview and recruitment processes, (i) directly, from You, or (ii) indirectly, from authorized third parties, such as job boards.

C–Pack Creative Packaging S/A collects, processes and uses the following categories of Personal Data about you in connection for the purposes defined above:

– Identification information (mainly surname, first name, gender);
– Contact information;
– Professional information;
– Information from previous recruitment sessions.

RECIPIENTS - Who do we share your personal data with?

We may disclose, as necessary, Your Personal Data to:

– Relevant staff appointed to a given job listing;
– HR Managers; If you chose to be visible for other jobs.

Regarding the disclosure of personal data described above, we:

Following processes and procedures ensures that disclosures are made only to internal personnel who are authorized to receive this information and who need the information to fulfill their job responsibilities; will provide Personal Data only to third party vendors authorized to receive and process this information and who have contractually agreed to (i) use technical and other appropriate measures to protect this information and (ii) process this information as instructed by C–Pack Creative Packaging S /A and as necessary, to perform its services to C–Pack Creative Packaging S/A; and will comply with applicable laws and regulations.

In the event that C–Pack Creative Packaging S/A is sold or all or part of its business is otherwise transferred to a third party, the Personal Data that C–Pack Creative Packaging S/A has collected and maintained about You in connection with Your potential recruitment may be transferred to that third party, subject to applicable law requirements.

C–Pack Creative Packaging S/A may also disclose information about you in cases where we have a good faith belief that we are required to do so by law, including pursuant to a court order or in circumstances where we believe such action is necessary to prevent fraud or cybercrime or to protect the rights, property or safety of C–Pack Creative Packaging S/A or any person, in each case, as required or permitted by applicable laws and regulations.

RETENTION PERIODS - How long will we keep your personal data?

If you are not hired, we will retain your personal data for 2 years from the date of collection of the information. If You are hired, we will retain Your Personal Data for the duration of Your employment contract.

We may also retain Your Personal Data, if necessary, to fulfill our legal and regulatory obligations, resolve disputes, to the extent permitted or required by law.

After this period, Your Personal Data will be erased from all systems of C–Pack Creative Packaging S/A.

SITE USERS

PURPOSES AND LEGAL BASIS - How and why do we process your personal data?

C–Pack Creative Packaging S/A collects and processes Your Personal Data with the purpose of measuring the audience of our Site, optimizing our Site, and analyzing how it is used.

The collection and processing of Personal Data is carried out based on Our legitimate interest in the functional management of our commercial activity in order to better know our customers and/or prospects and improve their experience on the Site, based on the legitimate interest of the person responsible for the handling referred to in Article 6(1)(f) of the GDPR.

PERSONAL DATA CATEGORIES - What data do we collect about you?

We may collect your personal data through the use of our website.

We collect, process, and use the following categories of Personal Data about you for the purposes set out below:

– Information related to the use of the website.

– Information related to the use of the website means all information collected through the website, such as actions taken on the website (e.g., log files identifying clicks made on the website) and information about how You use the website.

– IP address. When you use the website, we may automatically record your IP address (the unique address that identifies your computer on the Internet), which is automatically recognized by our server.

- Cookies. A "cookie" is a small text file that we may use to collect information about your website activity. For example, when someone visits a page on the Site, a cookie is placed on the user's machine (if the user accepts cookies) or reads whether the user has already visited the Site. Cookies can also be used to track users on the Internet. Most browsers can be set to notify you when you receive a cookie; you can also choose to block cookies from your browser by modifying your settings or using our cookie consent tool, but in this case, you will not be able to take advantage of the personalized features used by other users visiting the site. Some of the cookies we use may be flash cookies or Adobe cookies. To find out more about the terms of use for cookies, see our Cookies Policy.

– Web beacons (also called "GIF web beacons" or "web beacons"). Web beacons are tiny, uniquely identifiable images that act as cookies and allow us to count users who visit certain pages on the website and help us determine the effectiveness of promotional or advertising campaigns. When used in HTML emails, web beacons can inform the sender if and when the email has been opened. Unlike cookies, which are stored on the user's computer hard drive, web beacons are embedded in web pages invisibly.

RECIPIENTS - Who do we share your personal data with?

When necessary, C–Pack Creative Packaging S/A may disclose Your Personal Data to:

C–Pack Creative Packaging S/A personnel from relevant entities within C–Pack Creative Packaging S/A and subcontractors responsible for managing this Site;

Regarding the disclosure of Personal Data described above, C–Pack Creative Packaging S/A:

Following processes and procedures ensures that disclosures are made only to internal personnel who are authorized to receive this information and who need the information to fulfill their job responsibilities; will provide Personal Data only to third party vendors authorized to receive and process this information and who have contractually agreed to (i) use technical and other appropriate measures to protect this information and (ii) process this information as instructed by C–Pack Creative Packaging S /A and as necessary, to perform its services to C–Pack Creative Packaging S/A; and will comply with applicable laws and regulations.

In the event that C–Pack Creative Packaging S/A is sold or all or part of its business is otherwise transferred to a third party, the Personal Data that C–Pack Creative Packaging S/A collected and maintained about You may be transferred to that third party, subject to applicable legal requirements.

C–Pack Creative Packaging S/A may also disclose information about you in cases where we have a good faith belief that we are required to do so by law, including pursuant to a court order or in circumstances where we believe such action is necessary to prevent fraud or cybercrime or to protect the rights, property or safety of C–Pack Creative Packaging S/A or any person, in each case, as required or permitted by applicable laws and regulations.

RETENTION PERIODS - How long will we keep your personal data?

We will retain Your Personal Data for a maximum period of thirteen (13) months. After this period, your personal information will be deleted from all systems of C–Pack Creative Packaging S/A or made anonymous.

TRANSFERS

Is your personal data transferred to other countries? Why?

We may transfer Your Personal Data to affiliates of C–Pack Creative Packaging S/A, including entities located outside the European Economic Area, in countries where the level of data privacy protection is not considered equivalent to that applicable in European countries. We have entered into data transfer agreements based on the European Commission's model clauses with such affiliates to cover the protection of Your Personal Data.

In addition, we may use, for the purposes listed in this Privacy Policy, third party service providers that may also be located outside the European Economic Area, specifically data processors located in the United States, to provide applications and software. We enter into contractual agreements based on the model clauses of the European Commission to ensure the transfer of data to these data processors or we verify that these data processors comply and adhere to the Privacy Shield, which has been considered by the European Commission to be a sufficient level of protection for the transfer of personal data to the United States.

Any onward transfer (including C–Pack Creative Packaging S/A affiliates outside the EEA) is subject to compliance with applicable onward transfer requirements as mandated by applicable law.

DATA SUBJECT RIGHTS

What are your rights to your personal data?

If you have any questions about the personal data that C–Pack Creative Packaging S/A has collected about you, or if you wish to exercise any of your other rights under applicable data protection laws and regulations, please contact:

If you are a candidate: the email address indicated in the job offer;
If you are a customer: etica@en.c-pack.com.br; or
If you are a supplier: etica@en.c-pack.com.br
You have the right (i) to access Your Personal Data and information about the processing carried out by C–Pack Creative Packaging S/A, (ii) to request correction, supplementation or deletion of Personal Data about You that is inaccurate, incomplete or outdated , (iii) to request restriction on the collection, processing or use of personal data about you, (iv) to request data portability, (v) to give instructions regarding the retention, deletion and communication of your personal data after your death, or (vi) to obtain a copy of the appropriate safeguards put in place with respect to the cross-border transfers of the data set out above.

You also have the right, under certain circumstances, to object for legitimate reasons to the processing of Your Personal Data.

You also have the right to refuse any direct marketing communications by following the instructions attached to such email communications.

Please help us keep Your Personal Information updated by informing us of any change in name, address, or circumstance.

In case of complaints, you also have the right to file a complaint with the competent data protection authority.

SAFETY

How do we protect your personal data?

We take reasonable steps to ensure protection against any unauthorized access to and illegal use of Your Personal Data and against loss, destruction, or damage to Personal Data. We use physical, logical, and technical measures, as well as organizational and procedural controls to protect Your personal data, all subject to regular review.

By hiring a third-party service provider to process Your Personal Data, we ensure that they are also bound by a contract that guarantees a high standard of privacy protection and requires (among other provisions) that they only act in accordance with Our instructions and implement all measures necessary techniques on an ongoing basis to keep your personal data secure.

INFORMATION AND UPDATES

How are you informed and who to contact if you have any questions about privacy?

If you have any questions, comments or concerns about your personal data or this policy, please contact:

If you are a candidate: the email address indicated in the job offer;
If you are a customer: etica@en.c-pack.com.br; or
If you are a supplier: etica@en.c-pack.com.br

You are welcome to review this Privacy Policy regularly as it may be periodically updated to take account of changes in laws, regulations, or company practices.