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Oliver Privacy Notice

Effective Date: 22 May 2018

Oliver-Tolas Healthcare Packaging B.V., Oliver Healthcare Packaging Ireland Limited, Oliver Products Company, Oliver-Tolas Healthcare Packaging, Inc., Mangar Industries, Inc., Oliver Healthcare Packaging (Suzhou) Co., Ltd., Oliver Healthcare Packaging Asia Pte. Ltd., and Oliver Packaging and Equipment Company (collectively, "Oliver," we," "us," or "our") are committed to respecting your privacy. In support of our commitment, we developed this privacy notice to be transparent about the data we collect about you and how it is used and shared, as well as the choices and rights available to you with respect to the data we maintain about you. This privacy notice applies to:

• All Oliver websites, applications, communications, advertisements, and other online services and resources that display or link to this privacy notice (collectively, our "website and online services"), but excluding websites or online services that display or are otherwise provided under a different privacy policy or notice.
• Information about you collected offline or through our call centers (e.g., information contained in a business card provided to us at a trade show or information provided to a customer service rep over the phone), but excluding instances where your information is collected under a different privacy policy or notice made available to you at the time your information is collected.
• Information about you shared with us by third parties for our own use, as well as publicly-available information collected by us.

[If you reside in the United States or elsewhere outside of Europe, Oliver Products Company will be responsible for the data we collect, maintain, or otherwise process about you. If you reside in Europe, Oliver-Tolas Healthcare Packaging B.V. will be the controller of your personal data and responsible for the processing of such data by or on behalf of Oliver, and Oliver Healthcare Packaging Ireland Limited will be joint controller of such data.

I.  Information We Collect and How We Use It

     Collection and Use of Personal Data

     Personal Data Collected

We collect information that can be used to identify or contact a person (we refer to this as "personal data"). Personal data includes information that does not directly identify you by name or include your contact information, but which may be used to identify that a specific computer or device has accessed our website and online services and which if combined with certain other information could be used to identify you. The types of personal data we collect and process include:

We collect personal data when you provide it to us directly (e.g., when you submit a contact form through our website or provide us with your business card at a trade show); when generated by your activity on our website and online services (e.g., the amount of time spent on a particular page of our website); when shared with us by our business partners (e.g., email marketing vendors, trade show sponsors, or HR staffing agencies); and when available through publicly-available sources (e.g., information shared by you on LinkedIn).

         Use of Personal Data

We collect, use, store, organize, structure, disclose, or otherwise process personal data as described below:

• We process personal data for the purposes for which such personal data was provided. For example, if you share your name and contact information with us when submitting an inquiry or requesting information through our website, we will use this information to respond to you and provide you with the information requested. If you register to access an online portal or other online service requiring registration, we will use the information submitted by you to provide you with access to the relevant service and to maintain your account. If you purchase a product or service from us, we will use the personal data provided by you to fulfill the order and satisfy related contractual obligations, including to process your payment, facilitate delivery, and comply with any applicable service or warranty obligations (in these situations, we may also save your payment information so that you can use it the next time you want to order a product or service from us).
• To send you news and information about products and services that may be of interest to you, including to personalize your online service experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our website and online services, third-party sites, and via email or text message.
• To send important notices, such as communications about purchases and changes to our terms, conditions, and policies. Because this information is important to your interaction with Oliver, you generally may not opt out of receiving these communications.
• To help maintain the safety, security, and integrity of our website and online services, products, databases and other technology assets.
• For internal administrative purposes, such as auditing, data analysis, and research to improve our products, services, and customer communications. This includes processing for purposes of statistical analysis, including Google Analytics.
• For marketing activities, including third-party cookie tracking and creating an interest-based profile related to your interactions with us or others. See the section on Collection and Use of Non-Personal Data below and our Notice on Use of Cookies and Similar Technologies for additional information.
• If you enter a sweepstake, contest or similar promotion, we use the information you provide to administer such programs.
• To arrange interviews, consider you for employment, and personnel administration (to the extent you apply for a job through our website and online services).
• Where we have legal obligations to process the personal data and for legal proceedings and government investigations (such as pursuant to warrants, subpoenas, and court legal orders).
• To manage data subject requests.
• For internal investigations of possible misconduct or failure to comply with our policies and procedures.
• For the other purposes described in this privacy notice and our Notice on Use of Cookies and Similar Technologies.

The applicable legal bases for our processing of your personal data include the following:

• Based on your consent: In some cases, at the point at which you provide personal data, we may ask you for your consent to collect and process your personal data. If you provide us with your consent, you may later withdraw your consent (or opt-out) by contacting us as described below. If you withdraw your consent it will not affect any processing of your personal data that has already occurred. Where we process your personal data based on consent, we will provide more detailed information to you at the time when we obtain your consent.
• Compliance with applicable laws or performance of a contract: In specific circumstances, we may need to process your personal data to comply with a relevant law/regulation or to fulfill our obligations under a contract with you. Where we process your personal data to meet our legal obligations, you will likely not be permitted to object to this processing activity, but you will usually have the right to access or review this information unless it would impede our legal obligations. Where we are processing your personal data to fulfill our obligations under a contract with you, you might not be able to object to this processing, or if you do choose to opt-out or object to our processing, it may impact our ability to perform a contractual obligation that you are owed.
• Our legitimate interest: We may process your personal data based on our legitimate interests in communicating with you and managing our interactions with you regarding our products and services, scientific research, and educational opportunities. In addition to other rights you may have as described below, you have the right to object to such processing. You can register your objection by contacting us as described below.

       Collection and Use of Non-Personal Data

         Non-Personal Data Collected

When you use our website and online services, we also collect certain non-personal data that does not, on its own, identify any individual. The types of non-personal data we collect and process include:

• Log Data. When you use or interact with our website and online services, our servers record certain information that is automatically reported by your browser (such as Apple's Safari, Microsoft's Edge, Google's Chrome, or Mozilla's Firefox) or device each time you request our website and online services, or when content is downloaded to your browser or device from our website and online services. This "log data" includes your IP address (which is used to infer approximate location); Internet service provider; browser type and settings (e.g., content language, cookie/DNT preferences); device information (e.g., type of device, operating system, device manufacturer); referring/exiting URL; request/response date and time; clickstream data; device ID or advertising ID; and data contained in first-party cookies and similar technologies (discussed further below and in our Notice on Use of Cookies and Similar Technologies). However, to the extent that Internet Protocol (IP) addresses or similar identifiers are considered personal data by local law, we also treat these identifiers as personal data.
• Location Data. Depending on the website and online services and your computer or device permissions, we may collect information about your device's approximate (e.g., country or zip code) or precise location ("location data"). Various technologies may be used to collect this location information, such as IP address, GPS, and other sensors that may provide information on nearby devices, Wi-Fi access points, and cell towers. We will only collect your computer's or device's precise location with your consent.
• Cookie data. Our website and online services use cookies, pixel tags, software development kits, statistical identifiers, and similar technologies (referred to as "cookies and similar technologies") to collect and store certain non-personal data (such as log data, location data, and cookie data) when you visit or interact with our website and online services to help us secure our website and online services, as well as the information processed by our website and online services; monitor and enhance the performance of our website and online services; better understand user behavior; and facilitate and measure the effectiveness of advertisements and website features (information contained in or generated by the use of cookies and similar technologies is referred to in this privacy notice as "cookie data"). We treat information collected by cookies and similar technologies as non‑personal data. These cookies and similar technologies, including their use on our website and online services and your choices regarding such use, are further described under our Notice on Use of Cookies and Similar Technologies.
• Aggregated data. In addition, when we aggregate or anonymize information (including personal data), such aggregated or anonymized information is considered non‑personal data for the purposes of this privacy notice.

Please see our Notice on Use of Cookies and Similar Technologies to learn more about our use of cookies and similar technologies, the types of non-personal data collected through these technologies, and your choices regarding their use on our website and online services.

         Use of Non-Personal Data

We may collect, use, transfer, and disclose non-personal data for any purpose. However, if we combine non-personal data with personal data, the combined information will be treated as personal data for as long as it remains combined. We use non-personal data for a number of legitimate business purposes, some of which are described below:

• We collect log data, location data, and cookie data so that we can better understand website user behavior and improve our products, services, and advertising.
• Oliver and our online partners use cookies and similar technologies to remember personal data when you use our website and online services. Our goal in these cases is to make your experience with Oliver more convenient and personal. Knowing your country and language helps us provide a customized and more useful website experience. Knowing someone using your computer or device has shopped for a certain product or used a website feature helps us make our advertising and email communications more relevant to your interests. In such cases, if we associate non-personal data with personal data, the combined information will be treated as personal data for as long as it remains combined.
• We collect information regarding user activities on our website and online services. This information is aggregated and used to help us provide more useful information to our customers and website users, and to understand which parts of our website and online services are of most interest. Aggregated data is considered non‑personal data for the purposes of this privacy notice.
• We use non-personal data (including log data, location data, and cookie data) to understand and analyze trends, to administer the website and online services, to learn about user behavior on the website and online services, to improve our products and services, and to gather demographic information about our user base as a whole.

We may also collect similar data from emails sent to you to help us track which emails are opened and which links are clicked by recipients. In some of our email messages, we use a "click-through URL" linked to content on the Oliver website and online services. When customers click one of these URLs, they pass through a separate web server before arriving at the destination page on our website and online services. We track this click-through data to help us determine interest in topics and measure the effectiveness of our customer communications. If you prefer not to be tracked in this way, you should not click text or graphic links in the email messages.

• We may also use non-personal data (including log data, location data, and cookie data) to maintain and improve our website and online services; verify and authenticate users of our website and online services; prevent fraud and secure our website and online services and databases; process payments; facilitate product and service delivery; remember and analyze user preferences and interests; track and measure website and online service performance and effectiveness; develop and improve our products and services; deliver ads relevant to user interests or based on user location, demographics or device characteristics; and for any other purpose described in this privacy notice or our Notice on Use of Cookies and Similar Technologies.

Please see our Notice on Use of Cookies and Similar Technologies to learn more about our collection and use of non-personal data.

       Combining Information

Where permitted by law, we may combine the personal data you provide to us through the website and online services with information we collect through other Oliver website and online services, Oliver's offline records, and information provided to us by third parties. Where permitted by law and feasible, we may also combine your personal data with information collected through your use of the website and online services (such as log data, location data, and cookie data), in which case we will treat any information that is combined or associated with your personal data as personal data for as long as it can reasonably be linked with your personal data. We use this consolidated information to improve our website and online services and product offerings, enhance our marketing and research activities, communicate information to you, and for any other legitimate purpose described in this privacy notice.

II.  How Personal Data is Shared and Transferred

       Personal Data Shared with Third Parties

We disclose your personal data to third parties who provide us with various business services (e.g., monitoring and maintaining our website or internal business applications, preparing newsletters and mailings, and payments of commissions or other amounts). These service providers and contractors are restricted from using this personal data in any way other than to provide services on our behalf and subject to our documented instructions only.

We may also share your personal data with Oliver affiliates (e.g., for internal administrative purposes or where an Oliver affiliate supports a particular Oliver business function). The names and locations of such Oliver affiliates can be found here (Oliver affiliates) and here (Berwind).

We may also partner with other companies to provide you with products, services, or content on a joint or 'co-branded' basis. If we offer co-branded products, services or content, you may see both our logo and the logo of the co-branded partner. To access or use co-branded products, services or content, you may have to provide certain requested information which may be shared with our co-branded partners. You should read the individual privacy policies and terms of use of our co-branded partners, as these may differ in some respects from this privacy notice. You can always opt-out of sharing your personal data with a co-branded partner by choosing not to use the product, service or content provided.

We may also disclose information we collect to legal counsel, law enforcement, and other appropriate authorities in special cases, including: (i) when we have a reason to believe that such disclosure is necessary to identify, contact, or bring a legal action against someone who may be causing injury to or interference with our rights and property or those of any other person; or (ii) when we believe that it is required by applicable laws, court orders, or government regulations.

If all or part of Oliver is merged into another entity, the information we have about you may be transferred to a third party as part of that transaction. Your information may also be included among the assets affected by financing agreements undertaken by Oliver.

        International Transfers of Personal Data

In some instances, the service providers, business partners, Oliver affiliates, and others that we share personal data with are in other countries. The level of protection for your personal data in these other countries may not be the same as the level of protection in your country. In these cases, we protect any information transferred to third countries using appropriate safeguards, such as contractual clauses approved by relevant supervisory authorities (where required and applicable). If you reside in Europe or your personal data is otherwise subject to European law, all Oliver affiliates outside of the European Union that access or receive your personal data are subject to data protection contracts approved by the European Commission and that impose on such affiliates a level of protection for your personal data equivalent to European data protection requirements.

If you are visiting this website or online service from a country other than the United States, your information will cross an international boundary. The level of protection for your information in the United States may not be the same as the level of protection in your country. Your use of the website or online service will result in the collection, storage, and processing of your information in the United States and in any country to which we may transfer your information during our business operations.

In any event, we only share personal data with Oliver affiliates and third parties performing services on our behalf if such affiliates and third parties provide sufficient guarantees to implement appropriate technical and organizational measures in such a manner that the processing they conduct will meet the requirements of applicable law and ensure the protection of your personal data.

III.   Your Rights

You have various rights with respect to the collection, use, transfer and processing of your personal data, as described below. However, we reserve the right to limit these rights at any time where permitted under applicable law, including where your identity cannot be reasonably verified or to the extent your rights adversely affect the rights and freedoms of others. To exercise any of the rights below, please contact the Oliver affiliate responsible for the processing of your personal data using the applicable contact information below.

         Access Right

You have the right to obtain confirmation as to whether or not your personal data is being processed by Oliver. Where we are processing your personal data, you have the right to access the data and to obtain certain information about the processing of such data.

        Right to Rectification

You have the right to obtain rectification of any personal data that is inaccurate or incomplete, including by means of providing a supplementary statement.

        Right to Erasure

You have the right to have your personal data erased where one of the following applies:

• Your personal data is no longer necessary with regards to the purposes for which it was collected.
• You withdraw your consent (where the processing is based on such consent).
• You object to the processing where such processing is based on Oliver's (or a third party's) legitimate interest and there are no overriding legitimate grounds for the processing.
• Your personal data must be erased to comply with a legal obligation under applicable law.

However, this right to erasure will not apply to the extent the processing is necessary for:

• Compliance with a legal obligation which requires processing; or
• Archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes, to the extent permitted under applicable law.

        Right to Restriction of Processing

You have the right to restrict the processing of your personal data where one of the following applies:

• The accuracy of the personal data is contested.
• The processing is unlawful and you oppose the erasure of your personal data and request the restriction of its use instead.
• Oliver no longer needs the personal data for the purposes of the processing, but it is required for the establishment, exercise or defense of legal claims.
• Where the processing is based on Oliver's (or a third party's) legitimate interest and you have objected to processing (as described immediately below).

        Right to Object

You have the right to object (on grounds relating to your situation) at any time to the processing of your personal data for direct marketing purposes or where the processing is based on Oliver s (or a third party's) legitimate interest. When objecting to processing based on our legitimate interest, Oliver will no longer process your personal data unless Oliver demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise, or defense of legal claims.

        Right to Withdraw Consent

Where the processing of your personal data is based on your consent, you have the right to withdraw such consent at any time, without affecting the lawfulness of processing based on consent before such withdrawal.

        Right to Data Portability

You have the right to receive your personal data, which you have provided to Oliver, in a structured, commonly used and machine-readable format, and have the right to transmit such data to another entity without hindrance from Oliver, where each of the following conditions are met:

• Your request does not adversely affect the rights of others;
• Your request does not adversely affect Oliver's rights (including intellectual property rights);
• The processing is based on your consent or the performance of a contract to which you are a party; and
• The processing is carried out by automated means.

       Right Not to Be Subject to Solely Automated Decisions

You have the right not to be subject to a decision based solely on automated processing (including profiling) which produces legal effects concerning you or similarly significantly affects you, unless permitted under applicable law.

       Right to Submit a Complaint to Supervisory Authorities

IV.  How We Protect Personal Data

We provide reasonable technical, physical, and organizational safeguards to protect your personal data, including safeguards designed to protect personal data from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed which may lead to physical, material or non-material damage. To the extent appropriate or required by applicable law, these security measures include:

• Access to personal data is limited to authorized employees and service providers who need access to perform the activities described in this privacy notice on our behalf.
• Personal data is pseudonymized where appropriate or required by law, and sensitive personal data transferred to or stored on any mobile device is encrypted using industry-accepted encryption solutions.
• Oliver personnel engaged in the processing of personal data are informed of the confidential nature of personal data, receive appropriate training on their responsibilities, and are obligated pursuant to Oliver policy to maintain the confidentiality of personal data.
• The effectiveness of Oliver security measures is regularly tested, assessed, and evaluated to ensure the ongoing security of processing systems.
• Internet-connected databases containing personal data are monitored for unauthorized intrusions using network-based and/or host-based intrusion detection mechanisms.
• Service providers and other third parties engaged by us to process personal data on our behalf are contractually obligated to process personal data only on our documented instructions and must provide similar security measures as those used by Oliver or as required under applicable law.

Although we strive to provide reasonable and appropriate security for the personal data we process and maintain, no security system can prevent all potential security breaches. In particular, email or forms sent using our website and online services may not be secure. You should take special care before deciding to send us information via email. Further, if you create an account through our website and online services, it is your responsibility to protect your access credentials from unauthorized access or use.

V.  Retention and Deletion of Personal Data

Oliver implements and maintains reasonable restrictions on the retention of personal data and generally disposes of such personal data once it is no longer necessary for the purposes for which it was collected or further processed. However, we may continue to store archived copies of your personal data for legitimate business purposes and as necessary to comply with applicable law. In addition, we may continue to store anonymous, aggregated or anonymized information for any legitimate business use described in this privacy notice.

VI.  Links to Third-Party Websites

This privacy notice only applies to Oliver websites and online services that link to this privacy notice. However, our website and online services may contain links to third-party sites or services (e.g., websites relating to industry trade shows and conferences). We do not endorse and are not responsible for the content of third-party websites or resources, and our privacy notice does not apply to any sites that are not controlled by Oliver, even if you access such sites via a link on our website and online services. You should review the privacy policies and terms of use of any third-party site before providing any information to the controller of such site.

VII.  How to Contact Us

If you have any questions about this privacy notice, our use of your personal data, or your rights with respect to such use, you may contact the applicable Oliver affiliate using the contact information below:

VIII.  Changes to Our Privacy Notice

Oliver reserves the right to amend this privacy notice at our discretion and at any time. When we change it, we will post the updated notice on our website and online services, and it will be effective as of the date posted. Your continued use of our website and online services following the posting of changes will constitute your acceptance of such changes.