Last Updated and Effective: August 1, 2022
Good data handling is central to everything we do.
It is important to explain how we handle your data and highlight the steps Novolex takes to protect your information.
This Privacy Policy ("Policy") has been prepared for this purpose - it sets out how Novolex and its affiliates and subsidiaries, (collectively “Novolex”, "we", "us", "our") collect and use your personal information and any rights you may have.
Certain parts of this Policy only apply to users in the EU / UK and some parts only apply to users in California – we have flagged this in the relevant section.
Contact Us: If you have questions, please contact us at privacy@novolex.com. For your protection, we may need to verify your identity before assisting with your request.
Information you give us
You may give us information in many ways and in different forms ("personal information"). This may include information that can directly or indirectly identify you (either in isolation or combined with other information). You give us your personal information when you:
If you are a California resident, please see Appendix below.
Information we collect automatically
When you visit our website, we may automatically collect your:
We may also collect information about you through our security systems (such as CCTV) when you visit our premises or attend our events.
Information we receive from other sources
We may receive information about you from other sources if you use any of the other services we provide on this website, or from other Novolex affiliates or subsidiaries. We also work closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, analytics providers, credit reference agencies) and may receive information about you from them (including information that is publicly available). We process all personal information we obtain from such other sources in accordance with this Policy.
Sensitive information
Generally, we do not intentionally process personal information which falls within the meaning of 'special category data' (e.g., information relating to criminal activity, information which may disclose details of your racial or ethnic origin, or which implies specific religious or political beliefs). Where we do process this type of personal information we will only do so with your consent.
We use the information we collect to provide you with the best possible experience when you access our website and engage with us, including by buying or using our services and products. This includes using your information for the following purposes:
Data sharing
We may share your information with Novolex affiliates and subsidiaries and with other third parties, including organisations providing a service to us or acting as our agents, including, but not limited to, sub-contractors (including their agents), consultants and professional advisers, advertising agencies, infrastructure and IT suppliers, database providers, backup and disaster recovery specialists, email providers, insurance companies, auditors, financial institutions, payment service providers and other service providers necessary for improving our products and services.
We may also share your information with third parties when: (1) it is necessary to involve a third party service provider in order to facilitate or extend our services; (2) explicitly requested by you; (3) required by a court order or any legal or regulatory requirement; (4) in connection with the sale, merger, consolidation, change in control, transfer of assets, bankruptcy, liquidation, restructure or reorganisation of a business (or a part thereof); (5) to enforce our contracts and if we are defending a legal claim your information may be transferred as required in connection with defending such claim; (6) to ensure the safety and security of our users, customers, consumers and third parties; and (7) to protect our rights and property and the rights and property of our guests and third parties.
The information we provide them, including your personal information, will only be provided in connection with the performance of their function. They will not be permitted to use your personal information for any purposes other than those outlined in this Policy.
We may share non-personal information with third parties as reasonably necessary to meet our business needs.
We do not sell or rent personal information.
EU / UK Users only
The legal grounds that we rely on to use or otherwise process such users' personal information are:
Where required by law, your prior consent will be obtained before we send you direct marketing.
You may choose not to receive direct marketing from us at any time by contacting us or selecting the unsubscribe option in our email communications.
Links to other websites Where we provide links to other websites, we do so for informational purposes only. If you access other websites using the links provided, the operators of these websites may collect information from you which will be used by them in accordance with their privacy policy, which may differ from ours.
Data retention and security We will not retain your information for longer than is reasonably necessary for our business purposes, to resolve potential disputes, or for our legal or regulatory requirements (including for the purpose of satisfying any tax, accounting, or reporting requirements).
We will also retain a copy of your contact details if you object or opt out of receiving direct marketing communications from us. We will add your details to our suppression list to ensure you do not receive any future marketing communications from us.
When determining the appropriate retention period for personal information, we take into consideration (among other things) sensitivity of the information, risk of harm, purposes of processing, other available means, our relationship, and legal and regulatory requirements.
When we no longer need to use your information, we will remove it from our systems or take steps to promptly anonymise it so that you can no longer be identified from it.
We apply physical, technical, and administrative measures to protect your personal information that is under our control from unauthorised access and use. All information you provide to us is stored on secure servers.
As the Internet is an open global communications system, we cannot guarantee that any information, during transmission or while stored on our systems will be definitively safe from intrusion by others. If you suspect an unauthorized use or security breach of your personal information, please contact us immediately.
EU / UK Users only
You have the following rights when it comes to our handling of your personal information:
You also have the right to lodge a complaint with the relevant supervisory authority in your jurisdiction if you believe that we have not complied with our data protection obligations. If you are based in, or the issue relates to, the UK, the Information Commissioner's Office's contact information can be found here: www.ico.org.uk/concerns.
California Users only
We do not share personal information of California users with third parties for their own direct marketing purposes without your consent. California users under 18 years old, in certain circumstances, may request and obtain removal of personal information or content that they have posted on our website or services. Please be mindful that this would not ensure complete removal of the content posted on our website or services.
In accordance with applicable California data protection laws – the following rights when it comes to our handling of California User’s personal information:
Given that the Internet is a global environment and Novolex is an international organisation, using the Internet to collect and process personal information necessarily involves the transmission of data on an international basis. It is possible that your personal information will be transmitted to parties outside your region, including other Novolex affiliates or subsidiaries, where data protection laws may be different. We continue to take steps to protect data and ensure we are complying with all applicable data privacy laws and regulations.
This appendix seeks to provide additional information to residents of California and supplements the information provided in the Privacy Policy above.
To learn more about the categories of personal information we collect, how we collect it, why it is collected, with whom we share the information, and how long we retain it, please see the chart below.
Good data handling is central to everything we do.
It is important to explain how we handle your data and highlight the steps Novolex takes to protect your information.
This Privacy Policy ("Policy") has been prepared for this purpose - it sets out how Novolex and its affiliates and subsidiaries, (collectively “Novolex”, "we", "us", "our") collect and use your personal information and any rights you may have.
Certain parts of this Policy only apply to users in the EU / UK and some parts only apply to users in California – we have flagged this in the relevant section.
Contact Us: If you have questions, please contact us at privacy@novolex.com. For your protection, we may need to verify your identity before assisting with your request.
How we collect information from you
Information you give us
You may give us information in many ways and in different forms ("personal information"). This may include information that can directly or indirectly identify you (either in isolation or combined with other information). You give us your personal information when you:
- visit or use our website
- correspond or communicate with us (whether in person, through our website, email, over the phone or via any other medium)
- enquire about or purchase our goods or services
- subscribe to one of our newsletters
- provide us with information we request from you.
- name
- email address, phone number, or other contact information
- delivery or billing address (your or your employer's)
- payment information
- details of goods or services purchased
- location
- company
- job title
- your comments and questions
- details of our messages to you and from you (including when you sent it, when we received it and where you sent it from)
- details of the preferences you express to us
- other information set out in the relevant forms or pages you are filling out
- any additional information you chose to provide us when you contact us or otherwise interact with us (including the circumstances of your communication with us).
If you are a California resident, please see Appendix below.
Information we collect automatically
When you visit our website, we may automatically collect your:
- IP address
- log-in information
- browser type and version
- browser plug-in types and versions
- operating system and platform
- device type
- device identifiers
- information about your visit (including the URL clickstream to, through and from our website, content you viewed or searched for, download errors, timing, and length of visits to certain pages and page interaction).
We may also collect information about you through our security systems (such as CCTV) when you visit our premises or attend our events.
Information we receive from other sources
We may receive information about you from other sources if you use any of the other services we provide on this website, or from other Novolex affiliates or subsidiaries. We also work closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, analytics providers, credit reference agencies) and may receive information about you from them (including information that is publicly available). We process all personal information we obtain from such other sources in accordance with this Policy.
Sensitive information
Generally, we do not intentionally process personal information which falls within the meaning of 'special category data' (e.g., information relating to criminal activity, information which may disclose details of your racial or ethnic origin, or which implies specific religious or political beliefs). Where we do process this type of personal information we will only do so with your consent.
How we use your information
We use the information we collect to provide you with the best possible experience when you access our website and engage with us, including by buying or using our services and products. This includes using your information for the following purposes:
- providing and improving our products and services: we use your information to provide you with, and improve, the products and services you have requested, including when making purchases, sending you confirmation emails, or contacting you regarding any account you have with us. Where relevant, this also includes using your information to makec payment to you or take payment from you (or your company). We may also use your information to register you for events. We use your information to improve our products, services, and website to better suit the needs of our customers and website users;
- creating and managing our relationship with you: we use your information to create your account, create a profile of you on our systems and manage our relationship with you. We also use your information to communicate with you regarding our relationship, including in connection with our products and services that you purchased (we will also keep records of certain of your personal information to maintain our internal records). Where you have asked not to be contacted by us, we will keep records of your preferences to maintain an up-to-date suppression list;
- administering the website: we use your information to administer our website for internal operations, including to understand any errors you may encounter when using our website;
- safety and security: we use information collected to keep our website and properties safe and secure and to help manage and administer our IT (Information Technology) systems;
- marketing: we use your information to communicate with you and keep you up to date with our activities and those of Novolex group companies that you or your company may be interested in and to make suggestions and recommendations to you and other users of our website about goods or services that may interest you or them. We may provide you with this information via email, text, or telephone;
- investigating any complaints and providing customer service: we may use your information to investigate any complaints on your behalf and to provide you with a more efficient customer care service;
- recruitment: We accept online applications to work in our company or in other companies of the Novolex group through the 'Careers' page of the website. We will receive the information provided in the application and supporting documentation (which may include a curriculum vitae and covering letter). We will use your personal information only for the purposes of progressing the recruitment process, assessing, and making a decision about your suitability for a role, communicating with you and carrying out reference checks. We will also use your information to comply with legal and regulatory requirements; and
- to comply with applicable law and make necessary disclosures: we may use your information to comply with applicable law and make necessary disclosures in response to requests which we are legally required to comply with, to law enforcement or regulatory authority, body, or agency or in the defence of a legal claims.
Data sharing
We may share your information with Novolex affiliates and subsidiaries and with other third parties, including organisations providing a service to us or acting as our agents, including, but not limited to, sub-contractors (including their agents), consultants and professional advisers, advertising agencies, infrastructure and IT suppliers, database providers, backup and disaster recovery specialists, email providers, insurance companies, auditors, financial institutions, payment service providers and other service providers necessary for improving our products and services.
We may also share your information with third parties when: (1) it is necessary to involve a third party service provider in order to facilitate or extend our services; (2) explicitly requested by you; (3) required by a court order or any legal or regulatory requirement; (4) in connection with the sale, merger, consolidation, change in control, transfer of assets, bankruptcy, liquidation, restructure or reorganisation of a business (or a part thereof); (5) to enforce our contracts and if we are defending a legal claim your information may be transferred as required in connection with defending such claim; (6) to ensure the safety and security of our users, customers, consumers and third parties; and (7) to protect our rights and property and the rights and property of our guests and third parties.
The information we provide them, including your personal information, will only be provided in connection with the performance of their function. They will not be permitted to use your personal information for any purposes other than those outlined in this Policy.
We may share non-personal information with third parties as reasonably necessary to meet our business needs.
We do not sell or rent personal information.
Why we use your information
EU / UK Users only
The legal grounds that we rely on to use or otherwise process such users' personal information are:
- where you have provided your consent: for example, when using technologies such as cookies;
- where the processing is necessary for the performance of a contract: for example, to allow us to facilitate the provision of services or delivery of goods you have ordered;
- where we need to comply with a legal obligation: for example, we may need to disclose your data to a law enforcement agency or to your or our representatives acting in a legal dispute; and
- where the processing is necessary for the purposes of our legitimate interests: this includes to: (1) provide our products and services to you and ensure effective administration and management of your relationship with us; (2) ensure your account is adequately protected and that our website, premises, network and information technology are secure and are being used in an appropriate manner; (3) better understand how you use our products, services and website and to make improvements; (4) research and analyse the products and services you want; (7) provide security over our business and who we partner with (including to prevent, detect, or investigate unauthorized use of our systems and/or abuse or mistreatment of our staff and personnel and to protect against those risks and ensure we comply with the law and our policies); (8) to undertake fraud and security checks; (9) to enforce our legal rights and to manage any dispute and take legal or other professional advice and (10) develop and maintain relationships with vendors, partners and other companies and dealing with individuals who work for them. Please contact us if you require further information about our legitimate interests.
Where required by law, your prior consent will be obtained before we send you direct marketing.
You may choose not to receive direct marketing from us at any time by contacting us or selecting the unsubscribe option in our email communications.
Links to other websites Where we provide links to other websites, we do so for informational purposes only. If you access other websites using the links provided, the operators of these websites may collect information from you which will be used by them in accordance with their privacy policy, which may differ from ours.
Data retention and security We will not retain your information for longer than is reasonably necessary for our business purposes, to resolve potential disputes, or for our legal or regulatory requirements (including for the purpose of satisfying any tax, accounting, or reporting requirements).
We will also retain a copy of your contact details if you object or opt out of receiving direct marketing communications from us. We will add your details to our suppression list to ensure you do not receive any future marketing communications from us.
When determining the appropriate retention period for personal information, we take into consideration (among other things) sensitivity of the information, risk of harm, purposes of processing, other available means, our relationship, and legal and regulatory requirements.
When we no longer need to use your information, we will remove it from our systems or take steps to promptly anonymise it so that you can no longer be identified from it.
We apply physical, technical, and administrative measures to protect your personal information that is under our control from unauthorised access and use. All information you provide to us is stored on secure servers.
As the Internet is an open global communications system, we cannot guarantee that any information, during transmission or while stored on our systems will be definitively safe from intrusion by others. If you suspect an unauthorized use or security breach of your personal information, please contact us immediately.
What rights do I have?
EU / UK Users only
You have the following rights when it comes to our handling of your personal information:
- Right to access your personal information. You may have the right to request a copy of the personal information we have about you and an explanation as to how the personal information is used. We will endeavour to respond within an appropriate timeframe and, in any event, within any timescales required by law.
- Right to rectify, erase or restrict the processing of your personal information. You may have the right to request that we rectify, erase, or restrict the processing of your personal information. We may need to continue to retain your personal information if we need to retain such information to comply with a legal obligation or to establish, exercise or defend legal claims.
- Right to withdraw consent. Where you have provided your consent, you may withdraw your consent at any time by contacting.
- Right to data portability. You can ask us to help you move some of your information to other companies. To help with that you have a right to ask that we provide your information in an easily readable format to another company. This right only applies in certain circumstances: (i) the personal information is information which you have provided to us; (ii) the personal information is being processed on the basis of consent or to perform a contract with you; (iii) the personal information is processed by automated means; and (iv) this would not adversely affect the rights and freedoms of others.
- Right to object. Where we process your personal information based on our legitimate interest, you can object to the way we process your personal information. We will comply with your request unless we have compelling legitimate grounds for the processing which override your interests and rights, or if we need to continue to process the information for the establishment, exercise, or defence of a legal claim.
You also have the right to lodge a complaint with the relevant supervisory authority in your jurisdiction if you believe that we have not complied with our data protection obligations. If you are based in, or the issue relates to, the UK, the Information Commissioner's Office's contact information can be found here: www.ico.org.uk/concerns.
California Users only
We do not share personal information of California users with third parties for their own direct marketing purposes without your consent. California users under 18 years old, in certain circumstances, may request and obtain removal of personal information or content that they have posted on our website or services. Please be mindful that this would not ensure complete removal of the content posted on our website or services.
In accordance with applicable California data protection laws – the following rights when it comes to our handling of California User’s personal information:
- Right to access your personal information. you have the right to request a copy of the personal information that we collect, use, and disclose about you. Before responding to your request, we may ask you to verify your identity and to provide further details about your request. We will endeavour to respond within an appropriate timeframe and, in any event, within any timescales required by law. You also have the right to not receive discriminatory treatment for exercising your access right.
- Right to delete your personal information. you may have the right to request that we delete your personal information, subject to some exceptions under applicable law. Once we have received and confirmed your request, we will delete (and direct our partners and service providers to delete) your personal information, unless an exception under applicable law applies. You also have the right to not receive discriminatory treatment for exercising your deletion right.
International data transfers
Given that the Internet is a global environment and Novolex is an international organisation, using the Internet to collect and process personal information necessarily involves the transmission of data on an international basis. It is possible that your personal information will be transmitted to parties outside your region, including other Novolex affiliates or subsidiaries, where data protection laws may be different. We continue to take steps to protect data and ensure we are complying with all applicable data privacy laws and regulations.
Changes to the Policy
We may change this Policy from time to time. If we do so, we will post a notice on our website home page whenever this Policy is changed in a material or a substantial way. You can see the date this Policy was last updated at the top of the Policy.Appendix I: List of Data Controllers and Contact Details
| Country | Data Controller | Contact Information |
| United Kingdom | Vegware Limited | 39 Melville Street, Edinburgh, EH3 7JF, Scotland |
| United States | Eco-Products | 4755 Walnut Street, Boulder, CO 80301, United States |
| United States | Novolex | 101 E Carolina Avenue, Hartsville, SC 29550, United States |
| United Kingdom | Waddington Europe Limited | 37-39 Burners Lane, Kiln Farm, Milton Keynes, MK11 3HA |
| Ireland | Par-Pak Europe Limited | Avoca River Park, Arklow, Co., Wicklow, Ireland |
| Netherlands | Eureka CaterWare B.V | Schaapherderhof 9, 2988 CP Ridderkerk, The Netherlands |
| Netherlands | Burrows Netherlands B.V. | Klarenanstelerweg7, Kerkrade NL 6468 EP |
Appendix II: California Privacy Law
This appendix seeks to provide additional information to residents of California and supplements the information provided in the Privacy Policy above.
To learn more about the categories of personal information we collect, how we collect it, why it is collected, with whom we share the information, and how long we retain it, please see the chart below.
| Category | What we collect | How we collect it | Why we collect it | With whom we share it | How long we retain it |
|---|---|---|---|---|---|
| Identifiers | Name, mailing address, email address, phone number, payment information, and other contact information. For more information please see the Information We Collect section above. | Collected online or offline when you directly provide it to us, through your use of our website or services, or from third parties. | We collect this information for the purposes listed in the How We Use Information section above. | Shared with our affiliates, partners, vendors, and service providers as described in the How We Share and Disclose Information section above. | We will not retain your information for longer than is reasonably necessary for our business purposes or for legal or regulatory requirements as described in the Data Retention section above |
| Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) | Name, mailing address, email address, phone number, payment information, and other contact information. For more information please see the Information We Collect section above. | Collected online or offline when you directly provide it to us, through your use of our website or services, or from third parties. | We collect this information for the purposes listed in the How We Use Information section above. | Shared with our affiliates, partners, vendors, and service providers as described in the How We Share and Disclose Information section above. | We will not retain your information for longer than is reasonably necessary for our business purposes or for legal or regulatory requirements as described in the Data Retention section above |
| Protected classification characteristics under California or federal law | Age and date of birth. For more information please see the Information We Collect section above. | Collected online or offline when you directly provide it to us, through your use of our website or services, or from third parties. | We collect this information for the purposes listed in the How We Use Information section above. | Shared with our affiliates, partners, vendors, and service providers as described in the How We Share and Disclose Information section above. | We will not retain your information for longer than is reasonably necessary for our business purposes or for legal or regulatory requirements as described in the Data Retention section above |
| Commercial information | Transactional information such as the products or services purchased. For more information please see the Information We Collect section above. | Collected online or offline when you directly provide it to us, through your use of our website or services, or from third parties. | We collect this information for the purposes listed in the How We Use Information section above. | Shared with our affiliates, partners, vendors, and service providers as described in the How We Share and Disclose Information section above. | We will not retain your information for longer than is reasonably necessary for our business purposes or for legal or regulatory requirements as described in the Data Retention section above |
| Biometric information | Not collected. | N/A | N/A | N/A | N/A |
| Internet or other similar network activity | IP address, browser type and version, browser plug-in types and versions, operating system and platform, device type and device identifiers For more information please see the Information We Collect section above. | Collected online when you directly provide it to us, through your use of our website or services, or from third parties. | We collect this information for the purposes listed in the How We Use Information section above. | Shared with our affiliates, partners, vendors, and service providers as described in the How We Share and Disclose Information section above. | We will not retain your information for longer than is reasonably necessary for our business purposes or for legal or regulatory requirements as described in the Data Retention section above |
| Geolocation data | Collected via IP address. For more information please see the Information We Collect section above. | Collected online when you directly provide it to us, through your use of our website or services, or from third parties. | We collect this information for the purposes listed in the How We Use Information section above. | Shared with our affiliates, partners, vendors, and service providers as described in the How We Share and Disclose Information section above. | We will not retain your information for longer than is reasonably necessary for our business purposes or for legal or regulatory requirements as described in the Data Retention section above |
| Sensory data | Not collected. | N/A | N/A | N/A | N/A |
| Professional or employment-related information | Company and job title. For more information please see the Information We Collect section above. | Collected online or offline when you directly provide it to us, through your use of our website or services, or from third parties. | We collect this information for the purposes listed in the How We Use Information section above. | Shared with our affiliates, partners, vendors, and service providers as described in the How We Share and Disclose Information section above. | We will not retain your information for longer than is reasonably necessary for our business purposes or for legal or regulatory requirements as described in the Data Retention section above |
| Non-public education information | Not collected. | N/A | N/A | N/A | N/A |
| Inferences drawn from other personal information | Information generated from your use of our website and services reflecting your preferences | Collected online or offline when you directly provide it to us, through your use of our website or services, or from third parties. | We collect this information for the purposes listed in the How We Use Information section above. | Shared with our affiliates, partners, vendors, and service providers as described in the How We Share and Disclose Information section above. | We will not retain your information for longer than is reasonably necessary for our business purposes or for legal or regulatory requirements as described in the Data Retention section above |
| Sensitive personal information | Not collected. | N/A | N/A | N/A | N/A |
