Policy for the protection of personal data of users of the Website pursuant to Article 13 of the EU General Data Protection Regulation 2016/679
With the present policy, Berlin Packaging Group wishes to inform users visiting the website https://www.alpack.ie/ (hereafter the ” Website “) of the policy adopted with regard to the protection of personal data, underlining its commitment and attention with reference to the protection of the privacy of the visitors of the Website. We kindly ask you to carefully read this privacy policy (the “Privacy Policy“), which applies both if you access the Website and decide to simply browse through it using our services, without purchasing any products, and if you decide to make any purchases.
Simple navigation within the Website is free and does not require any registration, with the exception of some areas in which the user may freely and expressly provide a series of data concerning him or her in order to access specifically identified services (e.g. to create his or her own account and make purchases in the online shop, subscribe to the newsletter or request information through the “Customer Service” section, etc.). Where, therefore, you intend to provide your personal data in order to access such further services, you will be expressly informed in accordance with EU Regulation 679/2016 General Data Protection Regulation (the “Regulation“) of the purposes and methods of use of your data by the Data Controller as well as of your right to request the deletion of your data or its update at any time.
Pursuant to Article 13 of the Regulation, the Data Controller provides you with the following information.
- Identity and contact details of the Data Controller
The Website is administered by Berlin Packaging Ireland Limited with registered office at Berlin Packaging Ireland Limited Unit A2, Three Rock Road, Sandyford Business Park Dublin, D18 ER27 Ireland – Pays ….., tax code and VAT no. IE4883116I, tel. …….., e-mail privacy.eu@berlinpackaging.com, in its capacity as data controller pursuant to the Regulation. - Types of personal data processed
No registration is required to access the Website. There are, however, sections of the Website that require registration or the use of a username and password (e.g. to register in the reserved area), or services for the use of which it is necessary to provide personal data (e.g. to proceed with the online shop, to access newsletter services, to contact us, etc.) [1] such as name, surname, e-mail, shipping address, telephone number.
With reference to data relating to navigation within the Website, see also point g. below concerning the profiling tools used by the Website. - Purpose and legal basis of processing
Data are collected and processed for purposes strictly related to the use of the Website, its services and the purchase of products online. The purposes for which the data are used are set out in detail in the specific notices provided by the Website in all cases of data collection. We therefore ask you to read the information notices that from time to time illustrate the characteristics of the processing operations that will be carried out by Berlin Packaging Ireland Limited (e.g. to access your account, to send requests through the “Customer Care” section, etc.). In particular, your data will be processed in order to manage your orders and to guarantee you the use of the services (including after-sales services) requested through the Website, to fulfil the related legal obligations, to respond to your possible requests, as well as, on the basis of your consent, to carry out marketing activities and analysis of your preferences.
Berlin Packaging Ireland Limited, may send by e-mail commercial communications, advertising and promotional material for the direct sale of its products similar to those purchased by you, without your consent, in accordance with the Ireland law on information society services and electronic commerce 34/2002 (‘LSSI’) (‘Soft Spam’);
Your data will be processed in full compliance with the data protection legislation [2]. - Optional provision of personal data
The provision of personal data is generally optional. Only in certain cases, failure to provide data may result in the impossibility to access specific services and to obtain what may be requested (e.g. registration – and the provision of personal data, e-mail address, delivery/billing address, credit/debit card data or bank details and telephone number – is necessary to proceed with the purchase of products online); failure to provide such data may therefore prevent Berlin Packaging Ireland Limited from allowing access to the services of the Website or from responding to users’ requests.
The data required from time to time are indicated in the data collection forms on the Website – e.g. by marking them with an asterisk (*) – and the consequences of failure to provide such data are set out in the specific information on the data collection pages. - Method of data processing and scope of communication
Data may be processed both electronically and on paper (e.g. for the management of purchases on the Website). Berlin Packaging Ireland Limited guarantees the lawful and correct processing of the personal data provided through the Website, in full compliance with the legislation in force, as well as the maximum confidentiality of the data provided during registration. The data shall not be disseminated and shall be processed by persons expressly authorised to manage the e-commerce Website and the CRM system. For purely organisational and functional reasons, Berlin Packaging Ireland Limited has appointed a number of service providers functional to the management of the Website as external data processors for the processing of users’ personal data for purposes strictly connected and related to the provision of the services provided. A full list of external data processors can be obtained by contacting privacy.eu@berlinpackaging.com.
The data may also be made available to the other companies in the Berlin Packaging group as well as to companies that provide us with services [1] useful for the management of your purchases and related services.
- Links to other sites
This notice is provided only for the Website (https://www.alpack.ie/) and not for any other websites that may be consulted by the user through links. Berlin Packaging Ireland Limited cannot be considered responsible for personal data provided by users to external parties or to any websites linked to our Website. - Profiling and/or personalisation tools
Berlin Packaging Ireland Limited does not carry out any promotional and/or advertising activities without the user’s prior express consent.
The website uses “cookies”, both technical (i.e. to facilitate navigation and use of the Website) and profiling (i.e. to analyse users and their behaviour and preferences, and to provide them with personalised advertising).
For a detailed explanation of the cookies used by the Website and how to deactivate them, please read our Cookie Policy.
- who processes your data:
Your data will not be disclosed or transferred to third parties for a fee. The personal data entered in the collection forms on the Website will be disclosed (limited to their respective sphere of competence) to persons authorised to process the data in the marketing, purchasing, finance and legal departments. The data may also be shared with our business partners as well as with companies that provide us with services [1]useful for handling your requests.
In addition to Berlin Packaging Ireland Limited, your data may also be processed by the European parent company Berlin Packaging Italy S.p.A. for specific marketing activities planned by the same company.
- Place of data processing and transfers outside the European Union
Processing related to the services provided by the Website is carried out in the European Union.
Due to the organisational policy of the Berlin Packaging group, to which Berlin Packaging Ireland Limited belongs, your personal data may be transferred to the United States of America where the servers hosting the group’s CRM (customer relationship management) applications are physically located.
The applicable legislation provides that your specific consent to the transfer to third countries is not required as the transfer is made on the basis of the adoption of adequate safeguards as per articles 46 and 47 of the Regulation, such as the adoption of standard contractual clauses approved by the EU Commission EU and on the basis of the Data Privacy Framework Program (‘DPF‘). - Period of data retention
Your data will be processed for the time periods provided for in the specific information provided at the time of collection [4].
Regarding the retention period of data collected through the use of profiling tools (e.g. cookies), please see our Cookie Policy. - Rights of data subjects
By means of a communication to be sent to privacy.eu@berlinpackaging.com, you may at any time exercise your rights [5] as set out in Articles 15 to 22 of the Regulation, including knowing what data we are processing, how and for what purposes we use it, modifying the data you have provided us with or deleting it, asking us to limit the use of your data, requesting to receive or transmit your data, without prejudice to the possibility of changing your consents (if any). You can also always object to the processing of your data, in particular for marketing purposes or the analysis of your preferences. - Who you can complain to
We remind you that, if you consider that the processing of your personal data violates the provisions of the Regulation, you may always lodge a complaint with the Data Protection Authority (https://www.dataprotection.ie/)or, if different, with the Data Protection Authority of the Member State in which you habitually reside or work or of the place where the alleged infringement occurred. - Applicable law
This Privacy Policy is governed by the Regulation, which ensures that personal data is processed in accordance with the fundamental rights and freedoms and the dignity of the data subject, with particular reference to confidentiality, personal identity and the right to protection of personal data. - Revision clause
Berlin Packaging Ireland Limited reserves the right to revise, modify or simply update, in whole or in part, at its sole discretion, in any manner and/or at any time, without prior notice, this Privacy Policy also in consideration of changes in laws or regulations on the protection of personal data. Changes and updates to the Privacy Policy may be notified to users as appropriate by:
(i) sending e-mails to registered users of the Website; and/or
(ii) publication on the Website’s home page and will be binding as soon as published and/or communicated.
We therefore ask you to regularly access this section to check the publication of the most recent and updated Privacy Policy or to check your e-mail inbox. The full text of the Regulation can be consulted on the website of the Personal Data Protection Authority (https://www.dataprotection.ie/).
Footnotes:
[1] Where Berlin Packaging Ireland Limited acquires information and personal data it will, from time to time, inform users in advance of the purposes for which such data is required and the manner in which it will be used. Where necessary, Berlin Packaging Ireland Limited will obtain the user’s specific consent to the relevant use of the data. By way of example, personal data such as name and surname, telephone number, e-mail address and other information that the user agrees to provide in order to use the services of the Website by filling in a specific registration form may be requested. Berlin Packaging Ireland Limited will use the personal data collected on-line solely for the purposes indicated during registration.
The data relating to the connection and navigation within the Website (such as the URI-Uniform Resource Identifier addresses of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the user’s operating system and computer environment) are collected for the sole purpose of obtaining anonymous statistical information on the use of the Website and to check its correct operation and are deleted immediately after processing. The data could be used to ascertain responsibility in the event of hypothetical computer crimes to the detriment of the Website: to the exclusion of this eventuality, the data will be deleted after the time required to provide the services illustrated on the Website has elapsed.
[2] Your data will be processed
– pursuant to art. 6, paragraph 1, lett. b) and c) of the Regulation, to manage your orders and guarantee you the use of the services (including after-sales services) requested through the Website, to fulfil the related legal obligations, to respond to your requests, if any;
– on the basis of your consent, pursuant to art. 6, paragraph 1, letter a) of the Regulations, to carry out marketing activities and analysis of your preferences by the data controller and Berlin Packaging Italy S.p.A..
In any case, the processing will be carried out in compliance with the provisions in force – and their subsequent amendments and/or additions – issued by the Personal Data Protection Authority.
[3] Your data will be disclosed to:
(i) payment processing companies;
(ii) product shipping and delivery companies;
(iii) legal, tax and audit consultants;
(iv) companies within the Berlin Packaging group
(v) third party companies for the management of the e-commerce website services and for sending the newsletter.
[4] Your data, provided for contractual purposes and for the execution of pre-contractual measures, shall be stored for as long as is necessary to fulfil the obligations towards you in connection with the business relationship and in any case no longer than ten (10) years after the conclusion of the contractual relationship.
If you decide to create your customer account by registering in the My Account section, your data will be processed as long as your account is active. You may close your account at any time and your request will be handled immediately or, in the case of a pending purchase order, immediately after it has been executed. Should your account remain inactive for three (3) years, Berlin Packaging Ireland Limited will contact you to find out whether you wish to maintain or close your account. If you do not wish to keep your account active, it will be closed and your data deleted.
Your purchase details will, however, be processed anonymously for analysis or promotional purposes.
Your bank details are only processed and stored securely by the operator of the payment service you have chosen (Paypal, Shopify Payments) for the time stipulated by national law.
Your data, collected through the “Customer Service” sections, or through the information request forms, etc., of the Website will be processed and stored for the time necessary to properly handle your requests. The processing of your data for marketing purposes (including the sending of the newsletter) may only take place after your consent has been obtained. When this consent is about to expire, Berlin Packaging Ireland Limited may contact you to find out whether you wish to continue to receive communications and newsletters about new products, services, offers from Berlin Packaging Ireland Limited or the Berlin Packaging group and, therefore, renew your consent. Your consent to the processing of your data for marketing purposes is also freely revocable at any time.
The data processed for the purpose of sending you answers to your enquiries, communications on Berlin Packaging Ireland Limited and Berlin Packaging branded products, offers, news and events, marketing communications, will be stored for five (5) years from the date of collection or from the date of your last contact with Berlin Packaging Ireland Limited for non-contractual reasons.
[5] Articles 15 to 22 of the Regulation recognise specific rights including:
- obtain confirmation as to whether or not personal data concerning you are being processed;
- to obtain access to your personal data and to the information indicated in Article 15 of the Regulation
- obtain the rectification of inaccurate personal data concerning you without undue delay or the integration of incomplete personal data
- obtain the deletion of personal data concerning you without undue delay;
- obtain the restriction of the processing of personal data concerning you;
to be informed of any rectification or erasure or restriction of processing of personal data concerning you; - receive or transmit to another data controller in a structured, commonly used and machine-readable format the personal data concerning you;
- to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you.
In particular, your right to revoke at any time any processing consents you may have given and to object to our analysis activities remains unaffected.
Furthermore, pursuant to Art. 21 of the Regulation, you shall have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you carried out in pursuance of the legitimate interests of the controller pursuant to Art. 6(1)(f) of the Regulation.