European Union Safe Harbor Privacy Policy

 
Automated Packaging Systems (“APS”) collects and uses personal information in our day to day activities to ultimately enhance the value of our products and services to the benefit of our customers, suppliers, and employees. We are a global company and as such, may transfer information throughout our corporate structure and across national boundaries. APS is dedicated to protecting the security and privacy of this information and to ensure compliance with all laws and regulations relating to the collection, use and transfer of personal information. This Safe Harbor Privacy Policy outlines the privacy principles that APS uses regarding the transfer of personal information from European Union (“EU”) member nations to the United States and is in accordance with Safe Harbor Principles established by the U.S. Department of Commerce and the European Commission.
 
SCOPE
This policy applies to all personal data received by APS in the United States from EU members, in any format, including electronic, written or verbal.
 
DEFINITIONS

“Personal Information” means any information that can be used to identify an individual. It does not include information that is encoded, anonymised, or publicly available information.

“Sensitive Personal Information” is information that pertains to racial or ethnic origins, political or religious beliefs, trade union memberships, or information relating to health or sex life. Sensitive personal Information will only be processed with the explicit consent of the individual.

 
SAFE HARBOR PRINCIPLES
 
Notice
APS will notify individuals of the reason for collecting and using any personal information. Further, as appropriate, we will disclose the choices individuals may have in limiting the use and disclosure of their personal information. 
 
Choice
APS will provide each individual the opportunity to choose (opt out) from allowing their personal information to be disclosed to a third party or to be used for a purpose other than the purpose for which it was originally collected or authorised. For sensitive personal information, the individual has the opportunity to explicitly consent (opt-in) to the disclosure of said information to a third party or for a use other than for which it was originally collected or authorised.
  
Transfers (to Third Parties)
APS may transfer information to a third party acting as an agent for APS, such as an outside consultant. Such information transfer will only take place so long as assurances are obtained from the third party that they will safeguard the information consistent with this Policy.
 
Security
APS takes reasonable precautions to protect personal data from loss, misuse, and
unauthorised access, disclosure, alteration, and destruction. These precautions may include password protections for online information systems and other similar restricted access procedures.
 
Data Integrity
APS takes reasonable steps to ensure that personal information is relevant to its intended use and that it is accurate, complete, and current.
 
Access
Upon request, individuals may get reasonable access to their personal information and have the ability to correct or amend any inaccuracies or incomplete information that may exist.
 
Enforcement
APS will conduct periodic audits to verify compliance to this Policy and the U.S. Federal Trade Commission is empowered to investigate complaints for noncompliance. Any APS employee found to be in violation of this policy will be subject to disciplinary action up to and including termination.
 
Dispute Resolution
Any questions or concerns regarding the use or disclosure of personal information should be directed to Automated Packaging Systems at the address given below. An individual can also contact the local EU Data Protection Authorities directly. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the principles contained in this policy. For complaints that cannot be resolved between APS and the complainant, APS has agreed to participate in the dispute resolution procedures of the panel established by the European Data Protection Authorities to resolve disputes pursuant to the Safe Harbor Principles.
 
Contact Information
Questions or comments regarding this policy should be submitted to Automated Packaging Systems:
 
By Email:
Info@autobag.com
 
By Mail:
Automated Packaging Systems
Attn: Director of Marketing
10175 Philipp Parkway
Streetsboro, Ohio   44241
 
Changes to this Safe Harbor Privacy Policy
This policy may be amended from time to time, consistent with the requirements of the Safe Harbor Principles. Appropriate notice will be given concerning such amendments.
  
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