Privacy Statement

Latest update: April 2022

This Oropan Privacy Statement (“Privacy Statement”) explains our privacy practices for the activities described herein. Please read this Privacy Statement carefully to learn how we collect, use, share, and otherwise process information relating to individuals (“Personal Data”), and to learn about your rights and choices regarding your Personal Data.

A reference to “Oropan,” “we,” “us” or the “Company” is a reference to Oropan SpA.

Responsible Oropan entity

Oropan is the controller of your Personal Data as described in this Privacy Statement, unless specified otherwise.

Processing activities covered

This Privacy Statement applies to the processing of Personal Data collected by us when you:

• Visit our websites that display or link to this Privacy Statement;
• Visit our branded social media pages;
• Visit our offices;
• Receive communications from us, including emails, phone calls, text messages or fax;
• Use our products and services as an authorized user (for example, as an employee of one of our customers who provided you with access to our services) where we act as a controller of your Personal Data;
• Register for, attend or take part in our events, webinars, or contests; or
• Participate in community and open source development;
• Receive certain products or services.

Our websites and services may contain links to other websites, applications, and services maintained by third parties. The information practices of other services, or of social media platforms that host our branded social media pages, are governed by their privacy statements, which you should review to better understand their privacy practices.

What Personal Data do we collect?

Personal Data we collect directly from you

The Personal Data we may collect directly from you includes identifiers, professional or employment-related information, financial account information, commercial information, visual information, and internet activity information. We collect such information in the following situations:

• If you express an interest in obtaining additional information about our products; request customer support; use our “Contact Us” or similar features; register to use our websites; sign up for an event, webinar or contest; or download certain content, we may require that you provide to us your contact information, such as your name, job title, company name, address, interest, phone number, email address or username and password;
• If you make purchases via our websites or register for an event or webinar, we may require that you provide to us your financial and billing information, such as billing name and address, credit card number or bank account information;
• If you interact with our websites or emails, we automatically collect information about your device and your usage of our websites or emails (such as Internet Protocol (IP) addresses or other identifiers, which may qualify as Personal Data (please see the “What device and usage data we process” section, below) using cookies, web beacons, or similar technologies;
• If you voluntarily submit certain information to our products, such as filling out a survey about your user experience, we collect the information you have provided as part of that request; and
• If you visit our offices, you may be required to register as a visitor and to provide your name, email address, phone number, company name and time and date of arrival. Additionally, due to the COVID-19 pandemic, and based on local legal provisions you may be required to provide information regarding your health status, including your temperature, COVID-19-related symptoms, exposure to COVID-19 positive individuals, and recent travel history.

If you provide us or our service providers with any Personal Data relating to other individuals, you represent that you have the authority to do so, and where required, have obtained the necessary consent or identified other lawful grounds, and acknowledge that it may be used in accordance with this Privacy Statement. If you believe that your Personal Data has been provided to us improperly, or want to exercise your rights relating to your Personal Data, please contact us by using the information in the “Contacting us” section below.

Personal Data we collect from other sources

We may also collect information about you from other sources including third parties from whom we purchase Personal Data and from publicly available information. We may combine this information with Personal Data provided by you. This helps us update, expand, and analyze our records, identify new customers, and create more tailored advertising to provide services that may be of interest to you. The Personal Data we collect from other sources includes identifiers, professional or employment-related information, education information, commercial information, visual information, internet activity information, and inferences about preferences and behaviors. In particular, we collect such Personal Data from the following sources:

• Third party providers of business contact information, including mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), IP addresses, social media profiles, LinkedIn URLs and custom profiles, for purposes of targeted advertising, delivering relevant email content, event promotion and profiling, determining eligibility and verifying contact information; and
• Another individual at your organization who may provide us with your business contact information for the purposes of obtaining services;

What device and usage data do we process?

We use common information-gathering tools, such as tools for collecting usage data, cookies, web beacons, pixels, and similar technologies to automatically collect information that may contain Personal Data as you navigate our websites, our services, or interact with emails we have sent to you.

Device and usage data

As is true of most websites, we gather certain information automatically when individual users visit our websites. This information may include identifiers, commercial information, and internet activity information such as IP address (or proxy server information), device and application information, identification numbers and features, location, browser type, plug-ins, integrations, Internet service provider, mobile carrier, the pages and files viewed, searches, referring website, app or ad, operating system, system configuration information, advertising and language preferences, date and time stamps associated with your usage, and frequency of visits to the websites. This information is used to analyze overall trends, help us provide and improve our websites, offer a tailored experience for website users, and secure and maintain our websites.

Cookies, web beacons and other tracking technologies on our website and in email communications

We use cookies technologies to gather information about the use of our websites and how people interact with our emails.

When you visit our websites, we, or an authorized third party, may place a cookie on your device that collects information, including Personal Data, about your online activities over time and across different sites. Cookies allow us to track use, infer-browsing preferences, and improve and customize your browsing experience.

The following describes how we use different categories of cookies and similar technologies and your options for managing the data collection settings of these technologies:

Social Media Features

Our websites may use social media features, such as the Facebook “like” button, the “Tweet” button and other sharing widgets (“Social Media Features”). Social Media Features may allow you to post information about your activities on our website to outside platforms and social networks. Social Media Features may also allow you to like or highlight information we have posted on our website or our branded social media pages. Social Media Features are either hosted by each respective platform or hosted directly on our website. To the extent the Social Media Features are hosted by the platforms themselves, and you click through to these from our websites, the platform may receive information showing that you have visited our websites. If you are logged in to your social media account, it is possible that the respective social media network can link your visit to our websites with your social media profile.

Your interactions with Social Media Features are governed by the privacy policies of the companies providing them.

Purposes for which we process Personal Data and the legal bases on which we rely

We collect and process your Personal Data for the following purposes. Where required by law, we obtain your consent to use and process your Personal Data for these purposes. Otherwise, we rely on another authorized legal basis (including but not limited to the (a) performance of a contract or (b) legitimate interest) to collect and process your Personal Data.

• Providing our websites and products: We process your Personal Data to perform our contract with you to fulfill our obligations under the applicable terms of the contract; if we have not entered into a contract with you, we base the processing of your Personal Data on our legitimate interest to operate and administer our websites and to provide you with content you access and request (e.g., to download content from our websites);
• Promoting the security of our websites: We process your Personal Data by tracking use of our websites and services, creating aggregated non-personal data, verifying accounts and activity, investigating suspicious activity, and enforcing our terms and policies to the extent it is necessary for our legitimate interest in promoting the safety and security of the services, systems and applications and in protecting our rights and the rights of others;
• Handling contact and user support requests: If you fill out a “Contact Us” web form or request user support, or if you contact us by other means including via a phone call, we process your Personal Data to perform our contract with you and to the extent it is necessary for our legitimate interest in fulfilling your requests and communicating with you;
• Managing contests or promotions: If you register for a contest or promotion, we process your Personal Data to perform our contract with you. Some contests or promotions have additional rules containing information about how we will process your Personal Data;
• Managing payments: If you have provided financial information to us, we process your Personal Data to verify that information and to collect payments to the extent that doing so is necessary to complete a transaction and perform our contract with you;
• Developing and improving our websites and products: We process your Personal Data to analyze trends and to track your usage of and interactions with our websites and services to the extent it is necessary for our legitimate interest in developing and improving our products;

• Sending marketing communications: We will process your Personal Data or device and usage data, which in some cases may be associated with your Personal Data, to send you marketing information, product recommendations and other non-transactional communications (e.g., marketing newsletters, telemarketing calls, SMS, or push notifications) about us and our affiliates and partners, including information about our products, promotions or events as necessary for our legitimate interest in conducting direct marketing or to the extent you have provided your prior consent (please see the “Your rights relating to your Personal Data” section, below, to learn how you can control the processing of your Personal Data by Oropan for marketing purposes);
• Complying with legal obligations: We process your Personal Data when cooperating with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws to the extent this requires the processing or disclosure of Personal Data to protect our rights or is necessary for our legitimate interest in protecting against misuse or abuse of our websites, protecting personal property or safety, pursuing remedies available to us and limiting our damages, complying with judicial proceedings, court orders or legal processes, respond to lawful requests, or for auditing purposes.

If we need to collect and process Personal Data by law, or under a contract we have entered into with you, and you fail to provide the required Personal Data when requested, we may not be able to perform our contract with you.

Who do we share Personal Data with?

We may share your Personal Data as follows:

• Service Providers: With our contracted service providers, who provide services such as IT and system administration and hosting, credit card processing, research and analytics, marketing, customer support and data enrichment for the purposes and pursuant to the legal bases described above; such service providers comprise companies located in the countries in which we operate;
• Contest and Promotion Sponsors: With sponsors of contests or promotions for which you register;
• Third party networks and websites: With third-party social media networks, advertising networks and websites, so that Oropan can market and advertise on third party platforms and websites;
• Third party App Marketplace partners: Specifically in relation to the App Marketplace available in some products, if you choose to interact with or use third-party tools, we may share your Personal Data with our third party partners who may contact you regarding their products or services;
• Professional Advisers: In individual instances, we may share your Personal Data with professional advisers acting as service providers, processors, or joint controllers – including lawyers, bankers, auditors, and insurers based in countries in which we operate who provide consultancy, banking, legal, insurance and accounting services, and to the extent we are legally obliged to share or have a legitimate interest in sharing your Personal Data;
• Oropan Family Affiliates: With affiliates within the Oropan corporate group and companies that we acquire in the future after they are made part of the Oropan corporate group, to the extent such sharing of data is necessary to fulfill a request you have submitted via our websites or for customer support, marketing, technical operations and account management purposes.
• Third Parties Involved in a Corporate Transaction: If we are involved in a merger, reorganization, dissolution or other fundamental corporate change, or sell a website or business unit, or if all or a portion of our business, assets or stock are acquired by a third party. In accordance with applicable laws, we will use reasonable efforts to notify you of any transfer of Personal Data to an unaffiliated third party.

For more information on the recipients of your Personal Data, please contact us by using the information in the “Contacting us” section, below.

 How long do we keep your Personal Data?

We may retain your Personal Data for a period of time consistent with the original purpose of collection (see the “Purposes for which we process Personal Data and the legal bases on which we rely” section, above) or as long as required to fulfill our legal obligations. We determine the appropriate retention period for Personal Data on the basis of the amount, nature, and sensitivity of the Personal Data being processed, the potential risk of harm from unauthorized use or disclosure of the Personal Data, whether we can achieve the purposes of the processing through other means, and on the basis of applicable legal requirements (such as applicable statutes of limitation).

After expiry of the applicable retention periods, your Personal Data will be deleted. If there is any data that we are unable, for technical reasons, to delete entirely from our systems, we will implement appropriate measures to prevent any further use of such data.

For more information on data retention periods, please contact us by using the information in the “Contacting us” section, below.

Your rights relating to your Personal Data

You may have certain rights relating to your Personal Data, subject to local data protection laws. Depending on the applicable laws these rights may include the right to:

• Access your Personal Data held by us;
• Know more about how we processed your Personal Data;
• Rectify inaccurate Personal Data and, taking into account the purpose of processing the Personal Data, ensure it is complete;
• Erase or delete your Personal Data (also referred to as the right to be forgotten), to the extent permitted by applicable data protection laws;
• Restrict our processing of your Personal Data, to the extent permitted by law;
• Transfer your Personal Data to another controller, to the extent possible (right to data portability);
• Object to any processing of your Personal Data. Where we process your Personal Data for direct marketing purposes or share it with third parties for their own direct marketing purposes, you can exercise your right to object at any time to such processing without having to provide any specific reason for such objection;
• Opt out of certain disclosures of your Personal Data to third parties;
• Not be discriminated against for exercising your rights described above;
• Not be subject to a decision based solely on automated processing, including profiling, which produces legal effects (“Automated Decision-Making”). Automated Decision-Making currently does not take place on our websites or in our services; and
• Withdraw your consent at any time (to the extent we base processing on consent), without affecting the lawfulness of the processing based on such consent before its withdrawal.

10.2 How to exercise your rights

To exercise your rights, please contact us by sending a mail or written comunication to the following address:……..

Please note that opting out of marketing communications does not opt you out of receiving important business communications related to your current relationship with us, such as communications about your contract or event registrations, products announcements or security information.

 How we secure your Personal Data

We take appropriate precautions including organizational, technical, and physical measures to help safeguard against accidental or unlawful destruction, loss, alteration, and unauthorized disclosure of, or access to, the Personal Data we process or use.

While we follow generally accepted standards to protect Personal Data, no method of storage or transmission is 100% secure. If you have any questions about the security of our websites, please contact us by using the information in the “Contacting us” section, below.

Changes to this Privacy Statement

We will update this Privacy Statement from time to time to reflect changes in our practices, technologies, legal requirements, and other factors. If we do, we will update the “effective date” at the top. If we make a material update, we may provide you with notice prior to the update taking effect, such as by posting a conspicuous notice on our website or by contacting you directly, or where required under applicable law and feasible, seek your consent to these changes.

We encourage you to periodically review this Privacy Statement to stay informed about our collection, processing and sharing of your Personal Data.

Contact us

Oropan Inc. is a company established at:
………………………………

If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us using the contact details below. We will investigate and attempt to resolve complaints and disputes and will make every reasonable effort to honour your wish to exercise your rights as quickly as possible and, in any event, within the timeframes provided by applicable data protection laws.

We may be reached at: privacy@oropan.com.

You may also contact our Data Protection Officer by emailing the following: dpo@oropan.com.