Privacy Statement

PRIVACY POLICY
rose plastic USA, L.L.L.P.
Effective Date: May 22, 2019

rose plastic USA, L.L.L.P. (“rose plastic US”, “we” and/or “our”) has prepared this privacy policy (this “Privacy Policy”), to provide visitors to our website important information about the personal data we collect, use, transfer, and/or process in the course of operating this website (the “Site”).
In this Privacy Policy, you will find information about the types of personal data we collect regarding you as a visitor and/or user of this Site, how and why we process such personal data, with whom we may share such information, as well as how we protect your information.
In this Privacy Policy, we also describe the processes by which you may contact us in order to exercise your rights, in accordance with applicable law, to: (1) access, correct, restrict, or delete your personal data; (2) object to the processing of certain aspects of your personal data; and (3) ask any questions you may have about our privacy practices.  
This Privacy Policy may be updated and/or otherwise revised periodically to reflect changes in our data processing practices and/or policies.  We will post notices of all such changes on our applicable websites and/or materials and the “Effective Date” noted above will indicate when this Privacy Policy was most recently revised.  Except as may be otherwise required under applicable law, revisions to this Privacy Policy will be effective on the Effective Date noted without any other notice or approval by you.  In certain jurisdictions, applicable law may require additional processes and procedures, in which case, revisions to this Privacy Policy will not be effective until we have met our obligations accordingly.


1.     Website Operator

rose plastic US is the operator of the Site, is responsible party for the privacy practices set forth herein and, where applicable, may be considered the data controller.  
You may contact us as follows:

rose plastic USA, L.L.L.P.
P.O. Box 698 California PA 15419
525 Technology Dr, Coal Center, PA 15423
USA
Phone: 1-724-938-8530
Fax: 1-724-938-8532
Email: privacy@rose-plastic.us


2.     How We Obtain Personal Data

As more specifically detailed below, we collect Personal Data from data subjects through the Site, and other information you provide directly to us, including by email.  

3.     Personal Data That You Submit

For the purpose of operating the Site, and our business, we collect, use, store and/or otherwise process the following personal data (as further detailed below, “Personal Data”).

a.    Contact forms
If you submit inquiries to us via our contact form, the information provided in the contact form as well as any contact information provided therein will be stored by us in order to handle your inquiry and in the event that we have further questions.  Please note that, depending on the nature of your request, we may share your information, and inquiry, with an affiliated rose plastic entity who is better suited to respond appropriately to your inquiry.  Except as expressly set forth immediately above, we will not share this information without your consent.  
You have the right to revoke at any time any consent you have previously given to us. To do so, all you are required to do is to send us notice of your revocation via e-mail; provided such notice of revocation includes information needed by us to identify the consent being revoked, and the personal data to which it relates. This shall be without prejudice to the lawfulness of any data collection that occurred prior to your revocation.
The information you have entered into the contact form shall remain with us until you ask us to eradicate the data, revoke your consent to the archiving of data or if the purpose for which the information is being archived no longer exists (e.g. after we have concluded our response to your inquiry). This shall be without prejudice to any mandatory legal provisions – in particular retention periods.

b.    Newsletter
If you would like to subscribe to the newsletter offered on this website, we will need from you an e-mail address as well as information that allow us to verify that you are the owner of the e-mail address provided and consent to the receipt of the newsletter. No further data shall be collected or shall be collected only on a voluntary basis. We shall use such data only for the sending of the requested information and shall not share such data with any third parties.
The processing of the information entered into the newsletter subscription form shall occur on the basis of your consent. You may revoke the consent you have given to the archiving of data, the e-mail address and the use of this information for the sending of the newsletter at any time, for instance by clicking on the "Unsubscribe" link in the newsletter. This shall be without prejudice to the lawfulness of any data processing transactions that have taken place to date.
The data you archive with us for the purpose of the newsletter subscription shall be archived by us until you unsubscribe from the newsletter. Once you cancel your subscription to the newsletter, the data shall be deleted. This shall not affect data we have been archiving for other purposes.

Newsletter software MailChimp
This website uses the services of MailChimp to send out its newsletters. The provider is the Rocket Science Group LLC, 675 Ponce De Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA. Among other things, MailChimp is a service that can be deployed to organize and analyze the sending of newsletters. Whenever you enter data for the purpose of subscribing to a newsletter (e.g. your e-mail address), the information is stored on MailChimp servers in the United States.
With the assistance of the MailChimp tool, we can analyze the performance of our newsletter campaigns. If you open an e-mail that has been sent through the MailChimp tool, a file that has been integrated into the e-mail (a so-called web-beacon) connects to MailChimp’s servers in the United States. As a result, it can be determined whether a newsletter message has been opened and which links the recipient possibly clicked on. Technical information is also recorded at that time (e.g. the time of access, the IP address, type of browser and operating system). This information cannot be allocated to the respective newsletter recipient. Their sole purpose is the performance of statistical analyses of newsletter campaigns. The results of such analyses can be used to tailor future newsletters to the interests of their recipients more effectively.
If you do not want to permit an analysis by MailChimp, you must unsubscribe from the newsletter. We provide a link for you to do this in every newsletter message. 


The data is processed based on your consent.  You may revoke any consent you have given at any time by unsubscribing from the newsletter. This shall be without prejudice to the lawfulness of any data processing transactions that have taken place prior to your revocation.
The data you archive with us for the purpose of the newsletter subscription shall be archived by us until you unsubscribe from the newsletter. Once you cancel your subscription to the newsletter, the data shall be deleted from our servers as well as those of MailChimp. This shall not affect data we have been archiving for other purposes.
For more details, please consult the data privacy policies of MailChimp at: https://mailchimp.com/legal/terms/.

c.    Job Application process
For Site visitors who choose to apply for jobs through the jobs portal on our Site, we collect and process job applicants’ personal data for the purpose of processing the job application. This will be the case, for example, if you apply for a position at our company by completing our online application forms and provide us with your personal application documents accordingly, or if you send your application to us via e-mail.

Storage of applicants’ data is for the purpose of managing the job application process, and any resulting employment relationship.
If you become an employee with us, we will store the data sent to us for the purpose of managing the employment relationship in accordance with legal regulations.

Deletion of data belonging to unsuccessful applicants
If, on the other hand, no employment relationship between you and us comes into being, we will keep your application documents for a period of six months after notifying you that your application was unsuccessful and will then delete them, unless you wish to be included in our pool of applicants and provided that there are no other overriding legitimate legal or business interests preventing their deletion.

 
4.     Third Party Tools - Plug-Ins and Tools

a.    Facebook plug-ins (Like & Share button)
We have integrated plug-ins for the Facebook social network, provided by Facebook Inc., 1 Hacker Way, Menlo Park, California 94025, USA, on our website. You will be able to recognize Facebook plug-ins by the Facebook logo or the "Like" button on our website. An overview of the Facebook plug-ins is available under the following link: https://developers.facebook.com/docs/plugins/.
Whenever you visit our website and its pages, the plug-in will establish a direct connection between your browser and the Facebook server. As a result, Facebook will receive the information that you have visited our website with your plug-in. However, if you click the Facebook “Like” button while you are logged into your Facebook account, you can link the content of our website and its pages with your Facebook profile. As a result, Facebook will be able to allocate the visit to our website and its pages to your Facebook user account. Please note that, as the operator of the Site, we do not have any knowledge of the transferred data or its use by Facebook. For more detailed information, please consult the data privacy declaration of Facebook at: https://www.facebook.com/privacy/explanation.
If you do not want Facebook to be able to allocate your visit to our website and its pages to your Facebook user account, please log out of your Facebook account while you are on our website.

b.    Twitter plug-in
We have integrated functions of the Twitter social media platform into our website. These functions are provided by Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA. While you use Twitter and the "Re-Tweet" function, websites you visit are linked to your Twitter account and disclosed to other users. During this process, data are transferred to Twitter as well. Please note that we, as the operator of the Site and its pages, do not know anything about the content of the data transferred and the use of this information by Twitter. For more details, please consult Twitter’s data privacy declaration at: https://twitter.com/en/privacy.
You have the option to reset your data protection settings on Twitter under the account settings at https://twitter.com/account/settings.

c.    Instagram plug-in
We have integrated functions of the Instagram public media platform into our website. These functions are being offered by Instagram Inc., 1601 Willow Road, Menlo Park, CA 94025, USA. If you are logged into your Instagram account, you may click the Instagram button to link contents from our website to your Instagram profile. This enables Instagram to allocate your visit to our website to your user account. Please note that we, as the operator of the Site and its pages, do not have any knowledge of the content of the data transferred and its use by Instagram.
For more information on this subject, please consult Instagram’s data privacy declaration at: https://instagram.com/about/legal/privacy/.

d.    LinkedIn plug-in
Our website uses functions of the LinkedIn network. The provider is LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA. Any time you access one of our sites that contains functions of LinkedIn, a connection to LinkedIn’s servers is established. LinkedIn is notified that you have visited our websites with your IP address. If you click on LinkedIn’s "Recommend" button and are logged into your LinkedIn account at the time, LinkedIn will be in a position to allocate your visit to our website to your user account. Please note that we, as the operator of the Site, do not have any knowledge of the content of the transferred data and its use by LinkedIn.
For further information on this subject, please consult LinkedIn’s data privacy declaration at: https://www.linkedin.com/legal/privacy-policy.

e.    XING plug-in
Our website uses functions of the XING network. The provider is the XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany. Any time one of our sites/pages that contains functions of XING is accessed, a connection with XING’s servers is established. As far as we know, this does not result in the archiving of any personal data. In particular, the service does not store any IP addresses or analyze user patterns.
For more information on data protection and the XING share button please consult the data protection declaration of XING at: https://www.xing.com/app/share?op=data_protection.

f.    YouTube with expanded data protection integration
Our website uses plug-ins of the YouTube platform, which is being operated by YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA. We use YouTube in the expanded data protection mode. According to YouTube, this mode ensures that YouTube does not store any information about visitors to this website before they watch the video. Nevertheless, this does not necessarily mean that the sharing of data with YouTube partners can be ruled out as a result of the expanded data protection mode. For instance, regardless of whether you are watching a video, YouTube will always establish a connection with the Google DoubleClick network.
As soon as you start to play a YouTube video on our website, a connection to YouTube’s servers will be established. As a result, the YouTube server will be notified, which of our pages you have visited. If you are logged into your YouTube account while you visit our site, you enable YouTube to directly allocate your browsing patterns to your personal profile. You have the option to prevent this by logging out of your YouTube account.
Furthermore, after you have started to play a video, YouTube will be able to place various cookies on your device. With the assistance of these cookies, YouTube will be able to obtain information about our website visitor. Among other things, this information will be used to generate video statistics with the aim of improving the user friendliness of the site and to prevent attempts to commit fraud. These cookies will stay on your device until you delete them.
Under certain circumstances, additional data processing transactions may be triggered after you have started to play a YouTube video, which are beyond our control.
For more information on how YouTube handles user data, please consult the YouTube data privacy policy under: https://policies.google.com/privacy?hl=en.

g.    Full-text search with ALGOLIA
We have integrated components from ALGOLIA into our website. ALGOLIA is an Internet-based full-text search engine that supports page content searches. Search requests are returned with instant visual feedback and typo-tolerance. This service can access the search requests entered in the web browser. To enable the use of this function, it is necessary to store your search request and your IP address.
The company that operates the ALGOLIA services is ALGOLIA Inc. (Delaware Corporation), 589 Howard Street, 5th floor, San Francisco, CA 94105, USA.
Further information can be found in the ALGOLIA Inc. data privacy policy, which you can access on: https://www.algolia.com/policies/privacy.

h.    Amazon Web Services – CloudFront
We use CloudFront on our website, which is a “Content Delivery Network” (CDN) provided by AMAZON WEB SERVICES, INC. We do not know what data CloudFront collects and uses in the course of providing its services. However, Amazon.com, Inc., is certified in accordance with the EU–US Privacy Shield, thereby guaranteeing compliance with the European data privacy laws. Proof of this certification is available in the Privacy Shield Framework directory: www.privacyshield.gov/list
The company that operates the CloudFront services is AMAZON WEB SERVICES, INC., 410 Terry Avenue North, Seattle WA 98109-5210, USA.
Further information can be found in the Amazon.com data privacy policy, which you can access on: https://aws.amazon.com/compliance/gdpr-center/.


5.     Website Operations - Subject always to your rights as set forth in Section 10 below:

a.    Cookies
In some instances, this Site and its pages use so-called “cookies”. Cookies do not cause any damage to your computer and do not contain viruses. The purpose of cookies is to make our website more user friendly, effective and more secure. Cookies are small text files that are placed on your computer and stored by your browser.
Most of the cookies we use are so-called “session cookies.” They are automatically deleted after your leave our site. Other cookies will remain archived on your device until you delete them. These cookies enable us to recognize your browser the next time you visit our website.
You can adjust the settings of your browser to make sure that you are notified every time cookies are placed and to enable you to accept cookies only in specific cases or to exclude the acceptance of cookies for specific situations or in general and to activate the automatic deletion of cookies when you close your browser. If you deactivate cookies, the functions of this website may be limited.
The website operator stores cookies here under to ensure the technically error free and optimized provision of the operator’s services. Other types of cookies (e.g. cookies for the analysis of your browsing patterns) are addressed separately in this data protection declaration.

b.    Server log files
The provider of this website and its pages automatically collects and stores information in so-called server log files, which your browser communicates to us automatically. The information comprises:

  • The type and version of browser used
  • The used operating system
  • Referrer URL
  • The hostname of the accessing computer
  • The time of the server inquiry
  • The IP address
  • This data is not merged with other data sources.

This data is recorded on the basis of Art. 6 Sect. 1 lit. f GDPR. The operator of the website has a legitimate interest in the technically error free depiction and the optimization of the operator’s website. In order to achieve this, server log files must be recorded.

c.    System Security and Data Privacy Protection – We monitor information on user activity within our system in order to protect the security of our systems and the privacy of our customers, for example, as an investigatory tool in case of a dispute or an unauthorized hack.  Such information includes information reported by your browser, Account Information when you login, IP addresses, User Agent, account activity and usage levels to better assist with service delivery and/or security.  

d.    Compliance with Legal Obligations - In addition to processing Personal Data for the purposes of operating the Site, we process Personal Data collected hereunder to comply with our own legal and regulatory obligations. For example, we may process personal information to comply with: applicable international sanctions, “know your customer”, anti-money laundering regulations, anti-bribery compliance requirements, record keeping requirements, required public filings, reporting requirements, court order, law enforcement order, and other legal and/or regulatory requirements.  

e.    Legitimate Interests - We may also use Personal Data collected hereunder in connection with the operation of the Site.  The types of processing/uses contemplated hereunder may include, without limitation, for our own administrative and business needs (tracking time, billing, invoicing, collection), audits and self-assessments for compliance with applicable laws, regulations, court order, law enforcement order, and applicable workplace policies, and for information technology purposes including without limitation trouble shooting, business continuity, disaster recover, data backup and recovery. 

6.      Analytics and Tracking

a.    Google Analytics
This website uses functions of the web analysis service Google Analytics. The provider of this service is Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Google Analytics uses so-called cookies. Cookies are text files, which are stored on your computer and that enable an analysis of the use of the website by users. The information generated by cookies on your use of this website is usually transferred to a Google server in the United States, where it is stored.

IP anonymization
On this website, we have activated the IP anonymization function. As a result, your IP address will be abbreviated prior to further processing by Google. On behalf of the operator of this website, Google shall use this information to analyze your use of this website to generate reports on website activities and to render other services to the operator of this website that are related to the use of the website and the Internet. The IP address transmitted in conjunction with Google Analytics from your browser shall not be merged with other data in Google’s possession.

Browser plug-in
You do have the option to prevent the archiving of cookies by making pertinent changes to the settings of your browser software. However, please note that you may not be able to use all of the functions of this website to their fullest extent if you elect to not allow cookies to be set. Moreover, you have the option prevent the recording of the data generated by the cookie and affiliated with your use of the website (including your IP address) by Google as well as the processing of this data by Google by downloading and installing the browser plug-in available under the following link: https://tools.google.com/dlpage/gaoptout?hl=en.

Objection to the recording of data
You have the option to prevent the recording of your data by Google Analytics by clicking on the following link. This will result in the placement of an opt out cookie, which prevents the recording of your data during future visits to this website: Google Analytics deactivation.
For more information about the handling of user data by Google Analytics, please consult Google’s data privacy declaration at: https://support.google.com/analytics/answer/6004245?hl=en.

Google Analytics Remarketing
Our websites use the functions of Google Analytics Remarketing in combination with the functions of Google AdWords and Google DoubleClick, which work on all devices. The provider of these solutions is Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.
This function makes it possible to connect the advertising target groups generated with Google Analytics Remarketing with the functions of Google AdWords and Google DoubleClick, which work on all devices. This makes it possible to display interest-based customized advertising messages, depending on your prior usage and browsing patterns on a device (e.g. cell phone) in a manner tailored to you as well as on any of your devices (e.g. tablet or PC).
If you have given us pertinent consent, Google will connect your web and app browser progressions with your Google account for this purpose. As a result, it is possible to display the same personalized advertising messages on every device you log into with your Google account.
To support this function, Google Analytics records Google authenticated IDs of users that are temporarily connected with our Google Analytics data to define and compile the target groups for the ads to be displayed on all devices.
You have the option to permanently object to remarketing / targeting across all devices by deactivating personalized advertising in your Google account. To do this, please follow this link: https://www.google.com/settings/ads/onweb/.
The consolidation of the recorded data in your Google account shall occur exclusively based on your consent, which you may give to Google and also revoke there. 
For further information and the pertinent data protection regulations, please consult the data privacy policies of Google at: https://policies.google.com/technologies/ads?hl=en.

b.    Facebook Pixel
To measure our conversion rates, our website uses the visitor activity pixel of Facebook, Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA (“Facebook”).
This tool allows the tracking of page visitors after they have been linked to the website of the provider after clicking on a Facebook ad. This makes it possible to analyze the effectiveness of Facebook ads for statistical and market research purposes and to optimize future advertising campaigns.
For us as the operators of this website, the collected data is anonymous. We are not in a position to arrive at any conclusions as to the identity of users. However, Facebook archives the information and processes it, so that it is possible to make a connection to the respective user profile and Facebook is in a position to use the data for its own promotional purposes in compliance with the Facebook Data Usage Policy. This enables Facebook to display ads on Facebook pages as well as in locations outside of Facebook. We as the operator of this website have no control over the use of such data.
In Facebook’s data privacy policies, you will find additional information about the protection of your privacy at: https://www.facebook.com/about/privacy/.
You also have the option to deactivate the remarketing function “Custom Audiences” in the ad settings section under https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen. To do this, you first have to log into Facebook.

7.     Data Retention

Subject to your rights in Section 10 below, we generally retain Personal Data for the periods specified applicable law, regulation, and/or court order, and in our document retention/filing polices, currently set at seven years.  We may also retain Personal Data for longer periods where there is a reasonable basis for retaining such data, including without limitation in connection with the establishment, exercise or defense of legal claims.      

8.     Exigent Circumstances

In addition to the disclosures set forth herein, we will disclose Personal Data about you: (1) if we are required to do so by law or legal process, (2) to law enforcement authorities, judiciary or other government officials, (3) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss in connection with an investigation of suspected or actual illegal activity; or (4) if necessary to protect the vital interests of any person.

9.     Jurisdiction

a.    rose plastic USA, L.L.L.P. is in the United States – rose plastic US processes Personal Data as described above in our home country, the United States of America.  The Site is not targeted towards, nor is the Site intended for use by users outside of the United States of America, Canada and Mexico.  rose plastic US does not represent or warrant that this Site is suitable for access or use outside of our territory and visitors accessing this Site from outside of our territory do so at their own risk.

b.    International Visitors – For our international visitors located outside of the United States of America, please note that the Site is a United States-based website intended for use only by our customers based in the United States, Canada and Mexico.  If you are seeking information about rose plastic US’s international affiliates, please refer to the flag and language in the upper right of our Site to directly access the appropriate international rose plastic affiliate website for your region and language.  

10.     Your Rights and Options 

a.   Revocation of your consent to the processing of data
To the extent our processing of your Personal Data is based on your express consent, you can revoke at any time any consent you have previously given to us. To do so, all you are required to do is sent us an informal notification via email to privacy@rose-plastic.us; provided such email includes information sufficient to enable us to identify the consent you are revoking and the Personal Data to which such consent applies. This shall be without prejudice to the lawfulness of any data collection that occurred prior to your revocation. You may also object to processing that is described above as being based on our legitimate interests alone. In such instances, our business interests must be found to be compelling and to not jeopardize your individual rights before further processing may continue.

b.   Informational Rights
You may request information from us regarding the Personal Data that is identifiable to you as well as the manner in which we share certain categories of your Personal Data with third parties, for the third parties’ direct marketing purposes, if any. Per California Civil Code § 1798.83, you may submit a request to us and receive the following information:

  • The categories of Personal Data we disclose to third parties for the third parties’ direct marketing purposes, if any, during the preceding calendar year;
  • The names and addresses of third parties that received such information; and
  • If the nature of a third party’s business cannot be reasonably determined from the third party’s name, examples of the products or services marketed.

Please see our contact information below to make such a request.

c.    Correct/Update/Removal
This Site gives Users the following options for changing, modifying, and/or removing Personal Data previously provided:
 1.    You can send an e-mail to: info@rose-plastic.us

d.    Verification
In order to meet our obligations under applicable law, we may take reasonable steps to verify your identity before responding to demands as set forth in this Section 10. 

11.      Complaints, Concerns, Recourse

If you have unresolved concerns about the processing of your Personal Data, you may have the right to complain to a data protection authority where you reside, where you work or where you believe there has been an infringement of data protection laws, all in accordance with, and subject to, applicable local law.

12.    Security

We use commercially reasonable efforts to meet industry standards to safeguard the confidentiality of your personally information. Unfortunately, it is impossible to absolutely guarantee the security of data transmission over the Internet or any wireless network. Therefore, although we take such commercially reasonable measures to protect your information, we cannot ensure the security of any information you transmit to us or from online services and you do so at your own risk. 

13.    Do Not Track

Do Not Track (DNT) is a privacy preference that you can set in certain web browsers. When you turn on DNT, the browser may send a signal or other message to web services requesting that they not track you. At this time, our information collection practices will continue to apply as described in this Transparency Statement, regardless of any DNT signals that are sent by certain browsers or selected by you. For more information about DNT, please visit AllAboutDNT.org.

 

HOW TO CONTACT US

In order to exercise your rights hereunder, if you have any questions about this Transparency Statement and/or our processing of Personal Data, you may contact us in accordance with the information set forth in Section 1 above.