Legal definitions of personal information can vary across different jurisdictions. We strive to comply with laws in all the jurisdictions where we provide services, but for purposes of this Policy consider “personal information” to be any information that identifies you as an individual or is directly relatable to an identifiable individual. Not all information we collect and use is personal information under this definition. For example, information that has been de-identified or aggregated in a way that no longer allows identification of a particular person would not meet this definition. Similarly, information we gather about you from publicly available sources, such as government databases, may not be considered personal information in your jurisdiction. Where permitted we may combine personal information that you have given us with publicly-available information about you to create a profile about you, your interests, and preferences that help us tailor appropriate communications to you.

We may collect, store, and process personal information from the categories shown in the table below. Our listing of these categories does not mean that all categories or the examples listed in each category are collected about everyone who uses the Website. We are providing a full list here in the spirit of transparency.

We collect the categories of personal information listed above from various sources. This section lists and describes those sources.

Directly from you. You may be asked to provide personal information when you use the Website in certain ways. This information may include:

• Membership and Registration Information. When you set up an account with and register to use one or more of our programs, such as the Policy Readiness Knowledge Hub (the “Hub”) or Plastic IQ (the “Tool”), you may be required to provide information such as your name, title, company or organization, email address and to setup a password for future access to such password protected portions of the Website.
• Additional Information. Information that you provide to us, including when you complete online forms, post or comment through Website, use the “What Can I Recycle” chat feature, upload or submit any documents, photos or other material via the Website, request information or contact us with inquiries through the Website or via email, or when you use other aspects of our services, may be collected and stored.

We may offer you the option to send a communication to a friend or other contact directly via the Website, for example, by sharing an article with them. If so, The Partnership relies on you to only send to people that have given you permission to do so. The recipient’s personal information you provide (e.g., name, e-mail address) will be used to facilitate the communication, but not used by The Partnership for any other marketing purpose unless The Partnership obtains consent from that person. Your contact information and message may be included in the communication.

Indirectly from you. We may automatically collect personal information from you when you visit the Website through the use of tracking technologies or by other passive means. This information helps us to improve our offerings and allows us to ensure the Website works as designed and in a way that meets your expectations. Some examples of the sources of this passively collected personal information include: 

• Viewing History and Preferences. When you browse the Website and provided resources, we collect information about your use. For example, if you use our website search tool, we may collect information about that action, such as the search terms you utilize, the titles you select, and whether you download a particular resource or not.
• Log Information. We may automatically record information that your browser or mobile device sends whenever you visit the Website, and especially when you use a login mechanism. These logs may include information such as your web request, IP address, browser type, browser language, your computer operating system, email patterns, your mobile device and mobile operating system, the name of your internet service provider or your mobile carrier, the date and time of your request, and one or more cookies or other tracking devices that may uniquely identify your browser.
• Cookies and Similar Tracking Technologies. When you visit or access the Website or open emails from us, we may utilize cookies (small text files containing a string of characters sent to your computer) or similar tracking technologies, such as web beacons (also known as “tracking pixels”), embedded scripts, and various device recognition technologies, that uniquely identify you or your device to track your activity and hold certain information to improve your future visits. Cookies can be necessary for site navigation and performance, or used for targeting or advertising. To learn more about how we use cookies and other similar tracking technologies and the privacy choices you have with respect to cookie opt-out using our cookie preference tool, please see our separate Cookies Policy.

From third parties. We may collect personal information about you from third parties, either at your request or for our business purposes. These third-party sources vary depending on your engagement with us, but could include the following:

• Social Media and Similar Third-Party Services. Certain functionalities we make available may permit you to initiate interactions between services and software of The Partnership and certain third-party services, such as third-party social media platforms. For example, you may be able to link your social media or other third-party account to The Partnership; log into your account with The Partnership using a social media account (e.g., using Facebook Connect to sign-in); or otherwise connect our services to third-party services (e.g., to pull or push information to or from the Website). By linking these services, you authorize us to collect, store and use any information they may give us as a result of that connection. You can disconnect your social media from your account(s) with us by following the steps made available by the social media platform at any time. We also receive information from you when you interact with our pages, groups, accounts or posts on social media platforms. This could include aggregate data on our followers (e.g., age, gender and location), engagement data (e.g., “likes,” comments, shares, reposts and clicks), awareness data (e.g., number of impressions and reach) and information regarding individual users’ public profiles in accordance with the privacy practices of the various social media platforms we utilize. If you post information on a social media platform that references The Partnership (e.g., by using a hashtag associated with The Partnership or one of our affiliates in a tweet or status update), your post may be used, referenced or displayed on or in connection with the Website if otherwise permitted by relevant policies and applicable law.
• Technical Service Providers. We work with a variety of third-party service providers to enhance the services and to make the Website function the way you expect. These third parties may include, for example, companies that provide website hosting, analytics, and maintenance services or companies that provide marketing and advertising solutions. Many of these categories overlap with the passively collected personal information described above. In working with our service providers, we may share personal information with them and receive personal information back from them so that we may improve the Website. The third-party service providers we work with are authorized to use your information that we provide to them only to carry out the service they are providing for The Partnership. We require that the third-party processors securely store any personal information we provide to them and maintain it so that it can be accessed when needed for future purposes. Where appropriate, we enter into binding contracts to protect the use of your personal information by third parties. As an example, we use Google Analytics to analyze how users interact with the Website. Google Analytics has its own terms of use that we agree to and its own policy that describes how it collects and processes data, located here. You can opt out of Google Analytics’ collection and use of data generated by your use of the Website by installing the Google Analytics opt-out browser add-on. For more details please refer to Google Analytics’ article, “Safeguarding your data.”
• Payment and Donation Processor. We use third-party processors (the “Payment Processors”) to process payments and donations. They provide us with online e-commerce solutions to process member and event registrations and donations. When you use these third-party services, your Personal Information, including payment card numbers and certain identifiers, are collected and stored by the Payment Processors pursuant to their terms and procedures. The Payment Processors store data in a safe and secure manner with access limited to authorized personnel pursuant to the Payment Card Industry Data Security Standard (PCI-DSS). Your purchase transaction data is stored by the Payment Processors only as long as is necessary to complete your purchase transaction. We do not see your full payment card number (only the last 4 digits) and do not store your payment information. PCI-DSS requirements help ensure the secure handling of payment card information.
• Your Employer or Its Authorized Agents. Because many of our services are directed at other businesses who support and embrace our mission to advance a circular economy by building a better recycling system, many of the people visiting and using our Website do so on behalf of the company they work for. We may communicate with other people who work for your employer and, as part of those communications, we may be provided with personal information about you. For example, the person who enters information into a Circular Packaging Assessment for their company may provide us with contact information for someone involved in manufacturing or distribution. We may maintain information about all of these persons even though we have not yet communicated with them directly. All of these uses are for our and our customers’ business purposes, but out of an abundance of caution we list them here as they are potentially “third-party” sources of information we collect under certain laws.

We are not responsible for the privacy practices of third-party providers. By using our Website, you consent to the processing of your personal information by our third-party service providers in the manner and for the purposes described here and in their privacy policies that may be accessible when using certain features of the Website.

We use both personal information and non-personal information to provide services to you, to help improve your interaction with the Website, and to support the mission of The Partnership. Some examples of ways in which we use or disclose personal information include:

• To set-up and register an account to allow you to participate in the services we offer.
• To identify you when you log in to the Website.
• To create and maintain an online profile.
• To respond to your questions or inquiries.
• To populate/display information in public forums and to facilitate online communication among registered users.
• To ask you to participate in surveys, or otherwise provide feedback.
• To allow you to participate in interactive features of the Website when you choose to do so.
• To notify you of new resources that might be of interest to you.
• To improve, upgrade or enhance the Website and our services.
• To create de-identified or aggregated lists of information for any of the uses stated above.
• To operate the Website in accordance with our Terms and/or any other agreement you may have with us.
• To diagnose problems with our server, administer the Website, identify the most popular areas or features of the Website, identify where our users are coming from and determine the effectiveness of our promotional activities.
• To comply with legal obligations, resolve disputes and enforce agreements.
• To notify you regarding any concerns with the Website, including, as required by law, in the event that any sensitive personal information you provided to us is exposed to unauthorized third parties. In the event of such unauthorized exposure, we expressly reserve the right to provide notice to you electronically via any email address you have provided to us if permitted to do so by law.
• To carry out other purposes that are disclosed to you and/or to which you consent.

We may disclose some of this information to our affiliates and partners to inform them of the number of people who have seen and/or clicked through their advertisements or promotions.

Sweepstakes, Contests, and Promotions. The Partnership may offer sweepstakes, contests, and other promotions (each, a “Promotion”), including Promotions jointly sponsored or offered by third parties, which may require submitting personal information. If you voluntarily choose to enter a Promotion, your information, including personal information, may be disclosed to the Partnership, co-sponsors, service providers, and other third parties, including for administrative purposes and as required by law (e.g., on a winners list). By entering, you are agreeing to the official rules that govern that Promotion, which may include consent to additional or differing data practices from those contained in this Policy.

The categories of personal information that we may have shared for a business or commercial purpose include any of the categories of personal information shown in the table above. We do not “sell” your information in the traditional sense of the word, but out of an abundance of caution and in light of very broad views of what it means to sell data in certain potentially applicable privacy laws, we are disclosing that the ways in which we share information about you could be considered a sale in some jurisdictions. Some examples of ways in which we may share personal information include:

• Information you submit through any public forum we make available may be shared with other members via the forum. We think this is self-evident, but out of an abundance of caution and in light of very broad interpretations of what must be disclosed to you in certain privacy laws, we are disclosing this information to you. We may also provide access to forum membership directories, publish and share event attendance lists to event attendees and other members, and otherwise share information about your public interaction with us with other members. Typically the only information we would share in this circumstances is your name, title or position, address, telephone number, and email address.
• We may collect, report and share information on an aggregated basis with technical service providers, such as web developers. For example, we may inform our service providers regarding the number of unique users of the Website or provide them with aggregate information on the types of activities users conduct while using the Website. By using the services, you consent to the processing and handling of your personal information by our service providers in the manner and for the purposes described here and in their respective privacy policies. We do not authorize such third parties to use the information provided except as necessary to provide services to us or for purposes authorized by us.
• Like many companies, however, we use services that help us deliver content to you that we hope you will find interesting—that may include advertisements (sometimes this is known as interest-based advertising). In order to deliver this sort of interest-based content, our third-party service providers may need to receive some of your personal information. Making personal information (such as online identifiers or browsing activity) available to our partners may be considered a “sale” under certain privacy laws.
• Additionally, we may disclose your personal information (1) to comply with a law, regulation, or other governmental request, for example, to comply with subpoenas, court orders, legal process, or requests by law enforcement or governmental entities; (2) to investigate or defend against third-party claims against us; (3) where we believe the rights, property or safety of The Partnership, its users or the public is at risk; (4) to detect, prevent, or investigate fraud or other illegal activity or to enforce this Policy; (5) to repair or resolve technical issues in the operation of the Website; (6) to respond to a request by you to disclose the information, including your requests to allow access to your account and personal information by third-parties designated by you, as described in more detail below; (7) with your knowledge and consent; (8) to address emergencies or acts of god; and (9) as an asset of the business in the event of a sale, merger or other business combination or transfer involving us or our affiliated entities.

There are various ways you can choose to access, update, or limit the personal information you provide to us and that we collect and process.

Exercise Your Privacy Rights. Depending on where you live you may have certain privacy rights created by law. While laws vary between jurisdictions, we seek to provide the same basic level of privacy rights to everyone regardless of where you live. Thus, the rights described below may be used by anyone with whom we interact or about whom we collect personal information.

• Information Access and Portability. You can ask us what personal information we have about you and with whom we have shared that information. Subject to verification of identity, you also have a right to request and be provided with a copy of that information in a commonly used, machine readable format. Unless we are required to provide more information by an applicable law in your jurisdiction, that response will be limited to the following:
• Specific pieces of personal information we have collected about you.
• The categories of personal information we have collected (for reference see the table above for categories and examples of personal information that we may collect).
• The sources from which we have collected your personal information.
• Our business or commercial purpose for collecting or selling personal information.
• Whether we have sold your personal information for a business or commercial purpose.
• The categories of third parties to whom we have sold personal information, if any.
• Correction/Rectification. While you may have the ability to edit certain profile information as described below, you also have the right to request that we correct any mistakes or inaccuracies in your personal information provided we are able to verify your identity.
• Deletion/Erasure. You are entitled to request that we delete your personal information from our systems to the fullest extent possible. There may be certain circumstances, however, where we cannot delete all of your personal information. For example, if you posted within a forum and others have commented on your post, we may not be able to remove your original post. In some cases, deletion may be accomplished through de-identification of the information. Please note that certain information may be excepted from your deletion request. For example, we may keep your information where necessary to detect and resolve issues related to system security and fraud detection.
• Objection. You have the right to object to our use of your personal information where our processing is based on legitimate interests (as described above) or is for direct marketing purposes.
• Restriction. In certain circumstances, you have the right to request that we restrict the processing of your personal information.
• Withdraw Consent. While we try not to rely on consent as a basis for processing your personal information, where we do rely on that basis you have the right to withdraw your consent at any time.

To exercise your rights you may contact us via the Website here or by any other means provided below. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in order to fulfil your request. Please note that we may ask you to verify your identity before responding to such request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.

Non-Discrimination. We will not discriminate against you for exercising any of the rights listed in this section. Specifically, we will not (1) deny you services, (2) provide you a different level or quality of services from other users of the Website, (3) charge or suggest that we will charge you different prices or rates membership or event registration, except to the extent that not having your personal information limits our ability to provide you with desired services.

In addition to the rights discussed above, there are various other ways you can choose to access, update, or limit the personal information you provide to us.

Profile Preferences. If you are an account holder with a profile, your account name will be public, but you may limited whether other account information is shared or disclosed.

Unsubscribe from Emails. You may opt-out of receiving Emails from us by following the “unsubscribe” instructions included in certain emails we send you or by contacting us via the Website here or by any other means provided below.

Mobile Application Users. You may choose to uninstall our applications from your mobile device and delete the associated data.

Public Forum Posting. We may permit you to post or submit user generated content via public forums or message boards we make available. Any information you post publicly that identifies you personally may qualify as personal information in certain jurisdictions. Such information is necessarily available to other users of that forum when you post it. You should exercise caution when deciding to disclose personal information in our forums. The Partnership is not responsible for the disclosure of any information to any authorized user of the forum and may not be able to remove such information once posted. Additionally, if you provide personal information via the forums we may not be able to easily identify and single out that information in response to a request to exercise your privacy rights. If you make such a request we will instead provide you with copies of all messages linked to your account.

Google Analytics. As noted above, we use the Google Analytics service to gather and provide us with statistical data about how our Website is used. This Google service uses a cookie that can be recognized by Google when you visit other websites. You can opt out of Google Analytics’ collection and use of data generated by your use of the Website by going to http://tools.google.com/dlpage/gaoptout.

We take the security of personal information seriously. We employ reasonable technical, physical and administrative security measures to protect against the loss, misuse, unauthorized access, alteration and destruction of the personal information we collect from you. Reasonable efforts are made to secure our web servers, networks, host operating systems and databases against unauthorized access. Please remember that the security measures taken above are not foolproof; no one can guarantee that personal information will be protected in all situations. We cannot and do not guarantee that your personal information will never be accessed by an unauthorized party or otherwise breached. If we learn of a breach, we will comply with applicable law; however, unless a statute, regulation or other law provides you a right that cannot be waived, you specifically waive and covenant not to sue us for any data loss or breach of our system resulting in loss of personal information.

We will retain your personal information for the period of time required for the purposes for which it was collected, any compatible purposes which we subsequently establish, or any new purposes to which you subsequently consent, or to comply with legal, regulatory and other policy requirements. This period of time will usually be the period of your relationship or contract with us plus a period reflecting the length of time for which legal claims may be made following the termination of such relationship or contract. We reserve the right to delete or destroy any information collected, including personal information, at any time.

We will also retain certain usage data for internal analysis purposes. This data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Website, or we are legally obligated to retain this data for longer time periods.

We may collect data about your company during your usage of the Website in the form of your responses and non-responses to information we solicit. We do not view this information about your company practices to be personal information. In full disclosure and in the spirit of transparency, however, we disclose that we may use, share and disclose this company data in the following ways:

• We may anonymize and aggregate company data for comparisons and reporting and report those comparisons and reports to persons and companies outside of The Partnership.
• We may disclose any collected data, including company data entered for your company or other entity, to your company or to any principal for whom we can verify you are acting, as well as identifiable affiliated, parent and subsidiary companies.
• We may disclose or publish company data in ways you subsequently permit or consent to.

If you are located in the European Economic Area (“EEA”), the United Kingdom, or Switzerland, you have certain rights and protections under applicable law regarding the processing of your personal data. This section applies to you.

Legal Basis for Processing. When we process your personal information, we will do so in reliance on the following lawful bases:

• Legal obligation. Where the processing of your personal information is necessary for us to comply with a legal obligation to which we are subject.
• Contractual relationship. Where it is necessary for us to use your personal information in order to perform a contract to which you are a party or to take steps at your request. An example would be collecting and using your contact information in order to fulfill an order.
• Legitimate interests. We rely on this basis to collect and use personal information for our legitimate interests and the use of your personal information is fair, balanced and does not unduly impact your rights. For instance, it is in our legitimate interest to use personal information to protect the Website from any attacks and to ensure appropriate security. When we process your personal information to achieve such legitimate interests, we consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. We will not use your personal information for activities where our interests are overridden by the impact on you, for example where the use would be excessively intrusive (unless, for instance, we are otherwise required or permitted to do so by law).
• Consent. We may obtain your consent to use your personal information in certain circumstances. We will ensure that when we obtain your consent you are free both to give it and to decline to give it. Additionally, you may always withdraw your consent at any time without any further detriment to you.

Before collecting and/or using any special categories of data (as that term is defined in the EU General Data Protection Regulation, or as an equivalent term is defined by other privacy laws) we will establish a lawful exemption which will allow us to use that information. This exemption will typically be your explicit consent or the establishment, exercise or defense by us or third parties of legal claims.

Data Processing and Cross-Border Information Transfers. The Partnership is aware that there are certain restrictions on the cross-border transfer to the United States of personal information collected from residents of countries located in the EEA and the United Kingdom. However, because The Partnership’s personnel work primarily in the United States, it is likely that when you interact with us information you provide will be viewed or used by personnel in the United States. Please be advised that if you are located in the EEA or another region of the world that restricts data transfers to the United States, the information you provide to us voluntary may not be deemed to have the same level of data protection as that provided by your home country. Your consent to this Policy followed by your submission of such information represents your agreement to that transfer, to the fullest extent allowed under the law. In all such instances where personal information that we process on behalf of our customers and partners is transferred to the United States, we will take all reasonable steps necessary to ensure that appropriate safeguards designed to protect personal information are implemented (e.g., entering into approved standard contractual clauses).

Questions or Complaints. If you have a concern about our processing of personal information that we are not able to resolve, you have the right to lodge a complaint with the Data Protection Authority where you reside. Contact details for your Data Protection Authority can be found using the links below: 

• For individuals in the EEA: https://edpb.europa.eu/about-edpb/board/members_en
• For individuals in the UK: https://ico.org.uk/global/contact-us/
• For individuals in Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html

No Use of Website by Children Under 13. The Website, and the services offered through the Website are primarily intended for local government and corporate entities interested in furthering their recycling goals and promoting recycling in their communities. The Websites are not directed at or intended for use by persons under 13 years old. If you are under the age of 13 you should not be visiting the Websites. We do not knowingly collect or retain personal information from persons under the age of 13. If you are under the age of 13 and are visiting or otherwise using the Website please exit the Website immediately and do not disclose or provide any personally-identifiable information to us. If you are a parent or guardian who thinks your child has disclosed information to us, please contact us here so that we can remove that from our systems.

Parent or Guardian Permission for Minors; Acceptance of Responsibility. If you are over the age of 13, but less than 16 years of age and would like to use the resources, articles and other information made available on the Website to learn about recycling and affect change in your community or take the Pledge to Recycle we appreciate your dedication and commitment to our passion, but, please ask your parent or legal guardian to review and agree to this Privacy Policy and our Terms before you use any part of the services. Your continued use of the Website indicates that you have obtained such permissions; if you have not obtained such permission and you provide information about yourself through online forms and/or otherwise use the Website, you do so in violation this Privacy Policy and our Terms

If you are a parent or guardian who has granted your minor permission to use the Website, you agree and understand that you are responsible for monitoring and supervising your child’s usage. If you believe your minor has provided personal information to us or created a profile on the Website without your permission, please contact us immediately via the Website here so that we can remove that information from our systems.

Links to Third-Party Websites. Our Website may contain links to other websites and other websites may reference or link to our Website. We cannot control nor are we responsible for the privacy practices or the content of other websites. It is always a good idea to read the privacy policy on any third-party website that you visit. We encourage you to be aware when you are leaving our Website. This Policy applies only to personal information collected by The Partnership.

Do Not Track Signals. Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

We may update or change our privacy practices and this Policy from time to time. The date at the top of this Policy reflects the date of the most recent update. You are advised to review this Policy periodically for any changes. Your continued use of the Website signifies your continued assent to this Policy, as updated or amended at that time. However, we will not treat your previously collected personal information, to the extent it was collected based on your consent and/or a prior privacy policy, in a manner materially different than represented at the time it was collected without reobtaining your consent.

If you have questions about this Policy, or if you wish to exercise any of the privacy rights described in this Policy, you may contact us by calling us toll-free at 877-514-8774, by writing to us at our main corporate address below, or by contacting us via the Website here.

Users from the EEA may contact us at info@recyclingpartnership.org, or by writing to us at our main corporate address below.

Attn: Legal Counsel
The Recycling Partnership
20 F Street NW, 7th Floor
Washington, DC 20001, USA