GLASS HALLMARK COOKIES AND PRIVACY POLICY

Brussels, November 18, 2021.

This is the Privacy and Cookie Policy of the European container glass industry initiative known as the ‘Glass Hallmark.’

The glass hallmark is a trademarked communication tool designed by the industry to promote the “recyclability” and “inertness” qualities of glass as a material. It represents the ability of the container glass on which the mark is put to be recycled and to optimally preserve the content as a result of its inert nature. It can be used on every glass container irrespective of the way in which this glass container was manufactured, unless in a way that prevents the glass container concerned to be recyclable.

As of November 2021, the secretariat and administrative function for ‘Glass Hallmark’ is run through FEVE – the European Container Glass Federation (hereinafter referred to as “FEVE” or “we, us”).

This Cookies and Privacy Policy explains how we use the personal information that Glass Hallmark, represented by the European Container Glass Federation/Fédération Européenne du Verre d’Emballage AISBL (FEVE), collects or generates in relation to this website. The list below sets out what is covered in this Cookies and Privacy Policy.

1. Background
2. Categories of personal data
3. How we use your information
4. Disclosure of your information to third parties
5. International transfers of personal data
6. How we safeguard your information
7. How long we keep your personal data
8. Your rights
9. Cookies
10. Questions and concerns

1. Background

1.1 Glass Hallmark, represented by FEVE with its registered office at Avenue Louise 89, Bte. 4, 1050 Brussels, with company number 417.651.811, collects and uses certain Personal Data. Glass Hallmark is responsible for ensuring that it uses that Personal Data in compliance with data protection laws.

1.2 At Glass Hallmark we respect the privacy of our contacts and we are committed to keeping all your Personal Data secure. This Privacy Policy governs the handling of Personal Data by Glass Hallmark in the course of carrying on its activities.

1.3 We use the following definitions in this Privacy Policy:

“Glass Hallmark”, “we” or “us” means Fédération Européenne du Verre d’Emballage AISBL.

“Personal Data” means any data which relates to a living individual who can be identified from that data or from that data and other information which is in the possession of, or is likely to come into the possession of, Glass Hallmark (or its representatives or service providers). In addition to factual information, it includes any expression of opinion about an individual and any indication of the intentions of Glass Hallmark or any other person in respect of an individual.

2. Categories of personal data

2.1 This Cookies and Privacy Policy concerns the following categories of information that we collect about you:

• Information we receive through our website (“Website”); and
• Information we receive through or in connection with the provision of our services (“Glass Hallmark Services”).

2.2 We will collect and process the following Personal Data about you:

Information that you provide to Glass Hallmark. This includes information about you that you provide to us. The nature of the services you are requesting will determine the kind of Personal Data we might ask for, though such information may include (by way of a non-exhaustive list):

– basic Personal Data (such as first name; family name; position in the company; company name; company email address; business phone number; business address; city; postcode; country);

– any information that you choose to share with us (whether through our Website or otherwise) which may be considered Personal Data;

Information that we collect or generate about you. This includes (by way of a non-exhaustive list):

– Information about the Glass Hallmark Services which you have requested and our interactions with you;

– When you visit our Website, cookies are used to collect technical information about the services that you use, and how you use them. For more information on the cookies used by Glass Hallmark please see the cookie section below.

Anonymized data
– In addition to the categories of Personal Data described above, Glass Hallmark will also process further anonymized information and data that is not processed by reference to a specific individual.

3. How we use your information

3.1 Your Personal Data may be stored and processed by us in the following ways and for the following purposes:

• for ongoing review and improvement of the information provided on or operation and security of Glass Hallmark Websites;
• to assess your application for Glass Hallmark Services, where applicable;
• to invite you to events organized by Glass Hallmark, represented by FEVE and its partners;
• to manage your attendance to the above events;
• to set you up as a member;
• to provide you with Glass Hallmark Services
• to understand feedback on Glass Hallmark Services and to help provide more information on the use of those services quickly and easily;
• to communicate with you in order to provide you with services or information about Glass Hallmark;
• to understand your needs and interests;
• for the management and administration of our activities;
• in order to comply with and in order to assess compliance with applicable laws, rules and regulations, and internal policies and procedures; and / or
• for the administration and maintenance of databases storing Personal Data.

3.2 When we use Personal Data we make sure that the usage complies with law and the law allows us and requires us to use Personal Data for a variety of reasons. These include where:

• we need to do so in order to perform our contractual obligations with our members;
• we have obtained your consent;
• we have legal and regulatory obligations that we have to discharge;
• we may need to do so in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings;
• the use of your Personal Data as described is necessary for our legitimate interests, such as:
• allowing us to effectively and efficiently manage and administer the operation of our activities;
• conducting market research or business analysis;
• maintaining compliance with internal policies and procedures; and
• promoting our activities.

3.3 We will take steps to ensure that the Personal Data is accessed only by employees of Glass Hallmark, represented by FEVE, that have a need to do so for the purposes described in this Cookies and Privacy Policy.

4 Disclosure of your information to third parties

4.1 We may share your Personal Data within the Glass Hallmark group of members and related associations for the purposes described above.

4.2 We may also share your Personal Data outside of the Glass Hallmark group for the following purposes:

• with our business partners. For example, this could include intermediaries that introduced you to us. Personal Data will only be transferred to a business partner who is contractually obliged to comply with appropriate data protection obligations and the relevant privacy and confidentiality legislation;
• with third party agents and contractors for the purposes of providing services to us (for example, Glass Hallmark’s accountants, professional advisors, IT and communications providers and debt collectors). These third parties will be subject to appropriate data protection obligations and they will only use your Personal Data as described in this Cookies and Privacy Policy;
• to the extent required by law, for example if we are under a duty to disclose your Personal Data in order to comply with any legal obligation, or to establish, exercise or defend our legal rights.

5. How we safeguard your information

5.1 We have extensive controls in place to maintain the security of our information and information systems. The information that we handle is protected with safeguards appropriate to the sensitivity of the relevant information. Appropriate controls (such as restricted access) are placed on our computer systems. Physical access to areas where Personal Data is gathered, processed or stored is limited to authorised employees.

5.2 As a condition of employment, Glass Hallmark/FEVE employees are required to follow all applicable laws and regulations, including in relation to data protection law. Access to sensitive Personal Data is limited to those employees who need it to perform their roles. Unauthorised use or disclosure of confidential client information by a Glass Hallmark/FEVE employee is prohibited and may result in disciplinary measures.

6. How long we keep your personal data

6.1 How long we will hold your Personal Data for will vary and will be determined by the following criteria:

• the purpose for which we are using it – Glass Hallmark will need to keep the data for as long as is necessary for that purpose; and
• legal obligations – laws or regulation may set a minimum period for which we have to keep your Personal Data.

7. Your rights

7.1 In all the above cases in which we collect, use or store your Personal Data, you may have the following rights and, in most cases, you can exercise them free of charge. These rights include:

• the right to obtain information regarding the processing of your Personal Data and access to the Personal Data which we hold about you;
• the right to withdraw your consent to the processing of your Personal Data at any time. Please note, however, that we may still be entitled to process your Personal Data if we have another legitimate reason for doing so. For example, we may need to retain Personal Data to comply with a legal obligation;
• in some circumstances, the right to receive some Personal Data in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to Personal Data which you have provided directly to Glass Hallmark;
• the right to request that we rectify your Personal Data if it is inaccurate or incomplete;
• the right to request that we erase your Personal Data in certain circumstances. Please note that there may be circumstances where you ask us to erase your Personal Data but we are legally entitled to retain it;
• the right to object to, or request that we restrict, our processing of your Personal Data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your Personal Data but we are legally entitled to refuse that request; and
• the right to lodge a complaint with the relevant data protection regulator if you think that any of your rights have been infringed by us.

7.2 You can exercise your rights by contacting us using the details listed in paragraph 10 below.

7.3 You can find out more information about your rights by contacting the data protection regulator in your jurisdiction, the Belgian Privacy Commission (“Autorité de protection des données” or “Gegevensbeschermingautoriteit”), rue de la Presse 35, 1000 Brussels, or by searching their website at https://www.privacycommission.be.

8. Cookies

8.1. This section on cookies and the consent that you gave for the use of cookies apply to each use of this website. You gave your consent to the use of cookies in the cookie banner as described in the cookie banner and this section.

Glass Hallmark tries to keep the information on the cookies up-to-date but insists on the fact that the information is always a snapshot. Because of the constant innovation of the Website, the non-static character of the internet and the third parties involved in the use of cookies, it is possible that all cookies and information are not available here.

To the extent that we collect personal data with the help of cookies we will process them in accordance with this Cookies and Privacy Policy.

8.2. Types of cookies and purposes

A cookie is a small file that includes a small quantity of information sent to the browser of the website user by a web server and stored on the hard disk drive of the computer for archiving purposes. Certain parts of the Website runs on the basis of profile information recorded in the cookies.

The Website uses cookies in two ways. The cookies are first used to identify you as a user and to allow you to use our website. Those cookies are deleted at the end of a session unless you choose explicitly to save your user name and password. The cookies are also used to record information in order to re-use them and to save your user preferences. The cookies are part of the functionalities of our Website. If your browser does not accept the cookies, you will not be able to use this Website properly. In addition to Personal Data, the Website also records non personal data (number and duration of the visits, preferences, etc.). Those data are used to improve the Website and its use, for example by displaying information based on the interests of the user. Glass Hallmark will periodically receive a summary of the data rendered anonymous that cannot lead to identifiable users. Those data no longer allow to identify the individual user.

9. Questions and concerns

9.1 If you have any questions or concerns about Glass Hallmark’s handling of your Personal Data, or about this Policy, please contact our Privacy Officer using the following contact information:

Fédération Européenne du Verre d’Emballage AISBL (FEVE)
89 Avenue Louise, B-1000 Brussels
Email Address: secretariat@feve.org