Effective Date: November 17, 2023
- WHAT PERSONAL INFORMATION WE COLLECT AND HOW WE USE IT
Categories Of Personal Information That We Collect
Personal information is any data that personally identifies, describes, or could be reasonably linked, directly or indirectly, with a particular individual or household (“Personal Information”).
As identified in the chart below, over the past twelve months we have collected or may have collected Personal Information about you when you use our products and services, or interact with us through our Sites and/or call centers operated on our behalf.
We may share some of this information within our group of companies and with certain third parties for consumer and customer relations, advertising, promotion and insurance purposes. For more information, please see sections IV and V below.
Category of Personal Information Collected by Reynolds
Category Collected by Reynolds
Category Disclosed by Reynolds
Personal Identifiers such as your name, address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, credit card or debit card number, and telephone number.
Commercial information including, but not limited to records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Internet or network activity including your browsing history, search history, information on your interaction with our website, application, or advertisement.
Your audio, electronic, visual, or similar information. https://www.reynoldsconsumerproducts.com/privacy - _ftn2
Inferences that we may draw from the above information (except for sensitive Personal Information) reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Education information, employment, or employment history if you apply for a job through our Sites.
Sensitive Personal Information, such as Social Security number, driver’s license number or state identification card number, passport number, bank account information, or other similar identifiers if you apply for a job through our Sites.
If you purchase products through our Sites, our payment processor will collect financial information, such as credit card or debit card information, to process your payment.
Reynolds collects and discloses sensitive Personal Information through the Sites only if you apply for a job through our Sites. We do not use sensitive Personal Information for the purpose of inferring characteristics about individuals.
Reynolds does not collect Special Categories of Personal Information about you (e.g., your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data).
- How We Use Personal Information
We use the information we collect about you for a variety of purposes as described in this Policy, including to:
- provide, deliver, maintain and improve the products and services you request;
- provide you with customer service;
- provide updates, upgrades, repairs or troubleshooting our Sites;
- manage and configure our systems and networks;
- understand how the Sites are being used, including through the creation of operational and marketing reports based on de-identified and/or aggregated service usage information;
- inform you of additional products and services that may be of interest to you;
- protect the security of the Sites and our systems, prevent fraud, detect unauthorized reception, use, and abuse of any Reynolds product, service, website or application, and to enforce any Reynolds policy or applicable terms of service;
- protect our rights, our personnel, our property, and the safety of others;
- maintain our accounting, tax and other records;
- comply with applicable federal and state laws and regulations, as well as for the general administration of our business;
- deliver and personalize communications with you;
- create internal business and marketing reports; and
- provide advertising and marketing.
The legal basis that we rely upon to Process your Personal Information will depend on the circumstances in which it is collected and used. In most cases, the legal basis will fall into one of the following categories where:
- we need to perform the contract we are about to enter into or have entered into with you;
- it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
- we need to comply with a legal obligation; or
- you consent to the processing of your Personal Information.
You have the right to withdraw such consent at any time by contacting us.
If You Fail to Provide Personal Information
Where we need to collect personal information by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have requested from us, but we will notify you if this is the case.
- How We Disclose Personal Information
- Your Personal Information Rights
Reynolds may disclose your Personal Information to any member of our group, which means our affiliates, subsidiaries, and our ultimate holding company and its subsidiaries in compliance with applicable privacy principles, laws, regulations and rules.
In order to more efficiently provide the products and services you may request from us, Reynolds may also share your Personal Information with selected third parties who are acting or gathering information on our behalf as our agents, suppliers, or providers.
To this effect, we may disclose Personal Information to the following:
- Entities who perform tasks on our behalf; and
We may also disclose your Personal Information to third parties if:
- We or any member of our group are involved in a merger, sale, acquisition, or similar transaction, involving all or part of our business or assets, including in connection with due diligence; we may share your Personal Information with the prospective buyer or seller of such businesses or assets.
- We are under a duty to disclose or share your Personal Information in order to comply with any legal obligation, subpoena or other court order; or in order to enforce or apply any of our online Terms and Conditions and other agreements; or to protect the rights, property or safety of our group companies and organizations for the purposes of fraud protection and credit risk reduction; or for any other reason as required or permitted by law.
Depending on where you are based, you may have certain Personal Information rights. We set these out below:
Section 1 – Residents of California
Notice at Collection
We may collect certain categories of Personal Information about you when you. Please see What Personal Information We Collect and How We Use It for a detailed description of the categories of Personal Information, including sensitive Personal Information. We collect this information to provide the Sites and services to you, as described in more detail in How We Use Personal Information. We will retain these categories of information as described in more detail in Data Retention.
In the last 12 months, we have collected personal identifiers, commercial information, Internet or other electronic network activity information, audio, electronic, visual or similar information, and inferences drawn from the above. For job applicants, we also have collected education information and sensitive Personal Information. We collect this information from you when you provide it to us and when you interact with our Sites and/or call centers.
Section 2 – Residents of California, Colorado, Connecticut, Utah, and Virginia
Your Rights to Know and to Access Personal Information
If you are a resident of California, Colorado, Connecticut, Utah, or Virginia, and want to know the Personal Information we have collected about you in the last 12 months, you may submit a verifiable consumer request to us, and subject to our verification of that request, we will provide you with the following information:
- the categories of Personal Information we have collected about you;
- the categories of sources from which the Personal Information is collected;
- the business or commercial purpose for collecting, disclosing or selling, if applicable, the personal information;
- the categories of third parties with whom we have shared or sold, if applicable, your personal information; and
- the specific pieces of personal information we have collected about you.
In addition to these disclosures, you may submit a verifiable consumer request up to two (2) times in a twelve (12)-month period for access to your Personal Information we have collected. When you submit an access request, you can ask us to deliver the information by mail or electronically. If you elect to receive the information electronically, to the extent it is technically feasible for us to do so, we will provide it in a portable and readily useable format.
In order to submit a verifiable consumer request, please visit the “How You Can Submit a Verifiable Consumer Request” section below.
Your Right to Correct
If you are a resident of California, Colorado, Connecticut, or Virginia and you want to correct inaccuracies in the Personal Information that we have collected, processed, or otherwise obtained about you in the last twelve (12) months, you may submit a verifiable consumer request to us, and subject to our verification of that request, we will provide you with the opportunity to correct the inaccuracies, taking into account the purposes of processing the Personal Information.
Your Right to Delete
If you are a resident of California, Colorado, Connecticut, Utah, or Virginia, and want us to delete the Personal Information we have collected from or about you, you can send us a verifiable consumer request requesting that we delete some or all of such information, subject to certain exceptions. Once we receive and confirm your request to delete, we will delete such Personal Information from our active records, unless an exception applies. We will also notify any service providers and third parties with whom we have shared your Personal Information of your request.
Deletion requests are subject to certain limitations. We are not required to delete information where we are permitted or required to retain it, such as for tax, or record keeping purposes, to process orders and transactions, and for solely internal uses consistent with your relationship with us. If we deny your request to delete based on any of these exceptions, we will inform you in writing of the reason.
How to Submit a Request
For us to process a request to know, access, correct, or delete, it is necessary for us to verify your identity. We will ask you to provide certain additional information about yourself, such as name, physical address, email address and phone number, or other identifying information, to compare to information we have on file for you to verify your identity. We cannot fulfil your request if we cannot verify your identity. It may take up to forty-five (45) days to fulfil your request. If we cannot complete your request within the initial forty-five (45) day period, we will notify you in writing within forty-five (45) days of your initial request.
To request exercise one or more of your consumer rights, please submit a verifiable consumer request:
- 1-800 433-2244; or
California, Colorado, or Connecticut residents may authorize another person (your “agent”) to submit a request on your behalf. We will also require that you provide us with information sufficient for us to verify that you have authorized this person to act for you and to verify your identity as provided above.
Residents of Colorado, Connecticut and Virginia can appeal a decision regarding their consumer privacy requests by contacting us by email at RCPCommunications@ReynoldsBrands.com.
Your Right to Opt-Out of Selling or Sharing
We may disclose certain Personal Information to third parties, including third parties who may process your personal information for targeted advertising. These activities may be considered a “sale” or “share” under these state laws. The categories of Personal Information we may “sell” or “share” are personal identifiers, commercial information, and Internet or other electronic network activity information. We may disclose this information to advertising and marketing networks, and data analytics providers. If you are a resident of California, Colorado, Connecticut, Utah or Virginia you have the right to opt-out of sharing your Personal Information with third parties for these purposes. Email us at RCPCommunications@ReynoldsBrands.com with the “Request to Opt-Out” in the message.
Your Right to Non-Discrimination
We do not discriminate against consumers for exercising any of their rights with respect to their Personal Information. If you are a consumer exercising any of your rights under this policy, we will not deny you goods or services; charge you different prices or rates for goods or services; or provide different levels or quality of goods or services to you.
Section 2 UK and EU data subject rights
Your Right to Request Access to Your Personal Information
If you are a data subject in the UK or the EU, you have the right to submit a data subject access request. This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
We shall take steps to verify any request. This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
You may file more than one requests for access to your Personal Information, but if the number of requests is manifestly excessive, we have the right to refuse to comply. If you elect to receive the information electronically, to the extent it is technically feasible for us to do so, we will provide the requested information in a portable and readily useable format.
We try to respond to all verified requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Your Right to Delete
You have the right to ask us to delete or remove Personal Information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Your Right to Correct
You have the right to request that any incomplete or inaccurate data we hold about you is corrected, though we may need to verify the accuracy of the new data you provide to us.
Your Right to Object to the Processing of Your Personal Information
You have the right to object to the processing of your Personal Information where we are relying on a legitimate interest (or those of a third party), or where we are processing your Personal Information for direct marketing purposes. In some cases, we may have compelling legitimate grounds to continue to process your information.
Your Right to Restrict the Processing of Your Personal Information
You have the right to ask us to suspend the processing of your Personal Information in the following scenarios:
- If you want us to establish the data's accuracy.
- Where our use of the data is unlawful, but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
Your Right to Request the Transfer of Your Personal Information
You have the right to request the transfer of your Personal Information. If you make such a request, we will provide to you, or a third party you have chosen, your Personal Information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Your Right to Withdraw Consent
Where we are relying on consent to process your Personal Information you have the right to withdraw this consent at any point. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
You will not have to pay a fee to access your Personal Information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
EU And UK Contact
- International Transfers for Individuals Outside the United States
If you are based outside the US, we share your Personal Information with Reynolds business units/affiliates/subsidiaries. This will involve transferring your data outside the country or region where you are located. Whenever we transfer your Personal Information to the US, we will take reasonable steps to protect it, including by using contractual safeguards, such as standard contractual clauses, obtaining your consent, or using other lawful means to transfer the information.
- Security and Data Integrity
- Cookie Notice
In order to improve our Sites, we use “cookies” to maintain a record of your visit. A cookie is a small text file that is stored on your device when you visit one of our Sites. Cookies help us to improve our Sites and to enable us to understand how users interact with the Site; to store information about your preferences; to speed up your searches and may be used to recognize your computer. You can find more information at www.allaboutcookies.org and www.youronlinechoices.eu.
Most web browsers automatically accept cookies. If you would prefer to prevent your computer from accepting our cookies, you may follow your Internet browser’s steps for doing so. Please note, however, that if you do disable cookies from your browser, you may not be able to access certain sections of our websites.
We use both persistent cookies and session cookies. Persistent cookies remain on your device and allow websites to remember your preferences and recognize you when you return to the Sites. Session cookies allow websites to remember your actions on the Sites during a visit, and are automatically removed from your device when you close your browser.
We use the following types of cookies:
Strictly necessary/ Technical
These cookies are necessary to allow us to operate our Sites so you may access them as you have requested. These cookies, for example, let us identify the IP address from which you access Site content.
These cookies let us operate our Sites and Services in accordance with the choices you make. These cookies permit us to "remember" you in-between visits.
These cookies are used by us or our partners to market our products and services to you based on your activities on our Site or purchase history with us.
To administer our Sites and for research purposes, Reynolds also works with third party service providers to track and analyze usage and volume statistical information from our Site users. These third party service providers use persistent cookies to help us to improve the user experience, manage our Site content, and track user behavior.
The specific cookies that we use for our Sites are as follows:
The _ga cookie, installed by Google Analytics, calculates visitor, session and campaign data and also keeps track of site usage for the site's analytics report. The cookie stores information anonymously and assigns a randomly generated number to recognize unique visitors.
Installed by Google Analytics, _gid cookie stores information on how visitors use a website, while also creating an analytics report of the website's performance. Some of the data that are collected include the number of visitors, their source, and the pages they visit anonymously.
This cookie is installed by Google Tag Manager to collect data and provide analytics about how visitors interact with our advertising campaigns.
This cookie and variations on it are installed by Google Universal Analytics to restrain request rate and thus limit the collection of data on high traffic sites; the variations also allow us to monitor visitor interaction with our websites and site performance.
This cookie is installed by AudioEye to support the functioning of the accessibility features.
This cookie is set by Doubleclick to enable us to service advertising consistent with your interests.
Advertising and Analytics
How to manage cookies
You can prevent most cookies from being set onto your device by selecting the appropriate settings on your browser. You can also adjust the setting of your Internet browser to reject the setting of all or some cookies and to alert you when a cookie is placed on your device. Please note that if you use your browser settings to block all cookies (including strictly necessary cookies) you may not be able to access or use all or parts or functionalities of our Sites and Services.
For more information on cookies and how you can manage them on your browser and device, please see www.youronlinechoices.eu if you are located in Europe or www.aboutads.info/choices if in the United States.
Changes to our cookie notice
Any changes to our cookie notice will be posted on our Sites.
- Data Retention
We offer a range of Sites to our users, but our Sites are not intended to target children. We do not knowingly request or collect Personal Information from children. If we learn that we have collected information from a child, we will delete that information as provided under applicable privacy law. From time to time, we may offer Sites that appeal to a large range of people, and we may provide separate or additional Site-specific privacy notices consistent with applicable laws. As used in this Policy, “children” and “child,” refer to children under the age of 13, except for those jurisdictions where the privacy law specifies a different age.
- Other Sites
Our Sites may contain links to other websites, including the websites of third parties who are acting on our behalf as our agents, suppliers, or providers.
- Complaints and Questions
Reynolds takes your privacy concerns seriously. If you have any complaints regarding this policy, or questions about our privacy practices, you may write to RCPCommunications@ReynoldsBrands.com or send a letter to RCP Privacy Complaints at Reynolds Consumer Products, 1900 West Field Court, Lake Forest, Illinois 60045, Attention: Law Department.
You have the right to complain to your relevant data protection authority if you are not satisfied by our response.