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PRIVACY POLICY

Menasha Corporation (“Menasha,” “we,” “us,” or “our”) takes your privacy seriously. This Privacy Policy and Notice at Collection (“Notice”) describes the personal information that is collected through your interactions with Menasha and this website, https://www.menashacorporation.com (“Site”), and how that information is used, shared, and protected.

BY ACCESSING OR USING THIS SITE, YOU REPRESENT THAT YOU HAVE READ AND YOU UNDERSTAND THIS PRIVACY POLICY AND THE TERMS OF USE. IF YOU DO NOT AGREE TO THE TERMS OF THIS PRIVACY POLICY OR TERMS OF USE, DO NOT ACCESS THIS SITE OR SEND US PERSONAL INFORMATION. Please see the end of this Privacy Policy for additional terms that apply to persons located in the European Economic Area and the United Kingdom (collectively, the “EEA”), and residents of Mexico, Canada, California, or another jurisdiction with similar data privacy rights.

This Notice does not apply to job applicants or individuals acting in an employment context for Menasha, such as employees, independent contractors, owners, directors, officers, or medical staff members. When you apply for a job, Menasha processes your personal information as set forth in the “Careers” section of our Site. If you apply for a job through the Careers section of the Site, Menasha will use your personal data as set forth in the “California Consumer Privacy Notice to Job Applicants.”

This Notice does not apply to the information gathered by Menasha’s subsidiaries, Menasha Packaging Company, LLC, ORBIS Corporation, or ORBIS RPM, LLC. Please see the websites for those affiliates for their applicable privacy policies.

Our websites may include links to websites and/or applications operated and maintained by third parties. Please note that we have no control over the privacy practices of websites or applications that we do not own. We encourage you to review the privacy practices of those third parties.

If you wish to access this Notice in an alternate format or require an accommodation to access this Notice, please contact us at: [email protected].

Modifications to This Privacy Policy

Menasha reserves the right to modify or amend this Notice at any time. All changes will be effective immediately upon posting to this Site. Material changes will be conspicuously posted on this Site. If you do not agree to any modified terms posted to this Site, do not access this Site or send us any personally identifiable information.

Categories of Personal Information Collected

Please note that Menasha does not engage in sales directly to consumers acting in an individual or household capacity (“consumers”). As such, the information Menasha collects about consumers in providing various products and services (the “Services”) is limited. Menasha may collect and store the following types of information about you:

  1. Personal Information You Provide to Us for Services. Menasha may collect and store personal information, which is information that can be used to identify, locate, or contact a person, such as your name, business address, title, email address, phone number, mailing address, payment and transaction information for billing purposes, communications with us and survey responses, and purchase history that you may provide directly to us through our provision of the Services.
  2. Information Automatically Collected. Menasha may collect and store internet or other electronic network activity information from and about you automatically when you use this Site, including information or data that does not personally identify an individual person and is not readily available for that purpose. For example, Menasha may collect information such as your type of browser, operating system, search requests, website traffic information, the date and time you visited this Site, the amount of time you used this Site, the pages you visited on this Site, any device you are using to access this Site, and any hyperlinks you click on when using this Site. Please see Cookies and Other Tracking below for additional details.

We do not intend to collect any of the following categories of data:

  1. Sensitive Personal Information, such as Social Security number, government identification card number, account log-in, geolocation, racial or ethnic origin, religious or philosophical beliefs, union membership, the contents of your mail or electronic messages (unless Menasha is a party to that communication), or genetic data, if such information is used to infer characteristics about a consumer. In addition, sensitive personal information includes biometric information for the purposes of identifying an individual, health information, or information concerning a consumer’s sex life or sexual orientation. We do not intend to collect sensitive personal information from you for the purposes of inferring characteristics about you. Please refrain from providing any sensitive personal information to Menasha.
  2. Information from Children. This Site is not directed toward anyone under the age of eighteen (18) years old, or under the age of majority in your place of residence. If you are under this age, please stop using this Site.

How We Collect Your Personal Information

    1. When You Communicate with Us. We collect personal information when you voluntarily provide it to us and communicate with us. For example, when you call, mail, or email us, or when you post on this Site.
    2. When You Request Information. We collect personal information when you request information through this Site on the “Contact Us” page. In these instances, we collect first and last name, company name, job title, email address, phone number (optional), address (optional), and a message regarding your request. We may change the information we collect from time to time, but the information we request from you will be the same type of information as listed in this Section unless otherwise stated on this Site.
    3. We collect personal information if you provide it to us at a tradeshow, such as your name, address, email address, and phone number. We may use this information to send you communications about our goods and services. You can unsubscribe any time by following the instructions in Section 13 or by contacting us as set forth in the “Contacting Us” section below.
    4. Social Media. We may collect and store any information that you post on our Social Media (defined below) accounts, such as your name, social media handle, and public posts or comments you make on social media networks.
  • Automatically – Cookies and Other Tracking.

What types of online tracking mechanisms do we use? We may use cookies, web beacons, pixel tags, and other tracking technologies (collectively, “Cookies”) on this Site.

What are cookies, web beacons, and pixel tags? A cookie is a small text file that this Site saves onto your computer or device when you use this Site that provides us certain information about your activities. Cookies allow this Site to remember your actions and preferences and recognize you or your browser, along with some information you provided. Web beacons and pixel tags are small graphics on a webpage or email that monitor your activity when viewing a webpage or email.

Why do we use Cookies? We use Cookies to:

  • make our Site function properly;
  • provide us and our service providers with information that we will use to provide personalized experiences, such as to change the language on this Site;
  • provide us with valuable data and statistics about the usage and effectiveness of this Site and to help us improve this Site;
  • measure the effectiveness of our marketing campaigns and understand engagement with our emails (such as if messages have been opened, acted on, or forwarded); and
  • help us improve our Services.

What type of information do Cookies collect? The Cookies on this Site may collect information such as:

  • IP addresses assigned to the computers and other devices you use to access the Site;
  • your internet service provider;
  • device ID number;
  • approximate geographic location;
  • browser type;
  • Site pages visited;
  • websites you accessed before and after visiting this Site; and
  • data related to how and when you use this Site (such as the pages most read, time spent, search terms, and other engagement data) or engage with our advertising or communications.

How long do Cookies last? A Cookie can either be a “session” Cookie or a “persistent” Cookie. Session Cookies exist only for so long as you are visiting the applicable site and are typically deleted when you exit your web browser. Persistent Cookies exist for a set period of time, for example, up to several months or years. Each time you visit a site that has implemented a persistent Cookie, the persistent Cookie is renewed and that Cookie will remain active until its predetermined expiration date. You can manually delete persistent Cookies through your browser settings.

Third-Party Cookies. Cookies may either be “first-party” or “third-party” Cookies. A first-party Cookie allows your web browser to talk to the actual site that you are visiting (e.g., this Site). A third-party Cookie allows your web browser to talk to a third-party website, such as the source of an ad that appears on the website you are visiting or a third-party analytics provider.

How do you manage Cookies or Opt Out? Most browsers automatically accept cookies. You can disable this function by changing your browser settings, but disabling cookies may impact your use and enjoyment of this Site. Not all features or functions of this Site may work properly if you disable Cookies. You cannot disable all Cookies, such as Cookies that are essential to the functioning of this Site. You can opt out of cookies as discussed in Advertising and Remarketing below. California residents may opt out of certain third-party Cookies as discussed in the Right to Opt Out of Cookies and Sale/Sharing Using Online Technologies.

What types of site analytics are you using? The following is a list of third-party trackers that we may employ on our site. Please note that these may change from time to time, but we will do our best to keep this list up-to-date.

  • Site Analytics. We embed videos from our official Vimeo channel. When you press play, Vimeo may set cookies to enable the video to play and maintain the security of its service. These cookies do not directly identify anyone. If you have a Vimeo account and are logged in, Vimeo may set cookies for analytics and advertising purposes and collect data linked to your Vimeo account when you visit a page containing a Vimeo video. For more information, see the Vimeo cookies policy.

Purposes for Collection and Use of Your Information

We use the information we collect to deliver the products and services you request and customize your experience with us. We use your personal information as was stated (or obvious) at the point of collection. We also use your personal information in the following ways:

  1. Core Business Functions. We use personal information to support core business functions, including to maintain records related to business process management; loss and fraud prevention; to collect amounts owing to us; and to provide and maintain the functionality of our Site, including identifying and repairing errors or problems.
  2. Providing Products and Services. We use your personal data to provide you with the products and services you request from us. This includes storing and retrieving personal data as needed by our customers, promote trade shows, processing transactions with customers and business partners, using your personal data to communicate with you, to provide customer service, and for any other purposes that our customers request.
  3. Access, Manage, and Use Our Social Media Pages. Menasha is active on social media, including Facebook, Twitter, Instagram, YouTube, and LinkedIn (“Social Media”). You have the opportunity to comment on those Social Media platforms regarding Menasha and the programs, goods, and services we offer. Any content you post on a Social Media platform is public information and will be treated as non-confidential information.
  4. Marketing, Analytics, and Personalization. We use your personal data for marketing and promotional purposes, such as to send marketing, advertising, and promotional communications by email, text message or postal mail (such as trend alerts, promotions, new product launches, and event invitations); to show you advertisements for products and/or services tailored to your interests on social media and other websites; and to administer our sweepstakes, contests, and other similar promotions. We also use personal information to conduct research and analytics, including to improve our product offerings and services; to understand how you interact with our website, advertisements, and communications with you to determine which of our products or services are the most popular, and to improve our website and marketing campaigns; to personalize your experience, to save you time when you visit our website, and to customize the marketing and advertising that we show you; and to provide services, to better understand our customers’ needs, and to provide personalized recommendations about our products and services. See Cookies and Other Tracking above for additional information.
  5. Legal Obligations. We use personal information to comply with our legal or regulatory obligations, to establish or exercise our rights, to defend against legal claims, to enforce our agreements, and as otherwise required or permitted by law.

How We Disclose Your Personal Information

In addition to the specific situations discussed elsewhere in this Notice, we disclose personal information in the following circumstances:

  1. Employees and Corporate Affiliates. We may disclose your personal information with our employees and corporate affiliates, including our subsidiaries. Such corporate affiliates process personal information on our behalf as our service providers or independent controllers, where necessary to provide a product or service that you have requested, or in other circumstances with your consent as permitted or required by law.
  2. Service Providers. We may disclose personal information to our third-party service providers and representatives that provide certain services for Menasha vendors, consultants, and service providers pursuant to a written contract. These service providers perform certain services necessary to run our business (for example, wholesalers and distributors, data hosting and development, data analysis, customer service, legal, accounting, consulting, auditing, and other services) and assist us with our compliance requirements. For example, we share your personal information with our third-party service providers that host and manage this Site or that provide services through this Site. We share your personal information with our third-party service providers to: (i) put you in touch with wholesalers or distributors selling our products in response to your request; (ii) improve the content and functionality of this Site; (iii) perform data analysis and statistical analysis; (iv) help us with our marketing efforts; (v) help manage, administer, and fulfill sales; and (vi) troubleshoot problems with this Site.
  3. Other Users. By submitting a copyright infringement notice, counter-notice, or other similar notification through this Site or to Menasha, you consent to having that communication forwarded to any person or entity to whom the notice or counter-notice relates to in order to facilitate a prompt resolution of the copyright infringement claim. Copyright infringement notices and/or counter-notices from you will be treated in accordance with our Digital Millennium Copyright Act (“DMCA”) Policy found at: https://www.menashacorporation.com/dmca/. This Section is only applicable to you if you are located in the United States.
  4. Legal Process. We may disclose personal information in response to subpoenas, warrants, court orders, government inquiries, or investigations, or to comply with relevant laws and regulations. We may also disclose information to establish, exercise, or protect the rights of our company, employees, agents, and affiliates; to defend against a legal claim; to protect the safety and security of our visitors; to detect and protect against fraud; and to take action regarding possible illegal activities or violations of our policies.
  5. Transfer of Control. We may disclose personal data to a buyer, potential buyer, or successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Menasha’s assets, whether as a going concern or as part of bankruptcy, liquidation, receivership, or similar proceeding in which personal data held by Menasha are among the assets to be transferred, including as part of the due diligence process.
  6. Other Instances. We may use your personal information for other purposes consistent with your reasonable expectations. We may ask if you would like us to disclose your information with other third parties who are not described elsewhere in this Notice.

Data Retention

Menasha will retain personal information for as long as needed to provide our services. For example, if you are a customer, we keep information that personally identifies you as long as you are receiving our services. If you no longer receive services, we still may need that information for business and legal requirements, such as to comply with your state’s record retention regulations, protect against fraud, or respond to legal requests. Other information is deleted automatically after a set period of time, often set by law, unless we are legally required to hold it longer, such as for pending litigation. We may destroy, de-identify, or anonymize the information when it is no longer needed in identifiable form.

If you are a resident of Canada, the European Economic Area, or another international jurisdiction with similar privacy rights, please be advised that some of our third-party service providers and Menasha facilities are located in jurisdictions outside your country of residence, which means your personal information will be transferred outside of your jurisdiction, including to the United States. In addition, we may also transfer your personal information internationally if any of our servers, or any of our service providers’ servers, are located outside your country of residence, if one of our service providers or suppliers is located outside your country of residence, or if we share your information (in accordance with this policy).

How We Protect Your Personal Information

Menasha uses technical and organizational measures to ensure a level of security appropriate to the risk for all personal information processed. While we cannot guarantee that loss, misuse, or alteration to data will not occur, this Site has commercially reasonable security measures in place to help protect against the loss, misuse, and alteration of the information under our control. In the event that a breach into our security systems occurs and there is a possibility that an unauthorized person acquires your personal information, Menasha will notify you of the breach as required under applicable law.

YOU UNDERSTAND THAT NO DATA TRANSMISSION OVER THE INTERNET OR A MOBILE DEVICE CAN BE GUARANTEED TO BE 100% SECURE. WHILE WE STRIVE TO PROTECT YOUR PERSONAL INFORMATION, WE DO NOT GUARANTEE THE SECURITY OF ANY PERSONAL INFORMATION AND YOU PROVIDE SUCH PERSONAL INFORMATION AT YOUR OWN RISK.

Children’s Privacy

Our website is not intended for or directed to children under the age of 16. We do not knowingly collect or disclose the personal information of children under the age of 16.

Consumer Rights

Residents of the European Economic Area (“EEA”), United Kingdom (“UK”), Switzerland (collectively, the “EEA+”), Canada, California, and other jurisdictions with similar data privacy rights may exercise some or all of the rights described in this section. Please note that some of the rights may vary depending on your country, province, or state of residence. In addition, these rights are subject to various exceptions and limitations as discussed further below.

  • Right to Access/Know. You may have the right to obtain confirmation from Menasha as to whether or not personal information concerning you is being processed and how, what, when, why and for how long your personal information is processed and to whom it is disclosed.
  • Right To Delete (Erasure). You may have the right to request that we delete any of your personal information that we collect, subject to certain exceptions.
  • Right to Correct. You have the right to request correction of inaccurate personal information that we maintain about you or update the information we have on file.
  • Right to Data Portability. You may have the right to receive a digital copy (in a commonly used format) of all personal information that has been collected from you by any given organization.
  • Right to Opt-Out of Sale or Sharing. You may have the right to opt out of the sale of your personal information or disclosure of your personal information for targeted or behavioral advertising. However, Menasha does not sell your personal information, nor does it disclose your personal information for targeted or behavioral advertising, so this right is not available to you.
  • Right to Non-Discrimination. You have the right to be protected from discrimination for exercising your rights. We will not discriminate against you for exercising your rights.
  • Right to Object: You may have the right to object to the processing of your personal information if the processing is based upon Menasha’s legitimate interest or for the performance of a task carried out in the public interest, including any profiling based on such processing or direct marketing.
  • Right to Restrict Processing: You may have the right to request Menasha to restrict the processing of your personal information while your data subject rights requests are being investigated and answered.
  • Right not to be Subject to Automated Decision-Making, Including Profiling: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or significantly affects you. However, Menasha does not use automated decisionmaking technologies that produce a legal effect, and as a result, this right is not available to you.

Additional Information for California Residents

Categories of Personal Information Shared With Third Parties

We are in the business of helping other businesses protect, move, and promote their products. As such, our business model does not include selling your personal information to third parties in exchange for money. We also do not share your personal information for targeted or behavioral advertising. Please note that the right to opt out only applies to “sales” or “sharing” of personal information and does not restrict our ability to disclose information to third parties for valid business purposes.

In the preceding 12 months, depending on your interactions with us, we may have collected and disclosed for a business purpose the following categories of personal information:

‍‍Category of Personal Information‍Business or Commercial PurposeCategories of Parties with Whom Information is Disclosed for a Business Purpose
Identifiers, such as name, address, email address, IP address, and/or online identifier

· To provide the Services to you, such as processing orders and responding to your inquiries

· To perform Site analytics

· Service Providers, such as Site analytics companies, payment processors, wholesalers, and distributors
Internet or other similar network activity

· To provide the Services to you, such as processing orders and responding to your inquiries

· To perform Site analytics

· Service Providers, such as Site analytics companies, payment processors, wholesalers, and distributors

 

Right to Opt Out of Cookies and Sale/Sharing

Using Online Tracking Technologies

As discussed above, we do not sell your personal information for monetary consideration or share your information for targeted or behavioral advertising. As such, we do not offer a right to opt out in this regard.

 

Right to Complain to a Supervisory Authority

You may raise your concerns with your local data protection authority directly. We would, however, encourage you to contact us first at [email protected] as we aim to promptly, efficiently, and satisfactorily resolve any concerns or complaints you may have in relation to our processing of your personal data. If you are based in the UK or EEA and believe that we have not complied with data protection laws, you can complain to the UK ICO (www.ico.org) or your local EEA supervisory authority. The European Data Protection Board (EDPB) makes a list of EEA data protection authorities available at: https://edpb.europa.eu/about-edpb/about-edpb/members_en.

Exercising Your Rights

To exercise your rights as set out above, please contact us by:

  • calling 1-800-558-5073; or
  • by submitting a request here.

Depending on the sensitivity of your request, you may be required to provide additional information to verify your identity and request before further action is taken. If your request is for access to your personal data, we will confirm your email and one or more additional pieces of information provided in your request to verify against information already in our possession, such as name and state or country of residence. If we are unable to confirm that the data provided in your request matches our records, we will ask for additional information to verify your identity.

Your authorized agent may make a request on your behalf. We will consider any evidence the agent submits to demonstrate that you gave the agent signed permission to submit the request. We may email you to confirm that the agent is indeed acting on your behalf.

Communicating With Us

If you have any questions about our privacy or security practices, you can contact Menasha by mail, telephone, or email:

Menasha Corporation
1645 Bergstrom Road
Neenah, WI 54956
Toll Free: 800.558.5073
Local: 920.751.1000
[email protected]

If we need, or are required, to contact you concerning any event that involves your personal information, we may do so by e-mail, telephone, or mail.

Changes To This Policy

We may revise this Notice from time to time. We will provide additional notice, such as displaying a prominent notice on our website or sending an email to you, if we make any changes that materially affect your privacy rights.

Effective Date: February 1, 2024