Privacy Policy
Privacy and Cookie Policy
This Privacy and Cookies Policy applies to the website www.dssmithepack.co.uk, any subdomains thereto, and any webpages displayed on or through www.dssmithepack.co.uk or such subdomain (collectively, the “Site”) which is run by DS Smith Packaging Limited (the “Company”, “we” or “us”) with an address at 350 Euston Road, London, United Kingdom, NW1 3AX.
Version 3 11-07-2018
The Company recognises the importance of honest and responsible use of your personal information. This Privacy and Cookies Policy (this “Policy”) explains how the Company collects, uses and discloses personal information about you when you visit this Site and when you contact the Company, whether by e-mail, post, fax or telephone using the contact options on this Site. The information you provide to us through the Site will initially be collected by the Company, but may then be shared with affiliates of the Company (the Company, together with its Affiliates, the “Group”).
It is important to us that you feel comfortable in visiting the Site.
What type of information does the Company collect and why?
If you use the Site’s search feature, queries and results are logged anonymously without any user-specific details being collected. Our collection of website use information may also involve the use of cookies and Web beacons. Please see the “Cookies” section below for more information.
If you want to contact us or to use certain features that we provide on the Site, you will need to provide us with some additional personal information so that we can liaise with you and deal with your request, query or application. If you choose to provide us with your personal information, we will collect that information for our own use and for the purposes described in this Policy.
We collect information from you when you register on our site, place an order, subscribe to a newsletter, Use Live Chat or enter information on our site.
What type of personal information does the Company collect?
In connection with your use of the Site and its features, we may collect certain personal information from you. Some of this information is only collected if you choose to provide such information to us (such as your full name, title and gender), while some of this information is collected automatically (such as standard internet and website log information). The following are the categories of personal information that we collect from you:
- your full name, title and gender;
- your work and home contact details, such as address, telephone numbers and e-mail address;
- the reason for your contact, which may be a request or enquiry on your own behalf, a request or enquiry on behalf of someone else, a customer service need, providing a comment, a job application, or details in relation to a possible or existing order or service contract;
- if you create an account - your username, password, e-mail address and your full name, address and telephone numbers;
- employment and personal and educational details you choose to provide to us as part of any application for employment, such as your employee ID, including social security number, other governmental identity number, and if needed, driver’s license number and/or passport number, your date of birth, place of birth, nationality (and where applicable dual or former nationality) and eligibility (including evidence) to work in the relevant country;
- financial account information, such as credit card number and other payment information;
- your contact and marketing preferences;
- information necessary for legal compliance;
- standard internet and website log information and details of patterns about how website visitors behave on the Site. The information we may collect includes information about your Internet service provider, your operating system, browser type, domain name, the Internet protocol (IP) address of your computer (or other electronic Internet-enabled device), your access times, the website that referred you to us, the Web pages you request and the date and time of those requests.
- where you “like” us or make posts on our pages on social networking websites.
This information will be collected primarily from you as information voluntarily provided to us, but we may also collect it where lawful to do so from (and combine it with information from) public sources, third party service providers, individuals whom you have indicated have agreed for you to provide their personal information, government, tax or law enforcement agencies, and other third parties. We may also collect personal information about you from your use of services provided by affiliates of the Company.
How does the Company use information about you?
The Company may use information about you for purposes described in this Policy or disclosed to you on the Site or with our services. For example, we may use the information we collect from you when you register, make a purchase, sign up for our newsletter, respond to a survey or marketing communication, navigate the Site, or use certain other Site features in the following ways:
- to personalise your experience and to allow us to deliver the type of content and product offerings in which you are most interested;
- to improve the Site in order to better serve you;
- to allow us to better service you in responding to your customer service requests;
- to quickly process your transactions;
- to ask for ratings and reviews of services or products;
- to follow up after correspondence (live chat, email or phone inquiries)
- subject to your consent where required under applicable laws, to carry out direct marketing and/or e-mail marketing that you have requested;
- to perform any contract the Group has with you; and
- for compliance with legal, regulatory and other governance obligations.
Personal information will be kept in computerised files and electronic databases as set out in more detail below.
In most cases, the information the Company processes about you is required to deal with your request or registration, or required by law, or is necessary for the exercise of the Company’s legitimate business interests and needs, in which case, special care is taken to safeguard your rights and to ensure any such use is proportionate.
The Company or one of its affiliates may also convert personal information into anonymous data and use it (normally on an aggregated statistical basis) for research and analysis to improve the performance of the Site or the services provided by the Group.
What is the legal basis for the use of personal data?
The legal basis on which we rely to process your personal information include:
- On some occasions, we process your data with your consent (for example, when you agree that we may place cookies or process information that you input into our website).
- On other occasions, we process your data when we need to do this to fulfil a contract with you (for example, for billing purposes) or where we are required to do this by law (for example, to comply with governmental record-keeping obligations).
- We also process your data when it is in our legitimate interests to do so and when these interests are not overridden by your data protection rights (including, for example, when we share data with our affiliates).
Does the Company share personal information with third parties?
Your personal information will be made available for the purposes mentioned above (or as otherwise notified to you from time to time), on a ‘need-to-know’ basis and only to management, accounting, legal, logistics, audit, compliance, information technology and other corporate staff who properly need to know these details for their functions within the Group. Certain individuals who will see your personal information may not be based at the Company or in your country (please see below).
We may share personal information within the Group as needed for reasonable management, analysis, planning and decision making, including in relation to taking decisions regarding the expansion and promotion of our product and service offering, order or customer request fulfilment and for use by the Group for the other purposes described in this Policy.
Your personal information may also be made available to third parties (within or outside the Group) providing relevant services under contract to the Group (see below for further details), such as credit card processors, auditors and compliance managers, providers or call centres and IT hosting and IT maintenance providers. These third parties may use information about you to perform their functions on our behalf. The Company has put in place various security and data privacy measures, including with such third parties, in order to protect personal information and shall seek to comply with applicable legal requirements.
We use the following tools in order to improve the quality of our products: Hotjar and AutopilotHQ. They allow us to understand how our products are being used, i.e. the frequency of use of certain features etc. We use this data for internal use only. We also use a tracking code provided by Lead Forensics, which provides us with information on users’ IP addresses and the webpages that they visit. The Lead Forensics tool uses IP tracking for identifying businesses and only provides information that is readily available in the public domain, which does not include individual, personal or sensitive data regarding who has visited our website. This data may be used by us to contact the business about their experience or for marketing purposes and we will not pass this data to third parties for any reason. More information can be found at www.leadforensics.com.
We may disclose specific information upon lawful request by government authorities, law enforcement and regulatory authorities, where required or permitted by law, and for tax or other purposes. Personal information may also be released to third parties in response to legal process, and when required to comply with laws, or to enforce our agreements, corporate policies, and terms of use, or to protect the rights, property or safety of the Group, our employees, agents, customers, and others, as well as to parties to whom you authorise the Company to release your personal information.
We do not sell, trade, or otherwise transfer your personal information to outside parties (other than as part of any restructuring of the Group or sale of any business or assets of the Group) unless we provide you with advance notice. This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or serving our users, so long as those parties agree to keep this information confidential.
However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses, as further set out in this privacy policy.
Will your personal information be transferred abroad?
Some transfers of personal information have been explained above. Individuals within the European Economic Area (“EEA”) should be aware that recipients of their personal information, within the Group or third parties (as set out in this notice), may not be located within the EEA but instead located in countries which do not have equivalent protection for personal information to that within the EEA. Steps will be taken to protect your personal information in that instance consistent with applicable law. For example data is adequately protected by EU Commission approved standard contractual clauses, an appropriate Privacy Shield certification or a vendor's Processor Binding Corporate Rules. A copy of the relevant mechanism can be provided for your review on request to compliance.legal@dssmith.com.
What choices does the Company offer you with regard to direct marketing?
The Company may wish to provide you with information about new products, services, promotions and offers, which may be of interest to you and may invite you to take part in market research or request feedback on the Group’s products and services. This communication may occur by e-mail, telephone, post or SMS. We will obtain your consent and advise you of how to opt-out of receiving such communications where we are required to do so in accordance with applicable law.
What safeguards are in place to protect your personal information?
The Company takes reasonable steps to employ appropriate physical, technical and administrative security measures to help prevent loss, misuse, unauthorised access, disclosure or modification of your personal information. While we take these reasonable efforts to safeguard your personal information, we cannot guarantee the security of any personal information you disclose online. You accept the inherent security implications of dealing online and will not hold us responsible for any breach of security unless such breach has been caused by the specific negligence of the Group or their agents.
An external PCI compliant payment gateway handles all credit card transactions and we use regular Malware Scanning.
Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology.
We implement a variety of security measures when a user places an order enters, submits, or accesses their information to maintain the safety of your personal information.
All payment transactions are processed through a gateway provider and are not stored or processed on our servers.
What rights do you have to review and amend personal information?
You have the right to review and access your personal information held by the Company.
You also have the right to ask us to rectify, block, complete and delete your personal information, to restrict its use, and to ‘port’ your personal information (that is, to ask us to provide it to you in a structured, commonly used and machine readable format and to transmit it directly to another organisation).
In addition, you have the right to request further information about the handling of your personal information.
If you wish to do so, if you wish to amend your personal information or to notify the Company of a change in your details, please contact us:
- by emailing us at shop@dssmith.com;
- by calling us at 0808 1787227;
- by logging in to your account; or
- by chatting with us or by sending us a support ticket.
There are exceptions to these rights, however. For example, access to personal information may be denied in some circumstances if making the information available would reveal personal information about another person or if we are legally prevented from disclosing such information. In addition, we may be able to retain data even if you withdraw your consent, where we can demonstrate that we have a legal requirement to process your data.
If you have a question about the use of your personal information, or wish to file a complaint about it, please contact us, using the contact details set out above.
Finally, if you have unresolved concerns, you also have the right to complain to data protection authorities.
Keeping you informed
When we store your information, we do so for as long as necessary to (i) fulfill the specific purposes for which your personal information was collected, (ii) to perform the services set out in this notice, or (iii) to comply with our legal obligations or enforce our legal rights.
How we use cookies
We use cookies for certain areas of the Site. Cookies are small data files stored on your hard drive by a website. Cookies help us improve the Site and your experience. We use cookies to see which areas and features are popular and to count visits to our websites, to recognise you as a returning visitor and to tailor your experience of the Site according to your preferences. Overall, cookies help us provide you with better websites, by enabling us to:
- monitor which pages you find useful and which you do not;
- remember and process the items in your shopping cart;
- understand and save your preferences for future visits; and
- compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future (we may use trusted third-party services that track this information on our behalf).
We may also use cookies for targeting or advertising purposes. We may use Web beacons on the Site or in our e-mails. Web beacons are electronic images that may be used to deliver cookies, count visits, understand usage of Group websites and to tell if an e-mail has been opened and acted upon. Further details about cookie purposes and types are below. To delete or block cookies by browser settings at any time and for more general information about cookies including the difference between session and persistent cookies, visit www.allaboutcookies.org.
We also use Google Analytics on our Site to collect information about your online activity on the Site, such as the Web pages you visit, the links you click, and the searches you conduct on the Site. We use the information to compile reports and to help us improve the Site. The cookies collect information in an anonymous form, including the number of visitors to the Site, where visitors have come to the Site from and the pages they visited. For more information about the information gathered using Google Analytics please visit http://www.google.com/intl/en/analytics/privacyoverview.html. You can prevent these cookies by selecting the appropriate settings on your browser. If you do this you may not be able to use the full functionality of this Site. You may download and install the Google Analytics Opt-out Browser Add-on available here: http://tools.google.com/dlpage/gaoptout.
With your permission, our website utilises the Conversion Tracking Pixel service of Facebook Inc., 1601 S. California Ave., Palo Alto, CA 94304, USA (“Facebook”). This tool allows us to follow the actions of users after they are redirected to a provider’s website by clicking on a Facebook advertisement. We are thus able to record the efficacy of Facebook advertisements for statistical and market research purposes. The collected data remain anonymous. This means that we cannot see the personal data of any individual user. However, the collected data are saved and processed by Facebook. We are informing you on this matter according to our information at this time. Facebook is able to connect the data with your Facebook account and use the data for their own advertising purposes, in accordance with Facebook’s Data Use Policy found under: https://www.facebook.com/about/privacy/. Facebook Conversion Tracking also allows Facebook and its partners to show you advertisements on and outside Facebook. In addition, a cookie will be saved onto your computer for these purposes.
Only users over 13 years of age may give their permission. If you are younger than this age, please consult your legal guardians.
Please click here if you would like to revoke your permission: https://www.facebook.com/ads/website_custom_audiences
The cookies used on our Site are categorised in accordance with the International Chamber of Commerce United Kingdom Cookie Guide as follows:
- Cookies which are “strictly necessary” for functionality of the Site’s platforms. These cookies are essential in order to enable users to move around the Site and use its features.
- “Performance” cookies which collect information about how users navigate the Site, for example, which pages users access most frequently. They identify how users interact with the Site, any errors that occur, which pages are not used often, which pages take a long time to load, which pages users tend to visit and in what order. These cookies do not collect any information which could identify you and are only used to help us improve how our Site works and understand what interests the Site’s users.
- “Functionality” cookies which allow the Site to remember choices you make and your preferences as a logged in user (for example, based on your user name).
- “Targeting or advertising” cookies used to deliver advertising material relevant to an identified machine or other device (not a named or otherwise identifiable person) which are tailored to interests associated with the website activity tied to that machine or device. For example, if a cookie on a third party website recognises that a particular product was purchased from a particular device, that cookie may “talk to” marketing cookies on the Site to ensure advertisements about similar products displayed on the Site are accessed from that device. These cookies are also used to limit the number of times a user sees an advertisement as well as to help measure the effectiveness of an advertising campaign. They may also remember that the Site has been visited from a device and share that information with marketing organisations. The marketing cookies on the Site are operated by third parties with our permission. Marketing cookies are used to monitor from which advertising source a user was directed towards the Site so that we know whether it is worth us investing in that particular advertising source.
Cookie name/type |
Expiration Period |
Purpose |
Category of cookie as defined in the ICC Cookie Guide |
AspNetCore.Identity.Application |
Session (these cookies typically expire at the end of your session, in other words, when you close your browser) |
Authentication session to prevent having to login multiple times in one browser session. A unique ID that ties the current session to a database settings table. |
Strictly necessary/Functionality |
epack.basket |
30 days |
A unique ID that ties the current session to a database basket table. |
Strictly necessary/Functionality |
epack.cookie-compliance |
365 days |
Enables us to remember if you accept cookies from this website. |
Strictly necessary/Functionality |
Google Analytics |
2 years from set/update |
Provides a unique ID for each Web browser that visits this site. |
Targeting/advertising |
Google Analytics |
Session 30 minutes from set/update |
Used to establish and continue a user session with this website. |
Targeting/advertising |
Google Analytics |
Session (these cookies typically expire at the end of your session, in other words, when you close your browser) |
Used to establish and continue a user session with this website. |
Targeting/advertising |
Google Analytics |
6 months from set/update |
Used to calculate search engine traffic, ad campaigns and page navigation within this site. |
Targeting/advertising |
_lc_visitor_id bislr_identifier |
Persistent cookie: 2 years |
Set to analyse onsite behaviour to provide more relevant services and products. |
Targeting/advertising |
_hjClosedSurveyInvites |
365 days |
Set once a visitor interacts with a survey invitation to ensure that the same invite does not re-appear if it has already been shown. |
Targeting/advertising |
_hjDonePolls |
365 days |
Set once a visitor completes a poll to ensure that the same poll does not re-appear. |
Targeting/advertising |
_hjMinimizedPolls |
365 days |
Set once a visitor minimises a Feedback Poll widget. Used to ensure that the widget stays minimised when the visitor navigates through your site. |
Targeting/advertising |
_hjIncludedInSample |
365 days |
Set to let Hotjar know whether that visitor is included in the sample which is used to generate funnels. |
Targeting/advertising |
login_redirect |
Session |
Magento_customer module. Preserves the destination page the customer was loading before being directed to log in. |
Strictly necessary/Functionality |
mage-messages |
365 days. Cleared on frontend when the message is displayed to the user. |
Magento_theme module. Tracks error messages and other notifications that are shown to the user, such as the cookie consent message, and various error messages. The message is deleted from the cookie after it is shown to the shopper. |
Strictly necessary/Functionality |
X-Magento-Vary |
Based on PHP setting session.cookie_lifetime |
Magento_PageCache module. Configuration setting that improves performance when using Varnish static content caching. |
Strictly necessary/Functionality |
mage-cache-storage |
Session |
Magento_Customer, Magento_Persistent, Magento_NegotiableQuote modules. Local storage of visitor-specific content that enables ecommerce functions. |
Strictly necessary/Functionality |
section_data_ids |
Session |
Magento_Customer module. Stores customer-specific information related to shopper-initiated actions such as display wish list, checkout information, etc. |
Strictly necessary/Functionality |
Google advertising
We, along with third-party vendors such as Google use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our website.
Google's advertising requirements can be summed up by Google's Advertising Principles. They are put in place to provide a positive experience for users: https://support.google.com/adwordspolicy/answer/1316548?hl=en.
Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt-out of having making your site activity available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) that is running on websites from sharing information with Google Analytics about visit activity.
Do Not Track Signals
We honour Do Not Track signals and Do Not Track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.
Cookie settings
We will ask for your consent to the use of cookies set out in this Policy when you first access the Site and if we introduce any new cookies to the Site. When you first visit the Site, a box/banner will appear asking you to agree to the cookies that we set on the Site. Your continued use of the Site will be treated as consent to the use of these cookies for the purposes described.
If you reject cookies by clicking on “No thanks”, we will not set any further cookies on your device, except that we will set the “Strictly necessary” cookies detailed above, including a cookie to remember that you don't want any cookies set when you visit the Site.
You can usually choose to set your browser to warn you when a cookie is being set or to remove or reject cookies. Each browser is different, so review your browser’s Help menu to learn the correct way to modify your cookie settings. If you choose to remove or reject cookies, it will affect many features or services on the Site.
If you agree to cookies on the Site by clicking on the "I agree" button, we will set cookies on your device. If you wish to delete the cookies we have set on your device, please refer to your browser Help menu.
If you do nothing to indicate your cookie preference for the Site (in other words, if you do not click on either "I agree" or "No thanks"), we will treat this as acceptance and set cookies on your device. To modify your cookie settings, please refer to the Help menu of your browser.
Changes to this Policy
We keep this Policy under regular review. We may change this Policy from time to time by updating this page in order to reflect changes in the law and/or our privacy practices. The date at the top of this Policy will be updated accordingly.
We encourage you to check the date of this Policy when you visit the Site for any updates or changes. We will notify you of any modified versions of this Policy that might materially affect the way we use or disclose your personal information.
Contact/address details
If you have any questions about this Privacy Policy, please contact us at:
DS Smith ePack
350 Euston Road
London
NW1 3AX
Privacy and Cookie Policy
This Privacy and Cookies Policy applies to the website www.dssmithepack.co.uk, any subdomains thereto, and any webpages displayed on or through www.dssmithepack.co.uk or such subdomain (collectively, the “Site”) which is run by DS Smith Packaging Limited (the “Company”, “we” or “us”) with an address at 350 Euston Road, London, United Kingdom, NW1 3AX who is the controller of your data.
Version 4 --2021
The Company recognises the importance of honest and responsible use of your personal information. This Privacy and Cookies Policy (this “Policy”) explains how the Company collects, uses and discloses personal information about you when you visit this Site and when you contact the Company, whether by e-mail, post, fax or telephone using the contact options on this Site. The information you provide to us through the Site will initially be collected by the Company, but may then be shared with affiliates of the Company (the Company, together with its affiliates, the “Group”).
The Policy also describes your data protection rights, including a right to object to some of the processing which Company carries out. More information about your rights, and how to exercise them, is set out in the “What rights do you have to review and amend personal information?” section.
It is important to us that you feel comfortable in visiting the Site.
What type of information does the Company collect and why?
If you use the Site’s search feature, queries and results are logged anonymously without any user-specific details being collected. Our collection of website use information may also involve the use of cookies and Web beacons. Please see the “Cookies” section below for more information.
If you want to contact us or to use certain features that we provide on the Site, you will need to provide us with some additional personal information so that we can liaise with you and deal with your request, query or application. If you choose to provide us with your personal information, we will collect that information for our own use and for the purposes described in this Policy.
We collect information from you when you register on our site, place an order, subscribe to a newsletter, Use Live Chat or enter information on our site.
What type of personal information does the Company collect?
In connection with your use of the Site and its features, we may collect certain personal information from you. Some of this information is only collected if you choose to provide such information to us (such as your full name and title), while some of this information is collected automatically (such as standard internet and website log information). The following are the categories of personal information that we collect from you:
- your full name, title and gender;
- if you check out as a guest- your contact details, such as delivery address and registered addresses for payment cards which may be your home or work address, telephone number and e-mail address;
- the reason for your contact, which may be a request or enquiry on your own behalf, a request or enquiry on behalf of someone else, a customer service need, providing a comment, a job application, or details in relation to a possible or existing order or service contract;
- if you create an account - your username, password, e-mail address and your full name, address and telephone numbers;
- financial account information, such as credit card number and other payment information;
- your contact and marketing preferences;
- standard internet and website log information and details of patterns about how website visitors behave on the Site. The information we may collect includes information about your Internet service provider, your operating system, browser type, domain name, the Internet protocol (IP) address of your computer (or other electronic Internet-enabled device), your access times, the website that referred you to us, the Web pages you request and the date and time of those requests.
This information will be collected primarily from you as information voluntarily provided to us, but we may also collect it where lawful to do so from (and combine it with information from) public sources, third party service providers, individuals whom you have indicated have agreed for you to provide their personal information, government, tax or law enforcement agencies, and other third parties. We may also collect personal information about you from your use of services provided by affiliates of the Company.
How does the Company use information about you?
The Company may use information about you for purposes described in this Policy or disclosed to you on the Site or with our services. For example, we may use the information we collect from you when you register, make a purchase, sign up for our newsletter, respond to a survey or marketing communication, navigate the Site, or use certain other Site features in the following ways:
With your consent:
- To place any non-essential cookies or similar technologies on your device;
- To carry out direct marketing and/or e-mail marketing where we need your consent;
- when you consent to us, we can also check whether you have opened any emails we sent you or clicked on any links within the email
- To check whether you have opened our emails or clicked on links in the emails;
- to personalise your experience and to allow us to deliver the type of content and product offerings in which you are most interested;
In other cases where we need your consent we will let you know at the time we collect it. For our or others’ legitimate interests:
- to improve the Site in order to better serve you;
- to ask for ratings and reviews of services or products;
- to follow up after correspondence (live chat, email or phone inquiries);
- to carry out direct marketing and/or e-mail marketing where we do not need your consent;
- to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime, in accordance with applicable law.
Where it is necessary for the performance of a contract with you:
- To process your transactions and
- to respond to your customer service requests
We also process your personal data for compliance with legal, regulatory and other governance obligations.
The Company or one of its affiliates may also convert personal information into anonymous data and use it (normally on an aggregated statistical basis) for research and analysis to improve the performance of the Site or the services provided by the Group.
The provision of your name, address and payment details are mandatory when you place an order as otherwise we would not be able to process and deliver your order. Provision of all other personal data is optional.
Does the Company share personal information with third parties?
Your personal information will be made available for the purposes mentioned above (or as otherwise notified to you from time to time). Certain individuals who will see your personal information may not be based at the Company or in your country (please see below).
We may share personal information within the Group as needed for reasonable management, analysis, planning and decision making, including in relation to taking decisions regarding the expansion and promotion of our product and service offering, order or customer request fulfilment and for use by the Group for the other purposes described in this Policy.
Your personal information may also be made available to third parties (within or outside the Group) providing relevant services under contract to the Group (see below for further details), such as credit card processors, auditors and compliance managers, providers or call centres and IT hosting and IT maintenance providers. These third parties may use information about you to perform their functions on our behalf. The Company has put in place various security and data privacy measures, including with such third parties, in order to protect personal information and shall seek to comply with applicable legal requirements.
We may disclose specific information upon lawful request by government authorities, law enforcement and regulatory authorities, where required or permitted by law, and for tax or other purposes. Personal information may also be released to third parties in response to legal process, and when required to comply with laws, or to enforce our agreements, corporate policies, and terms of use, or to protect the rights, property or safety of the Group, our employees, agents, customers, and others, as well as to parties to whom you authorise the Company to release your personal information.
However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses, as further set out in this privacy policy.
Will your personal information be transferred abroad?
Some transfers of personal information have been explained above. Individuals within the European Economic Area (“EEA”) and the UK should be aware that recipients of their personal information, within the Group or third parties (as set out in this notice), may not be located within the EEA or the UK but instead located in countries which do not have equivalent protection for personal information to that within the EEA or the UK. Steps will be taken to protect your personal information in that instance consistent with applicable law. For example data is adequately protected by EU Commission approved standard contractual clauses, or a vendor's Processor Binding Corporate Rules. A copy of the relevant mechanism can be provided for your review on request to compliance.legal@dssmith.com.
Relying on our legitimate interests
We have carried out balancing tests for all the data processing we carry out on the basis of our legitimate interests, which we have described above. You can obtain information on our balancing tests by contacting us at compliance.legal@dssmith.com.
What choices does the Company offer you with regard to direct marketing?
The Company may wish to provide you with information about new products, services, promotions and offers, which may be of interest to you and may invite you to take part in market research or request feedback on the Group’s products and services. This communication may occur by e-mail, telephone, post or SMS.
Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above. In some cases, we are able to send you direct marketing without your consent, where we rely on our legitimate interests. You have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing, at any time. You can do this by following the instructions in the communication where this is an electronic message, or by contacting us using the details set out below.
What rights do you have in relation to your personal information?
You have the right to access your personal information held by the Company.
You also have the right to ask us to rectify, object to the processing, complete and delete your personal information, to restrict its use, and to ‘port’ your personal information (that is, to ask us to provide it to you in a structured, commonly used and machine readable format and to transmit it directly to another organisation).
In addition, you have the right to request further information about the handling of your personal information.
If you wish to do so, if you wish to amend your personal information or to notify the Company of a change in your details, please contact us:
- by emailing us at shop@dssmith.com;
- by calling us at 01908 088888;
- by logging in to your account; or
- by chatting with us or by sending us a support ticket.
There are exceptions to these rights, however. For example, access to personal information may be denied in some circumstances if making the information available would reveal personal information about another person or if we are legally prevented from disclosing such information. In addition, we may be able to retain data even if you withdraw your consent, where we can demonstrate that we have a legal requirement to process your data.
If you have a question about the use of your personal information, or wish to file a complaint about it, please contact us, using the contact details set out above.
Finally, if you have unresolved concerns, you also have the right to complain to data protection authorities where you live, work or believe a breach has happened.
How long will the Company keep your personal information?
We generally store your information for 24 months , or otherwise for as long as necessary to (i) fulfill the specific purposes for which your personal information was collected, (ii) to perform the services set out in this notice, or (iii) to comply with our legal obligations or enforce our legal rights.
How we use cookies
We use cookies for certain areas of the Site. Cookies are small data files stored on your hard drive by a website. Cookies help us improve the Site and your experience. We use cookies to see which areas and features are popular and to count visits to our websites, to recognise you as a returning visitor and to tailor your experience of the Site according to your preferences. Overall, cookies help us provide you with better websites, by enabling us to:
- monitor which pages you find useful and which you do not;
- remember and process the items in your shopping cart;
- understand and save your preferences for future visits; and
- compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future (we may use trusted third-party services that track this information on our behalf).
We may also use cookies for targeting or advertising purposes. We may use Web beacons on the Site or in our e-mails. Web beacons are electronic images that may be used to deliver cookies, count visits, understand usage of Group websites and to tell if an e-mail has been opened and acted upon. Further details about cookie purposes and types are below. at any point you would like to change your consent preferences about cookies set on our website you can visit our cookie preference centre here .
We use Hotjar and AutopilotHQ in order to improve the quality of our products. They allow us to understand how our products are being used, i.e. the frequency of use of certain features. We use this data for internal use only. We also use a tracking code provided by Lead Forensics, which provides us with information on users’ IP addresses and the webpages that they visit. The Lead Forensics tool uses IP tracking for identifying businesses and only provides information that is readily available in the public domain, which does not include individual, personal or sensitive data regarding who has visited our website. More information can be found at www.leadforensics.com.
We also use Google Analytics on our Site to collect information about your online activity on the Site, such as the Web pages you visit, the links you click, and the searches you conduct on the Site. We use the information to compile reports and to help us improve the Site. The cookies collect information in an anonymous form, including the number of visitors to the Site, where visitors have come to the Site from and the pages they visited. For more information about the information gathered using Google Analytics please visit http://www.google.com/intl/en/analytics/privacyoverview.html. You can prevent these cookies by selecting the appropriate settings on your browser. If you do this you may not be able to use the full functionality of this Site. You may download and install the Google Analytics Opt-out Browser Add-on available here: http://tools.google.com/dlpage/gaoptout.
With your permission, our website utilises the Conversion Tracking Pixel service of Facebook Inc., 1601 S. California Ave., Palo Alto, CA 94304, USA (“Facebook”). This tool allows us to follow the actions of users after they are redirected to a provider’s website by clicking on a Facebook advertisement. We are thus able to record the efficacy of Facebook advertisements for statistical and market research purposes. The collected data remain anonymous. This means that we cannot see the personal data of any individual user. However, the collected data are saved and processed by Facebook. We are informing you on this matter according to our information at this time. Facebook is able to connect the data with your Facebook account and use the data for their own advertising purposes, in accordance with Facebook’s Data Use Policy found under: https://www.facebook.com/about/privacy/. Facebook Conversion Tracking also allows Facebook and its partners to show you advertisements on and outside Facebook. In addition, a cookie will be saved onto your computer for these purposes.
Only users over 13 years of age may give their permission. If you are younger than this age, please consult your legal guardians.
Please click here if you would like to revoke your permission: https://www.facebook.com/ads/website_custom_audiences
The cookies used on our Site are categorised in accordance with the International Chamber of Commerce United Kingdom Cookie Guide as follows:
- Cookies which are “strictly necessary” for functionality of the Site’s platforms. These cookies are essential in order to enable users to move around the Site and use its features.
- “Performance” cookies which collect information about how users navigate the Site, for example, which pages users access most frequently. They identify how users interact with the Site, any errors that occur, which pages are not used often, which pages take a long time to load, which pages users tend to visit and in what order. These cookies do not collect any information which could identify you and are only used to help us improve how our Site works and understand what interests the Site’s users.
- “Functionality” cookies which allow the Site to remember choices you make and your preferences as a logged in user (for example, based on your username).
- “Targeting or advertising” cookies used to deliver advertising material relevant to an identified machine or other device (not a named or otherwise identifiable person) which are tailored to interests associated with the website activity tied to that machine or device. For example, if a cookie on a third party website recognises that a particular product was purchased from a particular device, that cookie may “talk to” marketing cookies on the Site to ensure advertisements about similar products displayed on the Site are accessed from that device. These cookies are also used to limit the number of times a user sees an advertisement as well as to help measure the effectiveness of an advertising campaign. They may also remember that the Site has been visited from a device and share that information with marketing organisations. The marketing cookies on the Site are operated by third parties with our permission. Marketing cookies are used to monitor from which advertising source a user was directed towards the Site so that we know whether it is worth us investing in that particular advertising source.
Google advertising
We, along with third-party vendors such as Google use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our website.
Google's advertising requirements can be summed up by Google's Advertising Principles. They are put in place to provide a positive experience for users: https://support.google.com/adwordspolicy/answer/1316548?hl=en.
Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt-out of making your site activity available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) that is running on websites from sharing information with Google Analytics about visit activity.
Do Not Track Signals
We honour Do Not Track signals and Do Not Track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.
Cookie settings
If you reject cookies by clicking on “No thanks” or if you do not click on either “No thanks” or “I agree”, we will not set any further cookies on your device, except that we will set the “strictly necessary” cookies detailed above, including a cookie to remember that you don't want any cookies set when you visit the Site.
You can usually choose to set your browser to warn you when a cookie is being set or to remove or reject cookies. Each browser is different, so review your browser’s Help menu to learn the correct way to modify your cookie settings. If you choose to remove or reject cookies, it will affect many features or services on the Site.
If you agree to cookies on the Site by clicking on the "I agree" button, we will set cookies on your device. If you wish to delete the cookies we have set on your device, please refer to your browser Help menu.
Changes to this Policy
We keep this Policy under regular review. We may change this Policy from time to time by updating this page in order to reflect changes in the law and/or our privacy practices. The date at the top of this Policy will be updated accordingly.
We encourage you to check the date of this Policy when you visit the Site for any updates or changes. We will notify you of any modified versions of this Policy that might materially affect the way we use or disclose your personal information.
Contact/address details
If you have any questions about this Privacy Policy, please contact us at:
DS Smith ePack
350 Euston Road
London
NW1 3AX
1. Introduction
DS Smith recognises the importance of transparent and responsible use of your personal information and is committed to protecting your personal information. This Privacy Policy (“Policy”) explains how DS Smith handles your personal information when you get in touch with us as a customer, prospect, supplier, partner, business contact, participant of our event, user of any of our websites, subscriber of our marketing communications or someone else getting in touch with us.
DS Smith (“we”, “us”, “our”) refers to DS Smith Packaging Limited with its registered office at 1 Paddington Square, London, United Kingdom, W2 1DL and its affiliates. You can also contact us by email at data.privacy@dssmith.com.
2. What type of personal information do we collect about you?
DS Smith may collect personal information from you as part of our business activities including through your use of our websites, when you contact or request information from us, request a quote, buy from us, sell to us, engage our services, provide services to us, attend our events, subscribe to our marketing communications, or as a result of your engagement with us.
The following are the categories of personal information that we collect from you:
- Basic information and contact details such as your full name and title, the company you work for, your title or position, address, telephone numbers and e-mail address;
- (Estimated) seniority, buying motivation and influence on buying decisions of key contact persons;
- If you create an online account - your username, password;
- Financial account information, such as bank account details and other payment details;
- Technical information collected through cookies and other tracking technologies, such as information from your visits to our websites or digital platforms, browsing and device usage information, or in relation to electronic materials and marketing communications we send to you;
- Information you provide to us for the purposes of attending our events or visiting our sites, including access and dietary requirements;
- Your marketing preferences (subject to receiving your express consent where required by applicable law);
- Any personal information contained in your request, enquiry or comment; and
- Any other personal information which you may provide to us.
3. How does DS Smith collect your personal information?
We place great importance on the responsible collection of personal information, which we may collect directly and indirectly.
We will collect personal information from you directly when you:
- make a purchase;
- contact us or make an enquiry or request a quote;
- fill a form or survey on any of our websites;
- register on any of our websites or digital platforms;
- wish to attend or have attended any of our events;
- wish to visit or have visited any of our sites or offices;
- subscribe to our electronic materials and marketing communications;
- make a tender or pitch your business to us;
- represent your company in dealing with us as a customer or supplier;
- use or visit our websites or digital platforms;
- interact with us directly.
As part of our operations, we may obtain personal information indirectly from various sources, such as from trusted third-party service providers, public authorities, regulators or law enforcement bodies. Where you have made your contact information available on your organisation's website, we may utilise this information to contact you. In situations where we enter into a contractual arrangement, your personal information may be furnished in a secure and confidential manner. We may also access publicly available sources, such as LinkedIn, as well as gather information from other third-party sources following all applicable legal requirements.
4. How does DS Smith use your personal information
DS Smith may use your personal information for purposes described in this Policy or communicated to you. We may use information about you for the following purposes:
- to respond and/or deal with your purchase, request or enquiry;
- for internal record-keeping;
- to contact you (directly, either by the Company or any of its affiliates, or through a partner or agent) by e-mail or phone for the above reasons;
- subject to your consent where required under applicable laws, to carry out direct marketing and/or e-mail marketing that you have subscribed to or requested;
- where necessary as part of any restructuring of the Company, or sale of any business or assets of the Group;
- to perform any contract the Group has with you;
- to maintain and improve our websites;
- to control access to our premises and for security purposes;
- for legal, regulatory, governance and risk management purposes, including establishing, exercising or defending our legal rights, complying with legal and regulatory obligations.
- to communicate with you and to keep you updated on relevant information or announcements.
- For ad personalization for better tailoring of the advertising content.
We use cookies and similar technologies from third parties for various purposes, including analytics, marketing, and improving website functionality. These technologies allow us to analyse site usage, optimise our services, and conduct marketing activities such as retargeting, which enables us to show relevant ads to users who have previously visited our site as they browse other websites. These services may connect data to your browser or device. Please read our cookies policy here. You can opt out of personalized advertising by adjusting your settings on these platforms, using your browser's cookie settings, or installing the Google Analytics Opt-out Browser Add-on available here. Your data may be accessed and/or deleted via Google's My Activity page. If you choose to opt out, you may not be able to use the full functionality of this website.
5. What is our legal basis for processing your personal information?
The legal basis on which we may rely to process your personal information include:
- On some occasions, we process your personal information with your consent (for example, when you agree that we may place cookies or process information that you input into our website e.g forms, surveys).
- On other occasions, we process your personal information when we need to do this to fulfil a contract with you (for example, for billing purposes) or where we are required to do this by law (for example, to comply with governmental record-keeping obligations).
- We also process your personal information when it is in our legitimate interests to do so and when these interests are not overridden by your data protection rights (including, for example, when we share personal information with our affiliates).
- We may also process your personal information to comply with a legal or regulatory obligation.
6. Who do we share your personal information with?
DS Smith is a multinational business comprising various affiliates spread across different countries. Consequently, your personal information may be shared with or processed by one or more entities within DS Smith.
Your personal information may also be made available to third parties such as:
- suppliers, service providers such as financial companies, auditors and professional advisers;
- telecommunication, IT hosting and IT maintenance providers;
- insurers and financial managers;
These third parties may use information about you to perform their functions on our behalf. The Company has put in place various security and data privacy measures, including with such third parties, in order to protect your personal information.
We may disclose specific information upon lawful request by government authorities, law enforcement and regulatory authorities, where required or permitted by law, and for tax or other purposes. Personal information may also be released to third parties in response to legal processes, and when required to comply with laws, or to enforce our agreements, corporate policies, and terms of use, or to protect the rights, property or safety of the Group, our employees, agents, customers, and others, as well as to parties to whom you authorise us to release your personal information.
We will not sell your personal information to any third party.
7. Will your personal information be transferred abroad?
Some transfers of personal information have been explained above. Individuals within the European Economic Area (“EEA”) and United Kingdom (UK) should be aware that recipients of their personal information, within the Group or third parties (as set out in this notice), may not be located within the EEA but instead located in countries which may not have equivalent protection for personal information to that within the EEA. In that case, steps will be taken to protect your personal information in compliance with applicable law. For example, data will be adequately protected by standard contractual clauses, an appropriate Data Privacy Framework certification or a vendor's Processor Binding Corporate Rules.
8. How long do we keep your personal information?
We will only retain your personal information for as long as reasonably necessary to fulfil the purposes for which it was collected. The retention of your personal information by us will be in accordance with our retention policy and applicable data protection legislation. We will securely destroy or erase your personal information at the end of the applicable retention period.
9. How do we store and secure your personal information?
Some of the personal information that we maintain will be kept in paper files, while other personal information will be included in computerised files and electronic databases.
We have put appropriate technical and organisational measures in place to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
10. What are your rights regarding your personal information?
You have a range of rights over your personal information. You can:
- request access: you have the right to ask us for a copy of the personal information we hold about you;
- request rectification: you can ask us to rectify your personal information you think is inaccurate or to complete your personal information you think is incomplete;
- object to processing: you have the right to object to the processing of your personal information in certain circumstances including opting out of direct marketing;
- Restrict processing: you have the right to ask us to limit the way we use your personal information;
- request erasure: you have the right to ask us to erase your personal information in certain circumstances;
- request your personal information to be ported: you have the right to ask that we send you or another entity the personal information we hold on you;
- lodge a complaint with your local data protection supervisory authority if you feel your rights have been infringed.
You may only exercise some of the rights above in limited circumstances, determined by the legal basis for collecting your personal data.
Please contact us at data.privacy@dssmith.com if you would like to exercise any of your privacy rights.
11. Changes to our Privacy Policy
We update this Privacy Policy regularly to reflect changes in the way we process your personal information. Please check our website regularly for any updates.
July 2024
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