Last updated: June 16, 2020
When does this Notice apply?
Avery Dennison respects your right to privacy. This Notice explains who we are, how we collect, share and use personal information about you, and how you can exercise your privacy rights. This Notice applies in general to all instances where we collect and process personal information. In particular this Notice applies to personal information that we collect through our website (“Website”) and personal information that we collect of our customers, suppliers, and other individuals through any other form of interaction whether online or offline. Whenever we collect your personal information, we will either provide you with a separate notice that will comply with relevant privacy and data protection laws or we will refer you to this Notice.
Who we are
Avery Dennison manufactures and distributes display graphics, labelling and packaging materials, retail graphic embellishments and RFID tags that companies around the world use to engage customers and efficiently manage their inventories. Our products are virtually everywhere you look, providing a crucial thread in the fabric of global commerce. For more information about Avery Dennison, please see the “About Us” section of our Website.
Who do we collect personal information from?
While we are a business-to-business company we collect and process personal information of various categories of persons in order to function and to maintain a relationship with the people that we hold personal information about.
We collect and process personal information about:
- Website visitors
- Customers, Suppliers, Business Partners (and their employees)
- Employees, Contractors and Staff (and applicants / candidates)
- Other visitors and people we connect with for professional or social reasons
What personal information does Avery Dennison collect and why?
1. Website visitors
Information that you provide voluntarily
Certain parts of our Website may ask you to provide personal information voluntarily: for example, we may ask you to provide your contact details (including your name, title, company, address, telephone number and email address). We will use this information for the purposes set out below:
- to improve our products and services;
- to respond to online queries, supply requested information on Avery Dennison products, process and ship orders, fulfill online marketing offers, establish approved links and for internal market analysis;
- to periodically send promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided;
- to contact you for market research purposes. We may contact you by email, phone, fax or mail. We may use the information to customise this Website according to your interests; and
- for the specific purpose stated on forms on this Website.
Information that we collect automatically
When you visit our Website, we may collect certain information automatically from your device. In some countries, including countries in the European Economic Area, this information may be considered personal information under applicable data protection laws.
Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location) and other technical information. We may also collect information about how your device has interacted with our Website, including the pages accessed and links clicked.
Collecting this information enables us to better understand the visitors who come to our Website, where they come from, and what content on our Website is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our Website to our visitors.
Some of this information may be collected using cookies and similar tracking technology, as explained further under the heading “Cookies and similar tracking technology” below.
2. Customers. Suppliers, Business Partners, and Visitors
If you are a current or prospective customer or supplier of ours (or if you are an employee, contractor, agent or other representative of a current or prospective customer or supplier of ours), we may collect and use the following personal information about you:
- Identification data – such as your name, date of birth, photograph.
- Contact details – such as business or delivery address, telephone/business email address, fax number, etc.
- Professional details – such as your job title/position, employer, company registration number, etc.
- Financial characteristics – such as account number and bank details, invoice address.
- National identifiers – such as tax ID and VAT number.
- Information relating to your (or your employer's) sales history with us.
- Other information you choose to provide to us, for example the purpose of your visit if you visit one of our site locations.
- IP addresses or other information that we may collect from you if you visit our Website
We may collect and use this personal information about you for the following purposes:
- For the purpose of general business relationship management within Avery Dennison, including contract management; for example, to enable us to deliver our services to you (or your employer), or to audit the provision of services by you (or your employer) to Avery Dennison.
- To manage our daily business activities, such as executing payments [or to set up a credit arrangement with you or your employer];
- To manage any queries, complaints or claims relating to the services you (or your employer) provide to Avery Dennison or that Avery Dennison provides to you (or your employer);
- For direct marketing, advertising and public relations purposes, in connection with Avery Dennison's business activities, products and services (including to make recommendations about our services and products), and to inform you (or your employer) about important developments within Avery Dennison;
- For product development purposes, to allow us to improve our products and services or develop new products and services;
- Where necessary to comply with laws and regulations, under judicial authorisation, or to exercise or defend the legal rights of Avery Dennison group companies;
- To help us conduct our business more effectively and efficiently or check and improve the quality of our products and/or services;
- To carry out research and development with various Avery Dennison partners;
- To investigate violations of law or breaches of other Avery Dennison policies.
3. Employees, Contractors and other staff
When we source candidates we minimise the personal information that we collect and process to only that which is necessary for recruitment. We have prepared a Recruitment Privacy Notice which deals specifically with the recruitment of employees, interns and other staff.
When we employ successful candidates, we have a need to collect and process additional information needed for the purposes of carrying out the obligations and exercising specific rights in the field of employment law. Our Data Privacy Notice clarifies to our employees who we use their personal information.
4. Other visitors and people we connect with
There might be occasions where we interact with people who are not regular contacts of ours. For example, we may hold events and have functions that may be attended by visitors and friends of friends.
- Identification data – such as your name, date of birth, photograph.
- Contact details (including emergency contact details) – such as next of kin details, email address, contact phone number.
- Professional details – such as your job title/position, employer, company registration number, etc.
- Other information you choose to provide to us, for example the purpose of your visit if you visit one of our site locations.
We may collect and use this personal information about you for the following purposes:
- For the management of our guest list
- For safety regulations and reasons related to emergency evacuations and roll call
- Photos and video footage may be taken to document and promote our events, business and activities
Further use of personal information
In general, we will use the personal information we collect from you only for the purposes described in this Privacy Notice or for purposes that we explain to you at the time we collect your personal information. However, we may also use your personal information for other purposes that are not incompatible with the purposes we have disclosed to you (such as archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes) if and where this is permitted by applicable data protection laws.
Who do we share your personal information with?
We may disclose your personal information to the following categories of recipients:
- to our group companies, third party services providers and partners who provide data processing services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our Website), or who otherwise process personal information for purposes that are described in this Privacy Notice or notified to you when we collect your personal information.
- to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
- to an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Notice;
- to any other person with your consent to the disclosure.
Legal basis for processing personal information (EEA visitors only)
If you are a visitor from the European Economic Area, our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
However, we will normally collect personal information from you only (i) where we need the personal information to perform a contract with you, (ii) where the processing is in our legitimate interests and not overridden by your rights, or (iii) where we have your consent to do so. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.
If we ask you to provide personal information to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest will normally be to operate our services and communicating with you as necessary to provide our services to you and for our legitimate commercial interest, for instance, when responding to your queries, improving our services, undertaking marketing, or for the purposes of detecting or preventing illegal activities. We may have other legitimate interests and if appropriate we will make clear to you at the relevant time what those legitimate interests are.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “How to contact us” heading below.
Cookies and similar tracking technology
We may use cookies and similar tracking technology (collectively, “Cookies”) to collect and use personal information about you, including to serve interest-based advertising. For further information about the types of Cookies we use, why, and how you can control Cookies, please see our Cookie Policy.
How do we keep your personal information secure?
We use appropriate technical and organisational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. Avery Dennison has a comprehensive Security program with a focus on protecting personal information.
International data transfers
Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country.
Specifically, our Website servers are located in the US, and our group companies and third party service providers and partners operate around the world. This means that when we collect your personal information we may process it in any of these countries.
However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Notice.These include implementing Binding Corporate Rules and the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies, which require all group companies to protect personal information they process from the EEA in accordance with European Union data protection law.
Data retention
We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
Your data protection rights
If you are a resident of the European Economic Area, you have the following data protection rights:
- If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided under the “How to contact us” heading below.
- In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided under the “How to contact us” heading below.
- You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under the “How to contact us” heading below.
- Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
- You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority (available here).
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
Updates to this Privacy Notice
We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Notice changes if and where this is required by applicable data protection laws.
You can see when this Privacy Notice was last updated by checking the “last updated” date displayed at the top of this Privacy Notice.
How to contact us
If you have any questions or concerns about our use of your personal information, please contact us at dataprivacy@averydennison.com.
If you wish to you wish to access, correct, update or request deletion of your personal information please fill out our Data Subject Access Rights form.
The data controller of your personal information is Avery Dennison Inc.
