Effective Date: 6/30/2020

I. Purpose and Scope

Reynolds Consumer Products LLC and certain of its Affiliates ("Reynolds") has created this Privacy Policy ("Privacy Policy") in order to demonstrate our firm commitment to your privacy. "Affiliates" means, with respect to any entity, any other entity which directly, or indirectly through one or more intermediaries, controls or is controlled by, or is under common control with, the specified entity, including companies such as Reynolds Presto Products LLC that generally do not offer their products and services under a "Reynolds" name brand.

Please read the following to understand how Personal Data collected on our websites may be used and shared. This Privacy Policy discloses our information gathering and dissemination practices for our main website http://www.reynoldsconsumerproducts.com and all other Reynolds websites linked thereto and/or owned by Reynolds ("Sites").

II. Changes to this Privacy Policy

This Privacy Policy is current as of the effective date set forth above. Reynolds reserves the right to change this Privacy Policy from time to time consistent with applicable privacy laws and principles. If we change the way in which we collect or use your information, we will inform you of those changes.  We encourage you to check this page regularly for updates.

III. Personal Data Collection and Use

THE CATEGORIES OF PERSONAL INFORMATION ABOUT YOU THAT WE COLLECT, USE, AND/OR DISCLOSE

As identified in the chart below, over the past twelve months, we may have collected information about you when you use our products and services, or interact with us through our websites, mobile applications, and/or call centers.  We may share some of that information with our business unites/affiliates/subsidiaries.  We do not sell your information to third parties for a profit or as the term “sale” is defined under the new California Consumer Privacy Act of 2018 (the “CCPA”). We do, however, share your information with certain third parties for consumer and customer relations, advertising, promotion and insurance purposes. 

Personal Information Collected by Reynolds	Category Collected by Reynolds	Category Shared by Reynolds
Personal Identifiers such as your real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.	YES	YES
Personal information covered by the California Consumer Records statute (Cal. Civ. Code 1798.80(e)) such as your name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	YES	YES
Protected personal information under California or federal law, including but not limited to your sex (including gender, gender identity, and gender expression).[1]	YES	NO
Commercial information including, but not limited to records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	YES	YES
Internet or network activity including your browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	YES	NO
Your specific geolocation data.	YES	NO
Your audio, electronic, visual, thermal, olfactory, or similar information.[2]	YES	YES
Inferences that we may draw from the above information reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	YES	NO

 

In addition to circumstances in which you provide us with your written consent, we use the information we collect about you for a variety of purposes, including:

• provide, deliver, maintain and improve the products and services you request;
• provide you with customer service;
• provide updates, upgrades, repairs or replacements for any of our service-related devices or software used in providing or receiving services;
• manage and configure our device(s), system(s) and network(s);
• understand how the service is being used, including through the creation of operational and marketing reports based on de-identified and/or aggregated service usage information;
• inform you of additional products and services that may be of interest to you;
• protect the security of the system, prevent fraud, detect unauthorized reception, use, and abuse of any Reynolds product, service, website or application, and to enforce any Reynolds policy or applicable terms of service;
• protect our rights, our personnel, our property, and the safety of others;
• maintain our accounting, tax and other records;
• comply with applicable federal and state laws and regulations, as well as for the general administration of our business;
• deliver and personalize communications with you;
• create internal business and marketing reports; and
• provide advertising and marketing.  

 

In other limited situations, unique or online identifiers associated with a consumer or household may be made available to a third party for analytics or other purposes.

Cookies
In order to improve our site, we utilize "cookies" to maintain a record of your visit, by using a cookie file that is stored on the hard drive of your computer. A cookie is a small text file that is transferred to a web browser by a web server and can only be read by the server that gave it to you. This information does not identify you personally and you remain anonymous unless you have otherwise provided us with Personal Data.

Cookies help us to improve our site and to deliver more personalized service by enabling us to estimate audience size and usage pattern; to store information about your preferences; to speed up your searches and may be used to recognize your computer.

Most web browsers automatically accept cookies. If you would prefer to prevent your computer from accepting our cookies, you may follow your Internet browser’s steps for doing so. Please note, however, that if you do disable cookies from your browser, you may not be able to access certain sections of our websites.

Pixels

Third parties with whom we contract may place and use pixels on our websites which are associated with cookies to allow internet-based ads to Reynolds Consumer Products website visitors who visit other websites.

Amazon

• Users can opt out of receiving interest-based ads from Amazon by visiting the Amazon Advertising Preferences page (http://www.amazon.com/gp/dra/info) or by visiting the Digital Advertising Alliance’s opt-out page (http://www.aboutads.info/choices/).
• No pixels, app, or service is used on pages directed to children under age 13.
• No personally identifiable information about the visitors to our websites are passed to Amazon.com or other business partners, including but not limited to, names, email addresses, telephone numbers.

 

Google Analytics

Our sites may use Google Analytics to track demographics and interests of our visitors, but is not personally-identifiable. Tracked information may include: age, gender, and interests based on browsing history. We will use this information for marketing purposes. Users can opt-out of being tracked here: https://tools.google.com/dlpage/gaoptout/

V. Disclosures/Onward Transfers

Reynolds may disclose your Personal Data to any member of our group, which means our subsidiaries and our ultimate holding company and its subsidiaries in compliance with applicable privacy principles, laws, regulations and rules.

In order to more efficiently provide the products and services you may request from us, Reynolds may also share your Personal Data with selected third parties who are acting or gathering information on our behalf as our agents, suppliers, or providers. 

To this effect, we may disclose Personal Data to the following:

• Third parties who perform tasks on our behalf; and
• Third parties who agree to provide adequate protections for your Personal Data that are no less protective than those set out in this Privacy Policy; and to use your information only for the purposes for which the third party has been engaged by us.

 

We may also disclose your Personal Data to third parties if:

• We sell or buy any business or assets, in which case we may disclose your Personal Data to the prospective seller or buyer of such businesses or assets.
• Any member of our group or substantially all of its or their assets are acquired by a third party, in which case Personal Data held by it about its customers will likely be one of the transferred assets.
• We are under a duty to disclose or share your Personal Data in order to comply with any legal obligation, subpoena or other court order; or in order to enforce or apply any of our online Terms and Conditions and other agreements; or to protect the rights, property or safety of our group companies and organizations for the purposes of fraud protection and credit risk reduction; or for any other reason as required or permitted by law.

 

VI. Right to Access, Change or Delete Personal Data

YOUR RIGHTS TO REQUEST, TO KNOW AND TO ACCESS PERSONAL INFORMATION

If you want to know the personal information we have collected about you in the last 12 months, you may submit a verifiable consumer request to us, and subject to our verification of that request, we will provide you with the following information:

• the categories of personal information we have collected about you;
• the categories of sources from which the personal information is collected;
• the business or commercial purpose for collecting, disclosing or selling, if applicable, the personal information;
• the categories of third parties with whom we have shared or sold, if  applicable, your personal information; and
• the specific pieces of personal information we have collected about you. 

 

In addition to these disclosures, you may submit a verifiable consumer request up to two (2) times in a twelve (12)-month period for access to your personal information.  When you submit an access request, you can request us to deliver the information by mail or electronically.  If you elect to receive the information electronically, to the extent it is technically feasible for us to do so, we will provide the requested information in a portable and readily useable format that allows you to transmit this information to another entity.

We will not, however, disclose any of the following information in response to an access request: your social security number, driver’s license number or other government-issued identification number, financial account number, any health or medical identification number, an account password, or security questions or answers in response to a request to know.

In order to submit a verifiable consumer request, please visit the “How You Can Submit A Verifiable Consumer Request section below.   

Right to Request Deletion

If you want us to delete the personal information we have collected from you, you can send us a verifiable consumer request requesting that we delete some or all of the information we have collected from you, subject to certain exceptions. Once we receive and confirm your personal information request, we will delete such personal information from our active records, unless an exception applies.  We will also notify any service providers and third parties with whom we have shared your personal information of your request. 

We are not required to, and do not have to agree to delete your information where preserving the information is necessary for us to:

• Complete the transaction for which the personal information was collected, provide a good or service requested by the consumer, or reasonably anticipated within the context of a business’s ongoing business relationship with the consumer, or otherwise perform a contract between the business and the consumer;
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
• Debug to identify and repair errors that impair existing intended functionality;
• Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
• Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 of Title 12 of Part 2 of the Penal Code;
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the businesses’ deletion of the information is likely to render impossible or seriously impair the achievement of such research, if the consumer has provided informed consent;
• To enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the business;
• Comply with a legal obligation; or
• Otherwise use the consumer’s personal information, internally, in a lawful manner that is compatible with the context in which the consumer provided the information.

 

If any of these exceptions apply, we are not required to delete your personal information.  In the event that we deny your request to delete based on any of these exceptions, we will inform you, in writing, of the reason.    

How You Can Submit A Verifiable Consumer Request For a Request to Know, Access, or Delete

In order for us to process a request to know, access or delete, it is necessary for us to verify your identity.  We will ask you to provide certain additional information about yourself, such as name, physical address, email address and phone number, and if those are not available other information such as a copy of your driver’s license or other government issued identification, to compare to information we have on file for you to verify your identity.  We cannot fulfill your request if we cannot verify your identity.   

It may take up to forty-five (45) days to fulfill your request, or up to a total of ninety (90) days if additional time is needed.  In the event that we cannot complete your request within the initial forty-five (45) day period, we will notify you in writing within the initial forty-five (45) day period. 

To request exercise one or more of your consumer rights, please submit a verifiable consumer request:

• 1800 433-2244; or
• RCPCommunications@ReynoldsBrands.com

You may authorize another person (your “agent”) to submit a request on your behalf.  For an authorized representative, we will typically require a copy of the registration with the California Secretary of State (if any), a valid power of attorney or a court appointment document, or some other documentation reflecting your appointment of the agent.  We will also require that you provide us with information sufficient for us to verify your identity as provided above.

YOUR RIGHT TO OPT-OUT OF THE SALE OF PERSONAL INFORMATION TO THIRD PARTIES IF WE WERE TO SELL YOUR INFORMATION

We do not currently sell your information to third parties, but to the extent we do in the future we will give you the right to opt out in compliance with applicable laws.     

YOUR RIGHT TO NON-DISCRIMINATION

We do not discriminate against consumers for exercising any of their rights with respect to their personal information.  If you are a consumer exercising any of your rights under this policy, we will not deny you goods or services; charge you different prices or rates for goods or services; or provide different levels or quality of goods or services to you.

VII. Security and Data Integrity

We will take all reasonable steps to ensure that your data is treated securely and in accordance with this Privacy Policy. Unfortunately, however, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee its security and any transmission is at your own risk. Once we have received your information, we will use reasonable procedures and security features to try to prevent unauthorized access.

VIII. Children

Reynolds has a separate privacy policy for children under the age of 13. To view this Children’s Privacy Policy please go to: www.reynoldsconsumerproducts.com/privacy.

IX. Other Sites

Our Sites may contain links to other websites, including the websites of third parties who are acting on our behalf as our agents, suppliers, or providers.

Reynolds is not responsible for the content, security, or privacy practices employed by third party websites. Once you leave our website, we encourage you to review the privacy policy of any website linked to from one of our Sites before using it.

XI.        Residents of the EU

Reynolds does not intentionally collect information from residents of the European Union (EU).  If we obtain actual knowledge that we have collected information about an EU resident, we will promptly delete that information.

XII.       Complaints and Questions

Reynolds takes your privacy concerns seriously. If you have any complaints regarding this policy, or questions about our privacy practices, you may write to RCPCommunications@ReynoldsBrands.com or send a letter to RCP Privacy Complaints at Reynolds Consumer Products, 1900 West Field Court, Lake Forest, Illinois 60045, Attention: Law Department.