1.1 The Permanent Materials Coalition is composed of APEAL, the Association of European Producers of Steel for Packaging, European Aluminium, the European Container Glass Federation (FEVE) and Metal Packaging Europe. The Permanent Materials Alliance collects and uses certain Personal Data. The Permanent Materials Alliance is responsible for ensuring that it uses that Personal Data in compliance with data protection laws.
“Permanent Materials Alliance”, “PMA”, “we” or “us” means Permanent Materials Alliance.
“Personal Data” means any data which relates to a living individual who can be identified from that data or from that data and other information which is in the possession of, or is likely to come into the possession of, PMA (or its representatives or service providers). In addition to factual information, it includes any expression of opinion about an individual and any indication of the intentions of PMA or any other person in respect of an individual.
2. Categories of personal data
- Information we receive through our website (“Website”); and
- Information we receive through or in connection with the provision of our services (“PMA Services”).
2.2 We will collect and process the following Personal Data about you:
- Information that you provide to PMA. This includes information about you that you provide to us. The nature of the services you are requesting will determine the kind of Personal Data we might ask for, though such information may include (by way of a non-exhaustive list):
– basic Personal Data (such as first name; family name; position in the company; company name; company email address; business phone number; business address; city; postcode; country);
– any information that you choose to share with us (whether through our Website or otherwise) which may be considered Personal Data;
- Information that we collect or generate about you. This includes (by way of a non-exhaustive list):
– Information about the PMA Services which you have requested and our interactions with you;
– When you visit our Website, cookies are used to collect technical information about the services that you use, and how you use them. For more information on the cookies used by PMA please see the cookie section below.
- Anonymized data
– In addition to the categories of Personal Data described above, PMA will also process further anonymized information and data that is not processed by reference to a specific individual.
3. How we use your information
3.1 Your Personal Data may be stored and processed by us in the following ways and for the following purposes:
- for ongoing review and improvement of the information provided on or operation and security of the PMA Website;
- to assess your application for PMA Services, where applicable;
- to invite you to events organized by PMA and its partners;
- to manage your attendance to the above events;
- to provide you with PMA Services
- to understand feedback on PMA Services and to help provide more information on the use of those services quickly and easily;
- to communicate with you in order to provide you with services or information about PMA;
- to understand your needs and interests;
- for the management and administration of our activities;
- in order to comply with and in order to assess compliance with applicable laws, rules and regulations, and internal policies and procedures; and / or
- for the administration and maintenance of databases storing Personal Data.
3.2 When we use Personal Data we make sure that the usage complies with law and the law allows us and requires us to use Personal Data for a variety of reasons. These include where:
- we need to do so in order to perform our contractual obligations with our members;
- we have obtained your consent;
- we have legal and regulatory obligations that we have to discharge;
- we may need to do so in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings;
- the use of your Personal Data as described is necessary for our legitimate interests, such as:
– allowing us to effectively and efficiently manage and administer the operation of our activities;
– conducting market research or business analysis;
– maintaining compliance with internal policies and procedures; and
– promoting our activities.
4 Disclosure of your information to third parties
4.1 We may share your Personal Data within the Permanent Materials Alliance’s members and related organizations for the purposes described above.
4.2 We may also share your Personal Data outside of PMA for the following purposes:
- with our business partners. For example, this could include intermediaries that introduced you to us. Personal Data will only be transferred to a business partner who is contractually obliged to comply with appropriate data protection obligations and the relevant privacy and confidentiality legislation;
- to the extent required by law, for example if we are under a duty to disclose your Personal Data in order to comply with any legal obligation, or to establish, exercise or defend our legal rights.
5. How we safeguard your information
5.1 We have extensive controls in place to maintain the security of our information and information systems. The information that we handle is protected with safeguards appropriate to the sensitivity of the relevant information. Appropriate controls (such as restricted access) are placed on our computer systems. Physical access to areas where Personal Data is gathered, processed or stored is limited to authorised employees.
5.2 As a condition of employment, PMA members are required to follow all applicable laws and regulations, including in relation to data protection law. Access to sensitive Personal Data is limited to those who need it to perform their roles. Unauthorised use or disclosure of confidential client information by a PMA member is prohibited and may result in disciplinary measures.
6. How long we keep your personal data
6.1 How long we will hold your Personal Data for will vary and will be determined by the following criteria:
- the purpose for which we are using it – PMA will need to keep the data for as long as is necessary for that purpose; and
- legal obligations – laws or regulation may set a minimum period for which we have to keep your Personal Data.
7. Your rights
7.1 In all the above cases in which we collect, use or store your Personal Data, you may have the following rights and, in most cases, you can exercise them free of charge. These rights include:
- the right to obtain information regarding the processing of your Personal Data and access to the Personal Data which we hold about you;
- the right to withdraw your consent to the processing of your Personal Data at any time. Please note, however, that we may still be entitled to process your Personal Data if we have another legitimate reason for doing so. For example, we may need to retain Personal Data to comply with a legal obligation;
- in some circumstances, the right to receive some Personal Data in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to Personal Data which you have provided directly to PMA;
- the right to request that we rectify your Personal Data if it is inaccurate or incomplete;
- the right to request that we erase your Personal Data in certain circumstances. Please note that there may be circumstances where you ask us to erase your Personal Data but we are legally entitled to retain it;
- the right to object to, or request that we restrict, our processing of your Personal Data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your Personal Data but we are legally entitled to refuse that request; and
- the right to lodge a complaint with the relevant data protection regulator if you think that any of your rights have been infringed by us.
7.2 You can exercise your rights by contacting us using the details listed in paragraph 10 below.
7.3 You can find out more information about your rights by contacting the data protection regulator in your jurisdiction, the Belgian Privacy Commission (“Autorité de protection des données” or “Gegevensbeschermingautoriteit”), rue de la Presse 35, 1000 Brussels, or by searching their website at https://www.privacycommission.be.
9. Questions and concerns
9.1 If you have any questions or concerns about Permanent Materials Alliance’s handling of your Personal Data, or about this Policy, please contact us using the following contact information:
APEAL – The Association of European Producers of steel for packaging
Avenue Ariane 5, Building ‘Integrale’ E3, ground floor, BE‐1200 Brussels
Phone: +32 2 537 9151
Avenue des Nerviens 85, 1040 Brussels
Phone: +32 2 775 63 63
FEVE – The European Container Glass Federation
Fédération Européenne du Verre d’Emballage AISBL (FEVE)
Avenue Louise 89, B-1000 Brussels
Phone: +32 2 536 0080
Metal Packaging Europe
Metal Packaging G.I.E.
Avenue des Arts 41, 1040 Brussels
Phone: +32 2 897 04 90