Privacy Policy

PLEASE READ THIS PRIVACY POLICY CAREFULLY BEFORE USING THIS WEBSITE

Sappi North America (“SNA”) respects your privacy and is committed to protecting the privacy and confidential information of those who register, order or otherwise access our website located at www.sappi.com (the “Website”).

This Privacy Policy describes and governs how we collect information in connection with your use of the Website and how we use and share that information. Please take the time to read this Privacy Policy.

We may revise this Privacy Policy periodically and will post any changes to the Website so that you are always informed about what information we collect, how we use it and under what circumstances we may disclose it. By continuing to use the Website after having an opportunity to review this Privacy Policy, you have accepted the Privacy Policy in its entirety and without modification and consented to our collection, use and sharing of the information as described in this Privacy Policy. If you do not agree with this Privacy Policy, please exit and do not use the Website.

1. What information does SNA collect?

The information we collect depends on how you use the Website.

Personal Information. In various areas of the Website, such as when you contact us, register to use the Website, order products or services, or participate in promotions or Interactive Areas (“Interactive Areas” include user galleries, blog comment posting areas and bulletin boards), we may request that you provide us with certain personally identifiable information (e.g., name, address, telephone number, e-mail address, company or employer name or other information from which your identity is discernible). Please keep in mind that if you do not submit personally identifiable information that is requested of you, you may be unable to access certain locations and features on the Website. When you provide us with personally identifiable information, we may use that information to better understand your needs and for the purpose of operating and improving the Website and our service offerings, products and your user experience. We may also use that information to contact you, for example, to answer a question or respond to a comment you have submitted, distribute our newsletters and allow participation in Interactive Areas. We will not sell your personally identifiable information to any third party.

Now and then, we may conduct surveys, contests, mailings and promotions. If you choose to participate in one of our surveys, contests, mailings or promotions, we may request personal information to enable us to execute the promotion or notify winners. Some of this information will be mandatory to participate; other information will be optional. We will tell you whether any information is mandatory or optional.

When you send us a request, we may ask you to identify yourself by name and/or e-mail address in order to send you a response, if appropriate.

Information Sent to Us by Your Browser. Most of the information we collect from you at the Website does not personally identify you to us, although it may be unique or consist of information that you consider personal. For example, we collect information that is sent to us automatically by your Web browser or by using cookies, pixel tags, web beacons and other Web technologies. This information typically includes your IP address, the identity of your Internet Service Provider, the name and version of your operating system, the name and version of your browser, the date and time of your visit, the pages you visit and any search terms you enter while on the Website. This information cannot be used to identify you personally unless you identify yourself to us by, for example, making a purchase, creating an account or by giving us your e-mail address.

Cookies, Pixel Tags, Web Beacons and Similar Technologies. We use "cookies," “pixel tags,” “web beacons” and other Web technologies for a number of purposes, including:

• to collect information about the ways you use this Website — for example, which pages you visit, which links you use, and how long you stay on each page;
• to support the features and functionality of this Website — for example, to save you the trouble of re-entering information already in our database or to prompt the settings you established on previous visits to this Website; and
• to personalize your experience when you use this Website.

Generally, the information we collect using these web technologies does not identify you personally. If, however, you have provided us with personal information by creating a SNA account or otherwise, we may link the information collected using these Web technologies to the personal information you have provided to us.

Cookies are small pieces of information stored by your browser on your computer’s hard drive. Most web browsers can be set to refuse to accept cookies, although this may affect your use of the Website. You can also erase cookies that are already on your computer, block all cookies or receive a warning before a cookie is stored. If you choose to have your browser refuse cookies, the Website may not function properly for you.

Pixel tags or web beacons are tiny graphic images used to help us analyze your online patterns, create content designed for your connection speeds, and deliver e-mail in a format you can read.

When you access this Website by clicking on a link in an electronic communication you receive from us, your browser tells us that someone has clicked on a particular link in that particular electronic communication. We use this information in aggregated form to improve our marketing efforts. If criminal activity is suspected, we may share our server logs and the personal information we have collected through this Website with the appropriate investigative authorities who could use that information to trace and identify individuals.

Website Analytics. This website uses one or more web analytics service providers. The service providers use "cookies", which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored on secure servers. The service providers will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. The service providers may also transfer this information to third parties where required to do so by law, or where such third parties process the information on behalf of the service providers. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. By using this website, you consent to the processing of data about you by SNA’s service providers in the manner and for the purposes set out above.

2. How does SNA use the information it collects?

When you place an order at Sappisamples.com, we use your information to process and fulfill your order. We may send you an e-mail to confirm or to update you on the status of your order. We may also need to contact you by regular mail, e-mail or phone if we have any questions about your order. We may also use your information to respond to any of your customer service inquiries.

We also use your information to operate and improve the Website and to deliver the products and services you have requested. We keep track of the pages you visit and the manner in which you use the Website to determine what products are most popular and whether to make changes to the Website. Also, we may, from time to time, review your information and information of other customers to help us analyze trends, purchasing patterns and preferences, and demographics.

When you place an order, create an account, give us your e-mail address, complete a survey or participate in a contest, mailing or other promotion on any of the Websites, we use the information you provide to us to send e-mail, regular mail or text messages, as applicable, to you about our products, services or other contests and promotions you might be interested in, unless you indicate that you do not wish to receive such e-mail, mail or text messages.

We may combine the information you provide to us with data that is publicly available and data that we collect through our contests and promotions, at our marketing events or receive from other sources whose policies meet industry standard privacy practices and applicable legal requirements.

Employment Information. You may use this Website to search for job openings at SNA and to submit a job application. When you use this Website to apply for a job, you will be asked to provide certain personal information, such as your name, address, telephone number, email address, educational background and employment history. You may also send us your résumé and other information relating to your job search or application. We use this information only for recruiting and employment purposes; we do not use it for marketing purposes. If you are hired by SNA, the information you provide during the recruiting process will become part of our employee records.

3. Does SNA share your information with third parties?

We may share your information with our trusted third party service providers to help us manage and operate the Website, process your orders, perform statistical analysis, send you e-mail, postal mail or text messages, provide customer support and perform other important services. Although these partners may not be affiliated with us, they are required to maintain the confidentiality of your information and are not authorized to discuss, disclose or make any use of your personal information except as necessary to provide such services.

We will not share your personal information with unaffiliated third parties to enable those third parties to offer you products or services or otherwise market or promote such product or services. Further, we will not share any personal information, other than mere contact information, with any affiliates of SNA for marketing or promotional purposes. However, we may partner with third parties to help us collect and aggregate certain information collected at the Website. We may share this aggregated, non-personally identifiable information with existing and prospective business partners and advertisers. None of the aggregate information will contain any information that identifies you individually.

We and our third party service providers may disclose specific individual information if we or they reasonably believe that it is necessary to: (i) investigate any suspected misuse of the Website; (ii) comply with applicable federal, state or local laws, rules, regulations or orders; (iii) to protect or defend the rights, property and interests of SNA, our customers, or the interests of our third party service providers; or (iv) under exigent circumstances, to protect the personal safety of users of the Website or the public.

Your information will be held by us for so long as is necessary for the purposes for which it was collected, for the settlement of any potential disputes that may be raised or otherwise in accordance with legal requirements.

Your information may be transferred to another entity that succeeds to all or part of SNA’s business in connection with a sale, reorganization, consolidation or merger.

4. How can you unsubscribe or change your information?

We want to communicate with you only if you want to hear from us. If you prefer not to receive information from us or would like to update or change your personal information or preferences, please send your request to us via the points of contact listed at the end of this Privacy Policy. Please provide your full name, company name, address, and email address so that we can locate you. We will respond to your request within a reasonable period of time. To unsubscribe from an e-mail list, please follow the instructions in any e-mail you receive.

5. What security measures does SNA use to protect your information?

We take care to provide a level of security appropriate to the sensitivity of the information we collect and maintain. Although we use measures to help protect your information against unauthorized access, use or disclosure, we cannot guarantee the security of information provided over the Internet or stored in our databases. Your transmissions are, therefore, at your own risk.

Not all of the pages on the Website are secure. Most of the pages on our Website provide information to you about SNA and our products and do not allow you to provide us with personal information. As a result, these pages are not secured using encryption or other technology. We do, however, use encryption technology (Secure Sockets Layer technology) to secure all pages requiring registration information. The information you provide is encrypted (or coded) using a secure server intended to maximize security. This encryption makes it extremely difficult, but not impossible, for a third party to access your information within SNA’s servers. You may use your browser tools to identify whether any particular webpage is “secure” or not.

6. Links to Other Websites.

This Website may, from time to time, contain links to websites owned and operated by third parties (“Third Party Sites”). We encourage you to review the privacy policies of such Third Party Sites so that you understand how those websites collect, use and share your information. We are not responsible for the privacy policies or other content on Third Party Sites.

7. Children

Access to and use of the Website is made available only to people who can form legally binding agreements under applicable law. The Website is intended for a general audience and is not intended to be used by minor children. SNA does not knowingly collect personal information from minor children. Children accessing the Website should obtain the permission and assistance of a parent or legal guardian. If you allow your minor child or a child for whom you are a legal guardian (a "Minor"), to access the Website, you will be solely responsible for: (i) the online conduct of such Minor; (ii) monitoring such Minor's access to and use of the Website; and (iii) the consequences of any use of the Website by such Minor.

8. Governing Law

This Privacy Policy will be governed by and construed in accordance with the laws of The Commonwealth of Massachusetts, without giving effect to its conflicts of law provisions. By accessing or using the Website, you consent and submit to the exclusive jurisdiction and venue of the state and federal courts located in Massachusetts. A printed version of this Privacy Policy will be admissible in judicial and administrative proceedings based upon or relating to this Privacy Policy to the same extent and subject to the same conditions as other business documents and records originally generated and maintained in printed form.

9. Miscellaneous

In the event that any provision of this Privacy Policy conflicts with applicable law, rule, regulation or order or if any provision is held invalid by a court with competent jurisdiction, then such provision will be deemed to be restated to reflect as nearly as possible the original intentions of the parties, and the remainder of this Privacy Policy will remain in full force and effect. Any failure by SNA to insist upon or enforce strict performance of any provision of the Privacy Policy or to exercise any right under the Privacy Policy will not be construed as a waiver or relinquishment of SNA’s right to assert or rely upon any such provision or right in that or any other instance, rather, the same will be and remain in full force and effect.

10. Contact Us

We welcome your comments and questions. Please contact us at:

Sappi North America

Attn: Privacy Policy Inquiries

255 State Street

Boston, MA 02109

© 2016 Sappi North America. All rights reserved.

Sappi Europe’s Policy for handling your personal data

Sappi Europe S.A. and its affiliated group companies (“Sappi” or “we”) are fully committed to protecting your personal data when using or processing them and recognize the importance of correct and lawful treatment of personal data.

Therefore, Sappi handles your personal data with utmost care and in strict compliance with applicable data protection laws, in particular the EU General Data Protection Regulation 2016/679 of 27 April 2016¹ and all relevant national measures.

How Sappi implements protection of your personal data in practice

1.    Who will process my personal data ?

The “Data Controller” of your personal data will be the following legal entity as well as all associated entities listed here:

2.    What is the purpose and legal basis for processing my personal data ?

Sappi is processing your personal data only for the following purposes:

• To manage your respective job application(s) via Sappi’s Online Career Portal (the “Career Portal”) for potential recruitment.
• Screen, assess and evaluate all educational and professional information and relevant background information in view of a potential recruitment.
• Prepare employment contract in case of positive evaluation and decision to hire. 

(jointly “Potential Recruitment”)

• Administration of the Career Portal.

No personal data are processed for any purposes other than Potential Recruitment or administration of the Career Portal.

The processing of your personal data is necessary in order to take steps prior to entering into an employment contract and is in Sappi’s legitimate interests, i.e. the interest to assess and evaluate you before deciding on making an offer of employment. 

3.    Which categories of my personal data will Sappi process ?

Sappi will collect and further process the following personal data from you:

a.    Data with regard to your identity (name, email address, telephone number(s), country of residence, postal address, etc.),
b.    Data with regard to your education (diploma’s, certificates, special trainings, etc.),
c.    Data with regard to your professional experience (profile, data on last employers and work carried out, special projects, etc.) ,
d.    Language skills,
e.    If applicable whether you possess a permit for working and/or reside in the European Economic Area (EEA) ,
f.    Any other personal information that you decide to share with Sappi,
g.    Any information automatically collected when visiting the Career Portal (such as the data about pages you visit, your computer IP address, device identifiers, your location, mobile network information, standard web log data, etc.).

Please note that you are not obliged to provide us with these data, but not doing so might adversely affect your chances of recruitment. 

4.    Who will have access to my personal data ?

Sappi’s responsible Human Resources Business Partner (“HR Business Partner”) as well as the respective Hiring Manager will have access to your personal data on a strict “need-to-know” basis for the purposes described under 2. Your personal data may also be shared with or transferred to Sappi’s external IT services providers.

5.    Will my personal data be transferred outside my country of residence ?

You are defining what Sappi is allowed to do with your personal data when creating your profile within the Career Portal. You can choose to make your profile visible to:

-    “Any Sappi entity worldwide”: this means that all HR Business Partners at Sappi worldwide will have access to your personal data.
-    “Any Sappi entity in my country of residence”: this means that all HR Business Partners in your country of residence will have access to your personal data.
-    “Only recruiters managing jobs I apply to”: this means that only the HR Business Partner managing your effective application to a vacancy will have access to your personal profile information. 

The above possibly entails that a Sappi affiliate of the Sappi Ltd. group² of companies located in a third country outside the EEA such as Sappi’s group headquarters in South Africa may require access to, store and process your personal data. To transfer your personal data in full compliance with the EU data protection principles, Sappi has implemented appropriate internal safeguards³. Additionally, as mentioned above, you decide at all times what we can do with your personal data, meaning you can at any time change the visibility parameters of your profile as well as the personal data you provided. By making your profile visible to “Any Sappi entity worldwide”, you expressly consent to the transfer of your personal data to South Africa and other non-EU entities. 

6.    Will Sappi decide on my application solely based on automated processing ?

No, Sappi does not base its decision whether or not to employ you solely on automated processing of your personal data. However, the Career Portal uses certain semi-automated processing in the form of specific questions if these are necessary to evaluate your skills which are required for a certain position, for example your language skills. It is nevertheless the Sappi contact person in charge who reviews the result of these questions. Additionally, you are at all times able to express your point of view, to obtain further explanation and to contest a decision.

7.    How long will my personal data be kept ?

When creating an account and setting up your personal profile within the Career Portal, you define which personal data you disclose to Sappi but also what Sappi can do with your personal data (see point 5). Your personal data will subsequently be retained for a maximum period of five (5) years. 

Note that you can at any time request that your personal data is deleted (see below under 7.) or delete your personal data yourself by clicking on the ‘delete’ button within the Career Portal.

8.    Your rights with regard to your personal data. Whom can I contact ?

You have at any time the possibility to contact Sappi should you need any support while applying or managing your personal data. Additionally, you have at any time the right to contact Sappi if you wish to 

-    access, correct or delete your personal data, or 
-    restrict or object the processing and transfer of your personal data, or 
-    withdraw your consent to the processing or transfer of your personal data, or
-    receive your data in order to transmit them to another controller (right to data portability).

Your contact at Sappi:

HR Business Partner. For full contact details please click here.

Supervisory Authority:

Additionally, we need to point out that you have a right to contact or lodge a complaint with the supervisory authority concerned. Depending on your country of residence, please consult the list of supervising authorities at the following link: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm 

9.    Consent

By submitting my application, I confirm having read this Data Protection Notice and hereby give my consent to Sappi 

-    to process my personal data for Potential Recruitment, and understand it may be retained by Sappi for a period of time following my application, and
-    to transfer my personal data within the Sappi Ltd. group of companies (see point 5).

Annex: Controllers and Data Protection Officers within Sappi

¹ Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation), OJ L 119, 4.5.2016, p. 1–88, available at http://eur-lex.europa.eu/eli/reg/2016/679/oj

² www.sappi.com

³ under the form of the “Standard contractual clauses for the transfer of personal data from the Community to third countries (controller to controller transfers)”, Commission Decision C(2004)5721.

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