U.S. Safe Harbor Statement

Signode Industrial Group LLC, a Delaware limited liability company, is part of Signode Industrial Group’s companies incorporated in the USA (“SIG U.S.”), and SIG U.S. adheres to the U.S.-EU and U.S.-Swiss Safe Harbor Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal data from the European Union, including from our employees. Accordingly, we follow the Safe Harbor Principles published by the U.S. Department of Commerce (the “Principles”) with respect to all such data.  This statement outlines our general practices and describes how we gather and use information and the notice and choice individuals have regarding our use of and their ability to correct their information.  More information about the Safe Harbor Frameworks may be found at http://export.gov/safeharbor/.

Safe Harbor Principles

Notice. When we collect your personal information, we’ll give you timely and appropriate notice describing what personal information we’re collecting, how we’ll use it, and the types of third parties with whom we may share it.

Choice. We will give you choices about the ways we use and share your personal information, and we’ll respect the choices you make.

Onward Transfers (sharing with third-parties).  Except as described in this policy, we won’t share your personal information with third parties without your consent.  If we transfer your personal information to another country, we’ll take appropriate measures to protect your privacy and the personal information we transfer.

Access.  We allow an individual access to their personal information and allow the individual to correct, amend or delete inaccurate information, except where the burden or expense of providing access would be disproportionate to the risks to the privacy of the individual in the case in question or where the rights of persons other than the individual would be violated.

Security. We take reasonable steps to protect information from loss, misuse and unauthorized access, disclosure, alteration and destruction. We have put in place appropriate physical, electronic and managerial procedures to safeguard and secure information from loss, misuse, unauthorized access or disclosure, alteration or destruction.

Integrity. We will only process personal information in a way that is compatible with and relevant for the purpose for which it was collected or authorized by the individual. To the extent necessary for those purposes, we will take reasonable steps to ensure that personal information is accurate, complete, current and reliable for its intended use.

Enforcement. We use a self-assessment approach to assure compliance with this privacy policy and periodically verify that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible and in conformity with the Principles. We encourage interested persons to raise any concerns using the contact information provided and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of personal information in accordance with the Principles.

If a complaint or dispute cannot be resolved through our internal process, we agree to dispute resolution using (an independent resource mechanism) as a third party resolution provider.

Questions

If you have any questions, comments or concerns related to our U.S. Safe Harbor Commitment, or our practices, please contact us at Privacy@Signode.com.