1.  About us

We are Silgan Closures GmbH. To find out how to contact us, head to section 10.

2. Your privacy

Data protection is all about trust and your trust is important to us. We respect your privacy. Insofar as we collect and process your personal data when you access our websites, we do so strictly in accordance with all applicable privacy and data protection laws and regulations, including the EU General Data Protection Regulation (GDPR). Personal data is information which enables us to identify you as an individual, for example your name, your email address or your phone number.

This document provides you with information regarding:

• which personal data we collect from you;

• why we collect this information;

• how this data will be used;

• how long it will be stored for;

• who else will be able to access this data;

• how you can contact us;

• your rights regarding the personal data that we have collected from you,including your rights to have the data rectified, deleted and to access your own data.

When you use our website, we also set cookies on your device – for more information on the cookies we use and how you can change your cookie settings, see [JavaScript Link]. We also embed YouTube videos on our websites. When you play these videos, personal data (such as your IP address and browser data) may be sent to YouTube or the companies behind them. We do not have any influence over this process. You can find more information on this at <https://tinyurl.com/mtw893vj>.

3. Which information do we collect?

We collect the following types of information:

3.1 Anonymous data collection

You can visit our websites without disclosing personal data. We then only store server log files, i.e. access data with which you cannot be identified as an individual. Examples of this type of data include the name of your Internet service provider, the Internet browser you are using, which page of our websites you are visiting, the date and time on which you accessed our websites and the name of the requested file. The sole purpose of this data is to improve our websites; this information cannot be traced back to you as an individual.

This anonymous data will be stored separately from any personal data provided by you and cannot be traced back to a specific person. It shall be used for statistical purposes to optimise our websites and our offers. The temporary storage of data and the use of server log files are governed by Art. 6(1)(f) GDPR. Log files are stored to ensure the functionality of the website. Data collected for a specific purpose shall be deleted as soon as it is no longer required to fulfil this purpose. Data collected for the purpose of providing access to our website shall be deleted once the respective session has been ended.

3.2 Collection and processing of your personal data

Processing of personal data may be necessary insofar as you wish to use one of our services via our website, or the websites of organisations with which we are affiliated. Consent from the data subject shall be obtained insofar as there is no legal basis for the processing of personal data. This shall be explicitly stated at the relevant points. This may be required should you contact us via our contact form, for example. Processing purposes for which we must obtain your consent are governed by Art. 6(1)(a). Processing of personal data necessary for the performance of a contract or for taking steps prior to

entering into a contract (for example, delivering goods or the performance of such services, or inquiries about our products and services) shall be carried out according to Art. 6(1)(b) GDPR.

The following data shall be collected if you browse on our websites, or the websites of organisations with which we are affiliated where our advertising is displayed:

• information about your devices (including manufacturer, model and operating system, IP address, browser type and mobile device ID);

• cookies and information about your browser and purchasing behaviour, the history of your activity on our websites and apps, your location, your product selection and information about when you click on our advertising (including adverts which are displayed on the websites of other organisations);

When you write to us using the contact form, we store the personal data you share with us, such as your name, company, address, email and phone number, and use this data for the purpose of individual communication with you in accordance with the requirements of the GDPR and the German Federal Data Protection Act (BDSG). Please note that generally, no confidential information should be sent via the contact form.

The processing of data sent via email is governed by Art. 6(1)(f) GDPR. Should the email be sent with the intention of entering into a contract, then Art. 6(1)(b) shall also apply for the processing of this data.

4. How do we use your personal data?

Below we outline for which purposes we shall use your personal data. Furthermore, we are legally obliged to state “the basis for the processing”. That means we must inform you for which reasons we are permitted to use your data. The legal basis for every intended purpose is either your consent that your personal data may be used, that we must use your personal data in order to perform a contract with you, or that we require your personal data for our legitimate interests (in which case we shall state what these interests are).

We share the cookies on our website and other data (with companies such as Google, YouTube, Twitter, Instagram and Facebook in order to make our advertising more relevant for you. Further information regarding cookies can be found in our cookie policy (JaveScript link). We oblige these third parties to handle your data confidentially and to adhere to all data protection provisions;

Purpose of processing data:
To inform you about changes to our products and to otherwise communicate with you. For example, we use your contact details to reply to your requests;
Our legal basis:
Legitimate interests – we use your personal data to keep you up to date about our products and to answer your questions.

Purpose of processing data:
To send you information about products, including promotional gifts, special offers and discounts.
Our legal basis:
Legitimate interests – we use your personal data to send you this information. In some cases (for example, when we are legally obliged to do so) we will ask for your consent before we send you this information.

Purpose of processing data:
To review your browsing history on our websites, to present you with special offers or to tailor your experiences online;
Our legal basis:
Legitimate interests – we use your personal data to send you these offers and to tailor your experience when you use our online services.

Purpose of processing data:
To help us review, develop and improve the products we offer.
Our legal basis:
Legitimate interests – we use your personal data to offer you and our other customers the best quality of service.

Purpose of processing data:
To measure and improve the effectiveness of our marketing communication, including online advertising.Sometimes we compare individual pieces of information from you (such as your email address or mobile phone number) with information from third parties who have also stored your personal data or who currently have a relationship with you online in order to identify you as a customer, so that we (or third parties on your behalf) can send you relevant marketing material online. For example, we compare your information with the information that social networking sites such as Twitter, Instagram and Facebook have stored about you so that they can identify you as a Silgan Closures customer and can personalise the Silgan Closures marketing that you receive through their websites or products.
Our legal basis:
Legitimate interests – we use your personal data to offer you a shopping experience that is tailored to you, to gain an understanding of the effectiveness of our marketing and to ensure that you are shown the most relevant adverts for you.

Purpose of processing data:
To facilitate, improve and personalise your experiences with our online services which are made available on our web and mobile portals and applications;
Our legal basis:
Legitimate interests – we use your personal data to offer you a personalised experience when using our digital services.

Purpose of processing data:
To carry out security controls for the protection against fraudulent transactions and for the prevention and detection of criminal activities;
Our legal basis:
Legitimate interests – we use your personal data to protect against unlawful activities. In some cases we may be legally obliged to pass on your personal data (for example, to prosecution authorities).

Purpose of processing data:
In case you file a claim against us.
Our legal basis:
Legitimate interests – we use your personal data to address your claims against us. In some cases we may be legally obliged to disclose your personal data (for example, as part of a judicial procedure).

Our websites and apps are not designed for children and we do not collect any information about children, at least not knowingly.

5. For how long do we store your data?

We are legally obliged to only store your personal data for as long as is required for its intended purposes. The time period for which we store your personal data is defined by a number of criteria, including the purposes for which we use the data, the quantity and sensitivity of data, the potential risk of unauthorized use or disclosure of the data as well as our legal and regulatory obligations.

6. With whom do we share your personal data?

We belong to the Silgan Group, to which the Silgan Closures Corporation as well as [l] also belong (further information about the Silgan Group can be found at: www.silgan.com).

We are entitled to pass on your personal data to third parties including but not limited to the following cases:

• We use third parties to carry out specific activities on our behalf that involve the processing of personal data. For example, we can involve third parties to send emails and SMS, to maintain and update our data bases with customer data (including deletion of repetitive or incorrect information), to analyse data to help us develop, provide and improve our services, to provide marketing support, to process payments and refunds, to conduct surveys, to provide customer services and to deal with claims. These third parties have access to your personal information to perform their functions but are not permitted to use this data for any other purposes. We may use the information that we receive from third parties to improve and build on our customer data base and for purposes such as credit assessment and fraud prevention. · We may pass on information that we have about you (such as email address and information regarding your purchases) to other Silgan Group companies or other third parties on our behalf who are also in possession of your data or who have an existing online relationship with you inorder to identify you and to make relevant marketing material available to you online. For example, we may share information with sites such as Facebook, Instagram, Twitter, YouTube and Google so that they can identify you as our customer and so that they can customise marketing that we send to you through their websites, applications and products.

• We may send your data to third parties to improve the quality and accuracy of our data base, to delete data records of deceased persons and those who have changed address, and to add marketing information, including in connection with credit assessments.

• We may pass your data on to third parties for market research purposes. Some of these may approach you with a request to complete surveys or to get involved in studies which we have commissioned.

• We may send your data to “Google Tag Manager“ (Google Tag Manager is a tag management provider that enables data collected during visits of our website to be used to facilitate functionality, analysis and marketing communication).

• We may pass personal data on to external agencies and organisations (including the police and other prosecution authorities) to prevent and uncover fraud (including fraudulent transactions) and criminal activities. These external agencies may review the information we provide them with by way of public or private data bases and use records of such reviews as part of future safety controls. We may also send personal data to the police and other prosecution authorities for the prevention and discovery of criminal offences.

• We may send personal data to our insurers when a claim is made against us or could be made against us.

• In the event that we sell a company or assets, we may disclose personal data in our possession to potential buyers of such companies or assets. If we or essentially all our assets are acquired by a third party (or become the subject of a restructuring within our company group), the personal data in our possession shall be considered one of the transferred assets.

• We may pass on the personal data which we have obtained from you or from third parties about you (including agreements between you and us (or one or more of our affiliated enterprises)) to third parties should we be obliged to disclose or share your personal data in order to comply with legal obligations or to enforce or apply agreements; or to protect our rights, property and safety, or those of our customers, employees or other third parties.

• We may share anonymous or aggregated data (such as aggregated statistics or anonymous data) with third parties.

7. Links to external sites

We may provide links to the websites of other companies in the Silgan Group on our website or mobile portals and applications. Using these websites is subject to the terms of use and policies available on these websites.

From time to time, we may build relationships with third parties that enable you to access their websites or applications (such as video players) directly from our websites or applications. Every third party has their own policies in regard to the processing of personal data and the use of cookies on their websites or applications. It is recommended that you read the data protection and cookie policies of these third parties.

Please note that we do not have any control over the websites and applications of third parties. When you click on these websites or use these applications, you exit the area controlled by us. We do not accept any responsibility or liability for problems related to the use of your data by third parties (including your personal data).

8. Where is your personal data processed?

Your personal data may be transferred, stored and processed in one or multiple countries outside the European Economic Area (EEA) , including in countries which do not offer the same level of protection for personal data. In these circumstances we will take reasonable steps to ensure that your personal data is appropriately protected in accordance with the legal requirements. In regard to personal data which is stored and processed outside of the EEA, we have ensured through relevant standard contractual clauses that your data is also protected outside of the EU through strict adherence to statutory provisions.

9. Your rights

You have the right to request the following from us:

• confirmation as to which personal data we have stored about you and to receive a copy of this data;

• to have any inaccurate personal data corrected;

• to have your personal data deleted when there is no longer a valid reason for us to continue to store it;

• temporary cessation of the use of your data should you question our right to use this data;

• cessation of the use of your personal data unless we can prove a valid reason for which we must continue to store it, for example, to back up a product warranty;

• cessation of the use of your personal data to send you marketing materials such as our catalogue, marketing emails, discounts or vouchers.

• the making available of your personal data that you have shared with us in a structured and customary electronic format or transfer of this information directly to another company where technically feasible; this applies when we are entitled to use your personal data based on your consent or because it is required to perform a contract with you (see “How we use your personal data” above).

Our security procedures provide that we may request proof of identity before sending you your personal data or before other requests can be met.

We wish to ensure that the personal data we have obtained about you and your preferences regarding how we should contact you are correct and up-to-date. Should one of the entries be incorrect, please inform us of this (see details below) and we shall update them.

You also have the right to file a complaint with the relevant data protection supervisory authorities if you are dissatisfied with how we handle your personal data. You can contact the supervisory authority at:

• Email: poststelle@lfd.niedersachsen.de

• Correspondence address: Landesbeauftragte für den Datenschutz Niedersachsen (LfD), Postfach 221, 30002 Hannover, Germany

• Phone: +49 511 120 500

• Fax: +49 511 120 4599

• Website: https://lfd.niedersachsen.de/startseite/

10. Who is responsible / how can you contact us?

To update your data or request a copy of your personal data:

• You can write to datenschutz@silgan-closures.de or Silgan White Cap Manufacturing GmbH, Hansastraße 4, 30419 Hannover, Germany.

• You can contact the data protection officer using the following email address: datenschutz@silgan-closures.de

11. Protecting your personal data

Transferring information online is not completely secure; this risk applies to the Internet as a whole and not specifically to our web shop and the associated services. We are unable to guarantee the complete security of the data you share with us (including personal data), and you carry out each data transmission at your own risk.

It is important that you protect your password and computer against unauthorised access. Make sure you log out and close your browser once you finish a session. That will ensure that others cannot access your personal data when you use a shared computer or a computer in a public space such as a library or internet café.

12. Updates to this policy

We may update this policy from time to time. The most recent version of this privacy policy shall be published on our website.