PRIVACY POLICY

Last updated January 1, 2024

 

The privacy notice for Aaron Thomas Company, inc (“we,” “us,” or “our”), describes how and why we might collect, store, use, and/or share (“process”) your information when you use our services (“Services”), such as when you:

 

Visit our website at http://www.atcouniveristy.com

 

Questions or concerns? Reading this policy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do no use our services. If you still have any questions or concerns, please contact us at HR@packaging.com.

 

SUMMARY OF KEY POINTS

 

This summary provides key points from our privacy notice.

 

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices that you make, and the features and training you use.

 

Do we process any sensitive personal information? We do not process sensitive personal information.

 

Do we receive any information from third parties? We may receive information form public databases, marketing partners, social media platforms, and other outside sources.

 

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you for security and fraud prevention, to track completion of training courses, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.

 

In what situations and with which parties do you share personal information? We may share information in specific situations and with specific third parties.

 

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.

 

How do you exercise your rights? The easiest way to exercise your rights is by contacting us. We will consider and act upon any request in accordance with applicable date protection laws.

 

Want to learn more about what we do with any information we collect? Review the privacy notice in full.

 

1. WHAT INFORMATION DO WE COLLECT?

 

Personal information you disclose to us

 

In Short: We collect personal information that you provide to us.

 

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

 

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the training and features you use. The personal information we collect may include the following:

 

Names, Email Addresses, Job Titles

 

Sensitive Information. We do not process sensitive information.

 

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

 

Information collected from other sources

 

In Short: We may collect limited data from public databases, marketing partners, and other outside sources.

 

In order to enhance our ability to provide relevant marketing, offers, and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, and from other third parties. This information include mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data,) Internet Protocol (IP) addresses, social media profiles, social media URL’s, and custom profiles, for purposes of targeted advertising and event promotion.

 

2. HOW DO WE PROCESS YOUR INFORMATION?

 

In Short: We process your information to provide, improve, and administer our Services, communicate with you for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

 

We process your personal information for a variety of reasons, depending on how you interact with our services, including:

 

To send administrative information to you. We may process your information to send you details about our training and services, changes to your terms and policies, and other similar information.

 

To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.

 

3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

 

In Short: We may share information in specific situations described in this section and/or with the following third parties.

 

We may need to share your personal information in the following situation:

 

Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

 

4. HOW LONG DO WE KEEP YOUR INFORMATION?

 

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

 

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

 

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it form any further processing until deletion is possible.

 

5. DO WE COLLECT INFORMATION FROM MINORS?

 

In Short: We do not knowingly collect data from or market to children under age 18 years of age.

 

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guarding of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take responsable measures to promptly delete such data from our records. If you become aware we may have collected from children under age 18, please contact us at HR@packaging.com.

 

6. WHAT ARE YOUR PRIVACY RIGHTS?

 

In Short: You may review, change, or terminate your account at any time.

 

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by suing the contact details provided in the section, “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” Below.

 

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

 

If you have questions or comments about your privacy rights, you may email us at HR@packaging.com.

 

7. CONTROLS FOR DO-NO-TRACK FEATURES

 

Most web browsers and some mobile operations systems and mobile applications include a Do-Not-Track (“DNT”) features or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitores and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

 

8. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

 

In Short: If you are a resident of California, you are granted specific rights regarding access to your personal information.

 

What categories of personal information do we collect?

 

We have collected the following categories of personal information in the past (12) months:

 

Category:

Examples:

Collected:

​

A. Identifiers

Contact details, such as real name, alias, postal address, telephone or mobile contact number, uniques personal identifier, Internet Protocol address, email address, and account name

NO

​

B. Personal Information as defined in the California Customer Records statue

Name, contact information, education, employment, employment history, and financial information

NO

​

C. Protected classification characteristics under state or federal law

Gender and date of birth

NO

​

D. Commercial Information

Transaction information, purchase history, financial details, and payment information

NO

​

E. Biometric Information

Fingerprints and voiceprints

NO

​

F. Internet or other similar network activity

Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements

NO

​

G. Geolocation data

Device location

NO

​

H. Audio, electronic, visual, thermal, olfactory, or similar information

Images and audio, video or call recording created in connection with our business activies

NO

​

I. Professional or employment-related information

Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us

NO

​

J. Education Information

Student records and directory information

NO

​

K. Inferences drawn from collected personal information

Inferences drawn from any of the collected personal information above to create a profile or summary about, for example, a individual’s preferences and characteristics

NO

​

L. Sensitive personal information

 

NO

​

We have use your personal information for our own business purposes, such as for undertaking internal research for technology development and demonstration, and/or to track completion of training courses. This is not considered to be “selling” of your personal information.

 

We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We will not sell or share personal information in the future belonging to website visitors, users, and other consumers.

 

California Residents

 

California Civil Code Section 1798.83, also known as the “Shine the Light” law permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to su using the contact information provided below.

 

If you are under 18 years of age, reside in California, and have a registered account with the Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed form all our systems (e.g., backups etc.).

 

CCPA Privacy Notice

 

This section applies only to California residents. Under the California Consumer Privacy Act (CCPA), you have the rights listed below.

 

The California Code of Regulations defines a “residents” as:

 

(1) every individual who is in the State of California for other than a temporary or transitory purpose and

(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose

 

All other individuals are defined as “non-residents.”

 

If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information.

 

Your rights with respect to your personal data

 

Right to request deletion of the data — Request to delete

 

You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting fro a legal obligation, or any processing that may be required to protect against illegal activities.

 

Right to be informed — Request to know

 

Depending on the circumstances, you have a right to know:

 

whether we collect and use your personal information;

the categories of personal information we collects;

the purposes for which the collected personal information is used;

whether we sell or share personal information the third parties;

the categories of personal information that we sold, shared, or disclosed for a business purpose;

the categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose;

the business or commercial purpose for collecting, selling, or sharing personal information; and

the specific pieces of personal information we collected about you.

 

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to very consumer request.

 

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

 

We will not discriminate against you if you exercise your privacy rights.

 

Right to Limit Use and Disclosure of Sensitive Personal Information

 

We do not process consumer’s sensitive personal information.

 

Verification process

 

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we can contact you through a communication method (e.g., phone or email) that you have previously provided to us. WE may also use other verification methods as the circumstances dictate.

 

We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purpose of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud prevention purposes. We will delete such additional provided information as soon as we finish verifying you.

 

Other privacy rights

 

You may object to the processing of your personal information.

You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing information.

You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.

You may request to opt out from future selling or sharing of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission.

 

To exercise these rights, you can contact us by submitting a data subject request, by email at HR@packaging.com, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.

 

9. DO WE MAKE UPDATES TO THIS NOTICES?

 

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

 

We may update this privacy notice form time to time. The updated version will be indicated by an “Last Updated” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

 

10. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

 

If you have questions of comments about this notice, you may email us at HR@packaging.com or contact us by post at:

 

Aaron Thomas Company, Inc.

7421 Chapman Avenue

Garden Grove, CA 9281

United States

 

11. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

 

Based on the applicable laws of your country and state, you may have the right to request access to the personal information we collect from you, change the information, or delete it. To request to review, update, or delete your personal information, please submit a request.