Privacy Policy

Effective as of January 1, 2020.

Introduction

Bunzl Distribution USA, LLC, together with its subsidiaries and affiliates that link to this Privacy Policy (“collectively, “Bunzl,” “we,” “our,” or “us”), respects the privacy of your information. This Privacy Policy is designed to assist you in understanding how we collect, use and safeguard the information you provide to us in using our websites (the “Sites”) and the services provided through our Sites (collectively referred to as the “Services”).

From time to time, we may change this Privacy Policy. If we do, we will post an amended version on this webpage. Please review this Privacy Policy periodically. Your continued use of the Site and Services after any such amendment signifies your acceptance thereof.

Collecting and Using Information

Personally Identifiable Information We Collect Online

Through your use of the Sites and Services, we may collect Personally Identifiable Information from you. “Personally Identifiable Information” is individually identifiable information about an individual consumer that we collect online and that we maintain in an accessible form. We collect the following types of Personally Identifiable Information:

Information You Provide

We may collect the following Personally Identifiable Information that you voluntarily provide to us:

        • Customer Account. If you create an account for any of our Services, you will provide us with your first and last name, email address, and password, and may provide us with your phone number and residential address. When you log-in to your account, you will provide us with your username or email and password.
        • Email Sign-Up. When you sign up for email promotions, you will provide us with your email address.
        • Request a Catalog. When you request a catalog be shipped to you, you will provide us with your first and last name, email address, phone number, and shipping address.
        • When you apply for a position with Bunzl, we will collect your first and last name, email address, and phone number. You may also be asked to provide other information, such as your residential address, or application materials, such as your resume and cover letter, and provide employment-related information (e.g., prior job history, desired compensation and start date).
        • Live Chat. When you choose to chat with us on our Sites, we may collect your email address and any Personally Identifiable Information that you may voluntarily provide.
        • Make a Purchase. When you make a purchase, we will collect your first and last name, email address, billing and shipping address, and phone number. We use payment processors to process your credit card transactions. Please see “Third-Party Processors” for more information.
        • Contact Us. When you send us any feedback, questions, comments, suggestions, ideas, or interact with our Sites or Services in any way, including through email or social media channels, we may receive your first and last name, email address, phone number, physical address and any other Personally Identifiable Information that you may voluntarily provide.

Information as You Navigate Our Sites

We may automatically collect certain Personally Identifiable Information through your use of the Sites and Services, such as the following:

        • Usage Information. We collect information such as which of the pages on the Sites you access, the frequency of access, and what you click on while on the Sites.
        • Device Information. We collect information about the device you are using, such as hardware model, operating system, application version number, and browser.
        • Mobile Device Information. In addition to the Device Information listed above, when you access our Sites via a browser on your mobile device, we collect and aggregate information about whether you are accessing the Sites via a mobile device or tablet, device type, and carrier.
        • Location Information. We collect location information from Sites visitors on a city-regional basis.

Third-Party Information

In some cases, we may receive certain Personally Identifiable Information from you about a third party. For example, as part of our job application registration process, you may provide the name, email address, and phone number of a third party. If you submit any Personally Identifiable Information about another individual to us, you are responsible for making sure that you have the authority to do so and to allow us to use their Personally Identifiable Information in accordance with this Privacy Policy.

How We Use Your Personally Identifiable Information

We use the Personally Identifiable Information we collect to provide the Services to you, to improve our Services and Sites, and to protect our legal rights. In addition, we may use the Personally Identifiable Information we collect to:

        • Process your account registration;
        • Remember your preferences (e.g., browsing language, account login information)
        • Process and fulfill purchases;
        • Review your job application;
        • Contact you regarding our products and services that we feel may be of interest to you;
        • Communicate with you about our Sites or Services or to inform you of any changes to our Sites or Services;
        • Provide support;
        • Maintain and improve our Sites and Services;
        • Defend our legal rights and the rights of others;
        • Efficiently maintain our business; and
        • Comply with applicable law.

We may use your Personal Information for any lawful purpose without a duty of accounting to you.

To the extent that we collect, extract, compile, synthesize, and analyze non-personally identifiable data or information resulting from your access to the Sites, the data and information will be solely owned by us, and we may use it for any lawful business purpose without a duty of accounting to you, provided that the data and information is used only in an aggregated form, without directly identifying you, any user or customer, or any other entity or natural person as the source thereof.

How We Share Your Personally Identifiable Information

We may share the information that we collect about you in the following ways:

        • With Bunzl’s affiliates and other companies worldwide;
        • With service providers who perform data services on our behalf (e.g., email, hosting, maintenance, backup, analysis, processing payments, fulfilling orders, delivering packages, etc.). Any such service providers will be under an obligation to us to maintain the confidentiality of your Personally Identifiable Information;
        • To service providers to prepare, deploy and analyze advertising content;
        • To the extent that we are required to do so by law;
        • In connection with any legal proceedings or prospective legal proceedings;
        • To establish, exercise, or defend our legal rights, including providing information to others for the purposes of fraud prevention;
        • To any person who we reasonably believe may apply to a court or other competent authority for disclosure of that Personally Identifiable Information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that Personal Information;
        • To any other person or entity as part of any business or asset sale; and
        • To any other person or entity where you consent to the disclosure.

Cookies and Other Tracking Technologies

We use cookies and other tracking technologies (such as pixels and web beacons) (collectively, “Cookies”). “Cookies” are small files of information that are stored by your web browser software on your computer hard drive, mobile or other devices (e.g., smartphones or tablets).

We use Cookies to:

        • Estimate audience size and usage patterns;
        • Understand and save your preferences for future visits, allowing us to customize the Sites and Services to your individual needs;
        • Advertise new content and services that relate to your interests;
        • Keep track of advertisements and search engine results;
        • Compile aggregate data about site traffic and site interactions to resolve issues and offer better site experiences and tools in the future; and
        • Recognize when you return to the Sites.

We may set some Cookies ourselves and others are set by service providers. We use Cookies set by service providers to provide us with useful information to help us improve our Sites and Services, to conduct advertising, and to analyze the effectiveness of advertising.

Cookies can be blocked by changing your Internet browser settings to refuse all or some Cookies. If you choose to block all Cookies (including essential Cookies) you may not be able to access all or parts of the Sites.

You can find out more about Cookies and how to manage them by visiting www.AboutCookies.org.

You can understand which third parties have currently enabled Cookies for your browser or mobile device and how to opt-out of some of those Cookies by accessing the Network Advertising Initiative’s website or the Digital Advertising Alliance’s website. For more information on mobile specific opt-out choices, visit the Network Advertising Initiative’s Mobile Choices website.

Third-Party Processors

To ensure that your Personally Identifiable Information receives an adequate level of protection, we have put in place appropriate procedures with the service providers we share your Personally Identifiable Information with to ensure that your Personally Identifiable Information is treated by those service providers in a way that is consistent with and which respects the applicable laws on data security and privacy. For example, if you use our Sites to purchase goods or products, we will use a third-party payment processor to process the transaction. We do not collect or receive the information provided to payment processors. As such, the collection and use of your financial data is governed by the terms of use and privacy policies of the third-party payment processor. We use Payeezy, and you can find their privacy policy here: https://www.firstdata.com/en_us/privacy.html.

Google Analytics

We use Google Analytics, a web analytics service provided by Google, Inc. Google Analytics uses Cookies or other tracking technologies to help us analyze how users interact with the Site and Services, compile reports on their activity, and provide other services related to their activity and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a returning visitor, and any referring website. The technologies used by Google Analytics do not gather information that personally identifies you. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies. To learn more about Google’s partner services and to learn how to opt-out of tracking of analytics by Google, click here.

“Do Not Track” Signals

Some internet browsers incorporate a “Do Not Track” feature that signals to websites you visit that you do not want to have your online activity tracked. Given that there is not a uniform way that browsers communicate the “Do Not Track” signal, the Sites does not currently interpret, respond to or alter its practices when it receives “Do Not Track” signals.

Choices About Your Personally Identifiable Information

Review and Request Changes to Your Personally Identifiable Information

You may use your account to access, correct, or view certain Personally Identifiable Information we have collected and which is associated with your account. To review or request changes to any of your Personally Identifiable Information, please contact customer service by telephone at 1-800-630-1823 or email us at privacy@bunzlnalegal.com.

Marketing Communications

To unsubscribe from emails from us, please click the unsubscribe link included in the footer of our emails. You also may submit a request to us at privacy@bunzlnalegal.com.

Security

We maintain commercially reasonable security measures to protect the Personally Identifiable Information we collect and store from loss, misuse, destruction, or unauthorized access. However, no security measure or modality of data transmission over the Internet is 100% secure. Although we strive to use commercially acceptable means to protect your Personally Identifiable Information, we cannot guarantee absolute security.

Third-Party Links

The Sites and Services may contain links that will let you leave the Sites and Services and access another website. Some of the linked websites are not under our control. Except as stated below, this Privacy Policy applies solely to Personally Identifiable Information that is acquired on these Sites and Services. We accept no responsibility or liability for these other websites.

Children’s Privacy

The Sites and Services are not intended for children under 18 years of age. By using our Sites and Services, you represent that you are 18 years of age or older. In compliance with the Children’s Online Privacy Protection Act, 15 U.S.C., §§ 6501-06 and 16 C.F.R., §§ 312.1-312.12, we do not knowingly collect, use, or disclose personal information from children under 13.

Notice to Nevada Residents

Nevada law allows Nevada residents to opt-out of the sale of certain types of personal information. Subject to a number of exceptions, Nevada law defines “sale” to mean the exchange of certain types of personal information for monetary consideration to a person for the person to license or sell the information to additional persons. We do not currently sell personal information as defined in the Nevada law. However, if you are a Nevada resident, you still may submit a verified request to opt-out of sales and we will record your instructions and incorporate them in the future if our policy changes. Opt-out requests may be sent to privacy@bunzlnalegal.com.

Notice to California Residents

The California Consumer Privacy Act (CCPA) requires that we provide California residents with a privacy policy that contains a comprehensive description of our online and offline practices regarding the collection, use, disclosure, and sale of personal information and of the rights of California residents regarding their personal information.

The CCPA defines “personal information” to mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal information does not include information that is publicly available, deidentified or aggregate information. For purposes of this “Notice to California Residents” section we will refer to this information as “Personal Information.”

Right to Know About Personal Information Collected, Disclosed, or Sold

Your Right

If you are a California resident, you have the right to request that we disclose what Personal Information we have collected about you in the 12-month period preceding your request. This right includes the right to request any or all of the following:

        • Specific pieces of Personal Information that we have collected about you;
        • Categories of Personal Information we have collected about you;
        • Categories of sources from which the Personal Information was collected;
        • Categories of Personal Information that we sold (if applicable) or disclosed for a business purpose about you;
        • Categories of third parties to whom the Personal Information was sold (if applicable) or disclosed for a business purpose; and
        • The business or commercial purpose for collecting or, if applicable, selling Personal Information.

The CCPA defines “sell” to mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a California resident’s Personal Information to another business or a third party for monetary or other valuable consideration.

How to Submit a Request to Know

You may submit a request to know by completing our online request form available https://www.bunzlnalegal.com/request-to-know/, emailing us at privacy@bunzlnalegal.com, or by calling us at 1-800-630-1823.

Our Process for Verifying a Request to Know

If we determine that your request is subject to an exemption, we will notify you of our determination. If we determine that your request is not subject to an exemption, we will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request. Our verification process may differ depending on whether you maintain a password-protected account with us.

If you maintain a password-protected account, we may verify your identity through existing authentication practices available through your account. Prior to disclosing the requested information, we will ask you to re-authenticate yourself with respect to that account.

If you do not maintain a password-protected account, or if you are an account-holder but we suspect fraudulent or malicious activity with your account, we will verify your identity as follows:

Request to Know Categories of Personal Information: We will verify your identity to a “reasonable degree of certainty” by verifying at least two data points that you previously provided to us and which we have determined to be reliable for the purpose of verifying identities.

Request to Know Specific Pieces of Personal Information: We will verify your identity to a “reasonably high degree of certainty” by verifying at least three pieces of Personal Information previously provided to us and which we have determined to be reliable for the purpose of verifying identities. In addition, you will be required to submit a signed declaration under penalty of perjury stating that you are the individual whose Personal Information is being requested.

Collection of Personal Information

The following table presents the categories of Personal Information that we may have collected, the categories of sources from which that information was collected, and the categories of third parties with whom we may have shared that Personal Information for the 12 months preceding the Effective Date of this Privacy Policy.

The CCPA defines “business purposes” to mean:

        • Auditing related to a current interaction with the consumer and concurrent transaction, including, but not limited to, counting ad impressions to unique visitors;
        • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
        • Debugging to identify and repair errors that impair existing intended functionality;
        • Short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction;
        • Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services;
        • Undertaking internal research for technological development and demonstration; and
        • Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device.

The CCPA defines “commercial purposes” to mean “to advance a person’s commercial or economic interests, such as by inducing another person to buy, rent, lease, join, subscribe to, provide, or exchange products, goods, property, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction.”

Categories of Personal Information Collected Categories of Sources from which Personal Information was Collected Business or Commercial Purpose for the Collection Categories of Third Parties with whom We Share Personal Information
Name

– Consumer

– Service providers

– Providing customer service

– Verifying customer information

– Sales Inquiries

–  Data analytics provider

– Sales and Distribution Partners

Email Address

– Consumer

– Service providers

– Providing customer service

– Verifying customer information

– Providing advertising or marketing services

– Sales Inquiries

– Data analytics provider

– Sales and Distribution Partners

Postal Address

– Consumer

– Third party (e.g. postal service)

– Providing customer service

– Verifying customer information

– Sales Inquiries

– Data analytics provider

– Sales and Distribution Partners

Telephone Number

– Consumer

– Service providers

– Providing customer service

– Verifying customer information

– Sales Inquiries

– Data analytics provider

– Sales and Distribution Partners

Other Online Identifiers – Social Media Accounts – Consumer

–  Providing customer service

– Verifying customer information

– Providing analytic services

Cookies, beacons, pixel tags, or other similar technology – Consumer

– Providing customer service

– Providing advertising or marketing services

– Data analytics provider

*Please see “Cookies and Other Tracking Technologies” section above for more information as to our use of cookies.

Internet protocol address – Consumer

– Providing analytic services

– Providing customer service

Browsing history – Consumer

– Providing analytic services

– Providing customer service

Geolocation data – Consumer

– Providing analytic services

– Providing customer service

Information regarding consumer’s interaction with website, application or advertisement –  Consumer

– Providing analytic services

– Providing customer service

Search history – Consumer

– Providing analytic services

– Providing customer service

Records of products purchased, obtained or considered, purchasing histories, search history browsing history – Consumer

– Processing or fulfilling orders and transactions

– Providing customer Service

– Sales Inquiries

– Providing analytic services

Disclosure or Sale of Personal Information

We do not believe we have sold any Personal Information to third parties for the 12 months preceding the Effective Date of this Privacy Policy.

The following is a list of categories of Personal Information that we may have disclosed for a business purpose in the 12 months preceding the Effective Date of this Privacy Policy:

        • Name
        • Email address
        • Postal address
        • Telephone number
        • Other Online Identifiers – Social Media Accounts
        • Cookies, beacons, pixel tags, or other similar technology
        • Internet protocol address
        • Browsing history
        • Geolocation data
        • Information regarding consumer’s interaction with website, application or advertisement
        • Search history
        • Records of products purchased, obtained or considered, purchasing histories, search history browsing history

We do not sell the Personal Information of minors under 16 years of age without affirmative authorization.

Right to Request Deletion of Personal Information

Your Right

If you are a California resident, you have the right to request that we delete the Personal Information about you that we have collected or maintain. However, a business is not required to comply with a request to delete if it is necessary for the business to maintain the Personal Information in order to, for example, complete a transaction, detect security incidents, comply with a legal obligation, or otherwise use the Personal Information, internally, in a lawful manner that is compatible with the context in which the consumer provided the information.

How to Submit a Request to Delete

You may submit a request to delete by completing our online request form available https://www.bunzlnalegal.com/request-to-delete, emailing us at privacy@bunzlnalegal.com, or by calling us at 1-800-630-1823.

Our Process for Verifying a Request

If we determine that your request is subject to an exemption, we will notify you of our determination. If we determine that your request is not subject to an exemption, we will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request. Our verification process may differ depending on whether you maintain a password-protected account with us.

If you maintain a password-protected account, we may verify your identity through existing authentication practices available through your account. Prior to deleting the Personal Information, we will ask you to re-authenticate yourself with respect to that account. If you submit a request to delete and you have an active customer account, we may not delete any information required to maintain the “active” account (e.g., your name, login credentials, email address, phone number, or shipping address) unless you expressly opt to close the account.

If you do not maintain a password-protected account, or if you are an account-holder but we suspect fraudulent or malicious activity with your account, we will verify your identity either to a “reasonable degree of certainty” or a “reasonably high degree of certainty” depending on the sensitivity of the Personal Information and the risk of harm to you by unauthorized deletion.

We will verify your identity to a “reasonable degree of certainty” by verifying at least two data points that you previously provided to us and which we have determined to be reliable for the purpose of verifying identities.

We will verify your identity to a “reasonably high degree of certainty” by verifying at least three pieces of Personal Information previously provided to us and which we have determined to be reliable the purpose of verifying identities. In addition, you will be required to submit a signed declaration under penalty of perjury stating that you are the individual whose Personal Information is being requested.

If we are unable to verify your identity to the applicable standard, we will treat your request to delete as a request to opt-out of the sale of the personal information that you provided as part of processing the request to delete. See the following section for a description of the right to opt-out of the sale of personal information.

Notice of Right to Opt-Out of Sale of Personal Information

Your Right

If you are a California resident, you have the right to direct a business that sells (or may in the future sell) your Personal Information to stop selling your Personal Information and to refrain from doing so in the future.

The CCPA defines “sell” to mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a California resident’s Personal Information to another business or a third party for monetary or other valuable consideration.

How to Submit a Request to Opt-Out

You may submit a request to opt-out by completing our online request form available https://www.bunzlnalegal.com/request-to-opt-out-of-sales/, emailing us at privacy@bunzlnalegal.com, or by calling us at 1-800-630-1823.

How We Process a Request to Opt-Out

We will act upon your request to opt-out within 15 days from the date that you submit the request. The CCPA does not require that we verify the identity of individuals who submit requests to opt-out of sales. However, we may deny the request if we have a good-faith, reasonable, and documented belief that the request is fraudulent. If we deny the request on this basis, we will notify the requesting party and provide an explanation why we believe the request is fraudulent.

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

We will not discriminate against California residents if they exercise any of the rights provided in the CCPA as described in this section “Notice to California Residents.” As such, we will not deny goods or services to that California resident; charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; provide a different level or quality of goods or services to the California resident; or suggest that the California resident will receive a different price or rate for goods or services or a different level or quality of goods or services. However, we are permitted to charge a California resident a different price or rate, or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to us by the individual’s data.

Authorized Agents

California residents may use an authorized agent to submit a request to know, delete, or opt-out of sales on your behalf.

If you use an authorized agent to submit a request to know or request to delete, we may require that (1) the authorized agent provide proof of your written permission and (2) you verify your identity directly with us. These requirements do not apply if you have provided the authorized agent with a power of attorney pursuant to California Probate Code sections 4000 to 4465.

If you use an authorized agent to submit a request to opt-out of sales, you will need to provide that authorized agent with written permission to do so and submit written proof to us that the agent has been authorized to act on your behalf.

Shine the Light Law

If you are a California resident, California Civil Code § 1798.83 permits you to request information regarding the disclosure of your personal information by us to third parties for the third-parties’ direct marketing purposes (as those terms are defined in that statute). To make such a request, please send an email to privacy@bunzlnalegal.com.

Accessibility

We are committed to ensuring this Privacy Policy is accessible to individuals with disabilities. If you wish to access this Privacy Policy in an alternative format, please contact us as described below.

How to Contact Us

To contact us for questions or concerns about our privacy policies or practices please contact us via any of the following methods:

In writing:

Bunzl Distribution USA, LLC

One CityPlace Drive, Suite 200

St. Louis, MO 63141

By phone: 1-800-630-1823.

By email: privacy@bunzlnalegal.com