This Privacy Policy sets out how we, The Food and Beverage Carton Alliance (FBCA) collect, store and use your personal data (i.e. information that relates to you) when you use or interact with our website,  www.fbcaglobal.com  (our website) and where we otherwise obtain or collect information about you. This Privacy Policy is effective from 20 January 2025.

FBCA  processes your personal data in accordance with the applicable data protection legislation in force, and, in particular, Regulation 2016/679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data and the free movement of such data (“GDPR”).

Access to the website www.fbcaglobal.com implies the User’s full and unreserved acceptance of this Privacy Policy, as well as its general terms of use and the cookie policy.

Summary

This section summarises how we obtain, store and use information about you. It is intended to provide a very general overview only. It is not complete in and of itself and it must be read in conjunction with the corresponding full sections of this Privacy Policy.

  • Personal data controller:  The Food and Beverage Carton Alliance (FBCA)
  • How we collect or obtain information about you:
    • when you provide it to us by contacting us via e-mail, via our website or by signing up for our press releases ;
    • from your use of our website,
    • from cookies ;
  • Information we collect:
    • Information collected when visiting our website:
      • Your IP address ;
      • information about your computer or device (e.g. device and browser type) ;
      • information about how you use our website (e.g. which pages you have viewed) ;
      • the time when you view them and what you clicked on ;
      • the geographical location from which you accessed our website (based on your IP address) ;
    • Information collected by cookies on our website: please refer to our cookie policy.
    • Information collected via email or contact webform: any information you choose to provide to us;
    • Information collected when registering for our newsletter:
  • your first and last name
  • your email
  • your job title
  • your company
  • your country
  • How we use your information:
    • For our legitimate administrative and business purposes (including e.g. ensuring the security of our website) ;
    • If you have subscribed to our press releases, to send you the press releases ;
    • Where applicable, to fulfil our legal obligations;
  • Disclosure of your information to third parties: to the extent necessary
    • to our service providers ;
    • to fulfil any contracts we enter into with you ;
    • to notify potentially illegal conduct to authorities ;
    • where required by law or pursuant to a decision from judicial or administrative authorities;
    • to preserve our legal interests or enforce our rights ;
  • Your rights in relation to your information
    • to access your information and to receive information about its use
    • to have your information corrected and/or completed
    • to have your information deleted
    • to restrict the use of your information
    • to receive your information in a portable format
    • to object to the use of your information
    • to withdraw your consent to the use of your information
    • to complain to a supervisory authority

Our details

The data controller in respect of our website is The Food and Beverage Carton Alliance (FBCA).

FBCA provides a European platform for beverage carton manufacturers and their paperboard suppliers to benchmark and profile cartons as renewable, recyclable and low-carbon packaging solutions.

FBCA is Registered in Belgium with VAT  BE 0453.905.263.

You can contact the data controller by writing to :

FBCA aisbl
250 Avenue Louise, Box 106
1050 Brussels  
Tel + 32 (0)2 504 07 10
info@fbcsaglobal.com

If you have any questions about this Privacy Policy, please contact the data controller at info@fbcaglobal.com.

Nature of the personal data collected

Information we collect when you visit our website

We collect and use information from website visitors in accordance with this section and the section entitled « Disclosure and additional uses of your information ».

Web server log information : We use a third party server to host our website, named Hetzner,  the privacy policy of which is available here: https://www.hetzner.com/legal/privacy-policy/. Our website server automatically logs the IP address you use to access our website as well as other information about your visit such as :

  • the pages accessed
  • information requested
  • the date and time of the request
  • the source of your access to our website (e.g. the website or URL (link) which referred you to our website)
  • your browser version and operating system

Our server is located in a data centre in Nuremberg, Germany.

We use the information collected via our web server log information for the following legitimate purposes:

  • Use of website server log information for IT security purposes : We collect and store server logs to ensure network and IT security and so that the server and website remain uncompromised. This includes analysing log files to help identify and prevent unauthorised access to our network, the distribution of malicious code, denial of services attacks and other cyber-attacks, by detecting unusual or suspicious activity.

Unless we are investigating suspicious or potential criminal activity, we do not make, nor do we allow, any attempt to identify you from the information collected via server logs.

  • Use of website server log information to analyse website use and improve our website : We use the information collected by our website server logs to analyse how our website users interact with our website and its features. For example, we analyse the number of visits and unique visitors we receive, the time and date of the visit, the location of the visit  and the operating system and browser used.

We use the information gathered from the analysis of this information to improve our website. For example, we use the information gathered to change the information, content and structure of our website and individual pages based according to what users are engaging most with and the duration of time spent on particular pages on our website.

Information collected via cookies

Cookies are data files which are sent from a website to a browser to record information about users for various purposes.

We use cookies on our website, including :

  • essential,
  • functional
  • analytical

For information on the exact cookies we place and how we use said cookies, please see our cookies policy which is available here. You can reject some or all of the cookies via our cookie banner at any time.

Information we collect when you contact us

We collect and use information from individuals who contact us in accordance with this section and the section entitled « Disclosure and additional uses of your information ».

  • Email : When you send an email to the email address displayed on our website we collect your email address and any other information you provide in that email (such as your name, telephone number and the information contained in any signature block in your email).
  • Post : If you contact us by post, we will collect any information you provide to us in any postal communications you send us.

We may use the abovementioned information, as applicable, for our legitimate business interests, (e.g. including answering your queries) or in connection with the execution of an agreement with you.

Information we collect when you interact with our website

We collect and use information from individuals who interact with particular features of our website in accordance with the section entitled « Disclosure and additional uses of your information ».

Information we collect when you subscribe to our newsletter

We collect and use the following information from individuals who subscribe to our newsletter for the purpose of sending the newsletter:

  • your first and last name
  • your email
  • your job title
  • your company
  • your country]

Sensitive Personal Information

‘Sensitive personal information’ is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person’s sex life or sexual orientation.

We do not knowingly or intentionally collect sensitive personal information from individuals, and you must not submit sensitive personal information to us.

If, however, you inadvertently or intentionally transmit sensitive personal information to us, you will be considered to have explicitly consented to us processing that sensitive personal information under Article 9(2)(a) of the GDPR. We will use and process your sensitive personal information for the purposes of deleting it.

Disclosure and additional uses of your information

This section sets out the circumstances in which will disclose information about you to third parties and any additional purposes for which we use your information.

Disclosure of your information to service providers

We use a number of third parties and who process your information for us on our behalf. If you would like further information about the identities of our service providers, please contact us directly by email and we will provide you with such information where you have a legitimate reason for requesting it.

Disclosure of your information to other third parties

We disclose your information to other third parties in specific circumstances based on our legitimate interests, legal obligation or in connection with the execution of a contract, as set out below :

  • To notify potentially illegal conduct to authorities: Indicating possible criminal acts or threats to public security to a competent authority . If we suspect that criminal or potential criminal conduct has been occurred, we will in certain circumstances need to contact an appropriate authority, such as the police. This could be the case, for instance, if we suspect that we fraud or a cyber crime has been committed or if we receive threats or malicious communications towards us or third parties.
  • In connection with the enforcement or potential enforcement our legal rights : We will use your information in connection with the enforcement or potential enforcement of our legal rights, including, for example, sharing information with our lawyers or debt collection agencies if you do not pay amounts owed to us when you are contractually obliged to do so. Our legal rights may be contractual (where we have entered into a contract with you) or non-contractual (such as legal rights that we have under copyright law or tort law).
  • In connection with a legal or potential legal dispute or proceedings : we may need to use your information if we are involved in a dispute with you or a third party for example, either to resolve the dispute or as part of any mediation, arbitration or court resolution or similar process.
  • For ongoing compliance with laws, regulations and other legal requirements : we will use and process your information in order to comply with legal obligations to which we are subject. For example, we may need to disclose your information pursuant to a court order or subpoena if we receive one.
  • Providing information to third parties such as Google Inc. : Google collects information through our use of Google Analytics on our website. Google uses this information, including IP addresses and information from cookies, for a number of purposes, such as improving its Google Analytics service. Information is shared with Google on an aggregated and anonymised basis. To find out more about what information Google collects, how it uses this information and how to control the information sent to Google, please see the following page: https://www.google.com/policies/privacy/partners/. You can opt out of Google Analytics by installing the browser plugin here: https://tools.google.com/dlpage/gaoptout. Information collected by Google Analytics is stored outside the European Economic Area on Google’s servers in the United States of America.

How long we retain your information

This section sets out how long we retain your information. We have set out specific retention periods where possible. Where that has not been possible, we have set out the criteria we use to determine the retention period.

Retention periods

Server log information: we retain information on our server logs for 10 years.  

Correspondence and enquiries: when you make an enquiry or correspond with us for any reason, whether we will retain your information for as long as it takes to respond to and resolve your enquiry, and for 10 years after which point we will delete your information.

Criteria for determining retention periods

In any other circumstances, we will retain your information for no longer than necessary, taking into account the following:

  • the purpose and use of your information both now and in the future (such as whether it is necessary to continue to store that information in order to continue to perform our obligations under a contract with you or to contact you in the future);
  • whether we have any legal obligation to continue to process your information (such as any record-keeping obligations imposed by relevant law or regulation);
  • whether we have any legal basis to continue to process your information (such as your consent);
  • how valuable your information is (both now and in the future);
  • any relevant agreed industry practices on how long information should be retained;
  • the levels of risk, cost and liability involved with us continuing to hold the information;
  • how hard it is to ensure that the information can be kept up to date and accurate; and
  • any relevant surrounding circumstances (such as the nature and status of our relationship with you).

How we secure your information

We take appropriate technical and organisational measures to secure your information and to protect it against unauthorised or unlawful use and accidental loss or destruction, including:

  • only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymised basis wherever possible;
  • using secure servers to store your information
  • verifying the identity of any individual who requests access to information prior to granting them access to information;
  • using Secure Sockets Layer (SSL) software

 Please note that transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means), you do so entirely at your own risk.

We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.

Transfers of your information outside the European Economic Area

All of your information is stored in Belgium. Other than to comply with any legal obligations to which we are subject (compliance with a court order, for example), we do not intend to transfer your information outside the EEA or to an international organisation. In the unlikely event that we are required to transfer your information outside the EEA (or to an international organisation) for such a purpose, we will ensure appropriate safeguards and protections are in place.

Google Analytics

Information collected by Google Analytics (your IP address and actions you take in relation to our website) is transferred outside the EEA and stored on Google’s servers. You can access Google’s privacy policy here: https://www.google.com/policies/privacy/

Country of storage: United States of America.

Safeguard(s) used: Google has self-certified its compliance with the EU-U.S. Data Privacy Framework: https://policies.google.com/privacy/frameworks?hl=en-US. The EU-U.S. Data Privacy Framework constitutes an approved transfer mechanism under Article 45 GDPR. You can access the European Commission decision on the adequacy of the EU-U.S. Data Privacy Framework here: https://commission.europa.eu/document/fa09cbad-dd7d-4684-ae60-be03fcb0fddf_en.

Your rights in relation to your information

Once you have provided your personal data, several rights are recognized under the Data Protection Legislation, which you can in principle exercise free of charge, subject to statutory exceptions. In particular, you have the following rights:

  • Right to withdraw consent: if your personal data is processed on the basis of you consent, you have the right to withdraw your consent at any time you choose and on your own initiative. You can do so by contacting us here : WITHDRAW CONSENT. The withdrawal of your consent will not affect the lawfulness of the collection and processing of your data based on your consent up until the moment where you withdraw your consent.
  • Right to access, review, and rectify your data: you have the right to access, review, and rectify your personal data. You may be entitled to ask us for a copy of your information, to review or correct it if you wish to review or rectify any information like your name or email address. You may exercise those rights here :
    REQUEST INFORMATION, REQUEST RECTIFCATION.
  • Right to erasure: you have the right to erasure of all the personal data processed by as described herein in case it is no longer needed for the purposes for which the personal data was initially collected or processed, in accordance with the Data Protection Legislation. You may exercise this right here : SEND REQUEST.
  • Right to object or restriction of processing: under certain circumstances described in the Data Protection Legislation, you may ask for a restriction of processing or object to the processing of your personal data. You may exercise this right here: SEND A REQUEST.
  • Right to object to processing for direct marketing: where your personal data is processed for direct marketing purposes, you may object to such processing. We do not process personal data automatically.
  • Right to data portability: you have the right to receive the Personal Data processed in a format which is structured, commonly used and machine-readable and to transmit this data to another service provider. You may exercise this right here : SEND REQUEST.

These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping.

For all requests, please include your full name and e-mail address which will help us in their handling. Where you request the exercise of your rights, we are required by law to use all reasonable measures to verify your identity before doing so. These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorised access to your information.

If anything is unclear, please contact us. If you have a complaint about our use of your information, you also have the right to contact the Belgian Data Protection Authority.

Drukpersstraat 35, 1000 Brussels
Tel +32 (0)2 274 48 00
contact@apd-gba.be 

Changes to our Privacy Policy

We update and amend our Privacy Policy from time to time.

Minor changes to our Privacy Policy

Where we make minor changes to our Privacy Policy, we will update our Privacy Policy with a new effective date stated at the beginning of it. Our processing of your information will be governed by the practices set out in that new version of the Privacy Policy from its effective date onwards.

Major changes to our Privacy Policy or the purposes for which we process your information

Where we make major changes to our Privacy Policy or intend to use your information for a new purpose or a different purpose than the purposes for which we originally collected it, we will notify you by email (where possible) or by posting a notice on our website.

We will provide you with the information about the change in question and the purpose and any other relevant information before we use your information for that new purpose.

Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purposes for which we originally collected it.