Data Privacy Policy

GDPR Policy

Plastic Bank is committed to fully comply with the EU’s General Data Protection Regulation (GDPR)

What is Plastic Bank’s policy concerning EU GDPR compliance?

Plastic Bank is committed to fully complying with the EU’s General Data Protection Regulation (GDPR) in all aspects of business. Plastic Bank operates with Data Protection by Design and by Default as a key philosophy, while also maintaining a robust GDPR compliance system and internal data security auditing process.

Plastic Bank is committed to holding the six data protection principles to the highest standards. They are:

• Lawfulness, fairness, and transparency
• Purpose limitation
• Data minimization
• Accuracy
• Storage limitations
• Integrity and confidentiality

Plastic Bank is fully GDPR compliant and takes an extreme compliance approach to meet the strictest standards required by our partners and users based in the EU

• Plastic Bank only uses physical opt-in consent-based data capture for legitimate business reasons.
• The privacy policy is accessible at all data inputs and transparently includes all of the GDPR requirements and reasonings for collecting, storing, and using the data.
• We maintain a robust GDPR compliance system and an internal auditing process. The proper GDPR policies and documentation are in place along with the proper GDPR security and data protection measures. This includes state of the art blockchain encryptions, Hyperledger Fabric smart contracts, IBM server and multi-cloud storage, and a custom-designed resilience system with multiple servers on multiple continents.
• Age of consent is appropriately verified through special tools built into our website and application that automatically adjust the required age based on each user’s country. Our school programs utilize in-app family accounts with the consent of a parental guardian.
• We utilize Data Protection Impact Assessments and Legitimate Interest Assessments to document the risk mitigation steps and reasonings to compliantly collect, store, and utilize the data.
• We maintain an updated GDPR compliant cookie protocol only used to optimize the user experience of new and returning visitors to our website.
• We have a storage limitation and retention period policy to anonymize data after 5 years since the last date of user activity or upon request from a discontinued user.
• Our website and app have features to allow a user to withdraw consent at any time.

Our GDPR Continuous Improvement Routines

• Our Director of Technology, Rob Stocks, has been appointed as Data Protection Officer, to proactively oversee Plastic Bank’s GDPR compliance company-wide.
• A GDPR committee consisting of Rob Stocks (DPO), as well as regional and departmental Compliance Officers, conduct an annual GDPR audit with regular GDPR compliance update meetings.

In effort to continuously maintain and improve our GDPR compliance, Plastic Bank maintains the following documents and policies:

• An Updated Data Privacy Agreement accessible through all data collection points
• Official GDPR Policy
• GDPR Compliance Audit Logs
• Historical Data Privacy Archives
• Updated Cookies Policy
• Data Flow Chart
• Data Asset Registry
• GDPR Meeting Tracker
• Data Security Strategy
• Data Protection by Design Outline
• Age of Consent List and System Tracker
• PIPEDA Breach Reporting Criteria
• (DPO) Data Protection Officer Responsibilities
• Legitimate Interest Assessment Forms
• Data Protection Impact Assessment Forms
• Employee Data Privacy Policy
• Data Subject Access Request Log
• Data Subject Erase Request Log
• Data Processor Compliance Agreement

Data Security & Privacy Policy v2.2

Last Updated: January 8, 2024
This policy explains how our organization uses and protects the personal data we collect from you when you use our website.

Who is collecting my data?

Plastic Bank does, as part of the Plastic Bank Recycling Corporation, which includes our separately incorporated international Plastic Bank operations in Brazil, the Philippines, Indonesia, Brazil, and Egypt.

What data do we collect?

Web Site:
Data collected varies depending on your interaction with the site.

• Name
• Email
• Country
• Address (purchases)
• Phone Number, Company Name (purchases, contact forms)
• Job Title, industry vertical (contact forms)
• Household and lifestyle data (footprint calculator)

App:

For registered members in our mobile application, we require additional information to comply with our code of conduct, audit trail requirements, “know your client” requirements, and various life improvement program qualifications.

• Name, Birthday, Gender, Phone, Email, Country (registration)
• National ID, City, Personal Picture (profile management)
• Address, Business Name, Business Description, Working Hours (create a business or processor)
• Family Member: Name, Birth Date, Relation , Education, School, Phone (community and school programs)
• GPS Location (find nearest partner, create a business or processor, token cash-out) qualifications

How do we collect your data?

You directly provide us with most of the data we collect. We collect data and process data when you:

• Register online or place an order for any of our products or services.
• Voluntarily complete a contact form or customer survey, or provide feedback on any of our forms or via email.
• Use or view our website via your browser’s cookies.
• Use our Plastic Bank app 

How will we use your data?

Within our website platform:

• To process your orders and manage your account.
• To email subscribed users with update newsletters
• To localize the information you see
• To make our programs and impact suggestions relevant to you
• To improve your user experience on our website
• To follow up with prospects who request more information or fill out one of our contact forms

Within our App used in Certified Recycling Ecosystems

• To customize your user experience
• For audit trails
• For benefit programs
• For livelihood enhancement
• For credit scores
• For user impact scores
• For impact claim verification
• To prevent child labour through proof of identity and age of consent
• For verified ethical sourcing and code of conduct compliance 

Data sharing with third party service providers

We may employ services from companies and individuals to help us operate our websites as described in the previous section, and to deliver benefits to members of our recycling ecosystems.

All third parties are required to provide us with an appropriate Data Processing Agreement and take appropriate security measures to protect your data in line with our policies. We do not allow them to use your data for their own purposes. We permit them to process your data only for specified purposes and in accordance with our instructions.

Where your data is shared with third parties, we always seek to share the minimum amount necessary.

Analytics and other third-party tools

We employ third-party tools to monitor and analyze the use of our websites, and to automate certain processes related to the development and operation of our websites.

User Analytics.

• We use Google Analytics to track website traffic. Google Analytics is a web analytics service offered by Google. Google uses the data collected to track and monitor the use of our websites. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network. For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en. We also encourage you to review Google’s policy for safeguarding your data: https://support.google.com/analytics/answer/6004245.
• We use HotJar to give us better insights on how visitors use our pages, navigation, and consume information.

Mailchimp. We use Mailchimp to manage our newsletters. For more information on the privacy practices of Mailchimp, please visit https://mailchimp.com/legal/privacy/, and more specifically the “Privacy for Contacts” section https://mailchimp.com/legal/privacy/#3._Privacy_for_Contacts

Advertising. We use tracking pixels and cookies to share usage information with various advertising and social media platforms including but not limited to Meta, TikTok, and LinkedIn to target website users and track the effectiveness of our marketing efforts.

Customer Relationship Management: We use Salesforce to manage sales enquiries.

Fulfillment

Transaction processing. When we process your order, we may send your data – in conjunction with the resulting information form and location information – to third-party payment processing platforms to exchange funds and prevent fraudulent purchases.

Merchandise delivery. We may share your data with fulfillment partners for delivery of purchases.

Social benefits delivery. We may share your data with third parties including but not limited to the Plastic Bank Foundation to provide social and community benefits to our collection ecosystems.

How do we store & protect your data?

• Shopper profiles and registered Plastic Bank Ambassador data is stored in an encrypted database on our website protected by industry standard firewalls and anti-virus software.
• Newsletter subscriber data is stored and processed by Mailchimp
• Business contacts are stored and processed by Salesforce.
• App user data is stored with our blockchain database in a private cloud.

Plastic Bank and our third party data partners protect your data by following industry standard best practices for maintaining up to date security software on our servers, conducting regular risk assessments, encrypting and securely backing up data.  Our staff are trained on the importance of protecting all personal data and we ensure that our  vendors and partners have similar practices in place.

Plastic Bank will keep your data for a maximum of 5 years from the last date of user activity or upon a verified request for deletion (see below). We may choose to delete some types of data that are no longer required for our operations or to comply with regulations. Any such deletions will be logged.

What are your data protection rights?

We would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

• The right to access & portability – You have the right to request us for copies of your personal data. We may charge you a small fee for this service.
• The right to rectification – You have the right to request that Our Company correct any information you believe is either inaccurate or incomplete.
• The right to restrict data processing and reject automated individual decisions with regards to your data.
• The right to be notified in the event of a breach that might have exposed your data.  Plastic Bank abides by the regulations in all of our operating regions with regards to notification and remediation.

How do I see what data you have about me?

If you are a registered web user, you can login to the site and request your data under Privacy in your Settings.

If you are not a registered web user but have subscribed to our newsletter, submitted a contact form, or registered with our app, you can send your request for your data file to [email protected]

How can I request my data to be corrected?

If you would like us to correct errors in the data we have collected and are not able to do so yourself through the website, app, or other services, please contact us through [email protected]

How can I request my data to be deleted?

If you are a registered web user, you can login to the site and request to have your data deleted in the Privacy section of your Settings.

If you are not a registered user but have subscribed to our newsletter, submitted a contact form, or registered with our app, you can send your request for deletion to [email protected]

Our Cookie Policy

To make this site work properly, we sometimes place small data files called cookies on your device. Most big websites do this too.

What are cookies?

A cookie is a small data file that a website will occasionally save to your device when you visit the site. It allows the website to remember your actions and preference (ie. login, language, display preferences, etc.) over a period of time so that you don’t have to re-enter the data every time you visit or traverse the site.

The cookie-related information is not used to identify you personally and the pattern data is fully under our control. These cookies are not used for any purpose other than those described here.

How do we use cookies?

A number of our pages use cookies to remember:

•  Whether or not you have replied to a pop-up survey that asks you if the content was helpful or not
•  Whether or not you have agreed to our use of cookies on this site

Some videos embedded in our pages use cookies to anonymously gather statistics on how you got there and what video you viewed. Cookies are also stored for Google Analytics, so we can monitor how our message is spreading. Enabling these cookies is not strictly necessary for our website to work, but it will provide you with a better browsing experience. You are free to delete or block our cookies at any time, however, some features of our site may not work as intended.

What types of cookies do we use?

The cookies used on our website are grouped into the following categories.

Necessary

Necessary cookies are absolutely essential for the website to function properly. These cookies ensure basic functionalities and security features of the website, anonymously.

Cookie	Duration	Description
__stripe_mid	1 year	Stripe sets this cookie cookie to process payments.
__stripe_mid	30 minutes	Stripe sets this cookie cookie to process payments.
_GRECAPTCHA	5 months 27 days	This cookie is set by the Google recaptcha service to identify bots to protect the website against malicious spam attacks.
cookielawinfo-checkbox-advertisement	1 year	Set by the GDPR Cookie Consent plugin, this cookie is used to record the user consent for the cookies in the “Advertisement” category .
cookielawinfo-checkbox-analytics	11 months	This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category “Analytics”.
cookielawinfo-checkbox-functional	11 months	The cookie is set by GDPR cookie consent to record the user consent for the cookies in the category “Functional”.
cookielawinfo-checkbox-necessary	11 months	This cookie is set by GDPR Cookie Consent plugin. The cookies is used to store the user consent for the cookies in the category “Necessary”.
cookielawinfo-checkbox-others	11 months	This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category “Other.
cookielawinfo-checkbox-others	11 months	This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category “Other.
cookielawinfo-checkbox-others	11 months	This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category “Other.
cookielawinfo-checkbox-performance	11 months	This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category “Performance”.
cookielawinfo-checkbox-performance	1 year	This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category “Performance”.
CookieLawInfoConsent	session	Records the default button state of the corresponding category & the status of CCPA. It works only in coordination with the primary cookie.
PHPSESSID	11 months	This cookie is native to PHP applications. The cookie is used to store and identify a users’ unique session ID for the purpose of managing user session on the website. The cookie is a session cookies and is deleted when all the browser windows are closed.
viewed_cookie_policy		The cookie is set by the GDPR Cookie Consent plugin and is used to store whether or not user has consented to the use of cookies. It does not store any personal data.

Functional

Functional cookies help to perform certain functionalities like sharing the content of the website on social media platforms, collect feedbacks, and other third-party features.

Cookie	Duration	Description
__atuvc	1 year 1 month	AddThis sets this cookie to ensure that the updated count is seen when one shares a page and returns to it, before the share count cache is updated.
__atuvs	30 minutes	AddThis sets this cookie to ensure that the updated count is seen when one shares a page and returns to it, before the share count cache is updated.
lang	session	LinkedIn sets this cookie to remember a user’s language setting.
mailchimp_landing_site	1 month	The cookie is set by MailChimp to record which page the user first visited.

Performance

Performance cookies are used to understand and analyze the key performance indexes of the website which helps in delivering a better user experience for the visitors.

Analytics

Analytical cookies are used to understand how visitors interact with the website. These cookies help provide information on metrics the number of visitors, bounce rate, traffic source, etc.

Cookie	Duration	Description
_ga	2 years	The _ga cookie, installed by Google Analytics, calculates visitor, session and campaign data and also keeps track of site usage for the site’s analytics report. The cookie stores information anonymously and assigns a randomly generated number to recognize unique visitors.
_gat_UA-41277959-1	1 minute	A variation of the _gat cookie set by Google Analytics and Google Tag Manager to allow website owners to track visitor behaviour and measure site performance. The pattern element in the name contains the unique identity number of the account or website it relates to.
_gcl_au	3 months	Provided by Google Tag Manager to experiment advertisement efficiency of websites using their services.
_gid	1 day	Installed by Google Analytics, _gid cookie stores information on how visitors use a website, while also creating an analytics report of the website’s performance. Some of the data that are collected include the number of visitors, their source, and the pages they visit anonymously.
_hjAbsoluteSessionInProgress	30 minutes	Hotjar sets this cookie to detect the first pageview session of a user. This is a True/False flag set by the cookie.
_hjFirstSeen	30 minutes	Hotjar sets this cookie to identify a new user’s first session. It stores a true/false value, indicating whether it was the first time Hotjar saw this user.
_hjIncludedInPageviewSample	2 minutes	Hotjar sets this cookie to know whether a user is included in the data sampling defined by the site’s pageview limit.
_hjIncludedInSessionSample	2 minutes	Hotjar sets this cookie to know whether a user is included in the data sampling defined by the site’s daily session limit.
at-rand	never	AddThis sets this cookie to track page visits, sources of traffic and share counts.
CONSENT	2 years	YouTube sets this cookie via embedded youtube-videos and registers anonymous statistical data.
iutk	5 months 27 days	This cookie is used by Issuu analytic system to gather information regarding visitor activity on Issuu products.
uvc	1 year 1 month	Set by addthis.com to determine the usage of addthis.com service.