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 * About us
   * Innovation
   * Excellence
   * Our history
   * CEO and management team
   * Risk management systems
   * Certifications
   * Governance and ethics
   * Tax Strategy
 * Sustainability
   * Our Strategy
   * Reports and disclosure
   * External Engagement
 * Blog
 * News and events
   * Events calendar
   * Our stories
   * Press releases
 * Careers
   * Frequently Asked Questions
   * Global professional opportunities
   * Graduate opportunities
 * Investors
   * Investor Registration
   * Financial results
   * Investor information
   * Debt information
   * Company presentation
   * Contact us
 * Contact us
   * Our locations
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 * Pharma and medical
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   * Medical device packaging films
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   * kpEnhance
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 * Consumer packaging
   * General thermoforming films
   * Static control films
   * PCR films for sustainability
   * Specialty Films
 * Food packaging
   * Protein food packaging
   * Food-to-go packaging
   * Flexible films packaging
   * Rigid food packaging films
   * Dairy packaging
   * Fresh produce packaging
   * Bakery packaging
   * Sustainability
   * Recycled Coastal Plastics
 * Labels
   * Sustainable label films
   * Shrink sleeves
   * Pressure - Sensitive Labels
   * Roll sleeves
   * Capsules
   * Battery
 * Cards and graphics
   * Cards
   * Graphics
 * Home, building and construction
   * Construction
   * Tape films
   * Cooling tower films
   * Decorative films
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 * Privacy policy


KLÖCKNER PENTAPLAST COMPANIES' WEBSITE PRIVACY POLICY

Effective: May 2018


This notice describes in detail on the basis of the EU General Data Protection
Regulation (GDPR) that KP Holding GmbH & Co. KG and its subsidiaries ("Klöckner
Pentaplast Companies") have adopted in order to address our concerns about
privacy, concerns we know you share ("Privacy Policy"). This Privacy Policy
describes the types of information we collect on this website (the "Klöckner
Pentaplast Website"), how and for which purpose that information may be used,
and with whom that information may be shared. This Privacy Policy also describes
the measures we take to protect the security of the information collected, and
the choices you, as a user of the Klöckner Pentaplast Website, can make about
how and for which purpose we use the information you provide to us. Finally,
this Privacy Policy tells you how you can contact KP Holding GmbH & Co. KG, the
administrator of the Klöckner Pentaplast Website, in the event that you have any
questions or concerns about our Privacy Policy or any information which we have
collected from you or that you have provided to us.



CONTENT

 1.  Responsible within the meaning of Art. 4 para. 7 GDPR
 2.  Communication via contact form/telephone/email/post
 3.  Data processing of contact persons
 4.  Applications
 5.  Data processing for marketing purposes
 6.  Newsletter subscription
 7.  Investor Portal
 8.  Cookies and web beacons
 9.  Encryption
 10. Your rights as a data subject
 11. No obligation to provide personal data
 12. Links to other sites
 13. Contact data of the Data Privacy Officer

1. Responsible within the meaning of Art. 4 para. 7 GDPR
Unless otherwise stated in the individual sections (highlighted by the headings)
of this Privacy Policy, the…

KP Holding GmbH & Co. KG
P.O.Box 1165, 56401 Montabaur
Industriestraße 3-5
56412 Heiligenroth
Germany
Phone: +49 (0) 2602 915 0
Fax: +49 (0) 2602 915 297
Email: kpinfo@kpfilms.com

is the controller of the data within the meaning of Art. 4 para. 7 GDPR.

2. Communication via contact form/telephone/email/post
Purpose of data processing/legal basis:
Personal information that you provide to us when filling out contact forms, by
telephone, e-mail, post or in direct contact, will of course be treated
confidentially. We use your data exclusively for a specific purpose in order to
process your enquiries. The legal basis for data processing is Art. 6 para. 1 f)
GDPR. The justified interest on the part of KP arises from the interest in
answering inquiries from customers and interested parties and thus to maintain
and promote their satisfaction.

Recipients/categories of recipients:
As a matter of principle, we do not pass on the data to third parties outside
the kp Group. Within the kp Group your data will be passed on for processing
your inquiry, among other things. Exceptionally, data are processed by order
processors on our behalf. These are carefully selected, audited by us and
contractually bound by Art. 28 GDPR. An overview of all kp Group companies can
be found here.

Storage duration/criteria for defining the storage duration:
All personal data that you provide us with enquiries will be deleted or
anonymized by us at the latest 90 days after the final reply to you. The
retention of 90 days is explained by the fact that it can happen in isolated
cases that you as a customer or prospective customer must contact us again after
an answer to the same thing and we must then be able to refer to the preliminary
correspondence. Experience has shown that after 90 days there are usually no
more questions about our response.

3. Data processing of contact persons
Purpose of data processing/legal basis:
Klöckner Pentaplast Group companies process contact information from customers,
prospects, suppliers and other business partners for communication by e-mail,
telephone, fax and mail. In addition, the contact details of the contact persons
are also processed in the Finance section as part of the master data of business
partners.
The legal basis for data processing is Art. 6 para. 1 f) GDPR. The legitimate
interest on the part of kp arises from the interest to conduct or initiate the
business relationship with customers, interested parties, suppliers and other
business partners and to maintain personal contact with contact persons.

Recipients/categories of recipients:
As a matter of principle, we do not pass on the data to third parties outside
the kp Group. Within the kp Group, your data will be passed on for the purpose
of carrying out or initiating the business relationship, among other things. An
overview of all kp Group companies can be found here. Exceptionally, data are
processed by order processors on our behalf. These are carefully selected,
audited by us and contractually bound by Art. 28 GDPR.

Storage duration/criteria for defining the storage duration:
Personal data will be stored for the purpose of conducting business relations
for as long as there is a legitimate interest in doing so. Especially in the
area of finance, contact details of contact persons may be subject to statutory
retention periods and must be stored for the duration of these periods.

4. Applications
Klöckner Pentaplast Group companies are constantly on the lookout for qualified
and motivated employees. Please note that applications that you send us by
e-mail will be sent to us unencrypted. We therefore recommend the use of the
online application program.

Purpose of data processing, legal basis and functioning:
All information and attachments that you save in your profile and send with an
application will be processed by us exclusively for processing the application
you submitted via the profile.

You can create a personal profile with a personal password on the KP Online
Applicant Portal. The data of your profile can be viewed by us at any time. We
use an encryption method for the online transmission of your applicant data in
this system, so that your data is protected from unauthorized access.

As soon as you create a concrete application via your profile and send it to us,
our recruiters will have the right of access to your application data.

The legal basis for the processing of data within the application process is in
principle Art. 6 Para. 1 b) GDPR, or Art. 88 GDPR in conjunction with the
National Data Protection Act applicable in your country provided that your
country has made use of the opening clause in Art. 88 GDPR and has regulated the
processing of data in the context of application and employment relationships
nationally.

In Germany this is new in connection with § 26 Paragraph 1 Sentence 1 BDSG. Art.
88 GDPR.

The legal basis for a kp internal forwarding and processing of your application
data for other positions or within the framework of an applicant pool is your
consent pursuant to Art. 6 para. 1 a) GDPR. In addition, we will never pass on
your application to third parties.

5. Data processing for marketing purposes
Purpose of the data processing/legal basis:
The companies in the Klöckner Pentaplast (kp) Group use personal data for
marketing purposes, in particular for advertising by email, phone and post. The
purpose of this data processing in a marketing context is to inform data
subjects of products and services that are offered by the companies in the kp
Group. The legal basis for sending advertising material by post is Art. 6 (1)
(f) GDPR. In this connection, kp’s legitimate interest arises out of its
interest in sending customers and interested parties information about products
and services. The legal basis for marketing initiatives by email or phone is
normally a declaration of consent provided by you. For marketing initiatives
involving existing customers there are additional legal bases contained in
special legislation based on DIRECTIVE 2002/58/EC .

You can refuse consent to receive future advertising at any time by fill out the
form on this page.

Recipients/categories of recipient:
We unequivocally assure you that we do not pass on your data to third parties
outside the kp Group. Within the kp Group your data are passed on for purposes
including that of initiating or developing a business relationship with you. You
will find an overview of all the companies in the kp Group here. In exceptional
cases, data is processed by processors on our behalf. These are in every
instance carefully selected, audited by us and under contractual obligation in
accordance with Art. 28 GDPR.

Storage period/criteria for determining the storage period:
If you refuse your consent to receive advertising, we will immediately block
access to your data and then erase it, provided that it is not required for
other purposes.

6. Newsletter
Purpose of data processing/legal basis:
You have the opportunity to order the free kp Newsletter through this website
and other channels (by phone, in person at trade fairs, etc.). The legal basis
for data processing in the context of sending newsletters is your consent in
accordance with Art. 6 para. 1 a) GDPR. Purpose of the data processing in the
context of the order of the kp newsletter is the information of the newsletter
subscribers to products and services of the enterprises of the kp group. The
newsletter is sent irregularly, but usually not more than four times a year per
division.

As far as you register for the free kp Newsletter, we need your email address as
mandatory. If you voluntarily provide additional information about yourself
(name, surname, last name, company, country, selection newsletter), we use this
data only to offer the newsletter in your own language if possible and to
address you personally. The specification of your company is for information
purposes only.

After submitting the registration form you will receive an email with a
confirmation link. If you click on the link contained in it, you are registered
for the newsletter. This will be displayed by forwarding you to a confirmation
page. By confirming the registration, you agree that you agree with the
described processing of your e-mail address and any optional data provided.

The consent to order the newsletter can be withdrawn at any time with effect for
the future, by pressing the corresponding unsubscribe link in one of the
newsletters or write a message to newsletter@kpfilms.com.

Recipients/categories of recipients:
In principle, we do not disclose the data to third parties outside the kp Group.
Within the kp Group, your data will be used i.a. to conduct or initiate the
business relationship. An overview of all kp Group companies can be found here.
Insofar as external newsletter processors are used to carry out the newsletter,
they are contractually obligated pursuant to Art. 28 GDPR and have accordingly
been checked for provision of suitable organizational and technical security
measures.

Storage duration/criteria for determining storage duration:
If you revoke your consent to receive the kp Newsletter, your data will be
blocked immediately and then deleted. As a result, you will no longer receive
the kp Newsletter.

7. Investor Portal
Purpose of data processing/legal basis:
As an investor in the kp Group or as an interested party, you have the
opportunity to register for the Investor Portal on this homepage. You can then
retrieve current information in the portal on a regular basis, which is relevant
in this regard. The storage of your data, which you must provide at
registration, is based on your consent. You can revoke this consent at any time.
We need your data to inform you about new figures and investor relations topics
of the kp Group. In the case of a registration, you will be informed quarterly
by email about the next investor call and investor related figures.

Recipients/categories of recipients:
Your data will only be managed by kp Group companies. An overview of all kp
Group companies can be found here.

Storage duration/criteria for determining storage duration:
Your personal data will be stored as long as you are registered in the Investor
Portal.

8. Cookies and web beacons
When you visit the Klöckner Pentaplast website, your browser automatically sends
us certain Internet-related information (such as Internet Protocol or IP address
of the computer you are using). The Klöckner Pentaplast website may also use
cookies and web beacons in order to better understand how visitors use the
Klöckner Pentaplast website so that they may improve your user experience. The
cookies and web beacons will be deleted no later than after such statistical
evaluation has been completed.

Cookies are small text files that websites often store on the computer hard
drives of visitors to their sites. A cookie contains a unique code, which is
used to recognize your computer when a user of your computer returns to a
website that was visited previously. Web beacons are Internet tools that help us
determine, for example, whether a website page has been viewed. The Klöckner
Pentaplast website uses cookies and web beacons to enhance the online experience
of our visitors and to better understand how the Klöckner Pentaplast website is
used. Cookies and web beacons may indicate, for example, whether you have
visited the Klöckner Pentaplast website before or whether you are a new visitor.

Cookies and web beacons on the Klöckner Pentaplast website cannot be used to run
programs or deliver viruses to your computer. They are uniquely assigned to you,
and can only be read by a web server in the domain that issued the cookie or web
beacon to you and will solely be used for the purpose of call
control/recognition in the event of the repeated use of the homepage. The
Klöckner Pentaplast website does not match your personally identifiable
information with the cookie or web beacon assigned to you. We will not share or
sell non-aggregated information contained within cookies or web beacons with any
third party. You have the ability to accept or decline cookies or web beacons.
Most web browsers automatically accept cookies, but you can usually modify your
browser setting to decline cookies and Web beacons. The "help" button on the
toolbar of most browsers will tell you how to stop accepting new cookies, how to
be notified when you receive a new cookie, and how to disable existing cookies.
However, please note that if cookies and/or web beacons are disabled, you may
not be able to use the full range of services or features of the website.


8.1 Usage data about your visit to our website

Purpose of data processing and legal basis
Information that arises during your use of our Internet pages (these are: the
page from which the file was requested, the name of the file, the date and time
of the query, the amount of data transferred, the access status such as "file
transferred", "file not found", etc.), A description of the type of web browser
used and an anonymous IP address - shortened by the last three digits by the
Google Analytics program) are used by us for user guidance, for statistical
evaluations, to adapt our web pages to your needs and to prevent irregular
queries to our web offer. We use temporary and permanent cookies to control your
connection to our websites during the session. No personal data will be stored
or processed in any other way. The cookie only allows us to identify you as a
unique but unknown user during your visit to the site.

Klöckner Pentaplast uses pseudonyms to create user profiles. The user profiles
are not merged with the data of the bearer of the pseudonym. According to
DIRECTIVE 2002/58/EG, you have the right to object to the creation of user
profiles. You can exercise this right by sending us an e-mail to
kpinfo@kpfilms.com In creating user profiles, the Klöckner Pentaplast Companies
comply with the strictest applicable security standards.

Recipients/categories of recipients:
Access to the cookies stored in your system for these purposes is not given.

Storage duration/criteria for defining the storage duration:
We do not store your user data for longer than three months.


8.2 Web tracking using Google Analytics

Purpose of data processing/legal basis:
We create pseudonymous user profiles with the help of Google Analytics for the
demand-oriented design of our website. Google Analytics uses "cookies", which
are text files placed on your computer, to help the website analyze how users
use the site. The information generated by the cookie about your use of this
website is usually transferred to a Google server in the USA and stored there.
However, because we have activated IP anonymisation on this website, your IP
address will first be reduced by Google within Member States of the European
Union or in other states party to the Agreement on the European Economic Area.
Only in exceptional cases will the full IP address be transmitted to a Google
server in the USA and only shortened there. Google will use this information for
the purpose of evaluating your use of the website, compiling reports on website
activity and providing us with other services relating to website activity and
internet usage.

You can object to the creation of pseudonymous user profiles at any time. There
are several ways to do this:


 1. One way to object to web analysis by Google Analytics is to set an opt-out
    cookie that instructs Google not to store or use your data for web analysis
    purposes. Please note that with this solution the web analysis will only not
    take place as long as the opt-out cookie is stored by the browser. If you
    would like to set the opt-out cookie now, please click here.
 2. you can also prevent the storage of the cookies used to create your profile
    by adjusting your browser software accordingly.



Depending on the browser you are using, you may be able to install a browser
plug-in that prevents tracking. Please click here and install the browser plugin
available there.

The legal basis is your for this data processing is your consent according to
art. 6 para. 1 lit.a) GDPR.

Recipients/categories of recipients:
Your data will only be processed by companies of the kp group and the service
provider Google commissioned by us.

Storage duration/criteria for defining the storage duration:
Personal data is not stored by using Google Analytics.


8.3. Webtracking via Act-On beacon

Purpose of data processing / legal basis:
For the appropriate configuration of our website we create with your consent
pseudonymous user profiles using act-on "beacons". A beacon is a pixel-sized
file that is retrieved from the server of the software provider Act-On when you
visit our website. Information is also captured when you visit custom landing
pages built within the platform (those URL’s would start with
“marketing.kpfilms.com”). Within the framework of this retrieval, technical
information such as information about the browser and your system, as well as
your IP address and time of retrieval are initially collected. In addition, a
distinction can be made between known and unknown visitors. If you have already
filled out our contact form, you have already had e-mail contact with us or you
have shared your contact information with us in some other way, we can recognise
you and allocate the information. If you access our website from another
technical device, this information will also be linked to allocate this
information to you.

The information is used for the technical improvement of the services based on
the technical data or the target groups and their reading behaviour based on
their retrieval locations (which can be determined by means of the IP address)
or the access times. Statistical surveys also include determining when a website
was visited and which links were clicked. This information can be assigned to
individual website visitors. The evaluations help us to better understand the
customer behaviour of our users and to adapt our contents to them or to send
different contents according to the interests of our users.

To do this, we use a system that alerts us when a certain level of activity is
reached (e.g., certain pages are accessed more often, documents downloaded,…).
If you have given your prior consent, we may contact you in this case to discuss
products you may be interested in. Kindly note that the Klöckner Pentaplast
Group is only providing B2B solutions and is not offering its products directly
to consumers. It is also used to analyse website traffic and behaviour patterns,
which in turn will help kp make the website more user-friendly.

The information generated by the beacon about your use of this website is
generally transmitted to and stored on Act-On's server in Ireland. However, if
it cannot be excluded that your data is transferred to third countries, we have
concluded standard contractual clauses with our service provider. Act-On will
use this information to evaluate your use of the website for us, to compile
reports on website activity and to provide other services to us related to
website and internet usage.

You can revoke your consent to the creation of the pseudonymous user profiles at
any time. If you wish to revoke your consent to the web analysis by Act-On,
please update your cookie preferences disabling the statistic cookies using this
link. In any event an opt-out option will always be included in any e-mails
generated using the Act-On web analysis tool that you would receive from us.

The legal basis for this data processing is your consent pursuant to Art. 6
para. 1 sentence 1 lit. a) DSGVO.

Recipients/ categories of recipients:
Your data collected here will only be processed by companies in the KP Group and
by Act-On, the service provider commissioned by us.

The external processor has been contractually obliged by us in accordance with
Art. 28 DSGVO and has been checked accordingly for the provision of suitable
organisational and technical security measures.

Storage period/ Criteria for determining the storage period:
We will store your data for no longer than three (3) years after your last
interaction with us. If you revoke your consent to data processing within the
scope of the Act-On beacon, your data will be deleted immediately.

9. Encryption
We take technical and organizational security measures to protect your data from
unwanted access as comprehensively as possible. In addition to securing the
operating environment, we also use encryption methods. The information you
provide is transmitted in encrypted form using an SSL protocol (Secure Socket
Layer) and authenticated to prevent misuse of the data by third parties. You can
recognize this by the fact that the lock symbol is closed in the status bar of
your browser and the address line is marked with "https" at the beginning.

10. Your rights as a data subject
The data subject has the right to request a statement from the data controller
as to whether personal data relating to him or her is being processed; if this
is the case, he or she has the right to be informed about this personal data and
the right to the information referred to in detail in Art. 15 GDPR.

The data subject has the right to require that inaccurate personal data relating
to him or her be immediately rectified by the data controller and, where
applicable, that incomplete personal data be completed (Art. 16 GDPR).

The data subject has the right to request that personal data relating to him or
her be immediately erased by the data controller where one of the grounds
referred to in Art. 17 GDPR applies, for example when the data is no longer
needed for the intended purposes (right to erasure).

The data subject has the right to request that the data controller restricts
processing where one of the conditions referred to in Art. 18 GDPR applies, for
example if the data subject has objected to processing, for a period enabling
the controller to examine the matter.

The data subject has a right to data portability under the conditions of Art. 20
DSGVO

The data subject has the right, on grounds relating to his or her particular
situation, to object at any time to the processing of personal data relating to
him or her. The controller shall no longer process the personal data, unless he
or she is able to demonstrate legitimate grounds for the processing which
override the interests, rights and freedoms of the data subject, or for the
establishment, exercise or defence of legal claims (Art. 21 GDPR).

Without prejudice to any other administrative or judicial remedy, every data
subject has the right to lodge a complaint with a supervisory authority if the
data subject considers that the processing of personal data relating to him or
her infringes the GDPR (Art. 77 GDPR). The data subject can exercise this right
with a supervisory authority in the member state in which he or she resides or
works or in which the alleged infringement took place.

In any of the above cases, or if you have an unresolved query or wish to make a
complaint, please contact us in writing, or use the form on this page.

11. No obligation to provide personal data
Apart from under the circumstances described in the previous sections, the
provision of personal data is not required, either contractually or by law or
for the conclusion of a contract. You are not under obligation to make personal
data available unless information to the contrary has been provided beforehand.
The non-provision of your personal data can, under certain circumstances, mean
that we cannot answer your contact request or enter into a business
relationship.

12. Links to other sites
Occasionally we provide links to other websites for your convenience and
information. These sites operate independently and are not under our control.
These sites may have their own privacy policies in place, which we strongly
suggest you review if you visit any linked websites. We are not responsible for
the content of these sites, any products or services that may be offered through
these sites, or any other use of these sites. We reserve the right to terminate
any link at any time, and the inclusion of any link does not constitute or imply
an endorsement, authorisation, sponsorship or affiliation by or between us and
the linked website, or any of the products or services provided therein. If you
access any of the websites linked to the Klöckner Pentaplast website, you do so
entirely at your own risk.

13. Contact data of the Data Privacy Officer
You can contact the Data Protection Officer of the German KP companies under the
following contact details:

Fieldfisher (Germany) LLP
Dr. Felix Wittern
Am Sandtorkai 68
20457 Hamburg
Germany
+49 (0)40 878 869 81 14
felix.wittern@fieldfisher.com



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Klöckner Pentaplast Group
4 Kingdom Street
London
W2 6BD



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NameGoogle AnalyticsProviderGoogle LLCPurposeCookie used by Google to analyze
the website. This generates statistical data about the user behavior of the
website visitor.Data protectionhttps://policies.google.com/privacyCookies
_ga
Runtime: 2 years
Used to distinguish users
_gid
Runtime: 1 year
Used to distinguish users
_gat
Runtime: 10 minutes
Used to reduce requests
_utma
Runtime: 2 years
Stores the amount of your visits, the time of the first visit, the previous
visit, and the current visit
_umtb
Runtime: 30 minutes
Is used to check approximately how fast people leave the page
_utmc
Runtime: Session
Is used to check approximately how fast people leave the page
_utmt
Runtime: 1 day
Used to process the type of request requested
_utmz
Runtime: 6 months
Records whether the visitor came from a search engine (and if so, the search
keyword used), a link, or from no previous page (e.g. a bookmark).
DSID
Runtime: 2 weeks, Domain: doubleclick.net
Google security cookies to authenticate users, prevent fraudulent use of
credentials and protect user data from unauthorized access.
IDE
Runtime: 1 year, Domain: doubleclick.net
Used to optimize advertising on Google DoubleClick to provide ads that are
relevant to users, to improve campaign performance reports, or to prevent a user
from seeing the same ads multiple times.
1P_JAR
Runtime: 1 month, Domain: google.com
Used to optimize advertising on Google DoubleClick to provide ads that are
relevant to users, to improve campaign performance reports, or to prevent a user
from seeing the same ads multiple times.
NID
Runtime: 6 months, Domain: google.com
The NID cookie contains a unique identifier that Google uses to store your
preferences and other information, including your preferred language (eg,
German), how many search results you want to display per page (eg, 10 or 20),
and whether the Google SafeSearch filter should be enabled.

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NameAct-On tracking beaconProviderAct-On SoftwarePurposeCookie used by Act-On
Software to analyze the website. This generates statistical data about the user
behavior of the website visitor.Data
protectionhttps://act-on.com/privacy-policy/Cookies
wp43678
Runtime: 1 years
Used to distinguish users
wp43553
Runtime: 1 years
Used to distinguish users


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