Privacy Policy
1. Purpose and Scope of this Notice
Propelis is a provider of comprehensive packaging, design and brand management solutions to organisations in the consumer packaged goods industry (our “Customers“).This data protection notice (“Notice“) sets out our commitment to safeguarding the privacy of those using the Propelis website (“Website“) and the products and services we provide to our Customers and the confidentiality of any information that we collect about you.
In this Notice, your personal data means any information which Propelis processes about you which you can be directly or indirectly personally identified (“Personal Data“). This Notice sets out how we will use Personal Data that we may obtain from you and applies whenever your submit your Personal Data to us in accordance with section 2.
When we mention Propelis, “we”, “us” or “our” in this Notice, we are referring to the relevant Propelis company responsible for processing your Personal Data. Propelis is the controller in respect of any Personal Data which is processed by any of our offices located in the European Economic Area (“EEA“).
2. How we collect your Personal Data
We will collect and store any information you provide to us when you:
- have opted-in for marketing and/or other business communications;
- use/access our Website;
- use our social media
- are an existing Propelis customer;
- become an Propelis customer by purchasing products or services from us; and
- contact us by any means (including via our Website, over the phone, by email or by post).
3. Categories of Personal Data
The table below details the categories of Personal Data collected via the means set out above:
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When you opt-in to our marketing and/or other business communications |
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Category of Personal Data |
Personal Data we collect |
Description |
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Contact information |
Name Email address Telephone Number
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We process this information when you agree to receive marketing communications from us |
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Employment Details |
Company Location |
We process this information when you agree to receive business communications from us. |
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Marketing Data |
Area of interest and marketing preferences |
We process this information when you agree to receive business communications from us. |
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When you use/access our Website |
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Category of Personal Data |
Personal Data we collect |
Description |
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Device/IP Data |
IP address Operating system and browser used to access our website Browser plug-in types and versions Operating system and platform Internet Service Provider Time and date the Website was accessed |
This information is collected through the settings on our Website. For further information, please see the section on Cookies below. |
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Use our social media accounts |
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Category of Personal Data |
Personal Data we collect |
Description |
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Contact information |
Name Email address |
We process this information when you interact with our social media accounts, provided this information is publicly visible from your social media profile |
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Location Data |
Location Country |
We process this information when you interact with our social media accounts, provided this information is publicly visible from your social media profile |
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Employment Details |
Job title Company Area of Interest |
We process this information when you interact with our social media accounts, provided this information is publicly visible from your social media profile |
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If you are or become an Propelis Customer |
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Category of Personal Data |
Personal Data we collect |
Description |
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Contact information |
Name Email address Telephone number |
This information is collected to process and deliver your order. |
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Employment Details |
Job title Company |
This information is collected to process and deliver your order.
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Payment Information |
Billing information Communication with us and our staff |
This information is processed when you pay for your order. |
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Contact us by any means |
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Contact information |
Name Email address Telephone number Mailing address |
We process this information when you contact us through our Website, over the phone, by email or by post. |
4. Purposes for processing Personal Data
If you are from a jurisdiction that requires a legal basis for processing your Personal Data (such as the EU or the UK), that legal basis will depend on nature and context of the Personal Data collected.
The lawful bases are explained below:
- Performance of a Contract: When it is necessary for Propelis to process your Personal Data to:
- Comply with legal obligations under a contract with you. This includes our obligations under the terms and conditions of your order, or
- To verify information before entering into a contract with you.
- Legitimate Interest: Where Propelis has an interest in using your Personal Data in a certain way, which is necessary and proportionate in relation to a particular business need.
- Consent: When Propelis asks you to actively indicate your agreement to Propelis’ use of your Personal Data for a certain purpose.
- Compliance with Legal Obligations: When Propelis must process your Personal Data to comply with a law.
The table below details how Propelis will use your Personal Data and the accompanying lawful basis.
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Purpose |
Category of Personal Data processed |
Lawful basis for processing
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To register you for, or to provide you with a product or service in accordance with a contract we have entered into with you.
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Contact information; Employment Details
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Performance of a contract with you; Legitimate interest related to providing you with a product or service. |
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To process your payment to Propelis. |
Payment Information |
Performance of a contract. |
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To respond to an enquiry made by you (whether via the website, over the phone, by email, social media or by post). |
Contact information.
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Legitimate interest in resolving queries and complaints; Compliance with a legal obligation
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To provide customer service and support activities.
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Contact information Information related to your query or complaint.
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Performance of a contract with you; Legitimate interest in managing our relationship with you and ensuring we offer the best customer experience.
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Market our products or services |
Contact information; Marketing Data
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Legitimate interest in contacting customers and potential customers to promote our products or services and analysing how our customers use our products or services and to grow our business;
Consent (where required by law).
If you decide that you do not wish to receive any marketing communications from us, please see section 5 below.
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To conduct research and surveys.
For example, when we contact you to ask for feedback on your experience.
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Contact information
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Legitimate interest including to improve our product or service provision;
Consent
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To contact you to provide notices regarding your use of our products or services, or if your actions violate your agreement with us (if any). |
Contact information. |
Compliance with a legal obligation; Legitimate interest in protecting our business.
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To provide you with access to all parts of our Website, to authenticate and enable access to products or services and features of our Website for you, to personalise your experience on our Website, to protect our business and Website from fraud and other illegal activities (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data), and ultimately improve the functionality of the Website |
Contact information; Device/IP Data |
Performance of a contract with you; Legitimate interest in providing an enhanced, Customer friendly Website by understanding how our Website is used; Consent (where required by law). |
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To establish, exercise or defend legal claims.
For example, if we are involved in litigation and we must provide information to our lawyers in relation to that legal issue. |
Contact information; Device/IP Data; Employment Details; Marketing Data; Location Data Payment Information |
Legitimate interest including to seek legal advice and to protect ourselves, our Customers or others in legal proceedings. |
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To comply with a request from law enforcement, courts, or other competent authorities. |
Contact information; Device/IP Data; Employment Details; Marketing Data; Location Data Payment Information |
Compliance with legal obligations. Legitimate interest including to assist law enforcement authorities with prevent or detection of serious crime. |
Where required by applicable data protection laws, we will only use your Personal Data for the purposes for which we collect it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your Personal Data for any other reasonable purposes in connection with our engagement with you, the purpose and legal basis for any other further processing will be notified to you in advance from time to time.
If we require your information for the purposes of performing a contract with you and you fail to provide this information, or if the information you provide is not accurate, we may not be able to perform the contract we have or are trying to enter into with you.
5. Marketing
Marketing Communications
You may receive periodic emails, newsletters and mailings or phone calls from us with information about our products or services we believe may be of interest to you. You can opt-out of these marketing communications at no cost at any time, by emailing us at [info@propelis.com] or by writing to us at Propelis, 1330 W Fulton Street STE 800 Chicago, IL 60607, USA. It may take up to 14 working days to remove you from our mailing lists.
Additionally, an “unsubscribe” button will be provided in each marketing email communication sent by Propelis so that you can opt-out. However, we may continue to send transaction-related emails regarding products or services you have requests: you will not be able to opt-out of some of those communications.
‘Do Not Track’
Do Not Track (“DNT“) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. For information about “do-not-tract”, visit http://www.allaboutdnt.org.
6. How we share your Personal
Depending on your relationship with us, we may disclose some or all of your Personal Data to service providers and other parties listed in this section.
Service Providers and Affiliates
We will share Personal Data with our service providers and affiliates so that they can provide services to us. Our service providers help us to provide the Website, support or other services to you. We carefully select our service providers, and we take corresponding measures to protect your Personal Data when service providers are engaged.
Professional Advice
We may share Personal Data with our professional advisors so that they can provide us with guidance. These advisors can include legal advisors, financial advisors, consultants and accountants.
Legal Obligations
We may share Personal Data where this is required by law or regulation, or court or administrative order having force of law, or where required by any of Propelis’ regulators.
Enforcement of Rights
We may share Personal Data to establish, exercise or defend our legal rights, including providing information to others for the purposes of fraud prevention and reducing credit risk.
Other Disclosures
We may share Personal Data where we have stated or informed you otherwise (e.g. in this policy, on our Website or detailed in our terms and conditions).
Business Transfers
Your Personal Data may be transferred to a different entity, and our legal and other advisors, if we undergo, or evaluate, a merger, acquisition, bankruptcy or other transaction (or proposed transaction) in which that entity assumes control of our business or assets of our business (in whole or in part).
7. Transfers of Personal Data
Propelis is made up of different legal entities, details of which can be found Our global headquarters are located in the State of Illinois, North America and Accordingly, your Personal Data may be transferred and stored in countries across the world. We will always take steps to ensure any international transfer of data is carefully managed to protect your rights and interests.
Some transfers may be outside of the European Economic Area (“EEA“)/UK and for those transfers we will either:
- Only transfer your Personal Data to countries which are recognised as providing an adequate level of legal protection in accordance with Article 45 of the GDPR; or
- Ensure that transfers outside your country are subject to additional safeguards required under local law – for example, the EU Model Clauses pursuant to Article 46(2) of the GDPR or by relying on certification schemes. In particular, we are party to an Intra-Group Data Transfer Agreement which governs the transfer of Personal Data across all members of the Propelis group of companies, and which includes an appropriate mechanism to lawfully transfer Personal Data outside of the EEA, (namely the Standard Contractual Clauses).
You have the right to ask us for more information about the safeguards we have put in place (including a copy of the relevant contractual commitments) as mentioned above. Contact us if you would like further information or to request a copy where the safeguard is documented (which may be redacted to ensure confidentiality).
8. Data Security and Retention
We will take all reasonable steps to protect your Personal Data from unauthorised access, use and disclosure using appropriate physical, technical and organisational security measures based on the type of Personal Data and how we are processing that Personal Data. However, the Internet is global, and data transmitted via the Internet cannot be guaranteed by us to be completely secure during transmission. Accordingly, we cannot guarantee the security of any data that you disclose online.
We retain Personal Data for as long as necessary to provide you with our products or services or marketing purposes. In some cases, we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, to defend a legal claim or is otherwise required by applicable law, rule or regulation. In general, Propelis (or its service providers on its behalf) will hold this in accordance with our internal retention policy, unless we are obliged to hold it for a longer period under law or applicable regulations.
Any Personal Data is deleted or rendered unavailable as soon as the purpose of storage no longer applies. The data is also rendered unavailable or deleted when a prescribed storage duration mandated by the laws in your jurisdiction expires unless there is a necessity for the continued storage of the data for the conclusion of a contract or the fulfilment of a contract.
9. Your rights in relation to Personal Data
Under applicable privacy laws, you may have rights over your Personal Data as a data subject.
For further information on whether you can exercise any of the rights below in your jurisdiction, please contact us at: info@propelis.com. We have set out in this section certain data subject rights under the GDPR, which apply to data subjects based in the EEA/UK.
- Request access to your Personal Data. This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have exercised your right to object to processing (see below).
- Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation, which makes you want to object to processing on this ground.
- Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your Personal Data to another party.
- Withdraw your consent at any time if your Personal Data is processed on the basis of consent. If you withdraw your consent, this will not affect the lawfulness of how we used your Personal Data before you withdrew consent.
- Lodge a complaint with a competent supervisory authority if you consider that the processing of your Personal Data infringes applicable law. We request that you contact us in the first instance so that we can respond to your complaint. The contact details are available here: https://edpb.europa.eu/about-edpb/about-edpb/members_en for data subjects based in the EEA and here: https://ico.org.uk/global/contact-us/contact-us-public/ for data subjects based in the UK.
You can request to exercise the rights above by contacting us using the details below. Your rights will in each case be subject to the restrictions set out in applicable data protection laws. Further information on these rights, and the circumstances in which they may arise in connection with our processing of your Personal Data, can be obtained by contacting.
10. Changes to this Privacy Notice
We review and update our Notice from time to time. The most current version will always appear on our Website. If we amend this Notice, in whole or in part, at our sole discretion, any changes will be effective immediately.
11. Contact Information
If you have any questions or queries about this Notice, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at:
- Email: info@propelis.com
- Address: 1330 W Fulton Street STE 800 Chicago, IL 60607, USA
Last Updated: April 2024
