1. PURPOSE AND SCOPE OF NOTICE

This notice is intended to explain how your Personal Data will be handled by Smurfit Kappa Group (the "Group", "we", "us" and "our") and sets out the information including the personal information detailed below relating to you ("Personal Data") that will be collected and processed by the Group and/or on its behalf by its third party service providers in the context of your dealings with us.

2. APPLICATION OF THIS NOTICE

IMPORTANT: please note that this Notice, while intended to be as complete and accurate as reasonably possible, is not exhaustive and may be updated from time to time in accordance with section 7 of this Notice.

3. WHAT PERSONAL DATA WE PROCESS

If you use the Website, information about your visits to our Website, your location and IP address, the browser software you use and the date and time you access the Website.

4. WEBSITE USERS
If you visit our Website we may obtain, collect and process your Personal Data for the following purposes:

To provide, improve, test and monitor the effectiveness of the Website;

To monitor metrics such as total number of visitors, traffic data and demographic patterns;

To ensure content on the website is presented in the most effective manner for you and to enhance your use of the website; and

To notify you of any changes to the Website and/or our services.

We obtain, collect and process this personal information based on our legitimate interest in ensuring that the Website is operating smoothly and in order to analyse which content is of most interest to visitors. This helps us to keep the Website available and to improve your experience when you visit the Website.

5. RETENTION OF YOUR PERSONAL DATA

In general, we expect to keep your Personal Data for what we deem a reasonable period. Once we have determined that we no longer need to hold your Personal Data, we will delete it from our systems.

Please note that in certain circumstances, we may hold your data for a longer period, for example, if we are processing an ongoing claim or believe in good faith that the law or a relevant regulator may reasonably in our view expect or require us to preserve your Personal Data.

6. YOUR RIGHTS AND HOW TO EXERCISE THEM

You have a number of rights in relation to your Personal Data, which are set out in this section. In particular these rights include the right to object to processing of your Personal Data where that processing is carried out for our legitimate interests. Note that in certain circumstances these rights might not be absolute.

RIGHT	FURTHER INFORMATION
Right to Object	You have a right to object at any time to the processing of your Personal Data where we process your Personal Data on the legal basis of pursuing our legitimate interests. When we process your Personal Data based on our legitimate interests, we make sure to consider and balance any potential impact on you and your data protection rights. We will not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted by Member State or European Union law).
Right of Access	You have the right to request a copy of the Personal Data held by us about you and to access the information which we hold about you. We will only charge you for making such an access request where we feel your request is unjustified or excessive.
Right to Rectification	You have the right to have any inaccurate Personal Data which we hold about you updated or corrected.
Right to Erasure	In certain circumstances, you may also have your personal information deleted, for example if you exercise your right to object (see below) and we do not have an overriding reason to process your Personal Data or if we no longer require your Personal Data for the purposes as set out in this notice.
Right to Restriction of Processing	You have the right to ask us to restrict processing your Personal Data in certain cases, including if you believe that the Personal Data we hold about you is inaccurate or our use of your information is unlawful. If you validly exercise this right, we will store your Personal Data and will not carry out any other processing until the issue is resolved.
Right to Data Portability	You may request us to provide you with your Personal Data which you have given us in a structured, commonly used and machine-readable format and you may request us to transmit your Personal Data directly to another data controller where this is technically feasible. This right only arises where: (1) we process your Personal Data with your consent or where it is necessary to perform our contract with you; and (2) the processing is carried out by automated means.

We will provide you with information on any action taken upon your request in relation to any of these rights without undue delay and at the latest within 1 month of receiving your request. We may extend this up to 2 months if necessary however we will inform you if this arises. Please note that we may ask you to verify your identity when you seek to exercise any of your data protection rights.

You also have the right to lodge a complaint with the Data Protection Commission. For further information see www.dataprotection.ie.

7. CHANGES TO THIS NOTICE & QUESTIONS

We may amend this Notice on occasion, in whole or part, at our sole discretion. Any changes will be effective immediately upon communicating the revised notice to you.
If at any time we decide to use your Personal Data in a manner significantly different from that stated in this notice, or otherwise disclosed to you at the time it was collected, we will notify you by e-mail or post, and you will have a choice as to whether or not we use your Personal Data in the new manner.

If you have any questions, comments or concerns about the way your Personal Data are being used or processed by the Company, please submit your question, comment or concern in writing to our Data Protection Representative at grouplegal@smurfitkappa.com.