Effective Date: February 28, 2023

This Privacy Notice (“Notice”) is provided pursuant to the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, referred to as “CCPA”), and describes how Greif and its affiliates (“Greif” “us,” “we,” or “our”) process Personal Information of California consumers. This Notice supplements our other privacy policies and notices, including our Online Privacy Policy. In the event of a conflict between any other policy, statement, or notice and this Notice, this Notice will prevail as to California consumers and their rights under California privacy law.

As used in this Notice, the term “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you. Personal Information does not include information that is publicly available, de-identified, or aggregated.

Unless otherwise noted, the disclosures below that describe how and why we collect and use Personal Information also describe how and why we have collected and used Personal Information within the past twelve (12) months.

COLLECTION AND USE OF YOUR PERSONAL INFORMATION

We collect the following categories of Personal Information about California consumers. Note that the Personal Information we collect about you may vary depending on the nature of your interactions with us and may not include all of the examples below (some of which may be listed in multiple categories).

• Identifiers (such as name, email address, mailing address, telephone number, device identifier, Internet Protocol address, or other similar identifiers)
  
  
  • How We Use the Information: (1) to process your purchases, online orders, returns, exchanges, and other transactions, (2) to communicate with you, including to respond to your inquiries and to obtain your feedback, (3) to send you marketing materials and advertisements, (4) to recognize you when you use our website, (5) to allow you to participate in the features we offer on the website, (6) to audit, research and analyze your use of our website, (7) to maintain and improve the website, (8) to detect and prevent fraud, and (9) for any other internal business purposes
  • Sources of Personal Information: (1) directly from you, (2) automatically when you use our website, and (3) from Service Providers that help us to run our business
  • Categories of Recipients of Personal Information: Service Providers that help us to run our business
  • Why We Disclose Personal Information: so that our Service Providers can assist us in providing you with the products or services you requested, for customer service purposes, and for online security purposes
    
    
• Personal information described in Cal. Civ. Code § 1798.80(e) (such as name, email address, mailing address, telephone number, and payment card information)
  
  
  • How We Use the Information: (1) to process your purchases, online orders, returns, exchanges, and other transactions, (2) to communicate with you, including to respond to your inquiries and to obtain your feedback, (3) to send you marketing materials and advertisements, and (4) to detect and prevent fraud
  • Sources of Personal Information: directly from you and from Service Providers that help us to run our business
  • Categories of Recipients of Personal Information: Service Providers that help us to run our business
  • Why We Disclose Personal Information: so that our Service Providers can assist us in communicating with you, including providing you with the products or services you requested and for customer service purposes
    
    

• Commercial Information (such as records of products or services purchased, or purchasing or consuming histories)
  
  
  • How We Use the Information: (1) to manage the customer relationship including returns, exchanges, and other transactions, (2) to send you marketing materials and advertisements, and (3) to detect and prevent fraud
  • Sources of Personal Information: your purchases/purchase history related to your shopping experience with us
  • Categories of Recipients of Personal Information: Service Providers that help us to run our business
  • Why We Disclose Personal Information: (1) to process your purchases, online orders, returns, exchanges, and other transactions, (2) to communicate with you, including to respond to your inquiries, and (3) to market or advertise to you
    
    
• Internet or other electronic network activity information (such as browsing and search history on our website and information about how you interact with our website)
  
  
  • How We Use the Information: (1) to allow you to use the features we offer on the website, (2) to facilitate, manage, personalize, and improve your website experience, (3) to provide you with recommendations, (4) to audit, research and analyze your use of our website, (5) to maintain and improve the website, and (6) to detect and prevent fraud
  • Sources of Personal Information: obtained automatically when you use our website and from Service Providers that help us to run our business
  • Categories of Recipients of Personal Information: Service Providers that help us to run our business
  • Why We Disclose Personal Information: for security purposes and to improve our website and service
    
    
• Sensory data (such as audio recordings of customer calls and CCTV)
  
  
  • How We Use the Information: (1) to provide you with customer service, and (2) for security purposes
  • Sources of Personal Information: directly from you and from Service Providers that help us to run our business
  • Categories of Recipients of Personal Information: Service Providers that help us to run our business
  • Why We Disclose Personal Information: to provide you with customer service and for security purposes
    
    
• Inferences (such as information about your preferences and your buying behaviors or tendencies)
  
  
  • How We Use the Information: (1) to provide you with appropriate recommendations, (2) to improve the website, and our products, marketing, and advertising, (3) to help you find relevant products more quickly, and (4) to provide you with a better website experience
  • Sources of Personal Information: from Service Providers that help us to run our business and automatically when you use our website
  • Categories of Recipients of Personal Information: N/A
  • Why We Disclose Personal Information: N/A

In addition to the uses and disclosures of personal information described above, we may use and disclose any personal information as reasonably necessary to comply with law and legal requirements, cooperate with and respond to law enforcement requests, or as otherwise required by applicable law, court order, or governmental regulations. We also use personal information we collect as necessary to maintain appropriate records for internal administrative purposes, to protect our rights and interests or those of others, to resolve any disputes, to enforce our policies, or to prevent harm. Any personal information we collect may be provided to our professional advisors, including accountants, auditors, consultants, and lawyers, when reasonably necessary for our professional advisors to perform services for us and give us appropriate advice. Any and all personal information we collect may be given to another company in the event of a transaction such as a sale, merger, or other acquisition of some or all of our assets or business or as part of the negotiation or evaluation of such sale, merger, or other acquisition.

DISCLOSURES OF YOUR PERSONAL INFORMATION

Under California law, a “sale” of Personal Information does not necessarily involve an exchange of money. Instead, the term also includes disclosures of Personal Information to third parties under circumstances where the third parties may use the information for their own purposes. We do not sell (or share for cross-context behavioral advertising) the Personal Information of California consumers. We do not have actual knowledge that we sell or share the Personal Information of consumers under 16 years of age.

We may disclose the categories of Personal Information provided below to contractors and service providers for a business or commercial purpose:

o  Identifiers
o  Personal information described in Cal. Civ. Code § 1798.80(e)
o  Commercial Information
o  Internet or other electronic network activity information

HOW LONG WE KEEP YOUR PERSONAL INFORMATION

We may keep any Personal Information for as long as we reasonably need the Personal Information to comply with law and legal requirements, cooperate with and respond to law enforcement requests or court orders, to maintain appropriate records for internal administrative purposes, to protect our rights and interests or those of others, to resolve any disputes, to enforce our policies, or to prevent harm.

Where information is used for more than one purpose, we will retain it until the purpose with the latest period expires. For more information about our retention policies, please contact us at DataPrivacyTeam@Grief.com.

SUBMITTING REQUESTS RELATING TO YOUR PERSONAL INFORMATION

If you are a resident of California, you have the right to submit certain requests relating to your Personal Information as described below. To exercise any of these rights, please submit a request by emailing us at DataPrivacyTeam@Greif.com or by calling us at 1-800-763-0884. Please note that, if you submit a request to know, request to delete or request to correct, you will be asked to verify your identity in accordance with the law. You may designate an authorized agent to make a request on your behalf; however, you will still need to verify your identity directly with us before your request can be processed. An authorized agent may submit a request on your behalf using the webform or toll-free number listed above.

If we decline to fulfill your privacy rights request, we will tell you why, unless we are not legally permitted to do so.

Right to Know. You have the right to request the following details about the Personal Information we have collected about you:

• The categories of Personal Information we have collected about you, including
  1. The categories of sources from which the Personal Information was collected
  2. Our business or commercial purposes for sharing Personal Information
  3. The categories of recipients to which we disclose Personal Information
  4. The categories of Personal Information that we disclosed for a business purpose, and for each category identified, the categories of recipients to which we disclosed that particular category of Personal Information
• The specific pieces of Personal Information we have collected about you
  
  

Right to Delete Your Personal Information. You have the right to request that we delete Personal Information we collected from you, subject to certain exceptions.

Right to Correct Personal Information. If you believe that Personal Information we maintain about you is inaccurate, you have the right to request that we correct that information.

We will not discriminate against you if you choose to exercise any of your privacy rights under the CCPA.

CONTACT US

If you have questions about how Greif handles your Personal Information or if you need to access this notice in an alternative format or language, please contact us by calling 1-800-763-0884 or by emailing us at DataPrivacyTeam@Greif.com.