“Data Subject” means the individual to whom any given Personal Data covered by this Privacy Shield Policy refers.
“Personal Data” means any information relating to an individual residing in the European Union and Switzerland that can be used to identify that individual either on its own or in combination with other readily available data.
“Sensitive Personal Data” means Personal Data regarding an individual's racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, physical or mental health, or sexual life.

This Privacy Shield Policy applies to Personal Data transferred from European Union member countries and Switzerland to Justman Packaging & Display’s operations in the U.S. in reliance on the respective Privacy Shield framework and does not apply to Personal Data transferred under Standard Contractual Clauses or any approved derogation from the EU Directive.
Some types of Personal Data may be subject to other privacy-related requirements and policies. For example:

• Some Justman Packaging & Display websites have their own privacy policies.
• Personal Data regarding and/or received from a client is also subject to any specific agreement with, or notice to, the client, as well as additional applicable laws and professional standards.
• Employee Personal Information is subject to internal human resource policies including the Employee Data Privacy Notice.
  All employees of Justman Packaging & Display that have access in the U.S. to Personal Data covered by this Privacy Shield Policy are responsible for conducting themselves in accordance with this Privacy Shield Policy. Adherence by Justman Packaging & Display to this Privacy Shield Policy may be limited to the extent required to meet legal, regulatory, governmental, or national security obligations, but Personal Data covered by this Privacy Shield Policy shall not be collected, used, or disclosed in a manner contrary to this policy without the prior written permission of Justman Packaging & Display’s Chief Privacy Officer.
  Justman Packaging & Display employees responsible for engaging third parties to which Personal Data covered by this Privacy Shield Policy will be transferred are responsible for obtaining appropriate assurances that such third parties have an obligation to conduct themselves in accordance with the applicable provisions of this Privacy Shield Principles, including any applicable contractual assurances required by Privacy Shield.
  
  
  Privacy Shield Principles
  
  Justman Packaging & Display commits to subject to the Privacy Shields’ Principles all Personal Data received by Justman Packaging & Display in the U.S. from European Union member countries and Switzerland in reliance on the respective Privacy Shield framework.
  
  1. Notice
     Justman Packaging & Display notifies Data Subjects covered by this Choice Privacy Shield Policy about its data practices regarding Personal Data received by Justman Packaging & Display in the U.S. from European Union member countries and Switzerland in reliance on the respective Privacy Shield framework, including the types of Personal Data it collects about them, the purposes for which it collects and uses such Personal Data, the types of third parties to which it discloses such Personal Data and the purposes for which it does so, the rights of Data Subjects to access their Personal Data, the choices and means that Justman Packaging & Display offers for limiting its use and disclosure of such Personal Data, how Justman Packaging & Display’s obligations under the Privacy Shield are enforced, and how Data Subjects can contact Justman Packaging & Display with any inquiries or complaints.
  2. Choice
     If Personal Data covered by this Privacy Shield Policy is to be used for a new purpose that is materially different from that for which the Personal Data was originally collected or subsequently authorized, or is to be disclosed to a non-agent third party, Justman Packaging & Display will provide Data Subjects with an opportunity to choose whether to have their Personal Data so used or disclosed. Requests to opt out of such uses or disclosures of Personal Data should be sent to: us-privacy@justmanpackaging.com
     If Sensitive Personal Data covered by this Privacy Shield Policy is to be used for a new purpose that is different from that for which the Personal Data was originally collected or subsequently authorized, or is to be disclosed to a third party, Justman Packaging & Display will obtain the Data Subject’s explicit consent prior to such use or disclosure.
  3. Information Sharing and Accountability for Onward Transfer
     To effectively process data on behalf of a Justman Packaging & Display client (Client) to serve the Client’s needs, Justman Packaging & Display may need to share that data with certain third parties or sub-processors. In such instances, Justman Packaging & Display will execute any needed contracts, clauses or addenda to ensure that any third-party agents that it engages to process personal data does so in a manner that is consistent with the Privacy Shield Principles.
     Justman Packaging & Display will never share information gathered through Clients with any non-Governmental third parties for promotional purposes. The vendors that Justman Packaging & Display shares information with do not use it for any purpose other than to enhance our ability to deliver services to you and our Clients and are bound to keep the information confidential.
     In the case of an onward transfer, Justman Packaging & Display retains responsibility for the processing of personal information it receives under the Privacy Shield. Justman Packaging & Display will remain liable for subsequent transfers to third parties acting as an agent on its behalf if its agent processes such personal information in a manner inconsistent with the Privacy Shield Principles, unless Justman Packaging & Display proves that it is not responsible for the event giving rise to the damage.
     In the event we transfer Personal Data covered by this Privacy Shield Policy to a third party acting as a controller, we will do so consistent with any notice provided to Data Subjects and any consent they have given, and only if the third party has given us contractual assurances that it will (i) process the Personal Data for limited and specified purposes consistent with any consent provided by the Data Subjects, (ii) provide at least the same level of protection as is required by the Privacy Shield Principles and notify us if it makes a determination that it cannot do so; and (iii) cease processing of the Personal Data or take other reasonable and appropriate steps to remediate if it makes such a determination. If Justman Packaging & Display has knowledge that a third party acting as a controller is processing Personal Data covered by this Privacy Shield Policy in a way that is contrary to the Privacy Shield Principles, Justman Packaging & Display will take reasonable steps to prevent or stop such processing.
     With respect to our agents, we will transfer only the Personal Data covered by this Privacy Shield Policy needed for an agent to deliver to Justman Packaging & Display the requested product or service. Furthermore, we will (i) permit the agent to process such Personal Data only for limited and specified purposes; (ii) require the agent to provide at least the same level of privacy protection as is required by the Privacy Shield Principles; (iii) take reasonable and appropriate steps to ensure that the agent effectively processes the Personal Data transferred in a manner consistent with Justman Packaging & Display’s obligations under the Privacy Shield Principles; and (iv) require the agent to notify Justman Packaging & Display if it makes a determination that it can no longer meet its obligation to provide the same level of protection as is required by the Privacy Shield Principles. Upon receiving notice from an agent that it can no longer meet its obligation to provide the same level of protection as is required by the Privacy Shield Principles, we will take reasonable and appropriate steps to stop and remediate unauthorized processing.
     Justman Packaging & Display remains liable under the Privacy Shield Principles if an agent processes Personal Data covered by this Privacy Shield Policy in a manner inconsistent with the Principles, except where Justman Packaging & Display is not responsible for the event giving rise to the damage.
  4. Security
     Justman Packaging & Display takes reasonable and appropriate measures to protect Personal Data covered by this Privacy Shield Policy from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, taking into due account the risks involved in the processing and the nature of the Personal Data.
  5. Data Integrity and Purpose Limitation
     Justman Packaging & Display limits the collection of Personal Data covered by this Privacy Shield Policy to information that is relevant for the purposes of processing. Justman Packaging & Display does not process such Personal Data in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by the Data Subject.
     Justman Packaging & Display takes reasonable steps to ensure that such Personal Data is reliable for its intended use, accurate, complete, and current. Justman Packaging & Display takes reasonable and appropriate measures to comply with the requirement under the Privacy Shield to retain Personal Data in identifiable form only for as long as it serves a purpose of processing, which includes Justman Packaging & Display’s obligations to comply with professional standards, Justman Packaging & Display’s business purposes and unless a longer retention period is permitted by law, and it adheres to the Privacy Shield Principles for as long as it retains such Personal Data.
  6. Access
     Data Subjects whose Personal Data is covered by this Privacy Shield Policy have the right to access such Personal Data and to correct, amend, or delete such Personal Data if it is inaccurate or has been processed in violation of the Privacy Shield Principles (except when the burden or expense of providing access, correction, amendment, or deletion would be disproportionate to the risks to the Data Subject’s privacy, or where the rights of persons other than the Data Subject would be violated). Requests for access, correction, amendment, or deletion should be sent to: us-privacy@justmanpackaging.com
  7. Recourse, Enforcement, and Liability
     Justman Packaging & Display’s participation in the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework is subject to investigation and enforcement by the Federal Trade Commission.
     In compliance with the Privacy Shield Principles, Justman Packaging & Display commits to resolve complaints about your privacy and our collection or use of your Personal Data. Data Subjects with inquiries or complaints regarding this Privacy Shield Policy should first contact Justman Packaging & Display at: us-privacy@justmanpackaging.com
     Justman Packaging & Display has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit https://www.jamsadr.com/file-an-eu-us-privacy-shield-claim for more information or to file a complaint. The services of JAMS are provided at no cost to you.
     Under certain conditions detailed in the Privacy Shield, Data Subjects may be able to invoke binding arbitration before the Privacy Shield Panel to be created by the U.S. Department of Commerce and the European Commission.
     Justman Packaging & Display agrees to periodically review and verify its compliance with the Privacy Shield Principles, and to remedy any issues arising out of failure to comply with the Privacy Shield Principles. Justman Packaging & Display acknowledges that its failure to provide an annual self-certification to the U.S. Department of Commerce will remove it from the Department’s list of Privacy Shield participants.
  
  
  Changes to this Privacy Shield Policy
  
  This Privacy Shield Policy may be amended from time to time consistent with the requirements of the Privacy Shield. Appropriate notice regarding such amendments will be given.