Last revised: December 1, 2015
International Paper Company and its affiliates (collectively, “International Paper or IP”) respect individual privacy and values the confidence of its associates, customers, vendors and others with whom we do business. International Paper strives to collect, use and disclose personal information in a manner consistent with the laws of the countries in which we do business, and we pride ourselves on upholding the highest ethical standards in our business practices.
Definition. For purposes of this policy, personally identifiable information means any information or set of information, whether alone or in combination with other personal information, that International Paper can use, directly or indirectly, to identify a person. Personal information does not include information that is anonymous, nor does it include publicly available information that has not been combined with non-public personal information.
When gathering, processing, storing, using or disclosing personal information, International Paper shall observe the following principles:
Commitment to privacy. International Paper strives to collect, use and disclose personal information in a manner consistent with its core values and the laws of the countries in which we do business.
Notice and consent. International Paper makes an effort to inform persons whose personal information we collect about:
- The purpose for which we collect and use their personal information
- The types of third parties to which we disclose or may disclose that information
- The choices and means we offer the subjects of the information for limiting its use and disclosure
Choice. International Paper will also make an effort to offer persons whose information we possess an opportunity, where feasible and reasonable under the circumstances, to choose whether their personal information is (a) to be disclosed to a third party, or (b) to be used for a purpose other than that for which it was originally collected or subsequently authorized by the individual. International Paper will also make the effort to give individuals methods, reasonable under the circumstances, to exercise their choices.
Access and correction. Upon request and where required or otherwise appropriate, and within periods (if any) set by applicable law, International Paper will endeavor to grant individuals reasonable access to the personal information we have about them. The company may deny access where such denial is permitted by applicable law and where:
- Access could potentially disclose the personal information of somebody else and therefore violate another’s privacy rights
- Access could potentially disclose information relating to any ongoing International Paper investigation
- Access could potentially disclose International Paper’s confidential information
- The cost of access would be significantly disproportionate to the benefits of it
- International Paper has a good-faith belief that the request is not to correct data but to hide or alter data that could adversely affect the individual requesting the correction
- At any point it becomes clear that any individual’s access requests are unjustified or harassing in nature
In the event a request is denied, International Paper will notify the requestor in writing about the reasons for the denial. Consistent with how your information is maintained in the ordinary course of International Paper’s business, International Paper will provide the information in an understandable form. We may impose a reasonable charge when a request is made – for example, for photocopying or postage. International Paper will also take reasonable steps to allow individuals to correct, amend or delete information that is shown to be inaccurate or incomplete. To guard against fraudulent requests for access, International Paper may require sufficient information to confirm the identity of the individual making the request before granting access.
Data integrity. International Paper will endeavor to use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. International Paper will also take reasonable steps to ensure the personal information is relevant to its intended use, accurate, complete and current.
- It is required by a court order
- International Paper has reasonable grounds to believe it is necessary to protect the rights, privacy, safety or property of a person or group of persons
- It is necessary to establish or collect monies owed to International Paper or to complete a transaction with a third party
- It is necessary to permit IP to pursue available remedies or limit any damages we may sustain
- The information is public
Where we are obliged or permitted to disclose personal information, IP will not disclose more than is required. International Paper does not otherwise sell or rent personal information to other persons or entities except as specifically disclosed at the point of collection.
Access and disclosure outside the United States. Because our company does business in many countries, information collected by International Paper in one country may be processed in another country, including the United States of America, whose laws may provide different levels of protection from those in the country where the information is first collected. Personal information gathered in one country may be subject to access by and disclosure to law enforcement agencies of jurisdictions other than the country where the information is first collected. International Paper may also share personal information with organizations and entities that perform services on our behalf, and these organizations and entities may be located in countries other than the country in which the information is first collected.
Information collection. When you browse an IP website, you do so anonymously, and your personal information is not collected. Some areas of our websites, however, may request that you voluntarily supply us with personal information including your name, email address or the like for purposes such as correspondence, site registration, making a purchase, or participating in online surveys. In those instances, you may decline to provide your personal information, but as a result you may not be able to access those features. International Paper also may retain electronic communications you send to our customer service representatives, other representatives, webmasters, associates or service providers as a means to continually improve customer service.
International Paper websites track information about your visits to them. International Paper may collect certain non-personal information from you, which does not reveal your personal identity, such as browser information, information collected through cookies, pixel tags and other technologies, and aggregated information. For example, International Paper may use such information to compile statistics showing the daily requests for particular files on a site and what countries those requests come from. We use these statistics to customize our websites to better meet your needs and may also provide them to others.
Cookies. International Paper uses “cookies,” which are standard features of websites that allow the company to store small amounts of on data of your computer about your visit to our Site. Cookies help you navigate the Site and allow us to learn which areas of the Site are useful and which areas need improvement. International Paper uses several types of cookies. Essential, authentication and functionality cookies enable you to navigate the Site and to use its services and features. Without these necessary cookies, the Site will not perform as smoothly for you as we would like it to and some services may not be available to you. Preference cookies collect information about your choices and preferences, and ensure, for example, that the Site is customized to your preferred language. Finally, analytics cookies collect information about your use of the Site, and enable us to improve the way that it works.
Managing Cookies. You may refuse or accept cookies from the Site at any time by activating settings on your browser. Information about the procedure to follow in order to enable or disable cookies can be found on your Internet browser provider’s website via your help screen. You may wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html for information on commonly used browsers. Please be aware that if cookies are disabled, not all features of the Site may operate as intended.
IP addresses. Your “IP address” is a number automatically assigned to the computer you are using by your Internet Service Provider (ISP). When you visit an International Paper website, your IP address is automatically identified and logged, along with the time of your visit and the pages you visited or viewed. Collecting IP addresses is a common practice on the Internet. International Paper uses IP addresses to present content tailored to your country and for administering the Site. International Paper treats IP addresses as non-personal information.
Other websites. International Paper websites may contain links to other sites, and we make every effort to link only to sites that share our high standards and respect for privacy. However, we are not responsible for the content of, or the privacy practices employed by, those sites.
Children. International Paper does not knowingly collect any personal information (such as name, address and telephone number) from children under 13 years of age through our website. International Paper will specifically instruct children under 13 not to submit such information. We do not currently allow children under 13 to register for or participate in contests or promotions on this Site. However, if the parent or guardian of a child under 13 believes his or her child has provided us with personally identifiable information and wants it deleted, that parent or guardian should contact us to remove it from our systems. If International Paper discovers we have personally identifiable information about a child under 13 in retrievable form in our files, we will delete it. In addition, anyone under 18 years of age should get the permission of a parent or guardian prior to using or disclosing any personal information on our Site.
Security. International Paper takes reasonable and appropriate precautions to protect personal information in our possession from loss, misuse, unauthorized access, disclosure, alteration and destruction, and to respond to the misuse, loss or unauthorized use of such information.
International Paper Global Ethics & Compliance Office
6400 Poplar Avenue
Memphis, TN 39197