Privacy Policy

This is the general privacy policy (“Privacy Policy”) for Avery Products Corporation dba THRESHOLD (“THRESHOLD”). This Privacy Policy applies to all information THRESHOLD collects or acquires from or about individuals, whether online, offline, or otherwise, and whether existing now or in the future, including, without limitation: (i) via ThresholdSecurity.com and other THRESHOLD owned or controlled websites and their associated mobile sites, THRESHOLD’s mobile apps, and THRESHOLD-branded “consumer experience” third party sites.

This Privacy Policy does not apply to the personal information of individuals in their capacity as prospective, current, or former employees, contract workers, board members, or their emergency contacts, dependents, or beneficiaries.

THRESHOLD does not sell or share your personal information.

THRESHOLD is committed to respecting your privacy and protecting personal information you share with us.

This Privacy Policy explains:

What categories of personal information we collect
The categories of sources from which we collect this personal information
The purposes for which we use your personal information
How we may disclose your personal information
How long we keep your personal information
Changes to this Privacy Policy

By submitting your information to THRESHOLD, you expressly give THRESHOLD permission to receive, store, process and use such information in accordance with this Privacy Policy. This Privacy Policy also constitutes part of the Terms of Use that govern your use of our websites. In addition, this Privacy Policy constitutes part of the terms and conditions (such as official rules) that govern your participation in any and all events and activities offered or sponsored by THRESHOLD.

Assistance For The Disabled

Alternative formats of this Privacy Policy are available to individuals with a disability. Please contact [email protected] for assistance.

You may also Opt-Out of Marketing Communications from THRESHOLD by submitting a request to [email protected]. We may contact you for clarifications as part of this process.

1) WHAT CATEGORIES OF PERSONAL INFORMATION WE COLLECT

Personally Identifiable Information (“PII”) is any information that can identify or is linked to a specific individual, such as your name, mailing address, telephone number (including mobile number), email address, credit card number, debit card number, bank account number and other financial account information, birth date, gender, occupation, personal interests, demographic, location and household information, etc.

We Collect:

Identifiers, for example: real name, alias, telephone number, postal address, e-mail address, signature, photographs, and Social Security, driver’s license, or state identification card.
Commercial Information, for example: records of products or services purchased, and purchasing or consuming histories.
Internet Activity Information, for example: information about your usage of the Site, such as the pages you viewed, the services and features you used or interacted with; your browser type and details about any links or communications with which you interacted; internet protocol (IP); browser plug-in types and versions; and operating systems and platform.
Professional Information, for example: business contact information and title.
Financial Information, for example: payment card details, billing address, and shipping address.
User Content, includes content you submit when you contact customer service or otherwise contact Company. This may include recordings you create, including audio recordings or voicemail you submit in connection with customer service.
Communications Data, for example: during our communications with you, we collect the content of these communications as well as metadata about the communications, e., date and time of the call or text (SMS or MMS) message and phone numbers.
Inferences, for example: Company might infer based on your purchase history that you would be interested in other products or services.

Do We Use Cookies?

Yes. Cookies are small files that the Site or our service provider transfers to your computer’s hard drive through your Web browser that enables the Site’s or service provider’s systems to recognize your browser and capture and remember certain information. We use cookies to help us understand how users use the Site. For example, cookies gather information about how long you spend on a web page so that we can understand what web pages are of most interest to users. For more information please see our cookies policy.

If you prefer, you can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off cookies by adjusting your browser settings. If you turn off your cookies, some of the features on the Site may not function properly.

Google Analytics

We use cookies provided by Google Analytics, a third-party service provider, to assist us in better understanding our Site visitors. These cookies collect data tied to a user’s IP address, such as the length of time a user spends on a page, the pages a user visits, and the websites a user visits before and after visiting the Site. Based on this information, Google Analytics compiles aggregate data about Site traffic and Site interactions, which we use to offer better Site experiences and tools in the future. Google Analytics does not collect any personal information (other than IP Address which may be considered personal information in some countries). For more information on Google Analytics, visit https://support.google.com/analytics.

Web Beacons

We include small graphic images or other web programming code, called web beacons (also known as “pixel tags”, “web bugs” or “clear GIFs”), on the Site. The web beacons are minute graphics with a unique identifier. They are used to track the online movements of Web users. In contrast to cookies, which are stored in a user’s computer hard drive, web beacons are embedded invisibly on Web pages and are about the size of the period at the end of this sentence. Rejecting cookies using browser settings may not stop web beacons from tracking you.

Do Not Track Setting

The Site currently does not respond to web browser “do not track” (DNT) signals or other mechanisms that indicate your preference for having information collected over time and across different web sites following your visit to our Site. DNT is a preference you can set in your browser’s settings to let the website you visit, including the Site, know that you do not want the websites collecting your personal identifiable information. You can also visit https://allaboutdnt.com/ to learn more.

2) THE CATEGORIES OF SOURCES FROM WHICH WE COLLECT YOUR PERSONAL INFORMATION

You, for example, when you register with our Site, subscribe to online services, when you shop with us, register to participate in an event sponsored by THRESHOLD (such as a contest, sweepstakes, giveaway, promotion, survey, etc.) send information via message, chat, blog, post or similar functionality using a product or service of THRESHOLD , when you otherwise provide information directly to us, or print and save projects using THRESHOLD design and print tools (collectively, “Identification Activity”) .
Service providers, for example, analytics providers, IT, and system administration services.
Affiliated companies, for example, so that we can assist other companies in the CCL Industries family of companies in providing you with products or services.
Automated technologies, for example, browsing activity collected by automated technologies on the Site.
Third parties, for example, lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services.
Public sources, for example, public databases.
Marketing/advertising companies, for example, from social media platforms, consumer research companies, and analytics or marketing/advertising companies.
Surveillance/recording technologies installed by Company, for example, video surveillance in common areas of Company facilities, voicemail technologies, and audio recording technologies with consent to the extent required by law.
Government or administrative agencies, for example, law enforcement, public health officials, and other government authorities.
Acquired entity, if Company acquired another entity, Company might collect personal information from that entity.

Engaging in an Identification Activity is a voluntary activity on your part. If you elect to engage in an Identification Activity, THRESHOLD may ask you for certain PII. Depending on the activity, some of the information THRESHOLD asks you to provide may be identified as mandatory and some may be identified as optional. If you do not provide the mandatory information for a particular Identification Activity which requires it, you will not be able to engage in that activity. In addition, if you use THRESHOLD to send information to another person (e.g., a friend, a family member, etc.), THRESHOLD will also collect PII of that other person to the extent disclosed by you.

Aggregate and Anonymous Information (“AAI”) is any information that cannot identify or be linked to a specific individual. For example, THRESHOLD may collect anonymous group data (demographics, online browsing habits, interests and preferences, etc.) about users of our printing tools and services, users and members of THRESHOLD, etc. (collectively, “Users”). THRESHOLD also collects aggregate traffic data pertaining to the site, such as: total page views in a given time period; total impressions; average amount of time that Users spend on our site (or a part thereof) each time they visit; average amount of time that Users spend on each page of any one or more parts of the THRESHOLD site; percentage of Users from a certain geographical area, etc. Moreover, THRESHOLD may combine “User Activity Information” (as described below) about you and other Users of the THRESHOLD site to generate aggregate information that reflects activities, habits, preferences, interests, etc. about our Users as a group. THRESHOLD also collects location-based information such as zip code, city and state name. In addition, THRESHOLD may take PII and make it non-personally identifiable, such as by aggregating your information with information about other individuals, or by removing personally-identifiable elements (such as names) so as to “anonymize” or “de-personalize” your information.

3) THE PURPOSES FOR WHICH WE USE YOUR PERSONAL INFORMATION

Providing Products and Services, including:

To deliver our products and administer our services.
To communicate with you.
To improve our products and services, develop new products and services, and conduct research on further improvements.
To enhance your experience using our products and services and to personalize your online experience.

Support and Marketing, including:

For customer support.
To respond to any requests, queries, suggestions, feedback, or comments you may have.
Where you have agreed to receive such information, to send you marketing information about our products and services, including notifying you of marketing events, membership and rewards programs, promotions, and sweepstakes.
To inform you of any changes to the services, your account (if applicable), this Privacy Policy, or any other policies or terms in relation thereto.
To perform operations to maintain the services, including to conduct data analysis, testing, and research; and to monitor and analyze usage and activity trends.
Interest-based advertising on the THRESHOLD site: THRESHOLD may use your PII to provide to you interest-based ads (i.e., ads potentially relevant or tailored to your interests) about products and services of THRESHOLD and/or other company in our CCL family of brands.

Monitoring, Security, and Compliance, including:

To administer and protect our business and our Site (including troubleshooting, analysis, testing, system maintenance, support, reporting and hosting of data, and preventing fraud and abuse).
To store, host, or backup (whether for disaster recovery or otherwise) our services or any data contained therein.
To protect the rights, property, or safety of Company, you, or others.
In connection with a corporate transaction, sale, or assignment of assets, merger, divestiture, or other changes of control or financial status of Company or any of its subsidiaries or affiliates.
To report suspected criminal conduct to law enforcement and cooperate in investigations.
To exercise Company’s rights under applicable law and to support any claim, defense, or declaration in a case or before a jurisdictional and/or administrative authority, arbitration, or mediation panel.
To ensure compliance with applicable laws and regulatory obligations.

Incidental Purposes: Any incidental purposes related to, or in connection with, the above.

As a general matter, THRESHOLD uses information (PII and AAI) collected from and/or about our Users to improve our products and services so that they are appealing to as many people as possible, to administer and maintain operations of the THRESHOLD Interactive Network, to offer, market and advertise products and services to our Users, to administer and manage transactions and relationships with our Users, to personalize user experiences for our Users, and to build a strong community for our Users.

4) HOW WE MAY DISCLOSE YOUR PERSONAL INFORMATION

Company discloses personal information as necessary for the purposes described in Section 3 above to the following categories of external recipients:

Service providers and contractors: Company discloses your personal information to service providers and contractors for the purposes above to assist us in meeting our business needs and contractual and legal obligations.
- Company only discloses your personal information to service providers and contractors subject to written contracts under Company’s direction and instructions as required by applicable law.
- Service providers and contractors include auditors, administrative service providers, law firms, and any other entity providing services to Company
Affiliated companies: Other companies within the CCL Industries family, for example, to provide you with our products and services.
Government or administrative agencies: For example, Company may report unlawful activity to law enforcement.
Public: Company may disclose personal information to the public as part of a press release, for example, to announce the winner of a sweepstakes if required by state law.
Required Disclosures: We may be required to disclose personal information in a court proceeding, in response to a court order, subpoena, civil discovery request, other legal process, or as otherwise required by law.
Legal Compliance and Protections: We may disclose personal information when we believe disclosure is necessary to comply with the law or to protect the rights, property, or safety of Company, our users, or others.
Corporate Transactions: We reserve the right to disclose and transfer your personal information, including your personal information:
- To a subsequent owner or co-owner.
- In connection with a corporate merger, consolidation, bankruptcy, the sale of substantially all of our membership interests and/or assets or other corporate change, including to any prospective purchasers.

Unrestricted disclosure of AAI

Given the anonymous, non-personally identifiable nature of AAI, there are no restrictions under this Privacy Policy on how THRESHOLD may use, disclose, or otherwise share such information. For example, THRESHOLD may freely share Aggregate and Anonymous Information (AAI) with our Business Partners who may use such data for their own marketing, advertising, research, or other business purposes. THRESHOLD may also freely share AAI with our Service Providers in order for them to perform services to THRESHOLD. THRESHOLD does not sell your personal information or disclose it to third parties for cross-context behavioral advertising. We also do not sell the personal information of children under 16 nor disclose it to third parties for cross-context behavioral advertising.

Third Party Functionalities

The THRESHOLD site contains links to and/or enables certain third-party functionalities to enhance your experience, including, without limitation, social plug-ins, tools and APIs. Prior to using any third-party functionality (e.g., Facebook “Like” button) on the THRESHOLD site, you should consult the privacy notices of the third-party providers of such functionalities (including Facebook and its Custom Audience Tool), as THRESHOLD has no control over information that is submitted to, or collected by, such third parties, or how they may use the information. The privacy policies and data practices of such third parties may significantly differ from this Privacy Policy, and THRESHOLD makes no representation or warranty whatsoever about their policies and practices. Your communications and interactions with such third parties are solely between you and them, and are at your own risk.

To learn more about how to opt out or change your ad targeting preferences with Facebook, visit https://www.facebook.com/ads/preferences/

5) INFORMATION ACCESS & OPT-OUT

Information Access

If you have an active user account on the THRESHOLD site, you may access and update your user account information and preferences at any time (subject to the scheduled maintenance of the THRESHOLD site), by logging into your account and clicking on “My Account” and then changing your preference.

If you do not have an active account on the THRESHOLD site, or if you have provided your information to THRESHOLD offline, you may request to access, delete, update and correct your information as stored by THRESHOLD, by sending your request to us at THRESHOLD, Attn: CSC/Opt Out, P.O. Box 789, Farmington, CT 06034. Your request will be processed as soon as possible.

You may access a list of the personally identifiable information THRESHOLD has in its records about your account on this page. Once you have confirmed your email for your account you will have the options to download your data or request your account and data be deleted.

THRESHOLD does not sell your data.

Opt-Out

You can opt out of all our marketing uses (including email marketing, mobile email marketing, and mobile message marketing) of your PII by sending your request via email at THRESHOLD, Attn: CSC/Opt Out, P.O. Box 789, Farmington, CT 06034.

You may also opt out of marketing communications from THRESHOLD by submitting a request. We may contact you for clarifications as part of this process.

THRESHOLD will endeavor to honor your request promptly after receipt.

In addition, with respect to certain marketing uses of your PII, you may exercise your opt-out choice through the following alternative methods:

Our email / mobile email marketing (i.e., sending marketing emails (including our newsletters) to your Internet email account or your mobile email account):

Use the opt-out means (e.g., an “unsubscribe” link) provided in a marketing email that you have previously received from us.

HOWEVER, please note the following:

For email communications, your opt-out will stop further marketing and promotional emails from us BUT will NOT stop email communications from THRESHOLD relating to your Identification Activity, of a transactional, administrative or relationship nature, or as required by law, such as notification of a material change in this Privacy Policy and/or the Terms & Conditions for the Site, notification of an actual or suspected security breach that affects your Personal Information stored by or for THRESHOLD, etc.

For telemarketing, your opt-out will stop further marketing calls from THRESHOLD but will NOT stop calls from us relating to your Identification Activity of a transactional, administrative or relationship nature, or as required by law, such as notification of a material change in this Privacy Policy and/or the Terms & Conditions for the Site, notification of an actual or suspected security breach that affects your Personal Information stored by or for us, etc.

Data retention

THRESHOLD will retain your PII for as long as your account is active or as needed to provide you products or services, and as necessary to comply with our legal obligations, resolve disputes, and enforce agreements. AAI and AAI may be retained indefinitely.

You may request THRESHOLD delete your account on this page. We will send you an email to confirm your request to delete your data at which time your data will be deleted. Please note that the erasure of your data is permanent and irreversible.

6) PROTECTING CHILDREN

THRESHOLD takes special care to protect the safety and privacy of children. All products and services of the THRESHOLD site are intended for general audiences and are NOT directed to children. THRESHOLD does not knowingly permit children under age 13 to register on the THRESHOLD site for any product or Service. THRESHOLD does not knowingly collect or solicit Personally Identifiable Information about Users under age 13. If you are under the age of 13, you are not authorized to use our services or the Site

Children under age 13 should always ask their parents or guardians for permission before providing any Personally Identifiable Information to anyone online or through mobile devices. Parents and legal guardians should participate in your child’s online and mobile activities and use parental control or other Internet and/or mobile filtering technology to supervise your child’s access to the Internet.

7) LINKS TO THIRD PARTY SITES, SERVICES OR PRODUCTS

The THRESHOLD site contains links to sites operated and maintained by third-parties, as well as links to products and services (including software) provided by third-parties. For example, the THRESHOLD site may display third-party ads, and clicking on such ads will take you to the websites of those advertisers. THRESHOLD has no control whatsoever over such third-parties, their Internet sites, or their products or services. Once you enter a third-party site, this Privacy Policy will no longer apply, and any information collected from or about you on that third-party site will be governed by the privacy policies and practices of that third party. Third-party sites do not follow our Privacy Policy and their privacy practices may be substantially different from this Privacy Policy. Such third-party sites may send their own cookies to you and may collect data about you and make use of that data in ways that we would not. You access such third-party sites, services or products entirely at your own risk. You should always review and understand the privacy policies and practices for such third-party site, service or product before disclosing any personal information on such site or in exchange for such product or service.

8) CHANGES TO THIS PRIVACY POLICY

From time to time, THRESHOLD may change this Privacy Policy in whole or in part, to accommodate new technology, industry practices, regulatory requirements or for other purposes. THRESHOLD will provide notice to you if these changes are material and, where required by applicable law, THRESHOLD will obtain your consent. If you are a registered user or member of the THRESHOLD site (e.g., any of our social networking services), THRESHOLD may notify you of material changes to this Privacy Policy via email and/or may ask you to affirmatively acknowledge and consent to such changes (e.g., by checking a box or clicking a button) at the time of your next account login on the THRESHOLD site.

The effective date of this Privacy Policy is May 1, 2024.

For More Information

For questions or concerns about Company’s privacy policies and practices, please contact us at [email protected].