GDB Circular Privacy Policy

1. Scope of This Privacy Policy

This Privacy Policy applies to information collected:

• Through the Website;
• Through forms submitted on the Website;
• Through emails, telephone calls, text messages, or other communications initiated through the Website;
• When you request information regarding GDB Circular's recycled resin products, plastic scrap purchasing, facilities, services, or business opportunities;
• When you interact with Website features, analytics tools, embedded content, or links that refer to this Privacy Policy.

This Privacy Policy does not apply to information collected by third-party websites, applications, platforms, or services that may be linked from the Website. Those third parties maintain their own privacy policies and practices.

2. Information We Collect

We may collect personal information directly from you, automatically through your use of the Website, and from service providers or business partners.

3. Cookies and Similar Technologies

Cookies are small files stored on your browser or device. We may use cookies and similar technologies to:

• Operate and secure the Website;
• Remember visitor preferences;
• Understand how visitors use the Website;
• Measure Website traffic and performance;
• Identify and resolve technical problems;
• Improve Website content and functionality;
• Prevent fraud, misuse, and unauthorized activity.

Some cookies may be placed by third-party service providers that provide hosting, analytics, security, embedded content, or other Website functionality. You may configure your browser to refuse or delete cookies. Disabling cookies may affect the operation or availability of certain Website features. Where required by law, we will provide a cookie notice or consent-management tool before using non-essential cookies.

4. How We Use Personal Information

We may use personal information to:

• Respond to inquiries, requests, and messages;
• Communicate with prospective and existing customers, suppliers, vendors, and business partners;
• Provide information about recycled resin products, plastic scrap purchasing, facilities, services, or capabilities;
• Evaluate potential purchasing, supply, sales, logistics, or commercial opportunities;
• Prepare quotations, proposals, specifications, and other business communications;
• Process and administer transactions;
• Maintain customer, supplier, and business-partner relationships;
• Provide customer service and operational support;
• Manage Website forms and communications;
• Improve and personalize the Website;
• Analyze Website usage and performance;
• Maintain the security and integrity of our Website, systems, facilities, and business;
• Detect, investigate, and prevent fraud, misuse, security incidents, or unlawful activity;
• Comply with legal, regulatory, contractual, tax, accounting, and reporting obligations;
• Establish, exercise, or defend legal claims;
• Enforce our agreements, policies, and terms;
• Support a merger, acquisition, financing, restructuring, sale, or other business transaction;
• Carry out another purpose disclosed when the information is collected;
• Carry out another purpose with your consent.

5. Legal Bases for Processing

Where applicable law requires us to identify a legal basis for processing personal information, we may process information based on:

• Your consent;
• The performance of a contract or steps taken at your request before entering into a contract;
• Our legitimate business interests, provided those interests are not overridden by your rights;
• Compliance with legal obligations;
• The establishment, exercise, or defense of legal claims;
• Protection of the vital interests, safety, rights, or property of individuals or organizations.

6. How We Disclose Personal Information

We may disclose personal information to the following categories of recipients.

A. Service Providers

We may disclose information to vendors that provide services such as:

• Website hosting;
• Cloud storage;
• Information technology support;
• Cybersecurity;
• Website analytics;
• Customer relationship management;
• Email and communication services;
• Marketing support;
• Professional consulting;
• Accounting, auditing, insurance, and legal services.

These providers are permitted to use personal information only as necessary to provide services to us or as otherwise permitted by law. We may also disclose information to affiliates, subsidiaries, parent companies, or related business entities for legitimate operational, administrative, and commercial purposes; to business partners when necessary to respond to an inquiry, evaluate a transaction, provide requested services, or manage a business relationship; to legal and regulatory authorities where necessary to comply with law, protect rights and safety, investigate unlawful conduct, or enforce agreements; in connection with business transactions; and where you direct us to do so or provide consent. We do not sell personal information for money. If our use of advertising, analytics, or tracking technologies is considered a sale, sharing, or targeted advertising under an applicable state privacy law, eligible residents may have the right to opt out as described below.

7. Data Retention

We retain personal information only for as long as reasonably necessary to:

• Fulfill the purpose for which it was collected;
• Maintain business and commercial records;
• Manage ongoing customer, supplier, or business relationships;
• Comply with legal, regulatory, tax, accounting, and contractual obligations;
• Resolve disputes;
• Enforce agreements;
• Maintain security and prevent fraud.

Retention periods may vary depending on the nature of the information, the relationship involved, and applicable legal requirements.

8. Data Security

We use reasonable administrative, technical, and physical safeguards designed to protect personal information from accidental loss, unauthorized access, misuse, alteration, disclosure, or destruction.

However, no website, electronic transmission, storage system, or security measure is completely secure. We cannot guarantee the absolute security of information transmitted to or stored by us. Information submitted through the Website is provided at your own risk.

You should not send confidential business information, trade secrets, financial account details, government identification numbers, passwords, or other highly sensitive information through an unsecured Website form or ordinary email.

9. Your Privacy Rights

Depending on your location and applicable law, you may have the right to:

• Request access to personal information we maintain about you;
• Request correction of inaccurate personal information;
• Request deletion of personal information;
• Request a portable copy of certain personal information;
• Request restriction of certain processing;
• Object to certain processing;
• Withdraw consent where processing is based on consent;
• Opt out of certain targeted advertising, sales, or sharing of personal information;
• Appeal a decision concerning a privacy request;
• Lodge a complaint with an applicable privacy or data-protection authority.

These rights may be subject to legal limitations and exceptions. To submit a privacy request, contact us using the details in the "Contact Us" section below. We may need to verify your identity before completing your request. Authorized agents may submit requests where permitted by applicable law, subject to verification and authorization requirements. We will not unlawfully discriminate against you for exercising an applicable privacy right.

10. United States State Privacy Rights

Residents of certain U.S. states, including California and other states with comprehensive consumer privacy laws, may have additional rights concerning their personal information.

Depending on the applicable law, these rights may include the right to know what categories of personal information are collected, the sources of that information, the purposes for collection, and the categories of third parties to whom information is disclosed.

Eligible residents may also have the right to request access, correction, deletion, portability, or to opt out of certain sales, sharing, profiling, or targeted advertising.

GDB Circular may deny or limit a request where permitted by law, including where information is needed to complete a transaction, comply with a legal obligation, protect security, prevent fraud, or exercise or defend legal claims.

11. Marketing Communications

We may send business-related or promotional communications where permitted by law.

You may unsubscribe from promotional emails by using the unsubscribe mechanism included in the message or by contacting us. Even after opting out of promotional communications, we may continue to send non-promotional communications concerning inquiries, transactions, business relationships, security, or legal matters.

12. Third-Party Links and Services

The Website may contain links to external websites, social-media platforms, mapping services, industry publications, or other third-party resources.

We do not control and are not responsible for the privacy, security, content, or practices of third parties. Visiting a third-party website is subject to that third party's terms and privacy policy.

The inclusion of a link does not necessarily imply endorsement of the third party or its privacy practices.

13. Children's Privacy

The Website is intended for business and general informational purposes and is not directed to children under 13 years of age.

We do not knowingly collect personal information from children under 13. If we learn that we have collected personal information from a child under 13 without appropriate authorization, we will take reasonable steps to delete it.

Parents or guardians who believe that a child has submitted personal information to us should contact us promptly.

14. International Visitors

GDB Circular operates in the United States. If you access the Website from outside the United States, your information may be transferred to, stored in, and processed in the United States or another country where our service providers operate.

Data-protection laws in those jurisdictions may differ from the laws in your country. Where required, we will use appropriate safeguards for international transfers of personal information.

15. Do Not Track Signals

Some browsers offer a "Do Not Track" setting. Because there is not yet a universally accepted standard for responding to all Do Not Track signals, the Website may not currently respond to such signals.

Where legally required, we will recognize applicable browser-based opt-out preference signals, such as Global Privacy Control, to the extent technically supported and applicable to our data practices.

16. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices, technologies, legal obligations, or Website features.

When we update the policy, we will revise the "Last Updated" date at the top of this page. Material changes may also be communicated through a prominent Website notice or another appropriate method.

Your continued use of the Website after an updated Privacy Policy becomes effective indicates your acknowledgment of the revised policy, except where additional consent is required by law.

17. Contact Us

Questions, comments, or privacy requests may be submitted to:

Please include "Privacy Request" in the subject line of your email and provide sufficient information for us to understand and respond to your request.