Privacy Notice – Effective December 2022

This Web site (“Web site”) is operated by Toppan Merrill LLC (“Toppan Merrill”). The terms “Toppan Merrill,” “we,” “us,” “our” and “ours” when used in this privacy notice (“Privacy Notice”) includes parents, subsidiaries, divisions, branches, affiliates, or companies of Toppan Merrill. The terms “you,” “your” and “yours” when used in this Privacy Notice means any user of this Web site.

IMPORTANT: BY SUBMITTING PERSONAL DATA TO US AND/OR BY USING OUR WEB SITE, YOU GIVE YOUR CONSENT THAT ALL PERSONAL DATA THAT YOU SUBMIT MAY BE PROCESSED BY US IN THE MANNER AND FOR THE PURPOSES DESCRIBED BELOW.

Scope of Privacy Notice

You may visit our public Web site without providing any information about yourself. This Privacy Notice describes our current policies and practices with regard to personal data collected by us from you directly and/or through the Web site or Service Tools (as defined below). The term “personal data” refers to personally identifiable information about you. This Privacy Notice applies only to operation of Web sites that directly link to this notice when you click on the Privacy Notice link.

Service Tools

We provide service facilitation tools including, Toppan Merrill Bridge™ and Toppan Merrill Connect™ (“Service Tools”). These Service Tools are part of a business relationship. If you engage in a business relationship with Toppan Merrill, you are agreeing to the use of your contact details in accordance with this Privacy Notice. We may contact you regarding updates, modifications and additional service offerings. Your access to these Service Tools will be retained and used for support, transition and maintenance, as well as to comply with reporting, audit and data retention requirements.

Notification of changes to this Notice

Toppan Merrill is continually improving our methods of communication and adding new functionality and features to this Web site and to our existing services. Because of these ongoing changes, changes in the law and the changing nature of technology our data practices may change. We encourage you to check this page frequently and anytime you submit personal information via the Web site.

Collection, Use and Disclosure of your personal data

When you use our products and services or request information, we request personal information about you such as your name, employer’s address, e-mail address and telephone number. We may also ask for demographic information to enable us to provide you with a personalized service. The information you provide is either manually or electronically stored in our databases. We may share your personal data under these limited circumstances:

• Toppan Merrill offers you the opportunity to choose (opt out) whether your personal data is (a) to be disclosed to third parties, except when disclosure is made to a third party that is acting as an agent to perform task(s) on our behalf and under our instructions (see below) or (b) to be used for a purpose that is materially different from the purpose for which it was originally collected or subsequently authorized by the individual. Toppan Merrill will provide you with clear, conspicuous, and readily available mechanisms to exercise your choices should applicable circumstances arise. In order to request that Toppan Merrill not use your personal data, you should contact Toppan Merrill by email at [email protected].
• In order to provide you with the requested information on products or services, your personal data may be shared with other companies within our group of companies and third parties who act for us for further processing in accordance with the purposes for which the data was originally collected or for purposes to which you have consented. For example, sometimes a third party may have access to your personal data in order to support our information technology or to handle mailings on our behalf. Toppan Merrill requires that all third-party processors process your personal data with the same level of protection and in a manner consistent with the uses agreed upon in this Notice.
• We will keep your contact details on our database, and we may use your personal data for marketing purposes and market research. If you do not wish to receive e-mails or post from us for these purposes, please let us know by following the “unsubscribe” procedure described herein. We may use your personal data to administer this Web site and help us improve our services.
• We may share your personal data with other companies within our group of companies who may contact you about their products or services that may interest you.
• We may disclose the information in our databases and server logs to comply with a legal requirement, for the administration of justice, for the purposes of national security only to the extent that is strictly necessary and proportionate, to interact with anti-fraud databases, to protect your vital interests, to protect the security or integrity of our databases or this Web site, to take precautions against legal liability, or in the event of our sale, merger, reorganization, dissolution or similar event.
• If you submit your resume or CV, we will use the information to process your inquiry and to monitor recruitment statistics. Personal information about unsuccessful candidates will be held for 12 months before being destroyed or deleted.
• In the event of a corporate sale, merger, reorganization, dissolution or similar event, your personal data may be part of an asset transfer or sale.
• Toppan Merrill does not sell your personal information for consideration.

Data Security

We will take every sensible precaution to protect the information we collect from you including physical, technical, and organizational procedures to safeguard and secure the information from loss, misuse, unauthorized access, or disclosure. Access to this information is protected both online and off-line.

Anonymous data collected through this Web site

In addition to the information we collect as described above, we use technology to collect anonymous information about the use of our Web site. For example, our Web server automatically logs which pages of our Web site our visitors view, their IP addresses and which Web browsers our visitors use. This technology does not identify you personally; it enables us to compile statistics about our visitors and their use of our Web site. Our Web site contains hyperlinks to other pages on our Web site. We may use technology to track how often these links are used and which pages on our Web site our visitors choose to view.

Cookies

In order to collect the anonymous data described herein, we may use temporary “cookies” that remain in the cookies file of your browser until the browser is closed. Cookies by themselves cannot be used to discover the identity of the user. A cookie is a small piece of information which is sent to your browser and stored on your computer’s hard drive. Cookies do not damage your computer. You can set your browser to notify you when you receive a cookie. This enables you to decide if you want to accept it or not.

Data access and corrections

Upon receipt of your written request and by providing enough information to permit us to identify your contact data, we will disclose to you the personal data we acquired and hold about you, for which we may make a small charge. Upon request, we will correct, amend, or delete any personal data that is inaccurate and notify any third-party recipients of the necessary changes. You may update any information you have given to us by contacting us at [email protected]. Requests to delete personal data are subject to any applicable legal and ethical reporting or document retention obligations imposed on us.

Links to other Web sites

This Web site may contain hyperlinks to Web sites that are not operated by us. These hyperlinks are provided for your reference and convenience only and do not imply any endorsement of the activities of these third-party Web sites or any association with their operators. We do not control these Web sites and are not responsible for their operation, data or privacy practices. We urge you to review any privacy notice posted on any site you visit before using the site or providing any personal data about yourself.

Server Location

Toppan Merrill has data servers located in the U.S. If you are visiting this Web site from a country other than the country in which our servers are located, the various communications may result in the transfer of information across international boundaries. If you are accessing a Service Tool, the content data will be stored in accordance with the terms and conditions outlined in an agreement. However, your access information (e.g. user id and password), may be stored in the server located in the U.S. (see Toppan Merrill’s Continued Adherence to Privacy Shield Framework Principles below). Any personal data will be protected in accordance with this Privacy Notice. By visiting this Web site and communicating electronically with us, you consent to the processing and transfer of your data as set out in this Privacy Notice.

Continued Adherence to Privacy Shield Framework

Toppan Merrill continues to maintain compliance with the Principles in the EU-U.S. Privacy Shield Framework regarding the collection, use and retention of personal information as well as the notice, choice, onward transfer, security, data integrity, access and enforcement requirements from European Union member countries. If there is any conflict between the terms in this Notice and the Privacy Shield Framework Principles, the Privacy Shield Framework Principles shall govern.

For a listing of U.S. organizations that have self-certified to the Department of Commerce and declared their commitment to adhere to the Principles, visit https://www.privacyshield.gov/list.

By adopting the Privacy Shield Framework Principles, Toppan Merrill understands that it is subject to the investigatory and enforcement powers of the Federal Trade Commission and may be liable, under U.S. law, in cases of onward transfer of data to third parties outside the permitted uses agreed upon in this Notice.

For additional information, please refer to Privacy Policy FAQs

Enforcement

We will regularly review how we are meeting privacy objectives. In compliance with the Privacy Shield Framework Principles, Toppan Merrill commits to resolve complaints about our collection or use of personal information. EU and UK individuals with inquiries or complaints regarding Privacy Shield Framework Principles should first contact Toppan Merrill at [email protected].

Toppan Merrill has further committed to refer unresolved Privacy Shield related complaints to Judicial Arbitration and Mediation Services (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/about/submit-a-case for more information or to file a complaint. The services of JAMS are provided at no cost to you. Further, we commit to cooperate with EU data protection authorities (DPAs) and comply with the advice given by such authorities with regard to human resources data transferred from the EU in the context of the employment relationship.

The General Data Protection Regulation (GDPR)

Toppan Merrill is compliant with GDPR. Direct related questions to [email protected].

California Consumer Privacy Act (CCPA)

Toppan Merrill is compliant with CCPA. Direct related questions to [email protected].

Contact Us: Mail Unsubscribe

If you no longer wish to receive electronic mail, please click the “unsubscribe” link located at the bottom of the e-mail, or, by writing to us at: Toppan Merrill LLC, 1501 Energy Park Drive, St. Paul, MN 55108, Attn: Opt-Out List Master.