Our Commitment
At Sylvamo, our approach to privacy and data protection begins with our values: we always do the right things, in the right ways, for the right reasons.
An ethical approach. Sylvamo respects individuals’ privacy and values the confidence of its employees, customers, vendors and others with whom we do business. Sylvamo strives to collect, use, disclose and otherwise process personal data 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. We have implemented technical and organizational measures to protect any information we may collect.
Does this Privacy Notice apply to all Sylvamo websites?
Sylvamo and its affiliates (collectively, “Sylvamo,” “we,” “us,” “our”) are responsible for this website, including its mobile versions and designated mobile applications. This Website and Mobile Application Privacy Notice (the “Notice”) describes how we handle personal data we collect and use while you are accessing our website at www.sylvamo.com (our “Website”), any other website we own or operate, or mobile applications that reference this Notice, unless we have implemented a separate privacy notice for a particular site or mobile application. Certain Sylvamo websites and mobile applications may provide additional details about our privacy practices that are specific to those sites. Internal company policies and procedures govern our internal networks and systems and the processing of personal employee information.
Does Sylvamo have a Privacy Notice for job applicants?
Sylvamo does have a separate privacy notice for job applicants that is in the “Careers” section of our Website. If you apply for a job through the Careers section of the Website, Sylvamo will use your personal data as set forth in the “Applicant Data Privacy Notice”.
How does Sylvamo collect personal information and what types of personal information does Sylvamo obtain?
Online. We may collect and process your personal data when you contact us using the “Contact Us” form on the Website, or when you correspond with us by phone, e-mail or otherwise, in connection with the Website. Such data includes information you provide when making a purchase, reporting a problem, participating in online surveys or in other instances where you provide us with information in connection with the Website. It may include, for example, your name, postal address, telephone number, email address and IP address.
Offline. We may also receive personal information from you offline, such as when you visit our company, attend one of our events, place an order over the phone or contact customer service. We may also receive personal information about you from other sources such as public databases.
How does Sylvamo use cookies or other tracking technology?
We automatically collect basic technical information from all Website users – such as your IP address – through our automatic data collection tools, including cookies. Please see our cookies policy for more information.
How does Sylvamo use your personal data?
Sylvamo may need your personal data to fulfill a contractual relationship with you, to comply with legal obligations, or to pursue a legitimate interest – for example, to:
Respond to inquiries and fulfil your requests, such when you ask us to send you product information;
Send you administrative information such as information changes to our terms, conditions and policies;
Provide investor services to you;
Communicate with you about products, services and events related to Sylvamo;
Support the sale or transfer of all or a portion of our business or assets;
Review and evaluate your use of (or your decision not to use) our products and services in order to develop and improve the quality of our offerings and strengthen our relationship with you and our other existing and potential customers;
Achieve certain business purposes, such as data analysis, audits, new product development, usage trend identification and determining the effectiveness of our promotional campaigns;
Personalize your visit to the Website and assist you while you use it;
Prevent and detect fraud;
Comply with applicable laws, regulations or codes of practice.
Except where used in support of a contract with you or to fulfill a legal obligation, your personal information will only be used for legitimate interests as set forth above. Where legitimate interest is the basis for processing data, you have a right to object to the processing of your personal data, but where there are compelling reasons to override your objection, Sylvamo will continue to process personal data for those purposes in accordance with applicable law.
Does Sylvamo share your personal information with any third parties?
Business affiliations. Sylvamo may share your personal information with our affiliated companies. We may also use selected third parties to provide us with services, including: companies that provide technical support and assistance with the Website; companies engaged to market and distribute our products; or companies that assist with our internal recruitment, who may have access to personal data that you provide to us. Our affiliates may also have access to personal data that you provide to us, including through or in connection with our Website for the purposes set out in this Notice.
Legal purposes. The servers used in the operation of the Website automatically identify a computer by its IP address. If we, in good faith, determine that you have or are attempting to misuse or harm the Website, we may investigate and cooperate with appropriate law enforcement agencies to protect our rights or property. Similarly, we may share your personal data as required or permitted by law, including to fulfill a legal or regulatory obligation or otherwise to comply with a subpoena or similar legal process or government request. We may also share it when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property or the rights, property or safety of others. In such cases, we may share it with advisors, law enforcement agencies, judicial authorities and regulatory authorities.
Acquisitions. We may also transfer your personal data to a third party that acquires all or part of our assets or shares, or that succeeds us in carrying on all or a part of our business, whether by merger, acquisition, reorganization or otherwise.
Are third-party links accessible on Sylvamo’s Website?
The Website may contain links to other sites that Sylvamo does not control. 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.
Where does Sylvamo store your information?
Sylvamo is a global company with locations in many different countries. Therefore, we may transfer your information from one legal entity to another or from one country to another in order to accomplish the purposes listed above. These countries include the United States (which hosts the Website), member states of the European Union, the Federation of Russia, Canada, Brazil and other countries including some in Asia. We will transfer your information in a manner that is consistent with applicable legal requirements and for the purposes stated above. To accomplish cross-border legal transfers of personal information, Sylvamo relies on standard contractual clauses and other mechanisms permitted under applicable data protection laws and regulations.
How long does Sylvamo retain personal information?
Sylvamo will retain personal information as long as needed to comply with our contractual and legal or regulatory obligations. If the personal information is not subject to contractual or legal obligations, then Sylvamo will only retain the data for as long as is required for the original purpose for which it was collected or as permitted under the applicable data protection laws and regulations. Sylvamo may also retain anonymized data for statistical purposes, as well as to understand and improve our recruitment practices.
What choices do you have about how Sylvamo uses your personal information?
You retain the choice about whether or not to provide Sylvamo with your personal information, but if you choose not to do so, Sylvamo may not be able to perform activities such as considering you for employment or providing information about our products.
Users in Europe, Russia and Brazil. Individuals in Europe (the European Economic Area), Russia and Brazil have certain data privacy rights that include the right to:
Request confirmation as to whether or not their personal data is being processed, and if so, the purpose of the processing;
Request access to their personal data as permitted by law;
Request correction or erasure of their personal data;
Under certain circumstances authorized by law, obtain restriction of processing, seek anonymization or object to the processing of their personal data;
Obtain information regarding potential transfer of personal data to either affiliated companies or selected third parties, or to countries outside the geographical scope covered by their legislation;
Ask us to provide a copy of their personal data to them or to a third party in a digital format.
If you wish to exercise one of the above-mentioned rights, please send us your request via email to [email protected]. Please note, we will seek to verify your identity when we receive an individual rights request from you in order to ensure the security of your personal data. Individuals in Europe, Russia and Brazil also have the right to lodge a complaint about the processing of their personal data with their local data protection authority, which may also be known as a supervisory authority.
Users in California. California residents have certain rights provided in the California Consumer Privacy Act (“CCPA”) and this portion of our Privacy Notice informs California residents how to effectuate those rights. Please note, we will seek to verify your identity when we receive an individual rights request from you in order to ensure the security of your personal data. Please direct any rights requests or additional questions you may have regarding this Privacy Notice to:
Sylvamo Global Ethics and Compliance Office
6400 Poplar Avenue
Memphis, TN 38197
Email: [email protected]
If you do contact us, we will need to collect personal data and other information such as your name, address, telephone number or email in order to verify your identity. You may also authorize an agent to make a request on your behalf, who will need to provide similar information for verification.
Right to Deletion of Personal Data. California residents have the right to request the deletion of personal data as prescribed in Section 1798.105(a) of the CCPA. Sylvamo may not delete some or all requested personal data as allowed or required by applicable law.
Right of Access: Right to Request Disclosure of Data Collection and Sharing Practices. You may request to receive details about how we collect, use, and share your personal data. Specifically, you may request to receive the specific pieces of personal data that we have collected about you. You may also request to receive:
The categories of personal data that we have collected about you
The categories of personal data that we have disclosed for a business purpose,
The categories of sources from which we collected the personal data,
Our purposes for collecting that personal data, and
The categories of parties with whom we share your personal data
Right to Opt-Out of Sale. We do not, and do not intend to, sell your personal data.
Right to not be Discriminated Against for Exercising CCPA Rights. We do not discriminate against you for exercising any CCPA rights, such as the access and deletion rights described above.
Do Not Track
We treat the data of everyone who comes to our site in accordance with this Privacy Notice, regardless of their “Do Not Track” setting.
Security
Sylvamo takes reasonable and appropriate technical, legal and organizational measures, which are consistent with applicable privacy and data security laws to protect personal data in our possession from loss, misuse, unauthorized access, disclosure, alteration and destruction, and to respond to the misuse, loss or unauthorized use of such data.
International Use
You are solely responsible for complying with all local laws, rules and regulations regarding online conduct and Website access. When you are located in Europe, personal data collected from you, including via the Website, will be transferred to recipients in countries located outside Europe (including the United States where this Website is hosted), which may not provide a similar or adequate level of protection compared to that provided by European countries. You hereby expressly consent to the transfer of your personal data to recipients, as described in this Notice, who are located outside of Europe. We will transfer your data in accordance with legal requirements by entering into model contracts and taking other precautions, as necessary.
Children
Sylvamo does not knowingly collect any data from children under 13 years of age through the Website. Sylvamo 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 the Website. However, if the parent or guardian of a child under 13 believes his or her child has provided us with personal data and wants it deleted, that parent or guardian should contact us to remove it from our systems. If Sylvamo discovers we have personal data 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 data on the Website.
Contact information
Questions or comments about this Notice should be submitted to:
Sylvamo Global Ethics and Compliance Office
6400 Poplar Ave
Memphis, TN 38197
Email: [email protected]
Or
Lorraine Van Eyll, General Counsel, Europe
Email: [email protected]
Or
Marina Guglielmi, Data Protection Officer – Brazil
Email: [email protected]
Or
Guseva Irina Ivanovna, Data Protection Officer – Russia
Email: [email protected]
Updates to this Privacy Notice
We evaluate our privacy policies and procedures to implement improvements and refinements from time to time. If we make material changes to this Notice, we will notify you by means of a prominent notice on the Website prior to the change becoming effective. This Notice is also a part of our Terms and Conditions for the Website.
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