Privacy Policy

Introduction

This global privacy policy (the “Privacy Policy”) describes our practices in connection with the personal data that you provide to subsidiary of Domtar Corporation (each a “Group Company”) by any means, including off line forms (e.g., product orders), telephone calls, email, a website which is operated (as indicated in its conditions of use) by a Group Company (the “Site”) (the “Personal Data”). An updated list of our Group Companies is available here.

Domtar Corporation and its Group Companies (“We” or "Us" or “Our”) reserve the right to change this Privacy Policy from time to time at its sole discretion and without sending notice to you, so you should review this Privacy Policy periodically. The effective date of this notice and any revised or changed notice may be found on this page, on the bottom left hand corner of the notice. Any changes will be effective only after the effective date of the change and will not affect any dispute arising prior to the effective date of the change.

1. Effect of Updates to this Privacy Policy

The processing of your Personal Data (also known as personal information) will be governed by the Privacy Policy in force at the time your Personal Data are collected unless otherwise agreed by you or allowed under applicable law.

2. Who determines which Personal Data are collected, how and for which purposes (the data controller)?

The data controller will be:

For products or services contracted offline: the Group Company that contracts with you or collects your personal data, as identified in the terms and conditions applicable to the purchase or use of the relevant product or service.

For products and services contracted online:

All terms and conditions of Our products and services (unless expressly provided for therein), including this Privacy Policy, may be assigned to any third party.

3. How is your Personal Data collected?

Directly from you, when you are interacting with a Group Company, for example information you give Us as requested by phone, email or detailed in the forms you may be asked to complete and also information We collect automatically from your use of Our products and services such as your interaction with adverts that We place on websites or other media.

From third parties: when allowed by law, for example, if you are in the process of contracting for a product or service for which We need to evaluate your financial solvency, We may check your credit rating by consulting financial solvency files held by third parties, We may also receive your Personal Data from third parties for one of the purposes specified below.

4. Which Personal Data and for which purposes are they used by us?

We collect Personal Data (automatically, as detailed in the forms you will be asked to complete or provided by you in your e-mail queries or telephone inquiries, which may include health related data such as a degree of incontinence, prescriptions, etc.) as required for purposes including:

Please note that if you do opt-out of receiving marketing-related messages from Us, We will still send messages as necessary to fulfill other purposes (such as administrative messages relating to the operation of the product or service, for the issuance of invoices/bills, etc.).

Which Personal Data, and for which purposes, are they shared with third parties?

Personal Data may be used or shared with another Group Company or other third parties if:

All of these third party recipients may be located world-wide, including outside of the European Economic Area (EEA) (such as the US*). These countries may provide personal data protection standards that are not necessarily equivalent to those applicable in the EEA (in which case, specific safeguards are adopted by us for personal data originating in the EEA, such as ensuring the third party is subject to another adequacy finding or enters into a written agreement with us requiring that the third party provides a level of privacy protection equivalent to the one required within the EEA).

(*) In particular, this is the case of certain Group Companies in the US, including: Attends Healthcare Products Inc. (8020 Arco Corp Drive, Suite 200, Raleigh NC 27617 USA); Associated Hygienic Products, LLC (1029 Old Creek Rd, Greenville, NC 27834 USA); and Domtar Paper Company, LLC (234 Kingsley Park Drive, Fort Mill, SC 29715, USA); and others.

6. Your responsibilities when you provide Us with or allow Us access to your Personal Data

You must provide accurate Personal Data and only when you are 18 years of age(*) or over and keep them up-to-date. You must comply with any data protection and privacy legal requirements applicable to you. You must comply with and not disable any security measure of a Website. If you are acting as a (legal or de facto) representative of any legal entity, you must only provide your professional contact details in respect of that legal entity (and never your private contact details).

(*) We do not intend to collect, or direct any Personal Data collection to, data of individuals under 18 years old, and We request that these Personal Data are not provided to Us.

7. Managing your rights regarding your Personal Data held by Us as data controller

You may contact Us (for personal care products, at dpc.dataprivacy@domtar.com or for all other inquiries, communications@domtar.com with written proof of your identity) (i) to request a copy of your Personal Data; or (ii) to request that your Personal Data be rectified or deleted if it is inaccurate or incomplete; or (iii) to object to the processing of your Personal Data for certain purposes (such as direct marketing). We will answer your request as soon as reasonably practicable, and in any case, within the term legally determined (if there is one in the relevant jurisdiction).

You may also contact Us to unsubscribe from any of our direct marketing.

8. Cookies

Cookies are information files stored on your computer that help websites remember who you are and information about your visit. In those Websites where cookies are used, you will find a cookie policy which provides detailed information on which cookies are used therein, how to deactivate them and the consequences thereof.

9. Third party websites

The third party websites you access through the Site fall outside of Our control and are not covered by this Privacy Policy but governed by the privacy policies of these third parties’ websites that are neither reviewed nor endorsed by Us. We encourage you to review the privacy policies and terms of use of any third party site that you visit.

10. Computer Information

We log your current Internet address (this is usually a temporary address assigned by your Internet service provider when you log in), the type of operating system you are using, and the type of browser software used. In addition, We may keep track of what portions of this Site you are visiting. We aggregate this information to help Us improve or create a better experience for users of the Site. For example, We may upgrade those parts of the Site that are heavily visited.

Our site automatically records website usage information that We analyze statistically to track operational problems, to prevent fraud and to improve the effectiveness, security and integrity of the site. We do not use this information to track or record information about individuals. We will disclose this information to third parties only in aggregate form or as may be required by law. For each page that you visit, We collect and store the following technical information in what is called a web server log file:

For the purpose of enabling better website design and a better user experience, We employ Google Analytics (a web service by Google, Inc.) to track site traffic and provide aggregate reports of how the public interacts with Our website. Session cookies are employed by Google Analytics in the form of client-side JavaScript code. In utilizing this analytics service, We maintains its existing standards in regards to the sharing and disclosure of information, security and privacy safeguards for the data, and the data retention policy, each described below. Google Analytics analyzes website usage information automatically upon visits to the Our website(s). Users who do not wish to have their visit information collected by Google Analytics may opt-out by downloading a browser extension or by disabling cookies in their browser settings. Opting-out of web measurements will still permit users to access the full website, with all included information and functionality.

11. Tracking

We will respond to Web browser “do not track” signals. If you would like additional information about online tracking and various opt-out mechanisms, please see http://donottrack.us/

From time to time may include third-party advertisements, other parties may collect your personally identifiable information about your online activities over time and across different web sites when you visit this Site.

In addition, We use Google AdWords, so We are advertising the Site online through a form of tracking called remarketing, Third-party vendors, including Google, show Our ads on various sites across the Internet, and use cookies to serve you ads based on your past visits to this Site. You can opt out of Google's use of cookies by visiting Google's Ads Settings https://www.google.com/settings/ads/plugin. Alternatively, you can opt out of a third-party vendor's use of cookies by visiting the Network Advertising Initiative opt-out page. http://www.networkadvertising.org/choices/

Please note that not all tracking will stop even if you delete cookies.

12. Encryption

We use no encryption (data scrambling) on certain portions of the Site, but We use encryption on portions where you are transmitting personal information, such as information to contact Us or to seek employment. When you are on any web site that asks you for confidential information, you should check to see if the information being transmitted is encrypted in order to increase the security of your information. Keep in mind that there is no such thing as perfect security.

13. Additional Rights:

Applicable laws may give you additional rights that are not described in this online privacy policy.

For further information on Privacy matters contact for personal care products, at dpc.dataprivacy@domtar.com, or for all other inquiries, communications@domtar.com