Privacy Policy

Effective Date: March 30, 2022

I. Purpose and Scope

Closure Systems International Inc. and Affiliates (“CSI”) has created this Privacy Policy (“Privacy Policy”) in order to demonstrate our firm commitment to your privacy. “Affiliates” means, with respect to any entity, any other entity which directly, or indirectly through one or more intermediaries, controls or is controlled by, or is under common control with, the specified entity.

Please read the following to understand how Personal Data collected on our websites may be used and shared. This Privacy Policy discloses our information gathering and dissemination practices for our main website and all other CSI websites linked thereto and/or owned by CSI (“Sites”). 

For purposes of this Privacy Policy, “Personal Data” means data that personally identifies an individual or that may be used to personally identify an individual. This includes, but is not limited to data such as an individual’s name, date of birth, phone number, address and e-mail. Personal Data does not include data that is encoded or anonymized, or publicly available information that has not been combined with non-public Personal Data. If you decide not to provide us with Personal Data, you will still be able to use certain parts of our websites, although there may be some features or services that are unavailable to you. Unless otherwise noted below, Reynolds will not use or disclose your Personal Data for any purpose for which you have not consented. Please note that consent will be inferred if you were made aware of all potential subsequent uses of your Personal Data at the time it was collected. By submitting Personal Data on our Sites, you allow us to use such information for its intended purpose.

II. Safe Harbor

Due to the global nature of CSI’s business, transfers of Personal Data across national boundaries may occur. As a result, this Privacy Policy complies with the Safe Harbor Principles as agreed upon by the United States Department of Commerce and the European Commission regarding the collection, use, processing, disclosure, transfer and retention (collectively “Processing”) of Personal Data with respect to Personal Data transferred from the European Economic Area (EEA) to the United States.

II. Changes to this Privacy Policy

This Privacy Policy is current as of the effective date set forth above. CSI reserves the right to change this Privacy Policy from time to time consistent with applicable privacy laws and principles. Unless such changes afford greater protections, such changes will apply only to Personal Data received after the effective date of such change. If at any time you choose not to accept the terms of this Privacy Policy, you should not use the Sites.

IV. Personal Data Collection and Use

Lawful and correct treatment of Personal Data is very important to us. If you sign up to receive additional information about any of our products or services, or wish to use other special features or services offered through our Sites, you may be asked to provide Personal Data about yourself.

The information CSI collects is primarily used to provide information about our services and products to our customers and business partners. CSI will not rent or resell your Personal Data to third parties for marketing purposes.

In particular, CSI may collect and/or process the following information about you:

    • Information that you provide by filling in forms on our Sites, such as your name, address, e-mail address, phone number, the types of products you are interested in and information about your occupation. This includes information you may provide when you request additional information about our products and services or sign up to receive one of our e-mail newsletters.
    • Your contact information when you report a problem with one of our Sites.
    • Details of your participation in any market research we may conduct on our website, such as when you provide feedback about our products online.
    • If you contact us, we may keep a record of that correspondence.
    • If you enter a contest or promotion sponsored by us or any of our group companies, Reynolds may ask you for your contact information as well as other information about you to verify your eligibility to participate and to award prizes. Please note that participating in such contests is completely voluntary and is not required to use our Sites.
    • Reynolds may ask you to complete surveys that request certain demographic information (such as your age, income, occupation and postal code) and/or additional information about yourself which Reynolds may use for research purposes. Please note that you do not have to respond to these survey requests.

V. Non-Personal Data

In some cases, CSI may collect information that is not personally identifiable. Examples of this information includes, but is not limited to, the frequency of your use of our Sites and the route by which you choose to access it and your use of any hyperlinks available on any of our Sites. We and our service providers, agents or suppliers may process and use this data for purposes including, but not limited to, website development, assessing patterns of use, or planning and assessing CSI marketing initiatives. This information is gathered by certain tools and methods such as the collection of your IP address or the use of cookies and is maintained in the aggregate unless otherwise noted. To the extent that we link any non-Personal Data with Personal Data, we will treat such linked information as Personal Data.

In order to improve our site, we utilize “cookies” to maintain a record of your visit, by using a cookie file that is stored on the hard drive of your computer. A cookie is a small text file that is transferred to a web browser by a web server and can only be read by the server that gave it to you. This information does not identify you personally and you remain anonymous unless you have otherwise provided us with Personal Data.

Cookies help us to improve our site and to deliver more personalized service by enabling us to estimate audience size and usage pattern; to store information about your preferences; to speed up your searches and may be used to recognize your computer.

Most web browsers automatically accept cookies. If you would prefer to prevent your computer from accepting our cookies, you may follow your Internet browser’s steps for doing so. Please note, however, that if you do disable cookies from your browser, you may not be able to access certain sections of our websites.

IP Addresses
We use your IP address to help diagnose problems with our server, and to administer our Sites. We may also use your IP address to identify you when we feel it is necessary to enforce compliance with this Privacy Policy or our website Terms and Conditions, or to protect our services, Sites, systems, information, employees, business partners, service providers, users, customers or others.

VI. Disclosures/Onward Transfers

CSI may disclose your Personal Data to any member of our group, which means our subsidiaries and our ultimate holding company and its subsidiaries in compliance with applicable privacy principles, regulations and rules.

In order to more efficiently provide the products and services you may request from us, Reynolds may also share your Personal Data with selected third parties who are acting or gathering information on our behalf as our agents, suppliers, or providers.

To this effect, we may disclose Personal Data to the following:

    • Third parties who perform tasks on our behalf; and
    • Third parties who either
    • (a) comply with the Safe Harbor Principles or the EU Data Protection Directive in some other manner; or
    • (b) agree to provide adequate protections for your Personal Data that are no less protective than those set out in this Privacy Policy; and to use your information only for the purposes for which the third party has been engaged by us.

We may also disclose your Personal Data to third parties if:

    • We sell or buy any business or assets, in which case we may disclose your Personal Data to the prospective seller or buyer of such businesses or assets.
    • Any member of our group or substantially all of its or their assets are acquired by a third party, in which case Personal Data held by it about its customers will likely be one of the transferred assets.
    • We are under a duty to disclose or share your Personal Data in order to comply with any legal obligation, subpoena or other court order; or in order to enforce or apply any of our online Terms and Conditions and other agreements; or to protect the rights, property or safety of our group companies and organizations for the purposes of fraud protection and credit risk reduction; or for any other reason as required or permitted by law.

VII. Right to Access, Change or Delete Personal Data

If you have submitted Personal Data through a CSI site and you would like to review, request changes or have that information deleted from our databases, please contact CSI via “Contact us” on our website, email to or send a letter to CSI Legal Department, Closure Systems International Inc., 7820 Innovation Blvd., Suite 100, Indianapolis, Indiana 46278.

We will use all reasonable efforts to supply you with a copy of your Personal Data and/or correct any factual inaccuracies. Upon request, we will remove such information from our databases unless we are entitled or required to retain it pursuant to other agreements or by law.

Be sure to include your name and clear instructions regarding any change or deletion. In the event you choose to delete your Personal Data from our database, we will retain a record that such information had been deleted as well as your request for deletion as evidence of our compliance with this Privacy Policy.

VIII. Security and Data Integrity

We will take all reasonable steps to ensure that your data is treated securely and in accordance with this Privacy Policy. Unfortunately, however, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee its security and any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

IX. Children

The Sites are not intended for anyone under the age of 13. We do not solicit or encourage the transmission of information from or about children.

X. Other Sites

Our Sites may contain links to other websites, including the websites of third parties who are acting on our behalf as our agents, suppliers, or providers.

Reynolds is not responsible for the content, security, or privacy practices employed by third party websites. Once you leave our website, we encourage you to review the privacy policy of any website linked to from one of our Sites before using it.

XI. Opt-Out

If you no longer wish to receive information concerning our services or products, please contact us at the e-mail address listed below to notify us of your wishes.

XII. Complaints

CSI takes your privacy concerns seriously. If you believe that CSI has not complied with this Privacy Policy with respect to your Personal Data, you may write to or send a letter to CSI Privacy Complaints at Closure Systems International Inc., Attn:  Legal Department 7820 Innovation Blvd., Suite 100, Indianapolis, Indiana 46278.