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Marketing and Sales Privacy Notice
Updated: 25.07.2021

ACCO Brands Corporation, including its affiliates (collectively, “ACCO Brands,” “we,” “us,” or “our company”), is committed to respecting your privacy. One part of doing that is being transparent to you about how we collect, use, store, transfer and disclose information you share with us. This notice explains our approach and also lets you know about the rights you have over your information.

If you have any questions regarding your information or this notice, you can reach us anytime at DataPrivacy@acco.com.

What are the key points of this notice?
The key points of this notice that you should know are:
• The controller for your personal information is the entity listed in the “How can you contact us?” section below.
• We collect personal information primarily to market our products to you, enable you to make purchases on our websites, and provide you with product and customer service support.
• We use third-party service providers to help us maintain and protect our website, accept payments, deliver products to you, send marketing communications, and tailor our site to your interests.
• We do not sell and will not sell your information to third parties for their own use.
• You have rights over how the information we collect about you is used. For example, you can opt-out of marketing communications at any time. You can also request access to the information we hold about you or request that we delete that information in some cases.

What is the scope of this notice?
This notice explains how we use personal information—information that can be used to identify or contact an individual. It also explains how we use non-personal information—information that cannot, alone, be used to identify or contact an individual.
This notice applies to the website on which it is posted. It also applies to interactions with ACCO Brands via other channels, such as when you contact our customer support team or when we communicate with you on third party platforms like Facebook, Twitter, Twitch, Discord, Instagram, or YouTube. This notice does not apply to ACCO Brands websites with different privacy notices or to the practices of third-party websites and platforms.

Which ACCO Brands entity is the controller of your personal information?
The ACCO Brands entity listed in the “How can you contact us?” section below is the controller for your personal information.

What information do we collect from you?
We collect and process your information when you interact with our websites, interact with our social media accounts, purchase our products, use our internet-connected devices, contact our customer service employees, or interact with our company in another manner. The information we collect includes:

• Your name, username, and password;
• Your personal or business address, company name, email address, and phone number;
• Your industry sector;
• Your payment and delivery information, including billing and delivery address;
• Your order history;
• The product ID of the product you purchase;
• Customer support chat logs, emails, and call recordings;
• Your marketing preferences;
• Photos, videos, or other files that you submit to us or that are taken at events;
• Your interactions with our website, services, apps, programs, or other websites, such as products viewed, search history, clicked advertisements, IP address, date and time of visit, device used, browser used, and app usage;
• Inferences drawn from the information above, such as your product preferences and interests; and
• For business customers, we also collect creditworthiness and financial information, bank account details, the names of shareholders and management, tax identification numbers, national identification numbers, and identification documentation (where required).

What technologies do we use to collect information?
Beyond information that you actively provide to us, we also collect information passively via various technologies.

Cookies
Cookies are small text files that websites save on our local device when you visit a site. This allows websites to do a variety of things, such as remembering site preferences, creating a record of a visitor’s online activity, or identifying what parts of a site are visited most often.
We use various cookies on our website to deliver the best experience to visitors. We are committed to being transparent about the cookies we use and giving you the ability to control what cookies are placed on your device.
More details about the cookies we use and how you can manage your cookie preferences is contained in this website’s Cookie Notice.

Pixel Tags
Pixel tags are tiny graphic images (also known as web beacons, action tags, or transparent GIF files). We use pixel tags to:
• Tell us which parts of the website you have visited and to measure the effectiveness of any searches you may perform;
• Send you email messages in a format you can read and let us know when you have opened a message from us and whether you click on the links contained in the message; and
• Together with our ad marketing partners, track your interaction with online advertising, measure the performance of a marketing effort, and for targeted advertising.

File Metadata
If you submit a digital photo or other file to us, it may contain metadata or precise geolocation. If you do not want to share this data, you should delete the data before sharing it with us.

Embedded Links
Certain links in our emails and third-party websites may include tracking information embedded in the link. This tracking is accomplished via a redirection system that allows us to understand whether you clicked on the link and how the link is being used. In some cases, this non-personal information can be combined with personal information we have about you to improve our services and marketing campaigns.

What information do we collect from third parties?
In addition to information that we collect from you, we also collect information from third parties.

Business Lists
To support our marketing efforts, we sometimes collect from marketing providers lists of businesses that may be interested in our products, where permitted by local law. We use these lists to send marketing communications to relevant businesses. We also use these lists to append additional information to our existing customer lists or to ensure the accuracy of our existing customer lists. These lists can include any of the information mentioned above in the “What information do we collect from you?” section above.

Social Media Platforms
When you log into social media platforms from this website, public information such as your username is shared with the social media platform, which may then in turn provide that information to us. We also use social media platforms to provide targeted advertising.

Marketing Affiliates
We sometimes work with marketing affiliates and providers under what is commonly called “affiliate marketing.” Affiliate marketing allows us to identify when individuals click a link or ad on a marketing partner’s website and then subsequently make a purchase on our site. We then provide the marketing partner a commission for the sales it generates. We do not share your personal information with the marketing affiliate, however. Affiliate marketing is achieved using the technologies in mentioned in the “What technologies do we use to collect information?” section.

How do we use your information?
We use your information for the following purposes:

• In order to fulfil a contract or to take steps in connection with a contract, including:
    o Verifying your identity;
    o Processing payments;
    o Communicating with you;
    o Providing warranty coverage and product registration;
    o Providing customer service;
    o Arranging the delivery of products; and
    o Providing promotional or sweepstakes rewards.
• In order to conduct our business and to pursue our legitimate business interests, including:
    o Protecting and improving our services and websites, such as using analytics to better understand how our websites are used;
    o Enhancing our products, applications, or services;
    o Preventing malicious activity, security breaches, fraud, and other criminal activity;
    o Providing generalized and targeted marketing and advertisements;
    o Providing direct marketing materials regarding our products and services to businesses, subject to applicable law;
    o Personalizing our website or products for you;
    o Providing app or program functionality;
    o Managing your marketing preferences;
    o Responding to feedback, complaints, or reviews of our products, services, or websites;
    o Posting content provided by you, such as product reviews or social media posts;
    o Promoting our business via industry events, tradeshows, and other events;
    o Managing our financial processes and reporting;
    o Coordinating product recalls;
    o Providing requested product or material samples;
    o Inviting you to participate in marketing research or surveys; and
    o Pursuing and defending legal claims, as well as ensuring compliance with relevant laws.
• If you give your consent, we use your personal information for the following purposes:
    o Providing direct marketing materials to businesses and consumers regarding our products and services; and
    o Any additional purposes—we will ask for your consent at the time of collection.
• For legally required purposes, including in response to lawful requests by regulatory, civil or criminal authorities.

With whom do we share your information?
We share your information with various entities around the world, including some in countries that have privacy laws that may differ from those where you are located. For all transfers, we ensure there are suitable safeguards, such as a legal adequacy decision, standard contractual clauses, binding corporate rules, and Privacy Shield certifications. Details are available upon request.

ACCO Brands Corporation Group
We may transfer your personal information to other brands and companies in the ACCO Brands group in order to process orders, sweepstakes or for other marketing activities. List of ACCO Brands Affiliates.

Resellers and Dealers
In some cases, ACCO Brands does not sell products directly to customers, but instead directs customers to make purchases from a reseller or dealer. Where requested, we may share your information with those entities to assist you, for example to facilitate having the reseller or dealer provide you with a price quote or product support.

Service Providers
We will also transfer the personal information described in the “What information do we collect from you?” section above to service providers, who will process information on behalf of ACCO Brands for the above-described purposes. These processors include providers of website hosting and maintenance, marketing database hosting, call center operation, consumer engagement, advertising, shipping, and logistics services.

Analytic Providers
We use analytic providers such as Google Analytics to analyze your use of our website. In this context, we transfer anonymized data about the use of our website to the analytics provider, which then compiles statistical reports for us about the use of our website.

Product Feature Providers
For certain products, your personal information may be shared with third parties to provide additional functionality to those devices. For example, some products include voice control functionality via services like Amazon Alexa. In those cases, the collection and use of your data is controlled by the voice control provider, not ACCO Brands. We do not collect any personal information from these processes and do not collect or store any audio recordings.

Social Media Platforms
At various places on our websites we have implemented social network/ social media features. These features include:
• Links to ACCO Brands’ websites on social networks
• “Like” or “Share” buttons
• Embedded content, such as videos
The providers of the features above may use embedded content to identify you, the source of a visit and how you use our website.

When you use the recommendation functions, this communicates the URL of the respective website to the social network you have selected. A number of networks then immediately supplement the link with an excerpt of the content provided by our website. With most social networks, you are asked for confirmation before this is saved or forwarded.
We have integrated social media tools from social media providers such as: Facebook™, Twitter™, YouTube™, LinkedIn™, and Instagram™.
Please note that we do not have control of how these entities deal with the information you share with them and whether this information is made available to others. We recommend that you read their privacy policies carefully.

Legal Disclosures
We may disclose your information when required by law to do so, such as when information is subject to a subpoena or court order, or in furtherance of ACCO Brands’ legal interests, such as when defending or pursuing a legal claim.

Purchaser of Our Business
If our business or a part of our business is sold or integrated into a different company, we may disclose your information to our advisors and to the advisors of the potential purchaser and will pass such information on to the new owners of the company.

What rights do you have?
You have the following rights over your personal information:
• To opt out of marketing communications;
• To request details regarding the processing of your personal information;
• To request a copy of your personal information, and in some cases, have your information transferred to another company;
• To correct or delete your personal information held by ACCO Brands;
• To limit the processing of your personal information;
• To withdraw your consent, where we rely on that consent to process your information;
• To opt-out of targeted advertising;
• To object to or restrict the processing of your personal information; and
• To submit a complaint with the relevant data protection authority, depending on your location.

Exercising Rights
In order to exercise these rights, please click the Manage My Data link in the footer of this website or contact us using the information in the “How can you contact us?” section below.
You can also opt-out of marketing communications (withdraw your permission) by clicking the “Unsubscribe” link in emails or changing your preferences in your account settings.

If you would like to exercise your rights via an authorized agent, we require a signed authorization or power of attorney, which can be submitted to DataPrivacy@acco.com. We also require you, as the consumer, to directly verify your own identity with our company via the “Data Access Request” tab available after clicking the Manage My Data link in the footer of this website.

Limitations
Your rights may be limited, for example, if during the fulfillment of your request, information about another person would be disclosed or if you ask us to delete information that we are legally required to store or need to operate our business.

When submitting a request for a copy of your personal information, we require that you provide your email address, full name, address, telephone number, and date of birth. We utilize that information to verify your identity with a third-party service provider. This is done to protect your information and ensure that the right information is provided to the right person.

Non-Discrimination
ACCO Brands does not discriminate against individuals exercising their rights over their information and it does not offer any financial incentives in connection with the collection, sale, or deletion of your personal information.

Complaints
If you have an unresolved privacy concern, you may also have the right to lodge a complaint with the relevant data protection authority or state attorney general, depending on your location.

How can you avoid targeted advertising?
We sometime advertise on third-party websites and platforms, and we may also show third party advertisements on our websites. We and our vendors use the information described in the “What technologies do we use to collect information?” section above to target advertising based on your online activity, including past visits to our sites or third-party sites.

You can opt-out of targeted advertising by turning off non-essential cookies in this website’s cookie preferences page. This can be done at any time by clicking the “C” in the bottom right corner of the website or via the site’s Cookie Notice (depending on the website).

There are also certain third-party mechanisms that visitors can use to limit targeted advertising, which vary by country. Please note that these opt-out mechanisms are browser specific. If you wish to opt-out of targeted advertising across all browsers, you need visit the above websites from each browser you use. Also, please be aware that if you opt out of receiving targeted advertising, you will still be served with advertisements, but they will no longer be targeted to your interests.

Please note that we do not currently respond to “Do Not Track” signals from browsers.

For whom is this site intended?
This site is only intended for adults, and we do not knowingly collect personal information from children under the age of 13. If you are a parent or legal guardian and think your child has provided us personal information, please contact us using the information in the “How can you contact us?” section below in order to have that information deleted.

How long will we maintain your information?
We will keep your personal information for as long as needed to fulfill the purpose for which it was collected. We will also maintain your information as needed to establish compliance with our legal obligations and to ensure we continue to respect any opt-out requests.

How can you contact us?
If you have concerns regarding the processing of your information, you can contact us using any of the following methods, and your concerns will be forwarded to our privacy team or data protection officer:

ACCO UK Limited
Oxford House, Oxford Road,
Aylesbury,
Buckinghamshire,
HP21 8SZ
Email: DataPrivacy@acco.com

PN-GL-MKT-ACCO-EN-2021.05-V2