Grounded Packaging Privacy Policy

Effective date: 20 August 2025

1. WHO WE ARE

“Grounded”, “we”, “us” or “our” means the Grounded Packaging group of operating companies:

• Grounded Packaging Limited (New Zealand)
• Grounded Packaging Pty Limited (Australia)
• Grounded Packaging (UK) Limited (United Kingdom)
• Grounded Packaging Inc. (United States)

This policy describes how we collect, use, disclose and protect personal information when you visit grounded.co or other websites we operate, interact with us as a customer, supplier or partner, or otherwise engage with our services.

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How to contact us about privacy

Email: privacy@groundedpackaging.co

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The Grounded entity you interact with is your “controller” or “organisation” for privacy purposes. If you are unsure, contact us and we will direct your request to the right entity.

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2. SCOPE

This policy applies to personal information we handle in all markets where we operate. It is built on Australian law and includes additional terms for residents of the UK and EEA and for residents of the United States.

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3. THE PERSONAL INFORMATION WE COLLECT

Information you give us

• Account, profile and contact details such as name, job title, company, email, phone and shipping information
• Order, invoice and payment details
• Communications with us including emails, messages and support requests
• Preferences, consents and marketing choices
• Any information you choose to provide in surveys, events or product feedback

Information we collect automatically

• Device and usage data such as IP address, browser, device identifiers, pages viewed and interactions with our sites and emails
• Cookie and similar technology data. See Cookies and similar technologies below

Information from third parties

• Business contact data from your employer or colleagues
• Logistics, payment, fraud prevention, analytics and advertising partners
• Public and commercially available sources such as company registers and trade directories

Sensitive information

We do not intentionally collect sensitive information such as health data or precise geolocation. If you provide any sensitive information, we will handle it only for the purpose you provided and as allowed by law.

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4. HOW WE USE PERSONAL INFORMATION

We use personal information to

• Provide our products and services, including quotes, samples, orders, deliveries and customer support
• Manage our relationship with you and your organisation
• Improve and develop our products, sites and services
• Run security, fraud prevention and quality assurance processes
• Send service communications about your account or orders
• Send marketing communications where permitted and manage advertising performance
• Comply with legal obligations and enforce our terms

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5. OUR LEGAL BASES

Where a legal basis is required, we rely on

• Performance of a contract, or steps prior to entering a contract
• Legitimate interests such as running and improving our business, securing our services and communicating with business contacts, balanced against your rights
• Consent for certain marketing activities and for non-essential cookies
• Legal obligations, such as record keeping and responding to lawful requests

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6. DISCLOSURE OF PERSONAL INFORMATION

We disclose personal information to

• Service providers who host, store, process payments, provide analytics, advertising, communications, customer support, logistics and related services
• Your organisation and our professional advisers where appropriate
• Other Grounded group companies for internal administration, support and consolidated reporting
• Authorities or third parties where required by law or to protect rights, safety and security
• A buyer and their advisers in connection with a merger, acquisition or other corporate transaction

We do not sell personal information. We may “share” limited identifiers and internet activity with advertising and analytics partners to deliver or measure cross-context advertising. You can opt out of this in the United States as described below.

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7. INTERNATIONAL TRANSFERS

We operate globally. Your information may be transferred to, stored in or accessed from countries that may have different privacy laws to yours, including Australia, New Zealand, the United Kingdom and the United States.

For transfers from the UK or EEA, we use lawful transfer safeguards such as the European Commission’s Standard Contractual Clauses and the UK International Data Transfer Addendum, together with additional measures where appropriate.

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8. RETENTION

We keep personal information only as long as needed for the purposes above. This usually means

• Order and account records kept for the life of the relationship plus required regulatory periods
• Marketing data kept until you opt out or your account is inactive for a reasonable time
• Cookie-level data kept according to the cookie’s lifespan

We will delete or de-identify data when it is no longer required.

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9. SECURITY

We use technical and organisational measures designed to protect personal information. No method of transmission or storage is completely secure. If we suspect a data breach that poses a risk to you, we will act promptly and notify you and regulators where required.

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10. YOUR CHOICES

Marketing

You can unsubscribe from marketing emails at any time using the link in the email or by contacting privacy@groundedpackaging.co. We may still send non-marketing messages about your orders or account.

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Cookies

You can control cookies in your browser settings. In the UK and EEA we seek opt-in consent for non-essential cookies. Use the Cookie Settings link on our site to change your consent at any time.

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11. YOUR RIGHTS

Australia and New Zealand

You can request access to and correction of your personal information. You can make a privacy complaint to us. If you are not satisfied with our response, you can contact the Office of the Australian Information Commissioner or the Office of the Privacy Commissioner in New Zealand.

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United Kingdom and EEA

You have rights to request access, correction, deletion, restriction and portability of your personal data. You can object to processing that is based on legitimate interests and you can withdraw consent at any time. You also have the right to lodge a complaint with your local data protection authority or with the UK Information Commissioner’s Office.

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United States

Depending on your state, you may have rights to know and access information we hold about you, to delete or correct it, to receive it in portable format, and to opt out of sale or sharing for cross-context advertising. California residents also have the right to limit the use and disclosure of sensitive personal information.

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How to exercise your rights

Email privacy@groundedpackaging.co and tell us what you would like to do. We will verify your request and respond within the time required by law. You can authorise an agent to make a request on your behalf in jurisdictions that permit it.

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12. COOKIES AND SIMILAR TECHNOLOGIES

We use cookies, pixels and similar technologies to

• Make the site work and keep it secure
• Measure and improve performance and features
• Understand how visitors use our site
• Personalise content and measure advertising

Essential cookies are always on because the site will not function without them. Non-essential cookies are used with your consent where required. You can review or change your choices through the Cookie Settings link.

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13. ADDITIONAL INFORMATION FOR UK AND EEA RESIDENTS

Controller and contact

The Grounded entity you interact with acts as controller. Contact privacy@groundedpackaging.co for all requests.

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Lawful bases

We generally process your personal data for contract performance, legitimate interests, consent and legal obligations. Where we rely on legitimate interests, these include operating, improving and securing our services and communicating with business contacts about our products and services. You can object to processing based on legitimate interests.

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International transfers

When we transfer your data outside the UK or EEA, we use recognised safeguards as described above.

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Your rights and complaints

You can exercise your rights using the contact details above. You also have the right to complain to your local supervisory authority. Contact details are available on the ICO and European Data Protection Board websites.

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14. UNITED STATES PRIVACY DISCLOSURES

This section supplements the policy for residents of U.S. states with consumer privacy laws, including California.

Notice at collection

Categories we collect

• Identifiers such as real name, email address, phone number, IP address and device identifiers
• Customer records such as billing and shipping details
• Commercial information such as products purchased or considered
• Internet or network activity such as browsing history and interactions with our site and emails
• Professional information such as job title and employer
• Inferences drawn from the above to improve our services

Sources

• Directly from you, your organisation and your devices
• Service providers, partners and public sources

Purposes of use

• To provide, secure and improve our services
• To process orders and payments and manage customer accounts
• For analytics, reporting and advertising
• For legal compliance and to prevent fraud

Retention

We keep information only as long as needed for these purposes, consistent with the Retention section above.

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Disclosure for a business purpose

We disclose the categories above to service providers and contractors that help us operate, such as hosting, payment, logistics, analytics, communications and advertising partners.

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Sale or sharing

We do not sell personal information for money. We may share identifiers and internet or network activity with advertising and analytics partners to deliver or measure cross-context advertising. You can opt out using the Do Not Sell or Share link on our site and we honour Global Privacy Control signals enabled in your browser.

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Sensitive personal information

We do not use or disclose sensitive personal information for the purpose of inferring characteristics about you. We only use any sensitive information you provide for necessary purposes allowed by law.

Your U.S. privacy rights

• Right to know, access and portability
• Right to deletion
• Right to correction
• Right to opt out of sale or sharing for cross-context advertising
• Right to limit use and disclosure of sensitive personal information, if applicable
• Right to non-discrimination for exercising your rights

How to exercise your rights

Use the Do Not Sell or Share link on our site to opt out. For other requests email privacy@groundedpackaging.co. We will verify your identity and respond within the time required by law. You may also use an authorised agent, subject to verification requirements.

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15. CHILDREN

Our services are for business use and are not directed to children. We do not knowingly collect personal information from anyone under 16 years of age.

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16. THIRD-PARTY LINKS AND SERVICES

Our site may link to third-party sites and services. Their privacy practices are governed by their own policies. We are not responsible for their practices.

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17. CHANGES TO THIS POLICY

We may update this policy from time to time. If we make material changes we will post an updated version on this page and update the effective date.

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18. HOW TO CONTACT US

For any privacy question or request, contact

Email: privacy@groundedpackaging.co

If you make a complaint, we will investigate and respond. If you are not satisfied, you can contact your local privacy authority as described above.