Worldwide Responsible Accredited Production (“WRAP”) provides the privacy policy below (the “privacy policy”) to explain how your personal information will be treated. We understand that you are aware of and care about your own personal privacy interests and we take that seriously. This privacy policy describes WRAP’s policies and practices regarding its collection and use of your personal data and sets forth your privacy rights. Information privacy and security is an ongoing responsibility, and so we will from time to time update this policy.
WRAP reserves the right to amend this privacy policy at any time. Please check back frequently to see changes. Your use of the site constitutes your acceptance of the privacy policy, as it may be amended from time to time.
1. Collection and Use of Personal Information
WRAP may collect personal data and other information in connection with information you give us, your use of the website, through cookies and web beacons, and through third parties.
Registration and facility audit
When you register for a WRAP audit, we collect information about the facility you work for including (but not limited to) company name, address (including your country location), information about production and buyers you share with us, as well as employee and facility email addresses.
When you request a WRAP audit, we will also receive detailed facility information as required by the WRAP audit documentation process, including photographs of your facility, staff and employees, financial records relating to payroll and benefit verification, notes from interviews with employees, copies of relevant employment policies, documentation of corrective actions taken to meet WRAP requirements, business records such as license and occupancy certifications, and other data collectively referred to as the “audit report”. Your request to register your facility with WRAP and to complete a WRAP audit is permission for WRAP to use the information contained in the audit report and the application to generate anonymized reports that may be shared by WRAP with third parties. Such reports will remove identifying information and will use aggregated data from other Audit Reports.
Registration and requests for a WRAP audit is your permission for WRAP to share your facility audit report or information extracted from such reports with past and current buyers from your facility.
In addition, WRAP may share audit reports or information extracted from such reports with prospective buyers who may be interested in placing production orders with your facility. WRAP may share such information with prospective buyers on terms and conditions determined in its sole discretion. WRAP may share such certification information in its sole discretion.
A facility may affirmatively request that WRAP not share its audit report or information extracted from the report with past, current, or future buyers by electing to opt out when applying to WRAP. If a facility elects to opt out of sharing its certification status, WRAP will take reasonable measures to not share such information with buyers.
To ensure transparent and accurate information regarding a facility’s certification status, WRAP maintains and publicly shares the current certification statuses of facilities that are or were WRAP certified including, addresses, dates of certification, and related data.
Training
WRAP provides a variety of training courses throughout the year and around the globe, including auditor training, social compliance verification training for buyers, CTPAT training, and other such courses, both live and on demand (collectively “training”). If you register for training, we may access the information in your application to provide you with information and services associated with the training. We will collect your name and contact information, which we will store in our database(s) and use to provide you with information and services associated with the event. We process this information to fulfill the training you have elected to participate in.
If you are a speaker or presenter at one of our training events, we will collect information about you, including your name, employer, contact information, and photos, and we may also collect information provided by event attendees who evaluated your performance as a speaker or presenter. We may also make and store a recording of your voice and likeness in certain instances.
We keep a record of your participation in WRAP training events as an attendee or presenter. This information may be used to provide you with services or to tell you about other training events and publications. It may also be used to help WRAP understand our stakeholders’ needs and interests to better tailor our products and services to meet your needs.
In association with attending one of or more of our training events, you may have the option to download an “app” to help you navigate the event and plan your schedule. The app may require the device identifier associated with the device you use it on. Information may also be collected from you when you register on the app, enter information, write posts/comments, add content to favorites, provide ratings or submit educational content (such as documents, videos, narrations and images), are active on an educational activity, download materials, create content, and when you use mobile device resources (such as camera or microphone) to scan Quick Response (QR) codes, submit photos, record narrations and send educational materials.
Newsletter and eblasts
WRAP provides diverse content for its stakeholders and the public. If you sign up to receive WRAP’s newsletter and email blasts, you will need to provide us with some of your personal data. You may, at your option, choose to unsubscribe from WRAP’s newsletter and related emails.
WRAP uses Google Analytics to track how often people gain access to or read our content. WRAP uses this information in the aggregate to understand what content our stakeholders find useful or interesting so that we can produce helpful content to meet stakeholders’ needs. You may opt-out of third-party cookies from Google Analytics on its website.
WRAP may also conduct surveys that are used to produce research on industry topics. Participation in those surveys is voluntary.
Correspondence with WRAP
If you correspond with WRAP by email, the post service, phone, or other form of communication, WRAP will retain such correspondence and the information contained in it, which will be used to respond to your inquiry; notify you of training events, publications, or other services; or keep a record of your complaint, accommodation request, and the like. If you wish to have WRAP refrain from communicating with you, please contact us at info@wrapcompliance.org. If you ask WRAP not to contact you by email at a certain email address, WRAP will mark that email address on its “do not send” list to comply with your request.
Payment Information
You may choose to purchase goods or services from WRAP using a payment card. Typically, payment card information is provided directly by users, via the WRAP website, into the PCI/DSS-compliant payment processing service to which WRAP subscribes, and WRAP does not, itself, process or store the card information. Occasionally, stakeholders or customers ask WRAP employees to, on their behalf, enter payment card information into the PCI/DSS-compliant payment processing service to which WRAP subscribes. We strongly encourage you not to submit this information by email. When WRAP employees receive payment card information from customers or stakeholders by email, fax, phone, or mail, it is entered as instructed and then deleted or destroyed.
Use of WRAP Services Without Providing Data
The website is public facing and provides helpful information to a wide range of stakeholders with no obligation to share personal data.
Information Collected Through Use of WRAP Website
WRAP may collect and/or track (1) the home server domain names, email addresses, type of computer, and type of web browser of visitors to the WRAP website (“the site”), (2) the email addresses of visitors that communicate with WRAP or the site via email, (3) information knowingly provided by the visitor in online forms, registration forms and surveys, (including name, address, email, and other personal profile data), and (4) aggregate and user-specific information regarding page views.
The site collects certain information automatically and stores it in log files. The information may include internet protocol (IP) addresses, the region or general location where your computer or device is accessing the internet, browser type, operating system, and other usage information about the use of the site, including a history of the pages you view. We use this information to help us design our site to better suit our users’ needs. We may also use your IP address to help diagnose problems with our server and to administer the site, analyze trends, track visitor movements, and gather broad demographic information that assists us in identifying visitor preferences.
WRAP may use internet “cookies,” web beacons, or other technology to collect information from visitors’ hard drives. A cookie is a small amount of data that is sent to your browser from a website’s computer and is automatically stored on your computer. Cookies or other like technologies save data about individual visitors, such as the visitor’s name, password, username, screen preferences, the pages of a site viewed by the visitor, and the advertisements viewed or clicked by the visitor. When the visitor revisits the site, WRAP may recognize the visitor by the internet cookie or other like technology and customize the visitor’s experience accordingly. You can configure your browser to accept, reject and/or notify you when a cookie is set. Each browser is different, so check the “Help” menu of your browser for cookie settings. These cookies are optional and may be refused any time using your web browser software; however, doing so may make some parts of the WRAP site inaccessible.
Categories of WRAP cookies
Authentication: If you are signed into our services, cookies help us show you the right information and personalize your experience.
Security: We use cookies to enable and support some of our security features, and to help us detect malicious activity.
Preferences, features, and services: Cookies can help you fill out forms on our sites more easily. They also provide you with features, insights, and customized content.
Performance, Analytics, and Research: Cookies help us learn how well our sites and services perform. We also use cookies to understand, improve, and research products, features, and services, including to create logs and record when you access our sites and services from different devices, such as your work computer or your mobile device.
WRAP may also use other technologies to analyze trends, administer the site, improve users’ experience, track users’ movements around the site, gather analytics and demographic information, and for marketing.
Links to and Interaction with Third Party Products/Websites
The site may enable you to interact with or contain links to your user accounts with other third-party websites, mobile software applications and services that are not owned or controlled by us (each a “third party service”). We are not responsible for the privacy practices or the content of such third-party services. Please be aware that third party services may collect personal data from you. Accordingly, we encourage you to read the terms and conditions and privacy policy of each third-party service that you choose to use or interact with. Although this site strives to include only quality, safe, and relevant external links, users are advised to adopt a policy of caution before clicking any external web links mentioned throughout the site. External links are clickable text/banner/image links to other websites, such as Facebook or LinkedIn.
2. Use of Personal Data Collected
As explained above, WRAP processes your data to provide you with the goods or services you have requested or purchased from us, including stakeholder services, training events, publications, and other content; keep you informed; and provide professional development. We use this information to refine our goods and services, better tailor them to your needs, and to communicate with you about other services WRAP offers that may assist you or your company. Most of the time, WRAP needs to process your personal data to fulfill an order for goods or services — including stakeholder services — with all the attendant benefits and opportunities WRAP provides.
For example, WRAP may use your personal data to:
a) Communicate with you about your registration or to communicate information about the site.
b) Build higher quality, more useful services, such as by analyzing usage trends or measuring demographics and interests regarding specific areas of the site.
c) Provide you with prompt and effective customer service.
d) Support the operation of the site, troubleshoot problems, resolve disputes, and to enforce our terms and conditions.
e) Associate submitted information and/or additional information and/or device information and/or location information and/or log information to enable analysis by WRAP and send you communications we believe may be of interest to you.
f) Customize the advertising and content you see, including through use of location information and geofencing.
3. Disclosure of Personal Data Collected
WRAP may disclose your personal data:
a) At your request or with your consent.
b) To WRAP’s agents and advisors (such as our accountants or attorneys). We only disclose the personal information necessary for them to provide their services to you or to us, and only under strict confidentiality restrictions.
c) As WRAP believes necessary to: (a) comply with law (including court and government orders, and civil subpoenas); (b) enforce or apply WRAP’s terms and conditions and other agreements; or (c) protect the rights, property, or safety of WRAP, our employees, our users, or others.
d) If you partake (or we reasonably suspect that you are partaking) in any illegal or potentially illegal activity. We may disclose personal information even without a subpoena, warrant, or other court order, to the extent we feel is necessary to inform and cooperate with law enforcement agencies or other appropriate authorities.
e) In aggregated form, i.e., information about multiple users collectively without identifying any individual user, such as the total number of visitors to a particular section in a given week.
f) Third-party service providers: We employ other businesses, contractors, certain services and individuals to perform functions on our behalf. Examples include fulfilling orders, organizing training events, sending e-mail, removing repetitive information from stakeholder lists, processing credit card payments, sending communications, marketing, and providing customer service. They may have access to personal information needed to perform their functions, but may not use it for their own purposes, like sending you marketing offers about their products. WRAP may collect your location-based information and may share this information with our mapping provider and other third-party service providers.
g) Aggregate Information: We may share aggregate information, such as demographics and the Site usage statistics, with other organizations for business development, marketing, or promotional purposes. When this type of information is shared, the other parties do not have access to your personal information.
h) WRAP makes facility certification information on its website including in an interactive world map format.
i) To address emergencies or acts of God.
j) To address disputes, claims, or to persons demonstrating legal authority to act on your behalf.
k) In connection with the site’s use of interfaces with social media sites such as Facebook, LinkedIn, Twitter, and others. If you choose to “like” or share information from the site through these services, you should review the privacy policy of that service. If you are a stakeholder of a social media site, the interfaces may allow the social media site to connect your site visit to your personal data.
l) To providers of research and analytics services, including third-party tools we deploy (e.g., Google Analytics).
m) In the event that we sell or buy any business or assets, in which case we will disclose your personal information to the (prospective) seller or buyer of such business or assets, or if substantially all of our assets are acquired by a third party, personal information held by WRAP may be one of the transferred assets.
n) Audit related facility personal information obtained from registered facilities to conduct WRAP audits and certification process is addressed at paragraph 1 above.
4.Collection of Personal Data from Children
To the extent that WRAP is able to determine the age of users by their submissions to or communications with the site, WRAP will not knowingly (a) collect or post information from individuals under thirteen years of age (“children” or “child”) without their parent’s or guardian’s verifiable consent, or (b) provide any personally identifying information collected from children, regardless of its source, to any third party for any purpose whatsoever.
5. Security Measures
While no physical or electronic security system is impenetrable, WRAP strives to maintain levels of privacy and security consistent with industry standards. WRAP has implemented numerous security features to prevent the unauthorized release of or access to personal information. Although WRAP takes these measures to safeguard against unauthorized disclosure of a user’s data or personal information, WRAP cannot control internet transmissions and cannot guarantee or warrant that personal information transmitted to WRAP will never be compromised.
6. Third-Party Websites
The site may contain links to other internet websites. Unless we explicitly state otherwise, we have no control over these third-party sites and their privacy practices, and this privacy policy applies only to information you supply (or that we collect) in connection with use of the site. You should review third-party privacy policies in connection with visiting their websites.
7. Opt-Out Right
Visitors may opt-out of having their personal information collected by WRAP, used by WRAP for secondary purposes, or used by WRAP to send promotional correspondence to the visitor by contacting WRAP via email at info@wrapcompliance.org or via postal mail or telephone at the address and phone number below.
8. Access to and Ability to Correct Personal Data
Upon request via postal mail, email, or telephone (during regular business hours), WRAP will provide to visitors a summary of any personally identifiable information retained by WRAP regarding the visitor. Visitors may modify, correct, change, or update personally identifiable information that WRAP has collected through the site or may cause their personal record to be removed from WRAP’s database by contacting WRAP via postal mail, email, or the telephone number indicated below. WRAP may ask you for additional information to confirm your identity and for security purposes, before disclosing personal information requested to you. Your ability to delete your personal information may be limited in some circumstances. WRAP may retain information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.
9. Governing Law
This privacy policy and the privacy practices of WRAP will be subject exclusively to the laws of Virginia within the United States of America, excluding its conflict of law’s provisions, and you submit to personal jurisdiction in Virginia. The parties irrevocably agree that the state and federal courts located in, or governing Virginia shall have exclusive jurisdiction in respect of any dispute which may arise out of or in connection with this privacy policy. THE PARTIES HEREBY WAIVE TRIAL BY JURY. WRAP makes no representation that this privacy policy and such practices comply with the laws of any other state or country. Visitors who use the site and reside outside the United States do so on their own initiative and are responsible for compliance with local laws, if and to the extent local laws are applicable. If you reside outside of the United States, by using the site, you consent to the transfer and use of your information outside your country.
10. WRAP’s Right to Change Privacy Policy
WRAP may change the content of our site and privacy polity at any time. Please revisit our privacy policy from time to time to be sure you are familiar with our current policy because it is binding on you. If any change is unacceptable to you, your only recourse is to terminate your use of the site. Your continued use of the websites, and/or continued provision of personal information to us will be subject to the terms of the then-current privacy policy. We encourage you to periodically review this page for the latest information on our privacy practices.
Contact Information
If you have any questions regarding this privacy policy or you would like to review, change, and/or remove your personal information, you may contact us at:
Email: info@wrapcompliance.org
Attention: Nacer Ben Driouich
Telephone: +1-703-243-0970
Mailing address: 4201 Wilson Blvd., Suite 335, Arlington , VA. 22203
