This Privacy Policy (or “Policy”) describes how Covanta Holding Corp. and its affiliates and subsidiaries (“Covanta,” “we,” “us,” or “our”) collect, use and may disclose your personal information, as that term is defined below, via the Covanta website and other Covanta products and services that link to this Policy (collectively, the “Services”). If a Covanta product or service describes privacy practices applicable to specific types of information or in certain circumstances and those descriptions conflict with this Policy, those descriptions shall supersede this Policy. If you have questions or concerns about Covanta’s privacy practices, please contact us at [email protected].

Please check back frequently as your use of the Services constitutes acceptance of this Policy, as it may be amended from time to time, and you agree to be legally bound by this Policy.

INFORMATION WE COLLECT OR OBTAIN

We collect information about you in various ways.

Information You Provide to Us. We collect information you provide directly through the use of the Services, such as your name, email address, postal address, zip or postal code, phone number, employment and education history, family information, reference information, information such as password and security questions necessary to create and maintain a Covanta account, and any other information you choose to provide. Some of this information will be personal information (defined as information that can reasonably identify an individual on its own or in combination with other information Covanta possesses).Information We Collect When You Use Our Services. When you use or otherwise interact with the Services, we may collect information about you and we may combine this information with other information we believe to be about you. For example, we may collect:

• Log Information. When you visit or use some of the Services, such as our websites, some information is automatically logged, such as your computer’s operating system, Internet Protocol (“IP”) address, access times, browser type and language and the sites you visited before navigating to our sites.
• Cookies and Similar Technologies. We use various technologies to passively collect information, and this may include placing cookies, flash cookies, web beacons, or other tracking technologies on your computer or mobile device. Cookies are small data files stored on your hard drive or in device memory by a website. Web beacons (also referred to as “clear gifs”) are electronic images that may be used on our websites or in our communications. We may use web beacons to deliver cookies, count visits, understand usage and campaign effectiveness and understand how you interact with our Services and communications. For more information about cookies and similar technologies, please see our Cookies Policy.

We may be required to collect certain personal information about you by law or as a consequence of a contractual relationship we have with you. Failure to provide this information may prevent or delay the fulfillment of these obligations.

USE AND RETENTION OF INFORMATION

We use the information we collect and obtain described above to provide and improve existing services, to communicate valuable offers, and to develop new and exciting services. For example, we may use information about you to:

• Meet our legitimate or contractual interests, such as operating and improving the Services and creating or attempting to create new products and services;
• Monitor and analyze trends, usage and activities in connection with the Services;
• Personalize the Services and provide content and features we think will be of interest to you;
• Respond to your comments and questions and provide customer service;
• Provide and deliver products and services and send you related information, including confirmations, notices, updates, alerts, surveys, and support and administrative messages;
• Communicate with you about upcoming events and other news and information about products and services offered by Covanta, including in electronic form where you have consented to receive such information;
• Detect, investigate and prevent fraudulent transactions and other illegal activities and protect the rights and property of Covanta and others;
• Maintain secure online and offline environments;
• Meet our legal obligations to comply with lawful requests from law enforcement and other government entities or organizations; and
• Link or combine information about you with other information we get from third parties to help understand your needs and provide you with better service.

We use your personal information for these purposes

• With your consent, such as when you provide us information and consent to have it used for marketing purposes;
• In order to perform a contract, such as obtaining and sharing the address information associated with waste removal;
• To meet our legal obligations, for example to comply with law enforcement and other government requests; and
• To meet our legitimate interests, for example to ensure that we can provide and deliver products and services to you, and maintain and administer your accounts and membership profiles.

Data Retention. We may keep your personal information for as long as we have a relationship with you. We take into account our business goals and legal obligations when deciding how long to keep your personal information after our relationship with you has ended. We may retain records to investigate or defend potential legal claims. Third party partners may have different data retention policies.

SHARING OF INFORMATION

We may share your personal information with third parties under the following circumstances:

• Service providers and business partners. We may share your personal information with our service providers and business partners that perform marketing services and other business operations for us. For example, we may partner with other companies to process secure payments, fulfill orders, optimize our Services, send newsletters and marketing emails, support email and messaging services, and analyze information.
• Covanta Holding Corp is the parent company of several subsidiaries, including Covanta Environmental Solutions LLC, Covanta Energy (UK) Ltd, Covanta Europe Engineering Ltd, and Covanta Energy Marketing. We work closely with the businesses and companies that fall under the Covanta family. We may share the information we collect and obtain about you (e.g. your name, email address, and IP address) with other Covanta companies for security, marketing, contract fulfillment, internal or external legal or compliance obligations, and as allowed or required by law. For additional information applicable to residents of the EEA (as defined below) constituent countries, please see the relevant section of this Policy below.
• Law enforcement agency, court, regulator, government authority or other third party. We may share your personal information with these parties where we believe this is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of any third party, or as otherwise required or permitted by law.
• Asset purchasers. We may share your personal information with any third party that purchases, or to which we transfer, all or substantially all of our assets and business. Should such a sale or transfer occur, we will use reasonable efforts to try to ensure that the entity to which we transfer your personal information uses it in a manner that is consistent with this Privacy Policy.

We may also aggregate and de-identity your personal information so that it cannot reasonably be used to identify you, and we may then share this aggregated or de-identified information.

THIRD PARTY WEBSITES

The Services may include links to websites, web applications, or connected resources we do not control. This Privacy Policy does not apply to such third-party content and we are not responsible for the content of these linked sites or their treatment of your personal information. Such third party websites and online services may include social sharing features or other integrated tools, which let you share actions you take on the Services with other media, and vice versa. The use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the third party that provides the social sharing feature. You should review the privacy policies and terms of use for such third-party websites and online services prior to providing them with your personal information, although we are unable to verify the accuracy of these terms.

THIRD-PARTY ADVERTISING AND ANALYTICS SERVICES

We may allow others to serve interest-based advertisements across the internet and to provide analytics services. These entities may use cookies, web beacons and other technologies to collect information about your use of the Services and other websites over time, including your IP address, web browser, pages viewed, time spent on pages, links clicked and conversion information. This information may be used by Covanta and others to, among other things, analyze and track data, determine the popularity of certain content, deliver better advertising and content targeted to your interests both on our Services and across the web, and better understand your online and offline activities. For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices.

We may also work with third parties to serve ads on other websites or platforms, and these ads may sometimes be customized based on information we have about you. To opt out of us using your information in this way, please email us at [email protected].

INFORMATION CHOICES

Promotional Communications. You may opt out of receiving promotional emails and text messages from Covanta by following the instructions in those communications. Please allow up to 10 days for these opt outs to take effect. If you opt out, we may still send you non-promotional messages, such as emails about your accounts or our ongoing business relations.

Cookies. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies or reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of the Services.

Location Information. When you first visit one of the pages on our websites that collect location information, you will be asked to consent to the collection of location information. If you initially consent to our collection of location information, you can later stop this collection by changing the settings on your mobile device or web browser. If you do so, certain features of the Services will no longer function. You can also stop our collection of location information by mobile applications by following the standard uninstall process and removing any Covanta application(s) from your mobile device.

Your Personal Information Rights. In certain circumstances, you may have rights regarding your personal information, subject to local law. These may include rights to:

• access the personal information we hold about you;
• rectify the personal information we hold about you;
• erase the personal information we hold about you;
• restrict our use of your personal information;
• object to our use of your personal information;
• receive your personal information in an electronic format usable by a third party; and
• lodge a complaint with your local data protection authority.

You may withdraw your consent to a particular type of processing at any time.

Please note that we will likely require additional information from you in order to honor your requests and reserve the right to deny requests that we deem to not be from a confirmed data subject, or as otherwise permitted by law. We may also charge a fee for complex, extensive or repetitive requests, or as otherwise permitted by law.

If you would like to discuss or exercise such rights, please contact us at the details below.

Your California Privacy Rights. California law permits residents of California to request certain details about how their browsing information across the web and over time is shared with third parties for direct marketing purposes, and to provide options for participating in such sharing. To request information regarding the disclosure of your personal information or to opt out of having information about you shared with third parties for direct marketing purposes, please email [email protected] or write us at:

Covanta
Attn. Legal Department, CA Privacy Rights
445 South Street, Morristown, NJ 079860

If you are a California resident under the age of 18, and a registered user of any site where this policy is posted, you may also request and obtain removal of certain content or information you have publicly posted. To make such a request, please send an email with a detailed description of the specific content or information to [email protected].

Do Not Track. Some web browsers may be configured to send “Do Not Track” signals to the online services that you visit. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, the Services do not alter practices when a “Do Not Track” signal is received from a visitor’s browser. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

SECURITY OF INFORMATION

Covanta takes commercially reasonable measures to protect personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction. However, due to the nature of the internet and the nature of information technology in general, we cannot guarantee the security of your information. Please do not share information that may involve export controls, national security matters, or other highly sensitive information.

LOCATION OF INFORMATION

Covanta is based in the United States and the information we collect is governed by U.S. law, particularly that of the state of New York, and that law may have privacy protections that are different from the laws in your home jurisdiction.

INTERNATIONAL DATA TRANSFERS

Your personal information may be transferred to, stored, and processed in a country other than the one in which it was provided or where you are resident. When we do so, we put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to adequately protect your personal information. For more information on the safeguards in place, please contact us using the contact details set out below.

FOR CITIZENS OF EEA CONSTITUENT COUNTRIES

This section of the Policy applies to residents of EEA constituent countries. We are a controller for the purpose of Data Protection Legislation (as defined below). In this Policy, references to “you” and “your” are references to a user of our website.

Introduction

We are committed to protecting and respecting your privacy and handling your information in an open and transparent manner. This explains what information we collect from you, or that you provide to us, what we will use it for and with whom we share that information.  The Policy also sets out your rights and who can you can contact for more information. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. In this Policy, your information is sometimes called “personal data”. We may also sometimes collectively refer to handling, collecting, protecting and storing your personal data as “processing” such personal data.  In this Policy the term “Data Protection Legislation” means, the EU General Data Protection Regulation 2016/679; together with all other applicable legislation relating to privacy or data protection.

What information we collect about you

We may collect, record and use information about you in physical and electronic form and will hold, use and otherwise process the data in accordance with the Data Protection Legislation and as set out in this Policy.

The personal data we collect and process may include:

• your name;
• your contact information such as your email address and telephone number (or any telephone number used to call our customer services);
• your postings on any other social media applications and services that we provide;
• your IP address, your browser type and language;
• information about your visit to our website, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page.

How we collect information about you

• Information you give to us or we otherwise obtain from our business dealings with you. If you are a client, partner, a stakeholder in relation to one of our developments (such as on a community liaison committee) or other counterparty we may collect information from you or on your behalf in the context of that business relationship.
• Information you give to us. You may also give us by filling in forms on our site covanta.com, rookerysouth.covanta.com or dublinwastetoenergy.ie (our sites) (e.g. the contact us section or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register on the site for us to contact you, and when you report a problem with our site. The information you give us may include your name and e-mail.
• Information we collect about you.
  • Like most websites, we use “cookies” to help us make our site – and the way you use it – better. Cookies mean that a website will remember you. They’re small text files that sites transfer to your computer (or phone / tablet). They improve website use and speed – for example by automatically filling your name and address in text fields. There are more details in our Cookie Policy.
    
  • In addition, with regard to each of your visits to our site we will automatically collect certain information e.g. your IP address used to connect your computer to the Internet.

How we use your information

Our primary purpose in collecting your information is to the provision of our services, and to provide you with a safe, smooth, efficient, and customised experience. We may also use the information that you have provided to ensure that the content on our website is presented in the most effective manner for you and your computer.

We use your information for the following specific purposes:

• to provide you with the information and services that you request from us;
• to ensure that content from our site is presented in the most effective manner for you and for your computer;
• to send you news or updates -with your consent (given by joining a mailing list);
• to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• as part of our efforts to keep our site safe and secure;
• to measure or understand the effectiveness of advertising we may serve to you and others, and to deliver relevant advertising to you;
• to make suggestions and recommendations to you about services that may interest you.

Legal grounds for using your personal information

The law permits us to process your personal data in the way that it does because the processing is:

• necessary for the purposes of the legitimate interests that we pursue, which are to run and administer our business and to discharge our legal obligations to store and disclose information where necessary;
• necessary in order to comply with a legal obligation to which we are subject;
• you have explicitly agreed to us processing such information for a specific reason.

Sharing your information

The following categories of recipients may receive your personal information and process it for the purposes outlined in this Policy:

We may share your personal information with:

• our group companies including Covanta Holding Corporation and its affiliates
• other companies we deem necessary to provide you with our services, respond to your inquiries or for any other related purposes;
• other third parties for those purposes that may be reasonably ascertained from the circumstances in which the information was submitted;
• other business entities should we plan to merge with or be acquired by that business entity, or if we undergo a re-organisation with that entity; and
• any successor in interest, in the event of a liquidation or administration.

Links to Other Sites

Our website may contain links to other sites, including via our social media buttons. While we try to link only to websites that share our high standards and respect for privacy, we are not responsible for the content, security, or privacy practices employed by other websites and a link does not constitute an endorsement of that website. Once you link to another website from our website you are subject to the terms and conditions of that website, including, but not limited to, its internet privacy policy and practices. Please check these policies before you submit any data to these websites.

How we protect your information

We ensure that there are appropriate technical, physical, electronic, and administrative safeguards in place to protect your personal details from unauthorised access.

Unfortunately, the transmission of information via the internet (including by email) is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; 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 unauthorised access.

How long we keep your information

We will only keep the information we collect about you for as long as required for the purposes set out above or as required to comply with any legal obligations to which we are subject. This will involve us regularly reviewing our files to check that information is accurate, up-to-date and still required.

We may send you direct marketing communications, and retain your contact information necessary for this purpose for as long as you do not unsubscribe from receiving the same from us.

Transferring data outside of the EEA

Data that you submit via our website is sent to and stored on secure servers owned by or operated for us. Data may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”) and may also be processed by staff operating outside the EEA who work for us, or for one of our service providers, related companies, agents or contractors. Such transfers may be made in order to improve our website or to assist in our security or fraud protection activities.

Where recipients are outside the EEA, we ensure that the recipient provides an adequate level of protection for your personal data or the transfer is otherwise permitted under applicable Data Protection Legislation.

We do not generally rely on your consent as the legal basis for transferring your personal data to outside the EEA, however where we feel it is necessary or appropriate we may seek to rely on your consent as the legal basis for such processing. Where we do, you may withdraw your consent at any time in the manner described below.

Your rights

At any time, you have the right:

• to request access to or a copy of any personal data which we hold about you;
• to rectification of your personal data, if you consider that it is inaccurate;
• to ask us to delete your personal data, if you consider that we do not have the right to hold it;
• to withdraw consent to our processing of your personal data (to the extent such processing is based on previously obtained consent);
• to ask us to stop or start sending you marketing messages (e.g. our newsletter) at any time by using the below contact details;
• to restrict processing of your personal data;
• to data portability (moving some of your personal data elsewhere) in certain circumstances;
• to object to your personal data being processed in certain circumstances; and

Any request for access to or a copy of your personal data must be in writing and we will endeavour to respond within a reasonable period and in any event within one month in compliance with Data Protection Legislation. We will comply with our legal obligations as regards your rights as a data subject.

We will correct any incorrect or incomplete information and will stop processing your personal data, or erase it, where there is no legal reason for us to continue to hold or use that information.

We aim to ensure that the information we hold about you is accurate at all times. To assist us in ensuring that your information is up to date, do let us know if any of your personal details change.

You may also use these contact details if you wish to make a complaint to us relating to your privacy.

Changes to this Policy

Any changes we make to our Policy in the future will be posted on this page. Please check back frequently to see any updates or changes to our Policy.

Complaints

Questions, comments and requests regarding this Policy are welcomed and should be addressed to [email protected].

If you have any concerns about our use of your information, you also have the right (as a UK resident) to make a complaint to the Information Commissioner’s Office, which regulates and supervises the use of personal data in the UK, via their helpline on 0303 123 1113. For citizens of EEA constituent nations, you also have the right to make a complaint to the appropriate administrative or regulatory body of your nation of residency.

MERGERS, DIVESTITURES AND OTHER TRANSACTIONS

Should Covanta merge with, be acquired by, or transfer some or all of its assets to another entity, we may share your Personal Information with that entity or another entity in connection with such a transaction.

USE OF OUR SERVICES BY CHILDREN

Our Services are not intended for use by anyone younger than the age of 13 and we do not knowingly collect personal information from individuals younger than age 13.