EUROPEAN UNION DATA TRANSFER POLICY
EFFECTIVE DATE: 14 February, 2008

PURPOSE

This policy governs the personal information collected by Tupperware Brands Corporation and its subsidiaries ("Tupperware") from its employees residing in nations that have adopted the European Union (EU) Directive on Data Protection, No. 95/46/EC.

This policy is intended to ensure Tupperware is in compliance with the US Department of Commerce Safe Harbor program, and therefore that Tupperware satisfies the "adequacy" requirement under the European Directive on Data Protection. This will permit Tupperware companies within the EU to send personal data to Tupperware companies in the US, and for Tupperware companies in the US to receive such personal data.

NOTICE

Employees are asked to provide personal data at hiring, and throughout their employment, to permit us to compensate you for your work, provide fringe benefits, and other tasks related to the operation of the company.

CHOICE

Your personal data is occasionally transmitted to third parties within the EU (or within countries approved by the EU) to provide your compensation and fringe benefits, or to satisfy your government's reporting requirements. We may also transfer your data to another of our Tupperware affiliates within the EU (or EU-approved countries) for normal processing, simply to reduce costs by pooling resources. As these transfers are incidental to your employment, and are all within EU-approved areas, we will not request your prior consent to these transfers.

ONWARD TRANSFER

Tupperware is a global company, based in the United States. While most data processing for your compensation is done locally, special incentive programs (such as performance bonuses) are calculated at our headquarters in the U.S. In addition, we transfer data relating to career planning and management of our succession plan to our U.S. headquarters. If you are eligible for such a special incentive program, or are part of the succession plan process, portions of your personal data will be transferred to our headquarters in the U.S. We will attempt to transfer only the personal information necessary for administration of the incentive program.

ONWARD TRANSFER

Tupperware is a global company, based in the United States. While most data processing for your compensation is done locally, special incentive programs (such as performance bonuses) are calculated at our headquarters in the U.S. In addition, we transfer data relating to career planning and management of our succession plan to our U.S. headquarters. If you are eligible for such a special incentive program, or are part of the succession plan process, portions of your personal data will be transferred to our headquarters in the U.S. We will attempt to transfer only the personal information necessary for administration of the incentive program.

Each year, Tupperware certifies with the U.S. Department of Commerce that it is in compliance with the Safe Harbor certification framework. The EU has found this Safe Harbor program to provide adequate protection of your personal data while it is here in the U.S. If your personal data is transferred to third parties in the U.S. acting as our agent, that third party will be required to either 1) certify their compliance with the Safe Harbor principles as we have, or 2) enter into a written agreement containing privacy protection clauses approved by your home government for such transfers. As these transfers are incidental to your employment, and are all within EU-approved guidelines, we will not request your prior consent to these transfers.

SECURITY

Tupperware is serious about the security of your personal data. Both in your local country and in the U.S., we provide various security features. Access to both paper and electronic information is limited by the employee's job function. Paper records are protected by lock and key. Electronic records are protected by user name and password verification. Our processing applications are housed in our firewall protected networks.

DATA INTEGRITY AND ACCESS

Our HR and compensation functions include checks and procedures to keep your personal data accurate, complete, and current. Employees may review their personal data by submitting a written request to their local HR representative. If your personal data is inaccurate, you may submit a written request and we will correct, amend, or delete the information, as appropriate.

ENFORCEMENT

As part of our annual certification process we will review our compliance with this policy as part of our internal audit. Any complaints or disputes regarding personal data protection may be sent to you local HR Representative. Complaints or disputes that cannot be remedied by the local HR Representative should be forwarded to the General Counsel at email address intlaw@tupperware.com. Tupperware also agrees to cooperate with your local data protection authorities to resolve disputes.

Tupperware may change or terminate this policy in whole or in part at its discretion, and without prior notice to or the consent of any employee. Tupperware retains sole and absolute discretionary authority to resolve all questions arising in the administration, interpretation and application of this policy. This authority includes construing the terms of this policy, including any disputed or doubtful terms, and determining the eligibility of any individual to receive any policy benefit.



 

   
 

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