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Privacy

Privacy Policy

Welcome to “The Love of Benji” (https://www.theloveofbenji.com). We understand that privacy online is important to users of our Site, especially when conducting business. This statement governs our privacy policies with respect to those users of the Site (”Visitors”) who visit without transacting business and Visitors who register to transact business on the Site and make use of the various services offered by “The Love of Benji” (collectively, ”Services”) (”Authorized Customers”).

Personally Identifiable Information refers to any information that identifies or can be used to identify, contact, or locate the person to whom such information pertains, including, but not limited to, name, address, phone number, fax number, email address, financial profiles, social security number, and credit card information. Personally Identifiable Information does not include information that is collected anonymously (that is, without identification of the individual user) or demographic information not connected to an identified individual.

Is Personal Identifiable Information collected?

We may collect necessary user profile information from all of our Visitors. We collect the following additional information from our Authorized Customers: the names, addresses, phone numbers and email addresses of Authorized Customers, the nature and size of the business, and the nature and size of the advertising inventory that the Authorized Customer intends to purchase or sell.

What organizations are collecting the information?

In addition to our direct collection of information, our third-party service vendors (such as credit card companies, clearinghouses and banks) who may provide such services as credit, insurance, and escrow services may collect this information from our Visitors and Authorized Customers. We do not control how these third parties use such information, but we do ask them to disclose how they use personal information provided to them from Visitors and Authorized Customers. Some of these third parties may be intermediaries that act solely as links in the distribution chain and do not store, retain, or use the information given to them.

How does the Site use Personally Identifiable Information?

We use Personally Identifiable Information to customize the Site, to make appropriate service offerings, and to fulfill buying and selling requests on the Site. We may email Visitors and Authorized Customers about research or purchase and selling opportunities on the Site or information related to the subject matter of the Site. We may also use Personally Identifiable Information to contact Visitors and Authorized Customers in response to specific inquiries, or to provide requested information.

With whom may the information be shared?

Personally Identifiable Information about Authorized Customers may be shared with other Authorized Customers who wish to evaluate potential transactions with other Authorized Customers. We may share aggregated information about our Visitors, including the demographics of our Visitors and Authorized Customers, with our affiliated agencies and third party vendors. We also offer the opportunity to ”Opt-Out” of receiving information or being contacted by us or by any agency acting on our behalf.

How is Personally Identifiable Information stored?

Personally Identifiable Information collected by The Love of Benji is securely stored and is not accessible to third parties or employees of The Love of Benji except for use as indicated above.

What choices are available to Visitors regarding collection, use, and distribution of the information?

Visitors and Authorized Customers may opt-out of receiving unsolicited information from or being contacted by us, or our vendors and affiliated agencies by responding to emails as instructed.

Are Cookies Used on the Site?

Cookies are used for a variety of reasons. We use Cookies to obtain information about the preferences of our Visitors and the services they select. We also use Cookies for security purposes to protect our Authorized Customers. For example, if an Authorized Customer is logged on and the site is unused for more than 10 minutes, we will automatically log the Authorized Customer off.

How does “The Love of Benji” use login information?

The Love of Benji uses login information, including, but not limited to, IP addresses, ISPs, and browser types, to analyze trends, administer the Site, track a user’s movement and use, and gather broad demographic information.

What partners or service providers have access to Personally Identifiable Information from Visitors and or Authorized Customers on the Site?

The Love of Benji has entered into and will continue to enter into partnerships and other affiliations with several vendors. Such vendors may have access to specific Personally Identifiable Information on a need to know basis for evaluating Authorized Customers for service eligibility. Our privacy policy does not cover their collection or use of this information.

Disclosure of Personal Identifiable Information to comply with the law.

We will disclose Personally Identifiable Information to comply with a court order or subpoena or a request from a law enforcement agency to release information. We will also disclose Personally Identifiable Information when reasonably necessary to protect the safety of our Visitors and Authorized Customers.

How does the Site keep Personally Identifiable Information secure?

All of our employees are familiar with our security policy and practices. The Personally Identifiable Information of our Visitors and Authorized Customers is only accessible to a limited number of qualified employees who are given a password to gain access to the information. We audit our security systems and processes regularly. Sensitive information, such as credit card numbers or social security numbers, is protected by encryption protocols, in place to protect information sent over the Internet. While we take commercially reasonable measures to maintain a secure site, electronic communications and databases are subject to errors, tampering, and break-ins, and we cannot guarantee or warrant that such events will not take place and we will not be liable to Visitors or Authorized Customers for any such occurrences.

How can Visitors correct any inaccuracies in Personally Identifiable Information?

Visitors and Authorized Customers may contact us to update Personally Identifiable Information about them or to correct any inaccuracies by emailing us at [email protected]

Can a Visitor delete or deactivate Personally Identifiable Information collected by the Site?

We provide Visitors and Authorized Customers with a mechanism to delete/deactivate Personally Identifiable Information from the Site’s database by contacting. However, because of backups and records of deletions, it may be impossible to delete a Visitor’s entry without retaining some residual information. An individual who requests to have Personally Identifiable Information deactivated will have this information functionally deleted, and we will not sell, transfer, or use Personally Identifiable Information relating to that individual in any way moving forward.

What happens if the Privacy Policy Changes?

We will let our Visitors and Authorized Customers know about changes to our privacy policy by posting such changes on the Site. However, if we are changing our privacy policy in a manner that might cause disclosure of Personally Identifiable Information that a Visitor or Authorized Customer has previously requested not be disclosed, we will contact such Visitor or Authorized Customer to allow such Visitor or Authorized Customer to prevent such disclosure.

Links:

https://theloveofbenji.com contains links to other web sites. Please note that when you click on one of these links, you are moving to another web site. We encourage you to read the privacy statements of these linked sites as their privacy policies may differ from ours.

Children’s Online Privacy Policy

The Love of Benji is focused on ensuring the security of kids who utilize our site. This Children’s Online Privacy Policy clarifies our information gathering, disclosure, and parental consent practices with respect to personal information provided by children under the age of 13 (“child” or “children”), and uses terms that are defined in our Privacy Policy. It complies with the U.S. Children’s Online Privacy Protection Act (“COPPA”) and outlines our practices in the United States and Latin America with respect to children’s personal information.

Collection of Information, Use of it and Communication with Parents

Children can investigate the site and can view and print content without giving any individual data other than the automatic collection of device “persistent identifiers,” examined in more detail beneath. Our site gathers limited personal data if the child registers to become a member or presents a question or request to us. In the event, the data gathered does not permit contact with him or her or his or her gadget (counting, for instance, collected data), we may utilize and uncover it for any reason, to the degree allowed by applicable law.

Registration Process

In the event the child wants to register to our site, we require the following data to be submitted:

  • Username (we advise the child not to use his or her real name);
  • Password;
  • Birth month and year.

We additionally require the child to give a parent’s email address. We utilize the parent’s email address to look for parental consent for the child’s enrollment and to clarify what data we are gathering, how we plan to use it, and how the parent can renounce consent or demand whenever that we expel the record and erase any individual data collected from the child (counting the parental contact data). In the event, that you believe your child is taking part in an action that gathers individual data and you or another parent/guardian have NOT consented, or in the event that you no longer wish for your child to take an interest as an individual from the site, please don’t hesitate to reach us at [email protected] and we will erase your child’s record and the parental contact data.

Content Generated by Child

Specific exercises on our site and applications permit the child to make or control content and save it. Some of these exercises don’t oblige children to give any individual data, and during this time we may not bring about notice to the parents. In the event, when an activity asks the child to provide personal data, we will either ask the submitter to delete the information, or we will look for verifiable parental consent by email for collection. If in addition to collecting information that includes personal information, The Love of Benji also plans to post the content publicly or share it with a third party for the third party’s use, we will obtain a higher level of parental consent.

Persistent Identifiers

At the point when children collaborate with the site, specific technical data may consequently be gathered, both to make our site more exciting and helpful and for different internal purposes identified with our business. Examples of data that is automatically collected include the type of computer operating system, the device’s IP address or mobile device identifier, the web browser, the frequency with which the child visits various parts of our site, and information regarding the online or mobile service provider. This data is gathered utilizing techniques, for example, flash cookies, web beacons, and other unique identifiers (which we define under the “Cookies and Other Technologies” section of our general Privacy Policy). This data might be gathered by a third party or by us. The Love of Benji uses persistent identifier information for the sole purpose of providing support for our internal operations, including to:

  • Ensure that the site functions correctly;
  • Enable us to conduct research and analysis to understand, address and improve the use and performance of the site; and
  • Diagnose and respond to problems.

What Child’s Information is Visible on the Site?

We strictly restrict the amount of information freely available for an individual who is known to us as a child. When a child posts any content on the site, only the age and the content is visible to others. The child’s username is not published with this submitted content on our website. Even though the child may create a profile for his or her record (which incorporates the username, password, birth month and year, and parent’s email address), no part of the child’s profile other than the child’s age is openly visible.

What Child’s Information is Shared with Others?

We don’t uncover to outsiders any child’s personal information that we gather other than as follows, in compliance with applicable law: (a) with a parent’s authorization, (b) as required by any relevant law, (c) to third-party services who help us work or deal with the site, (d) as part of aggregated data shared with third-party service providers, our Board of Directors, funders and different accomplices, (e) to conform to legal process, (f) to respond to legislative solicitations, (g) to implement our Terms of Service, (h) to ensure our operations, (i) for assistance in fraud detection and prevention; (j) to secure the rights, protection, well being or property of The Love of Benji, your child or others, (k) to allow us to pursue available remedies or limit the damages that we may sustain, and (l) in connection with a disposition of all or a considerable part of our business, resources or stock, for example, a deal, merger, consolidation, redesign, joint venture, task, or bankruptcy or comparable procedures.

Parents Control over Child’s Information

Parents / Guardians may at any time, access, or change the individual data that we have gathered online from their children. Parents may likewise solicit us to stop the accumulation of information from their children, or to make no further utilization of, or erase, the individual data we have gathered online from their children, in which case, the child’s record will be deleted. For your child’s protection, we may need to check your identity before actualizing your demand. We will attempt to agree to your request when reasonably practicable.

How Parents may Raise Questions and Concerns?

If a parent has any questions or concerns about his or her child’s use of the site, we encourage the parent to contact us at [email protected]

California Privacy Rights

If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by The Love of Benji to third parties for the third parties’ direct marketing purposes. To make such a request, please send an email to [email protected]

We take great pride in the relationship of trust and we are dedicated to treating your personal information with care and respect. Pursuant to California Civil Code Section 1798.83(c)(2), The Love of Benji does not share guests’ personal information with other companies or others outside for those parties’ direct marketing use unless a guest elects that we do so.

For more information about our privacy and data collection policies, you may wish to review our Privacy Policy. If you are a California resident under the age of 18, and a registered user of any site where this policy is posted, California Business and Professions Code Section 22581 permits you to request and obtain removal of 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].

Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.

 

EU Privacy Policy

 

I. OBJECTIVE

The aim of this EU Privacy Policy (“the Policy”) is to provide adequate and consistent safeguards for the handling of Personal Data (as defined below) by all “FleishmanHillard entities” (as defined below) Fleishman-Hillard Inc. (“FleishmanHillard”) in accordance with Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (“the Directive”) and all the relevant transposing legislation of the Directive in the European Union/European Economic Area (“EU/EEA”), the Swiss Federal Data Protection Act, as such laws may from time to time be amended and valid during the application of this Policy, the Privacy Shield (defined below), and any other privacy laws, regulations and principles concerning the collection, storage, use, transfer and other processing of Personal Data transferred from the European Economic Area (“EEA”) or Switzerland to the United States including but not limited to the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (“the General Data Protection Regulation”) as of its entry into force on 24 May 2018.

II. SCOPE

This Policy applies to all FleishmanHillard entities in the EU that process Personal Data. “Consumer” “Consumer” means any natural person who is located in the EU, but excludes any individual acting in his or her capacity as an Employee. “Controller” means a person or organization which, alone or jointly with others, determines the purposes and means of the processing of Personal Data as referred to in Privacy Shield materials. “Employee” means any current, former or prospective employee, temporary worker, intern or other non-permanent employee of FleishmanHillard or any current or prospective subsidiary or affiliate of FleishmanHillard. “European Economic Area (“EEA”)” means the following countries: Austria, Belgium, Bulgaria, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Republic of Ireland, Italy, Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, The Netherlands, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, the UK. “FleishmanHillard entities (“FleishmanHillard”)” means Fleishman-Hillard Inc. and all affiliates or other entities owned or controlled by FleishmanHillard in the EEA, irrespective of their different denominations that such entities may hold in different jurisdictions in the EEA. “Personal Data” means any information relating to an identified or identifiable natural person (“data subject”); an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his physical, physiological, mental, economic, cultural or social identity and includes information, that (i) relates to an identified or identifiable Customer, Employee or Supplier’s representative; (ii) can be linked to that Customer, Employee or Supplier’s representative; (iii) is transferred to FleishmanHillard in the U.S. from the EEA or Switzerland, and (iv) is recorded in any form. “Privacy Shield” means the EU-US Privacy Shield framework and agreement between the United States of America, via the US Department of Commerce and the EEA relating to the protection of Personal Data. “Privacy Shield Policy” means the FleishmanHillard Privacy Shield Policy that further details the handling of EU persons Personal Data when transferred to or obtained by FleishmanHillard personnel in the USA; and such policy appears on the company global website www.fleishmanhillard.com, more specifically at https://fleishmanhillard.com/privacy-policy-general/ as well as on the company intranet, and other applicable company websites, e.g. EU company office websites. “Privacy Shield Principles” means the Principles and Supplemental Principles of the Privacy Shield. “Sensitive Personal Data” means Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership or concerning health or sex, and the commission or alleged commission of any offense, any proceedings for any offense committed or alleged to have been committed by the individual or the disposal of such proceedings, or the sentence of any court in such proceedings. “Supplier” means any supplier, vendor or other third party located in the USA and/or the EEA or Switzerland that provides services or products to FleishmanHillard. For the purposes of this Policy Suppliers shall be included within the definition of “Consumers” above. “Systems Privacy Point of Contact” means individual officers designated by FleishmanHillard as the initial points of contact for inquiries, complaints, or questions regarding privacy matters. Currently, such officers are identified at the end of this Policy. “Processing” is defined as any action that is performed on Personal Data, whether in whole or in part by automated means, such as collecting, modifying, using, disclosing, or deleting such data. This Policy does not cover data rendered anonymous or where pseudonyms are used. Data is rendered anonymous if individuals are no longer identifiable or are identifiable only with a disproportionately large expense in time, cost or labor. The use of pseudonyms involves the replacement of names or other identifiers with substitutes, so that identification of individual persons is either impossible or at least rendered considerably more difficult. If data rendered anonymous become no longer anonymous (i.e. individuals are again identifiable), or if pseudonyms are used and the pseudonyms allow identification of individual persons, then this Policy shall apply again.

III. APPLICATION OF LOCAL LAWS

This Policy is designed to provide compliance with all relevant applicable laws in the EEA and in particular those transposing the Directive. FleishmanHillard recognizes that certain laws might be modified to require stricter standards than those described in this Policy, in which case the stricter standards shall apply. FleishmanHillard will handle Personal Data in accordance with local law at the place where the Personal Data is processed. If applicable law provides for a lower level of protection of Personal Data than that established by this Policy, then this Policy shall prevail. Any questions about applicable legislation and FleishmanHillard’s compliance with it shall be addressed to FleishmanHillard’s local legal department or to the legal department in the US.

IV. PRINCIPLES FOR PROCESSING PERSONAL DATA

FleishmanHillard respects Employee, Consumer (including personnel of customers, suppliers, stakeholders, and third parties) privacy and is committed to protecting Personal Data in compliance with the applicable legislation in the EEA. This compliance is consistent with FleishmanHillard’s desire to keep its Employees and Consumers informed and to recognize and respect their privacy rights. FleishmanHillard will observe the following principles when processing Personal Data:

  • Data will be processed fairly and in accordance with applicable law.
  • Data will be collected for specified, legitimate purposes and not processed further in ways incompatible with those purposes.
  • Data will be relevant to and not excessive for the purposes for which they are collected and used. For example data may be rendered anonymous if deemed reasonable, feasible and appropriate, depending on the nature of the data and the risks associated with the intended uses.
  • Data subjects in the EU will be asked to provide their clear and unequivocal consent for the collection, processing and transfer of their Personal Data.
  • Data will be accurate and, where necessary kept up up-to-date. Reasonable steps will be taken to rectify or delete Personal Data that is inaccurate or incomplete.
  • Data will be kept only as it is necessary for the purposes for which it was collected and processed. Those purposes shall be described in this Policy.
  • Data will be deleted or amended following a relevant request by the concerned data subject, should such notice comply with the applicable legislation each time.
  • Data will be processed in accordance with the individual’s legal rights (as described in this Policy or as provided by law).
  • Appropriate technical, physical and organizational measures will be taken to prevent unauthorized access, unlawful processing and unauthorized or accidental loss, destruction or damage to data. In case of any such violation with respect to Personal Data, FleishmanHillard will take appropriate steps to end the violation and determine liabilities in accordance with applicable law and will cooperate with the competent authorities.

V. TYPES OF DATA PROCESSED

As permitted by local laws, the Personal Data relating to Employees may include the following:

  • name;
  • contact information;
  • date of birth;
  • government-issued identification information, passport or visa information;
  • educational history;
  • employment and military history;
  • legal work eligibility status;
  • information about job performance and compensation;
  • financial account information; and
  • other information Employees may provide.

Personal Data relating to Consumers may include:

  • Contact information, such as name, postal address, email address and telephone number; and
  • Personal Data in content Consumers provide on FleishmanHillard’s website and other data collected automatically through the website (such as IP addresses, browser characteristics, device characteristics, operating system, language preferences, referring URLs, information on actions taken on our website, and dates and times of website visits).
  • Financial account information.

 FleishmanHillard also may obtain and use Consumer Personal Data in other ways for which FleishmanHillard provides specific notice at the time of collection (including but not limited to e.g. surveys, focus groups, market research, inbound and outbound Consumer communications and education, etc.).

 VI. WAYS OF OBTAINING PERSONAL DATA

The ways by which FleishmanHillard obtains Personal Data are defined hereby. FleishmanHillard does not obtain any personal information about Employees or Consumers unless the Employee or Consumer has provided that information to FleishmanHillard in a way providing for its clear and unequivocal consent to do so including but not limited to visiting FleishmanHillard’s website, by completion of a written employment application, employee benefits application, insurance form, consent form, survey, or completion of an on-line or hard copy form. Employees and Consumers may choose to submit personal, private information by facsimile, regular mail, e-mail, or electronic transmission over our internal web site, interoffice mail, or personal delivery, as each of these methods may be deemed applicable each time.

 VII. PURPOSES FOR PERSONAL DATA PROCESSING

FleishmanHillard processes personal data for legitimate purposes related to human resources, business and safety /security. The limitation of purposes shall be taken into consideration before any type of processing of Personal Data and shall not be subject to any changes without prior notification. These principal purposes for Employee Personal Data include: Human resources purposes including but not limited to recruiting and hiring job applicants, and:

  • Managing Employee communications and relations
  • Providing compensation and benefits;
  • Administering payroll;
  • Processing corporate expenses and reimbursements;
  • Managing Employee participation in human resources plans and programs;
  • Carrying out obligations under employment contracts;
  • Managing Employee performance;
  • Conducting training and talent development;
  • Facilitating Employee relocations and international assignments;
  • Managing Employee headcount and office allocation;
  • Managing the Employee termination process;
  • Managing information technology and communications systems, such as the corporate email system and company directory;
  • Conducting ethics and disciplinary investigations;
  • Administering Employee grievances and claims;
  • Managing audit and compliance matters;
  • Complying with applicable legal obligations, including government reporting and specific local law requirements; and
  • Other general human resources purposes.

FleishmanHillard may also obtain and process Personal Data about Employees’ emergency contacts and other individuals (such as spouse, family members, dependents and beneficiaries) to the extent Employees provide such information to FleishmanHillard. FleishmanHillard processes this information to comply with its legal obligations and for benefits administration and other internal administrative purposes. For Consumer specific Personal Data, the purposes of processing may include:

  • Running day-to-day business relationship
  • Marketing activities
  • Management of financial accounts
  • Business Development Activities
  • Conduct of transactions or facilitation of offering of the FleishmanHillard Services
  • Conduct of surveys, focus groups, market research, inbound and outbound Consumer communications and education

For Client and Supplier specific information, the purposes of processing may include:

  • Management of its relationships with its Clients and Suppliers
  • Processing payments, expenses and reimbursements
  • Carrying out FleishmanHillard’s obligations under such contracts

If FleishmanHillard introduces a new process or application that will result in the processing of Personal Data for purposes that go beyond the purposes described above, FleishmanHillard will inform the concerned data subjects of such new process or application, new purpose for which the Personal Data are to be used, and the categories of recipients of the Personal Data.

VIII. SECURITY AND CONFIDENTIALITY

FleishmanHillard is committed to taking appropriate technical, physical and organizational measures to protect Personal Data against unauthorized access, unlawful processing, accidental loss or damage and unauthorized destruction. Equipment and Information Security To safeguard against unauthorized access to Personal Data by third parties outside FleishmanHillard, all electronic Personal Data held by FleishmanHillard are maintained on Systems that are protected by up-to-date secure network architectures that contain firewalls and intrusion detection devices. The data saved in servers is “backed up” (i.e. the data are recorded on separate media) to avoid the consequences of any inadvertent erasure, destruction or loss otherwise. The servers are stored in facilities with high security, access protected to unauthorized personnel, fire detection and response systems. The location of these servers is known to a limited number of FleishmanHillard’s Employees. Access security The importance of security for all personally identifiable information associated with FleishmanHillard’s Employees is of highest concern. FleishmanHillard is committed to safeguarding the integrity of personal information and preventing unauthorized access to information maintained in FleishmanHillard’s databases. These measures are designed and intended to prevent corruption of data, block unknown and unauthorized access to our computerized system and information, and to provide reasonable protection of Personal Data in FleishmanHillard’s possession. All employee files are confidentially maintained in the HR department in secured and locked file cabinets or rooms. Access to the computerized database is controlled by a log-in sequence and requires users to identify themselves and provide a password before access is granted. Users are limited to data required to perform their job function. Security features of our software and developed processes are used to protect personal information from loss, misuse, and unauthorized access, disclosure, alteration, and destruction.  Training FleishmanHillard will be responsible for conducting adequate training sessions regarding the lawful, enumerated intended purposes of processing Personal Data, the need to protect and keep information accurate and up-to-date, the lawful purposes of collecting, handling and processing data that is transferred from the EU to the US and the need to maintain the confidentiality of the data to which employees have access. Authorized users will comply with this Policy and FleishmanHillard will take appropriate actions in accordance with applicable law, if Personal Data are accessed, processed, or used in any way that is inconsistent with the requirements of this Policy.

IX. RIGHTS OF DATA SUBJECTS

Any person has the right to be provided with information as to the nature of the Personal Data stored or processed about him or her by FleishmanHillard and may request deletion or amendments. All Employees and Consumers have access to their own personal information and may correct or amend it as needed. Employees may view their own personnel record upon request by contacting the local Talent Development contact or by accessing certain information in the company’s internet and/or extranet. Consumers may contact the Privacy POC or [email protected] to review, update, and revise their Personal Data. If access is denied, the Employee and Consumer has the right to be informed about the reasons for denial. The person affected may resort to the dispute resolution described in Section XIII as well as in any competent regulatory body or authority. FleishmanHillard shall handle in a transparent and timely manner any type of internal dispute resolution procedure about Personal Data is conducted. If any information is inaccurate or incomplete, the person may request that the data be amended. It is every person’s responsibility to provide Talent Development in the case of Employees, or the Systems Privacy POC in the case of Consumers with accurate Personal Data about him or her and to inform such contacts of any changes. (e.g. new home address or change of name). If the person demonstrates that the purpose for which the data is being processed in no longer legal or appropriate, the data will be deleted, unless the applicable law requires otherwise.

X. TRANSFERS

 In connection with the activities described under Section VII, FleishmanHillard may transmit Personal Data outside the EU and more specifically to: (i) FleishmanHillard’s headquarters in St. Louis, Missouri, USA; (ii) FleishmanHillard’s different offices in the US; (iii) FleishmanHillard affiliated entities in the US. Moreover, Personal Data might be sent to the following third parties in or outside the EEA:

  • Selected Third Parties: FleishmanHillard will not disclose or share any personal information with any external entity or third party, except to an employee’s designated insurance provider, employee benefits administrator, travel professionals, clients to illustrate experience and qualifications for business purposes or promotion and not beyond that, to third party vendors and/or marketers upon Consumer’s explicit consent or as an employee or consumer may designate.
  • Other Third Parties: FleishmanHillard may be required to disclose certain Personal Data to other third parties: (i) As a matter of law (e.g. to tax and social security authorities); (ii) to protect FleishmanHillard’s legal rights; (iii) in an emergency where the health or security of an employee is endangered (e.g. a fire); (iv) to Law Enforcement Authorities in accordance with the relevant legislation in the different EEA Member States including but not limited to legislation transposing the EU/2016/1148 concerning measures for a high common level of security of network and information systems across the Union (“the Network Information Security Directive”).

FleishmanHillard complies with all the Privacy Shield Principles of the Privacy Shield and has taken the necessary actions to register within the Privacy Shield framework. In this regard FleishmanHillard has adopted a Privacy Shield Policy, describing in detail the company’s compliance with Privacy Shield Principles for data transferred from the EU to the US. This Privacy Shield Policy is available at the following link: https://fleishmanhillard.com/privacy-policy-general/

 XI. AUTOMATED DECISIONS

Automated decisions are defined as decisions about individuals that are based solely on the automated processing of data and that produce legal effects that significantly affect the individuals involved. FleishmanHillard does not make automated decisions for Employee or Consumer data. If automated decisions are made, affected persons will be given an opportunity to express their views on the automated decision in question and object to it.

XII. ENFORCEMENT RIGHTS AND MECHANISMS

FleishmanHillard will ensure that this Policy is observed and duly implemented. All persons who have access to Personal Data must comply with this Policy. Violations of the applicable data protection legislation in the EEA may lead to penalties and/or claims for damages. If at any time, a person believes that Personal Data relating to him or her has been processed in violation of this Policy, he or she may report the concern to the competent FleishmanHillard’s official. In particular If you have any inquires or complaints about the use or limitation of use of your personal information, you may contact your local human resource (“HR”) contact or the HR department at corporate headquarters: In the EU: Systems Privacy POC FleishmanHillard (Europe) Kay Fynmore Sr. Partner & Managing Director, Talent Development EU FleishmanHillard Fishburn 40 Long Acre, Covent Garden London WC2E 9LG United Kingdom Corporate Headquarters: Systems Privacy POCs Janelle Bailey, SVP & Sr. Partner Jonella Donius, EVP, Sr. Partner & CIO FleishmanHillard 200 No. Broadway St. Louis, Missouri 63102 Or contact: [email protected] Consumers FleishmanHillard is using JAMS (Judicial Arbitration and Mediation Services) as the Alternative Dispute Resolution Provider for Consumer specific data since September 23, 2016. Consumers may file a complaint concerning FleishmanHillard’s processing of their Personal Data. FleishmanHillard will take steps to remedy issues arising out of its alleged failure to comply with the Privacy Shield Principles. Consumers may contact FleishmanHillard as specified above about complaints regarding the company’s Consumer Personal Data practices. If a Consumer’s complaint cannot be resolved through FleishmanHillard’s internal processes, FleishmanHillard will cooperate with the alternative dispute resolution provider, JAMS, pursuant to the JAMS International Mediation Rules, available on the JAMS website at: www.jamsadr.com/international-mediation-rules . JAMS mediation may be commenced as provided for in the relevant JAMS rules. Employees For Employee Personal Data, FleishmanHillard is committed to cooperate with the different national EU Data Protection Authorities (“DPAs”) and comply with the dispute resolution procedures such DPAs may indicate in cases of complaints by Employees as well as with any regulations or guidelines such DPAs may issue from time to time in in accordance with EU and Member State data protection legislation. FleishmanHillard undertakes to register and/or keep its registration updated as a data controller and/or processor in all jurisdictions where FleishmanHillard maintains entities in the EU. XIV. COMMUNICATION ABOUT THE POLICY In addition to the training on this Policy, FleishmanHillard will communicate this Policy to current and new employees and consumers by posting it on the company’s EU offices’ websites as well as on selected internal FleishmanHillard websites and by providing a link to the Policy on information technology applications where Personal Data are collected and processed.  

  1. MODIFICATIONS OF THE POLICY

  FleishmanHillard reserves the right to modify this Policy as needed, for example, to comply with changes in laws, regulations or requirements introduced by DPAs. Changes must be approved by FleishmanHillard’s Privacy POCs, the office of the corporate legal department, or their designees who will seek input as they reasonably deem appropriate from corporate executives such as the CEO, CFO, COO, and Chief of Staff, for the amended Policy to enter into force. If FleishmanHillard makes changes to the Policy, this amended Policy will be submitted for renewed approval according to the relevant applicable provisions of the law. FleishmanHillard will inform FleishmanHillard Employees, Consumers and other persons (e.g. persons accessing FleishmanHillard websites to enter Personal Data such as job application information) of any material changes in the Policy. FleishmanHillard will post all changes to the Policy on relevant internal and external websites. Effective with the implementation of this Policy, all existing and applicable EU company privacy guidelines relating to the collection and/or processing of Personal Data will, where in conflict, be superseded by the terms of this Policy. No other internal policy that conflicts with this Policy shall be applicable with respect to the protection of Personal Data handled by FleishmanHillard in the EU. All parties to such agreements will be notified of the effective date of the implementation of the Policy. XVI. OBLIGATIONS TOWARDS DATA PROTECTION AUTHORITIES FleishmanHillard will respond diligently and appropriately to requests from DPAs about this Policy or compliance with applicable data protection privacy laws and regulations. FleishmanHillard’s employees who receive such requests should contact their human resources manager or business legal counsel. FleishmanHillard will, upon request, provide DPAs with names and contact details of relevant persons. With regard to transfers of Personal Data between FleishmanHillard entities, the importing and exporting FleishmanHillard entities will (i) cooperate with inquiries from the DPA responsible for the entity exporting the data and (ii) respect its decisions, consistent with applicable law and due process rights. With regard to transfers of data to third entities, FleishmanHillard will comply with DPAs’ decisions relating to it and cooperate with all DPAs in accordance with applicable legislation.

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