Providing your Personal Information to us is completely voluntary. “Personal Information” is information that can specifically identify you. We do not collect Personal Information unless you submit that information to us, including when you send us your resume through the Web site, or otherwise participate in our interactive features on the Web site. Additionally, we may also collect certain other types of information that, along with Identity Data Contact Data, and Financial Data may be considered and specifically named “personal data” in certain jurisdictions including the European Union (“EU”).
Categories of Personal Information we collect include:
- 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
IF YOU ARE SITUATED IN THE EU, PLEASE SEE THE SECTION “ADDITIONAL EU DISCLOSURES” THAT PERTAIN TO OUR COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL DATA AND ADDITIONAL RIGHTS YOU HAVE UNDER APPLICABLE LAW.
In addition, we may also collect information that is not Personal Information (“Non-Personal Information”). We may aggregate Personal Information so that the aggregated information does not personally identify you or anyone else, such as by using Personal Information to calculate the percentage of our visitors who live in a particular area (“Aggregate Information“). Because Non-Personal Information does not personally identify you, we may collect, use and disclose Non-Personal Information for any purpose permitted by law and subject to the section titled “Additional EU Disclosures”. In some instances, we may combine Non-Personal Information with Personal Information. If we combine any Non-Personal Information with Personal Information, the combined information will be treated by us as Personal Information.
Information Usage and Disclosure:
Besides using your Personal Information ourselves, we may send your Personal Information to other companies, affiliates and third parties to help us process your Personal Information for the purposes set out in this policy.
We use Personal Information and other information as described herein:
- to contact you about our (and our affiliates) products and services and provide you with our products and services
- to personalize your experience with us including by presenting products or services tailored to you
- to allow you to use, communicate and interact with others on our Web site
- to respond to your direct inquiries
- to add you to our mailing lists and send you emails from time to time
We will not sell your Personal Information to any third party not affiliated with Ketchum without your consent except in connection with the sale or merger of Ketchum or the division responsible for such services.
Additionally, we may disclose Personal Information and other information as we believe necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; (g) to allow us to pursue available remedies or limit the damages that we may sustain; and (h) for legitimate business interests.
We may use Aggregate Information and Non-Personal Information to improve and enhance your experience on the Web site and for our market research activities. For example, and subject to section titled “Additional EU Disclosures”, we may share Aggregate Information and Non-Personal Information with unaffiliated third parties, such as business partners, manufacturers, distributors and retailers, in a form in which means the shared information will not contain nor be linked to any Personal Information.
Please note that if you specifically consent to additional uses of your Personal Information, we may use your Personal Information in a manner consistent with that consent. Finally, we reserve the right to supplement your Personal Information with information we gather from other sources which may include information we gather from online and offline sources.
The security of your Personal Information is very important to us. [We attempt to provide for the secure transmission of your information from your computer to our servers by utilizing encryption software.] However, due to the inherent open nature of the Internet, we cannot guarantee that communications between you and Ketchum, or information stored on the Web site or our servers, will be free from unauthorized access by third parties such as hackers and your use of the Web site demonstrates your assumption of this risk. We have put in place reasonable physical, electronic, and managerial procedures to safeguard the information we collect. Only those employees who need access to your information in order to perform their duties are authorized to have access to your Personal Information. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the Contact section below.
We will retain your information for as long as needed to provide you with the Web site and for a reasonable time thereafter in accordance with our standard procedures or as necessary to comply with our legal obligations, to resolve disputes, and to enforce our agreements. Even if we delete some or all of your Personal Information, we may continue to retain and use anonymous or aggregated data previously collected. Please note that we will not be liable for disclosures of your data due to errors or unauthorized acts of third parties.
Protection for Children
Our Web site is intended for ages 18 and over. We do not knowingly collect Personal Information from children. When we become aware that Personal Information (or other information that is protected under applicable law) from a child under 13 (or such other age as may be restricted under local law) has been collected, we will use all reasonable efforts to delete such information from our database.
Other Web sites and Social Networking Services:
Our Web site may contain links to other web sites not maintained by Ketchum. Other web sites may also reference or link to our Web site. The inclusion of a link on the Web site does not imply endorsement of the linked site by us. We are not responsible for the privacy practices of websites operated by third parties that are linked to or integrated with our Web site, or for the privacy practices of third party Internet advertising companies. We encourage you to be aware when you leave our Web site, or surf the Internet, and to read the privacy statements of each and every web site that you visit.
The Web site may integrate with social networking services. You understand that we do not control such services and are not liable for the manner in which they operate. While we may provide you with the ability to use such services in connection with our Web site, we are doing so merely as an accommodation and, like you, are relying upon those third party services to operate properly and fairly.
To opt-out of any future promotional messages from us, you should send an unsubscribe request to us at firstname.lastname@example.org. We will process your request within a reasonable time after receipt. Please note that if you opt out in this manner, certain aspects of the Web site may no longer be available to you.
Changes to policy:
We reserve the right, at our discretion, to change, modify, add, or remove portions from this policy at any time. Your continued use of the Web site following the posting of any changes to this policy means you accept such changes.
Communications with Ketchum:
By providing your email address to us, you expressly consent to receive emails from us. We may use email to communicate with you, to send information that you have requested or to send information about other products or services developed or provided by us or by others that we believe will be of interest to its audience. If you receive an unwanted email from us, you can simply reply and ask not to receive future emails. We also give you the option to remove your Personal Information (and other information required by law) from our list of active users completely. All unsubscribe or opt-out requests should be sent to us at email@example.com and we will process your request within a reasonable time after receipt. We are not responsible for removing your information from the lists of any third party who has been provided your information in accordance with this policy, such as a business partner.
Under California Law, California residents have the right to request in writing from businesses with whom they have an established business relationship, (a) a list of the categories of Personal Information, such as name, email address and mailing address and the type of services provided to the customer that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes and (b) the names and addresses of all such third parties. To request the above information, please contact us by email at firstname.lastname@example.org. If you do not want your Personal Information shared with any third party who may use such information for direct marketing purposes, then you may opt out of such disclosures by sending an email to us at email@example.com.
Additional EU Disclosures:
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
- Where you have consented to a certain use of your personal data
- Where we need to comply with a legal or regulatory obligation
To the extent permitted under applicable laws, we will also process, transfer, disclose and preserve personal data when we have a good faith belief that doing so is necessary.
Ketchum Inc. is the data controller of all personal data collected through our Web site. To contact us, please see the section titled “Contact Us”.
If you are situated in the EU and have any complaints regarding our privacy practices, you have the right to make a complaint at any time to your local Supervisory Authority. We would, however, appreciate the chance to deal with your concerns before you approach your Supervisory Authority so please contact us in the first instance. If you have a complaint, please contact our privacy manager at firstname.lastname@example.org.
Provision of personal data and failure to provide personal data:
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we will not be able to provide services to you.
Collection of Personal Information from third party sources:
We also collect personal data about you from various third parties and public sources.
Withdrawing your consent:
If we are relying on your consent to process your personal data, you have the right to withdraw your consent at any time. You have the right to withdraw your consent at any time by contacting us at email@example.com.
We may transfer personal data from the EU to the USA and other countries, some of which have not been determined by the European Commission to have an adequate level of data protection. If we transfer personal data outside the EU to a processor, such transfer will be in compliance with the requirements of the GDPR.
Use of your personal data for marketing purposes:
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising:
- Promotional offers from us: We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or used our services and, in each case, you have not opted out of receiving that marketing.
- Third-party marketing: We will get your express opt-in consent before we share your personal data with any company outside of Ketchum and its related businesses for marketing purposes.
To see how you can opt out of marketing communications, please see the section titled “Opt-Out”.
Data Subject Rights:
If you are a situated in the EU, under GDPR, as a data subject, you have the following rights:
- Right to access – This right allows individuals to obtain confirmation as to whether or not personal data concerning him or her is being process and provide access to such personal data. It also allows individuals to request details of the processing of his or her personal data, including, without limitation, categories of recipients to whom the personal data have been or will be disclosed and purposes of processing.
- Right to rectify – This right allows individuals to rectify any inaccurate personal data about him or her.
- Right to restrict processing – This right allows individuals to block or suppress processing of personal data under certain circumstances.
- Right to be forgotten – This right is also known as the “right to erasure”. It is an individual’s right to have personal data erased or to prevent processing in specific circumstances.
- Right of data portability – This right allows individuals to move, copy or transfer personal data from one place to another in a secure manner without interrupting the integrity and usability of the information.
- Right to object to processing – This right allows individuals to object to certain types of processing, including direct marketing, profiling and providing for purposes of scientific or historical research and statistics.
To exercise your rights under the GDPR, please contact us at firstname.lastname@example.org. Please note that in order for you to assert these rights, we may need to verify your identity to confirm your right to access your personal data. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. In order to verify your identity, we may need to gather more personal data from you than we currently have.
For questions or concerns relating to privacy, we can be contacted at: email@example.com. If you are situated in the EU and have any complaints regarding our privacy practices, you have the right to complain to a supervisory authority.
Our Web site is maintained in the United States of America. Subject to the subsection “Data Transfer” in the section titled “Additional EU Disclosures”, by using the Web site, you authorize the export of your information to the USA and its storage and use as specified in this policy.