We at Porter Novelli (“we”, “us” or “our”) respect your privacy.
Porter Novelli is a company located in the United States. Porter Novelli United Kingdom, Cone Communications United States, Martec Porter Novelli Mexico and Porter Novelli Canada are affiliates of Porter Novelli.
Please see our European privacy notice for how we (to the extent we are subject to the General Data Protection Regulation) and our European affiliates process your personal data.
PURPOSE OF THIS POLICY
This Policy will inform you of the nature of the personal information about you that is processed by us and how you can request that we delete, update, transfer and/or provide you with access to it or otherwise cease processing it for a specific purpose. This Policy is intended to assist you in making informed decisions when using this Site.
We respect your concerns about privacy. We participate in the EU-U.S. Privacy Shield framework (“Privacy Shield”) issued by the U.S. Department of Commerce. We commit to comply with the Privacy Shield Principles with respect to any personal information that we receive from the European Union.
TYPE OF PERSONAL INFORMATION COLLECTED
Personal information is information that identifies you as an individual. Categories of personal information we collect include:
- contact information (g. name, physical address, telephone number, email address),
- information about your interests or affiliations,
- information for hiring and human resources (g.employment and education history, work eligibility status, date of birth, financial account information, government-issued identification information), and
- additional information you submit to us.
WAYS OF OBTAINING PERSONAL INFORMATION
We may collect and receive your personal information using different methods:
Personal information you provide to us. You may give us your personal information directly. This will be the case when, for example, you contact us with inquiries, complete forms on our Site or in hard copy or participate in a survey, subscribe to receive our marketing communications or provide feedback to us otherwise through your interactions with us.
Personal information received from third parties. From time to time, we will receive personal information about you from third parties. Such third parties may include analytics providers, payment providers, hotel and transport providers and third parties that provide technical services to us so that we can operate our Site and provide our services.
Publically available Personal information. From time to time we may collect personal information about you from publically available sources or media reports or personal information about you that you or a third party may make publically available to us (for example through speaking at events or publishing articles or other news stories).
HOW WE USE PERSONAL INFORMATION
Our primary goal in collecting personal information from you is to:
- verify your identity,
- provide our services to clients;
- help us improve our products and services and develop and market new products and services,
- carry out requests made by you to us,
- investigate or settle inquiries or disputes,
- comply with any applicable law, court order, other judicial process, or the requirements of a regulator,
- enforce our agreements with you,
- protect the rights, property or safety of us or third parties, including our other clients and users of the Site,
- provide support for the provision of our Services, and
- use as otherwise required or permitted by law.
USES OF PERSONAL INFORMATION COLLECTED THROUGH THIS SITE
The following describes how we use personal information that we collect through this Site:
- Client information.
Information we collect with respect to our clients and potential clients is used to enable us to respond to client requests, to administer client accounts with us, to conduct credit checks, and to verify and carry out financial transactions for payments made to us.
- Media and informational inquiries.
We may collect information for interviews requests, for media questions, or requests for information about our company. We may also provide you with the opportunity to sign up for newsletters or to receive copies of blogs and other information that we make available. Contact information may be requested in each case, together with details of other personal information that is relevant to these inquiries. This information is used in order to enable us to respond to your requests or media requests.
- Career Opportunities.
Potential employees and service providers may provide us with information to find out about and apply for career opportunities, including by providing resumes and other related information. This information is used to enable us to review applications, respond to these requests, and to make hiring decisions.
The information you provide to us may be archived or stored periodically by us according to our standard backup processes and our document retention policy.
OTHER USES OF PERSONAL INFORMATION
We may also collect information in other contexts other than this Site as described above. That information may be used in the manner described above and in other ways, such as:
- Surveys and voting.
We may collect personal information from you via surveys or voting polls. Participation is voluntary and you will have the opportunity to decide whether or not to disclose information. At times, you may have to register to vote or to take part in a survey. We would use that information to report the results of the survey or vote.
We may conduct promotions, contests or giveaways, which may require that you register to enter. We collect personal information from you in order to conduct the promotion, contest or giveaway and to deliver prizes or notices. Participation in these events and providing us with your information is voluntary.
- Industry information.
We collect and maintain databases containing, information about journalists, talent, social media influencers, social media users and other professionals in the public relations, news or media industry collected by us or by our trusted third party media analytics service providers. Such information may include an individual’s name, business contact details, professional interests and affiliations. This information may be information that is voluntarily supplied to us by those individuals through our Site or in other situations (such as public speaking events) or information that is public or available in third-party databases or via third-party content platforms (including social media platforms). Further, we may collect and/or review other publically available news stories and other journalistic content including content made available through public news sites and social media sites to understand what people are saying about us and our clients. We use this information to provide our services to our clients including ensuring we and our clients are fully up to speed on public opinion in any particular area and are fully briefed when it comes to dealing with the press. We may also use this information for our own internal administrative and promotional purposes. We make efforts to minimize the use of this information to that which is strictly necessary for our legitimate business interests.
- Interactive areas.
We may provide interactive areas, such as message boards, chat rooms or other forums. Participation in these areas by users is voluntary. We discourage you from submitting any information that may identify you personally when participating in these areas. Use of these public areas is not secure and we cannot ensure that your information will be protected.
- Marketing communications.
We may carry out marketing activities using your personal information. We may send marketing information to you by mail or email. We may also provide you with information about media and public relations events. It may be necessary to mention the purpose of other marketing communications at the point that we collect that information. We send this information and materials to you where you have consented to receive such information or materials, or where we have another lawful basis to do so to the extent required by law.
- Receipt of services.
If we have engaged you or the organization you represent to provide us with products or services (for example, if you or the organization you represent provide us with services such as IT support or financial advice), we will collect and process your personal information in order to manage our relationship with you or the organization you represent, to receive products and services from you or the organization you represent and, where relevant, to provide our Services to others.
- Business administration and legal compliance
We may use your personal information for the following business administration and legal compliance purposes:
- to comply with our legal obligations;
- to enforce our legal rights;
- to protect the rights of third parties; and
- in connection with a business transition such as a merger, reorganization, acquisition by another company, or sale of all or a portion of our assets.
PERSONAL INFORMATION OF CHILDREN
Our Site is intended for ages 18 and older. We do not intend to or knowingly collect personal information from children.
If you are a parent or guardian who has discovered that your child has submitted his or her personal information without your permission or consent, we will take reasonable steps to remove that information from the Company database at your request. To request removal of your child’s information, please send us an e-mail to [email protected] and be sure to include in your message your contact information.
SHARING YOUR INFORMATION
We may share your personal information with any of our group affiliates, or with our agents, partners, clients or contractors or professional advisers or government or regulatory bodies for the following purposes: (a) provide our services to clients or otherwise receive assistance in processing transactions; (b) fulfillment of requests for information, receiving and sending communications, updating marketing lists, analyzing data; (c) provision of IT and other support or internal administrative business services; or (d) assistance in other ancillary to the operation of tasks, from time to time. Our agents, partners and contractors will only use your information to the extent necessary to perform their functions.
We will not sell your personal information to other companies and we will not share it with other companies for them to use without your consent, except in the circumstances listed above or in connection with the sale or merger of Porter Novelli or the division or office responsible for the services.
Your personal data may be transferred to the United States, EU jurisdictions and/or other non-EU jurisdictions, as applicable.
OBTAINING YOUR CONSENT
Where our use of your personal information requires your consent, you can provide such consent:
- at the time we collect your personal information following the instructions provided; or
- by informing us by e-mail, post or phone using the contact details set out in this Policy.
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.
We provide you with reasonable access to the personal information maintained about you. We also provide you with a reasonable opportunity to correct, amend or delete the information where it is inaccurate. We may limit or deny access to personal information where permitted or required by law. These circumstances may include situations where the burden or expense of providing access would be disproportionate to the risks to your privacy in the case in question, or where the rights of third persons would be violated.
CHOICE AND MEANS
We generally offer you the opportunity to choose whether your personal information may be (a) disclosed to third-party controllers or (b) used for a purpose that is materially different from the purposes for which the information was originally collected or subsequently authorized by you. To the extent required by the Privacy Shield Principles or applicable law, we obtain opt-in consent for certain uses and disclosures of sensitive data. Unless we offer you an appropriate choice, we use personal information only for purposes that are materially the same as those indicated in this Policy. To exercise your choices you may contact us as indicated in this Policy.
We may share personal information with our affiliates and subsidiaries as described above under SHARING YOUR INFORMATION. We may disclose personal information without offering an opportunity to opt out, and we may be required to disclose such information (a) to third-party processors we have retained to perform services on our behalf and pursuant to our instructions, (b) if we are required to do so by law or legal process, or (c) in response to lawful requests from public authorities, including to meet national security, public interest or law enforcement requirements. We also reserve the right to transfer personal information in the event of an audit or if we sell or transfer all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, dissolution or liquidation).
Porter Novelli takes reasonable and appropriate measures to protect personal data from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the personal data. Also see CONFIDENTIALITY AND SECURITY OF YOUR INFORMATION below.
THIRD PARTY LINKS AND SERVICES
Our Site contains links to third party websites and services. Please remember that when you use a link to go from our Site to another website or you request a service from a third party, this Policy no longer applies.
Your browsing and interaction on any other websites, or your dealings with any other third-party service provider, is subject to that website’s or third party service provider’s own rules and policies. We do not monitor, control, or endorse the privacy practices of any third parties.
This 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 Site, we are doing so merely as an accommodation and, like you, are relying upon those third-party services to operate properly and fairly.
This Policy does not apply to these third-party websites and third-party service providers.
OPT OUT AND UNWANTED COMMUNICATIONS
To opt-out of any future promotional or marketing communications or any other communications from us, you should send a request to us at the contact information in the section entitled CONTACT DETAILS. We will process your request within a reasonable time after receipt. Please note that if you opt out in this manner, certain aspects of this Site may no longer be available to you.
CONFIDENTIALITY AND SECURITY OF YOUR PERSONAL INFORMATION
We are committed to keeping the personal information you provide to us secure. We take reasonable and appropriate measures to protect your personal information, including but not limited to sophisticated software and hardware that prevent personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the personal information.
Information regarding job applications is encrypted and transmitted in a secure way. We employ a security technology known as a secure-socket-layer (“SSL”) to protect the transmission of critical account information to the site. Only employees or third parties who need the information to process a specific request are granted access to personally identifiable information.
We might receive personal information under the Privacy Shield and subsequently transfer to a third party acting as an agent on our behalf. In such case, we remain liable if our agent processes such personal information in a manner inconsistent with the Privacy Shield Principles, unless we are able to prove that we are not responsible for the event giving rise to the damage.
- We use analytical cookies to recognize and count users of our Site, measure the effectiveness of our content, and understand how visitors use our Site.
- We may place, or allow a third party to place, functional cookies to make a website easier to use, such as cookies that maintain a user’s session.
- For example, job applicants who visit our Site and apply for a job are directed to a third-party site to submit applications and that site places a cookie that is used to maintain an applicant’s session. That same third party may also place other cookies, such as a LinkedIn cookie, that may also apply to job applicants. You can delete these cookies via your browser settings.
You can review your Internet browser settings to exercise choices you have for certain cookies. If you disable or delete certain cookies in your Internet browser settings, you might not be able to access or use important functions or features of this Sites, and you may be required to re-enter your log-in details.
COMPLIANCE WITH THE PRIVACY SHIELD
Porter Novelli complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. Porter Novelli has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.
We may make changes to this Policy from time to time. This Site includes a date on which it was last updated.
To ensure that you are always aware of how we use your personal information, we will update this Policy from time to time to reflect any changes to our use of your personal information. We encourage you to review this Policy periodically to be informed of how we use your personal information.
HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?
We retain personal information only for as long as is necessary for the purposes described in this Policy, after which it is deleted from our systems.
Regarding personal information we have processed in connection with the supply of our services to clients, we may retain personal information relevant to our services for up to five (does this need to be specified – “no longer than is necessary” ) years from the date of supply and in compliance with our obligations under the EU General Data Protection Regulation (or similar legislation around the world). We may then destroy such files without further notice or liability.
Regarding any other personal information we have processed, we may retain relevant personal information for up to three years (does this need to be specified – “no longer than is necessary” ) from the date of our last interaction with the relevant individual and in compliance with our obligations under the EU General Data Protection Regulation (or similar legislation around the world). We may then destroy such files without further notice or liability.
Porter Novelli is committed to cooperating with EU data protection authorities (DPAs) and comply with the advice given by such authorities with regard to human resources data transferred from the EU in the context of the employment relationship.
If any personal information is only useful for a short period (e.g. for a specific event or marketing campaign or in relation to recruitment), we may delete it at the end of that period.
If you have opted out of receiving marketing communications from us, we will need to retain certain personal information on a suppression list indefinitely so that we know not to send you further marketing communications in the future.
RECOURSE ENFORCEMENT AND LIABILITY
We are subject to the investigatory and enforcement powers of the Federal Trade Commission. We have mechanisms in place designed to effect compliance with the Privacy Shield Principles. We conduct an annual self-assessment of personal information handling practices to verify that the attestations and assertions we make about our Privacy Shield privacy practices are true and that such privacy practices have been implemented as represented and in accordance with the Privacy Shield Principles.
Consumer Recourse: You may file a complaint concerning our processing of your personal information. We will take steps to remedy issues arising out of any alleged failure to comply with the Privacy Shield Principles. You may contact us as specified below about complaints regarding our personal information handling practices..
For questions or concerns about this Policy, or to ask questions or express concerns about our collection, management and processing of personal information, Consumers may contact us by:
- sending an e-mail to [email protected]; or
- sending us a letter:
Attn: General Counsel
220 East 42nd Street
New York, NY 10017
ALTERNATIVE DISPUTE RESOLUTION
If a Consumer’s complaint cannot be resolved through our internal processes, we will cooperate with the alternative dispute resolution provider JAMS (Judicial Arbitration and Mediation Services) 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. The mediator may propose any appropriate remedy, such as deletion of the relevant personal information, publicity for findings of noncompliance, payment of compensation for losses incurred as a result of noncompliance, or cessation of processing of the personal information of the Consumer who brought the complaint. The mediator or the Consumer also may refer the matter to the U.S. Federal Trade Commission, which has Privacy Shield investigatory and enforcement powers over us. Under certain circumstances, Consumers also may be able to invoke binding arbitration to address complaints about our compliance with the Privacy Shield Principles.
Porter Novelli has further committed to refer unresolved Privacy Shield complaints to JAMs, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit www.jamsadr.com/international-mediation-rules for more information or to file a complaint. The services of JAMs are provided at no cost to you.
In addition to the above and under certain conditions, the individual may invoke binding arbitration for complaints that have not been resolved by any of the other Privacy Shield mechanisms. See Annex 1of the Privacy Shield framework for further information: https://www.privacyshield.gov/servlet/servlet.FileDownload?file=015t00000004qAg.