Daniel J. Edelman Holdings, Inc. includes Daniel J. Edelman, Inc., StrategyOne, Inc. d/b/a Edelman Intelligence, Zeno Group, Assembly Media, Matter, Inc., United Entertainment Group Holdings, LLC (UEG), The K Group Public Relations Company, d/b/a Krispr Communications, Edible, Inc., Edelman Miami Latin America Corp., The H & W Group, d/b/a Salutem, The R Group Public Relations Company, d/b/a Revere, First & 42nd, Inc., and all operating companies under the Edelman family of companies (collectively referred to as “the Company”).
At the Company, we are strongly committed to protecting privacy. The Company has adopted global privacy principles which guide how we manage and protect personal data and demonstrate how fair information practices are embedded in our culture. Read more on our Global Privacy Principles.
As part of our commitment, we strive to protect the privacy of visitors to the sites that we operate (collectively, the “Site”). You can navigate the majority of the Site without giving us any personal information which identifies you. However, sometimes we need additional information about you in order to provide you with information or services you want to receive from us. Also, this Site provides a variety of interactive features which provides you with a public forum through which you have the ability to provide information about yourself to the Company and others.
In this digital world, privacy is important to the Company and should be important to you. The Company believes in transparency and we provide this notice so that you can understand our online information practices and the choices you can make about the way your information is collected and used.
The Information We Collect and Process
The Company collects and processes two basic types of information:
- Personally identifiable information: This is information that personally identifies one individual from another or enables you to be individually contacted (for example, names, e-mail addresses and other contact information). This information is voluntarily provided to us by Site visitors and is used by us for the purpose of responding to user submissions and fulfilling requests for further information about our services.
- Aggregate user and tracking information: This information gives us insights on how Site visitors use our site. This data is anonymous and does not contain any personally identifiable information. We use this information to ensure that our website, e-mails and marketing efforts continue to appeal to Site visitors and clients.
Information you voluntarily provide to Company
The Company only collects personally identifiable information that you voluntarily provide, for example, when you use our “contact us” feature, sign up for a newsletter, set up a voluntary user profile to post content within our forums or interactive features. Examples of such personally identifiable information that you provide to us may include, among other information, your name, physical address and email address. Under such circumstances you consent to our use/processing of the information you provide consistent with this policy.
Other information the Company collects/processes
Our Site may use technologies such as “cookies” to provide visitors with tailored information upon each visit. Cookies are a common part of many commercial websites that allow small text files to be sent by a website, accepted by a web browser and then placed on your hard drive as recognition for repeat visits to the Site. Every time you visit the Site, our servers, through cookies, pixels and/or GIF files, collect basic technical information such as your domain name, the address of the last URL visited prior to clicking through to the Site, and your browser and operating system. We may also use third party analytical tools (e.g. Google Analytics) to analyze activities on the Site and use of the Site. You do not need to enable cookies to visit the Site; however, some parts of the Site and some services may be more difficult or impossible to use if cookies are disabled. Some Company cookie files remain on your computer’s hard drive unless and until you manually delete the file. The Company cookie files do not contain personally identifiable information.
The Way We Use Information
We store the personal information you provide in a secure database in order to provide you with the information, products, and/or services you request and may be used to provide you with additional information about our services we believe may be of interest to you. The information is stored for a time period and in a manner relevant to responding to your request unless you request that it be removed. The information you provide us will be shared with the Company employees and service providers to the extent necessary to administrate our systems and/or accommodate your request.
For example, if you provide your name, mailing address, telephone and/or email address and request more information about the Company’s services, this information will be shared with appropriate Company personnel to fulfill your request. This information will not be shared with non-affiliated third parties without your consent.
We use non-identifying and aggregate information about the use of the Site to improve the navigation, content, and design of the Site. This information may include, for example, the most and least requested pages, analyzing traffic regarding specific features, and the number of users from the U.S. and other countries, among other things.
The Company will not sell or distribute personally identifiable information collected from you outside of the Company without your consent (subject to the limited exceptions stated in this policy).
We may operate contests, sweepstakes or other promotions through the Site, which may require registration in order to enter. Your personally identifiable information may be used by us to contact you for winner notification, prize delivery confirmation or other promotional purposes. Your entry in the contest or sweepstakes may also result in your being added to our mailing lists as well as those of our promotional partners or clients associated with the contest or sweepstakes. Acceptance of a prize may require you (unless prohibited by law) to allow us to post publicly some of your information on the Site, such as in social media or on a winner’s page, in the event you win a contest or sweepstakes.
Surveys or Voting
From time-to-time we may request personally identifiable 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.
The Site provides interactive areas, such as chat rooms, forums and message boards available to its users. You are not required to provide any personal information when using these areas, but you may choose to do so. We strongly recommend that you DO NOT use your personal information as your user name and DO NOT post any personally identifiable information on line, since such information will be publicly available. We cannot ensure the security of any information you choose to make public in a chat room, forum, or message board. Also, we cannot ensure that parties who have access to such publicly available information will respect your privacy. Please exercise caution when deciding to disclose personal information in these areas.
The Company understands that the safety of your personal information is extremely important to you. Accordingly, the Company uses reasonable technological, physical and other measures to keep your information protected from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into due account the risks involved in the processing and the nature of the personal information. Due to the nature of the Internet and related technology, we cannot guarantee the security of your personal information and the Company expressly disclaims any such obligation.
The Company understands the need to protect the privacy of children. The Site is not intended for use by individuals under 13 years of age. The Company does not knowingly collect or maintain personal information from children under the age of 13 at our Site.
How You Can Access or Correct Your Information
You may access, update or remove the information you provided to us by contacting us – see “How to Contact Us” below. Upon receiving your email with the request to update or remove your information, our privacy team will: 1) log the receipt of your request, including the date and time received; 2) take reasonable steps (including seeking additional information or documentation) to the extent necessary to verify your identity, 3) evaluate the request (including, to the extent necessary, contacting the appropriate data holder); 4) once the evaluation is completed, take action consistent with the evaluation; and 5) respond to your request accordingly. The information you provide us may be archived or stored periodically by us according to backup processes conducted in the ordinary course of business. Information stored as part of this backup process will be deleted in due course on a regular schedule. We will not discriminate against you for seeking to access, update or remove any information.
Links to Other Websites
Our Site contains links to other websites. The Company is not responsible for any websites that it does not own or operate. You should carefully review the privacy policies and practices of other websites that you link to from the Site, as we cannot control or be responsible for their privacy practices.
Notice to California Residents- California Privacy Rights:
Pursuant to California law, California residents may request information from us concerning: the categories of information we have collected; the categories of sources from which the personal information is collected; the purpose for which we collect or sell the personal information; the categories of third parties with whom we share personal information; and the specific pieces of personal information we have collected. You also have the right to ask us to delete the personal information we maintain regarding you. We will not discriminate against you for exercising any of these rights.
If you are a California resident and would like to make such a request, please submit your request in writing to the address below.
Users Located in the European Union
The Company has self-certified with the U.S. Department of Commerce regarding the collection, use, and retention of personal data from European Union member countries in connection with the Privacy Shield Principles as part of the Privacy Shield program. To learn more about the Privacy Shield program, and to view the Company’s certification, please visit http://www.privacyshield.gov.
Internal and Independent Recourse Mechanisms
Notification of Changes
Accessing and updating your information; Limiting or Opting out
Visitors who would like to access, correct, update or delete any personally identifiable information may contact us with a request to do so at firstname.lastname@example.org. Similarly, Site users who wish to subscribe or unsubscribe to our marketing and informational communications or limit our use of any personally identifiable information in any way can do so by using the subscribe/unsubscribe options contained in our emails or by sending an email to email@example.com. We may take a reasonable period of time to respond to any request to update or modify any information, limit use of information or to opt out of or unsubscribe from any communications. We may also ask for additional information to authenticate the request. If you request the deletion, modification or limitation of use of your personal information maintained by us we will promptly review your request and respond. If we grant your request, such information may be retained for a period of time in our backup systems as a precaution against system failures. Some information may be retained for longer periods as required by law, contract or auditing requirements. In some circumstances we will not be able to limit use of your personal information without unsubscribing you from communications or deleting your information.
Members of the Media, Social Media Influencers/Users, Subject Matter Experts, Stakeholders
The Company maintains lists of publicly available information regarding media contacts, journalists, social media influencers/users, subject matter experts and other stakeholders and individuals who make their personal and/or professional information and/or opinions publicly available. Since such information is made publicly available by you, we believe that its processing should have no negative impact on your privacy. The information may include names and handles, gender, job title, biographical/educational/work information and interests, work address, telephone number, public posting activity, profile picture, public conversations, engagement, followers and follower count. We strive not to hold any sensitive personal data about individuals (such as data about race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union memberships, data about health, genetic and, biometric data) unless an individual has clearly put such data into the public domain by, for example, writing or speaking about it or by posting it on a social media profile. Lists are accessed and/or used by the Company for specific business purposes in conducting its own business and in conducting business on behalf of potential and existing clients. Such purposes may include communications for business purposes, including providing information that we believe to be relevant or introducing opportunities for influencer marketing arrangements or campaigns. These lists may be augmented by other information obtained from other sources, including its clients or through Company’s evaluation of the information processed. The Company takes reasonable measures to limit the information processed to be relevant to legitimate business purposes and to minimize any risks to individuals associated with the use of such information. Any individual may contact us to access, update and/or restrict use of such information consistent with applicable law by contacting us at firstname.lastname@example.org.
Where indicated by signage at our premises, the Company may utilise closed circuit television (“CCTV”) image capture for the purposes of maintaining security of premises and the prevention and investigation of potential crime. The data will be deleted after 30 days unless there is a reason, in relation to the above purposes, to keep a specific piece of footage for longer than that period. In any event, no footage will be held for longer than is necessary to achieve the purpose set out above. The footage is held in a secure location on a secure server and may only be accessed by specific Company employees.”
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