Privacy Policy


Introduction

Last Updated May 25,2018

We are Daniel J. Edelman Ireland Limited of Block 2, Harcourt Centre Harcourt Street, Dublin 2. (“We”)(“Edelman”) (“the Data Controller”)

Our data protection representative may be contacted on compliance@djeholdings.com

At Edelman, we are strongly committed to protecting privacy. Edelman 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.  This document is being provided to you in line with our obligations under the General Data Protection Regulation (GDPR), which comes into effect on the 25 May 2018.

We adhere to this Privacy Policy together with any disclaimers set out and same form the basis on which any personal data we collect from you or that you provide to us or that is provided to us relating to you by any means will be processed. Please note that this Privacy Policy relates only to living individuals in relation to their personal data.

As part of our commitment, we strive to protect the privacy of those who interact with our services including 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 (personal data).  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 Edelman and others.

In this digital world, privacy is important to Edelman and should be important to you. Edelman 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 lawful basis for processing your data and who we share it with

 

  • For clients and people who view and interact with the Site, we process data:

 

  1.  
  • to respond to your query when sent through our ‘contact us’ form
  • to sign up to our newsletter when you request subscription through our website
  • to carry out our obligations arising from any contracts entered into between us
  • to notify you about changes to our services
  • to comply with our legal obligations

 

The legal basis for this processing is our legitimate interest in the administration and operation of our business as well as our legitimate interest in marketing and promoting our services. We always include the option of opting out of receiving our communications, so you can opt out of receiving such communications at any time.

We may share this data with third parties who provide a service to us such as our external content management system or IT provider, or as reasonably necessary in order to provide our services to you. They may only process this data for the purpose of providing us with their services, and no other purpose.

We will retain this data for as long as necessary for the purposes described in this Privacy Policy and for as long as is required in order to comply with our legal obligations or until where applicable you exercise your right of erasure or opt-out from our mailing lists; we will then remove you from our lists without undue delay.

 

  • For our potential clients, we process data:

 

  1.  
  • in order to market our services
  • to provide you with updates and newsletters to which you have subscribed

 

The legal basis for the processing of this data is processing necessary for the purpose of the legitimate interests in promoting our services. We always include the option of opting out of receiving our communications, so you can opt out of receiving such communications at any time.

We share information such as your name and email address with third parties such as our newsletter service provider who sends out our newsletters. This provider is not permitted to use this data other than on our behalf.

We will retain this data for as long as necessary for the purposes described in this Privacy Policy and for as long as is required in order to comply with our legal obligations or until where applicable you exercise your right of erasure or you opt-out from our mailing lists; we will then remove you from our lists without undue delay

 

 

  • Members of the Media, Social Media Influencers/Users, Subject Matter Experts, Stakeholders that we liaise with on client matters, we process data:

 

  • In order to liaise with you about our client matters
  • in order to market our services
  • to provide you with updates and newsletters to which you have subscribed

 

The legal basis for the processing of this data is processing necessary for the purposes of the legitimate interests pursued by us in representing our clients.

We will retain this data for as long as necessary for the purposes described in this Privacy Policy and for as long as is required in order to comply with our legal obligations or until where applicable you exercise your right of erasure or you opt-out from our mailing lists; we will then remove you from our lists without undue delay.

 

  • For job applicants, we process data:

 

  • to recruit new employees
  • to ascertain your suitability for a specific role

 

The legal basis for this processing is processing necessary for the purpose of our legitimate interests in recruiting new staff. Please see the privacy notice in the job advertisement for further information about how we process applicant data.

We share the information you provide in your application with our contracted recruiter in order to make a shortlist of candidates. This recruiter is not permitted to use this data other than on our behalf. We may also send you emails about your application through our email service provider.

 

We will retain this data for one year after the initial application or sooner where applicable should you exercise your right of erasure.

 

The Information We Collect and Process

Edelman collects and processes two basic types of information:

  • Personal Data:This is information that personally identifies one individual from another or enables you to be individually identified or contacted (for example, names, e-mail addresses and other contact information). This information is voluntarily provided to us by you when you interact with us via our services (including out Site) and is used by us for the purpose of responding to user submissions and fulfilling requests for further information about our services. We may also receive your personal data from publicly accessible sources or third parties in which case you are entitled to know the identity of the third party furnishing us with same.
  • 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 Edelman

Edelman only collects personal data 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 personal data 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 data you provide consistent with this policy.

 

Other information Edelman 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 Edelman cookie files remain on your computer’s hard drive unless and until you manually delete the file. Edelman cookie files do not contain personally identifiable information.

The Way We Use Information

We store the personal data 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 Edelman employees and service providers only 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 Edelman services, this information will be shared with appropriate Edelman personnel to fulfill your request. This information will not be shared with non-affiliated third parties without your consent.

We use non-personal data 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.

When personal information is transferred to outside service providers, it is done under a contract which requires the companies to use the shared information only for the limited purposes for which it is provided to them in providing services to Edelman, and to agree to hold the information securely and confidentially in accordance with this privacy policy and applicable law (see also Transfers of data outside the European Economic Area (EEA) below).

Edelman will not sell or distribute personally identifiable information collected from you outside of Edelman without your consent (subject to the limited exceptions stated in this policy).

Promotions

We may operate contests, sweepstakes or other promotions through the Site, which may require registration in order to enter. Your personal data may be used by us to contact you for winner notification, prize delivery confirmation or other promotional purposes. Subject to the specific terms and conditions applicable, 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 personal data 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.

Exceptions

Edelman may preserve and has the right to disclose any information about you or your use of the Site without your prior permission if Edelman has a good faith belief that such action is necessary to: (a) protect and defend the rights, property or safety of Edelman or its clients or their respective partners, employees, affiliates, other users of the Site, or the public; (b) enforce the Terms of Use for the Site; or (c) respond to claims related to your use of the Site.   We may also disclose information as we deem necessary to satisfy any applicable law, regulation, legal process or lawful governmental request (including to meet national security or law enforcement requirements and in accordance with Article 23 of the GDPR) or in the event of a sale or potential sale of Edelman or one of its business units.

Interactive Areas

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 data as your user name and DO NOT post any personal data in these interactive areas, 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.

Data Security

Edelman understands that the safety of your personal data is extremely important to you. Accordingly, Edelman uses reasonable technological, physical and other measures to keep your personal data 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 data.  Due to the nature of the Internet and related technology, we cannot guarantee the security of your personal data and Edelman expressly disclaims any such obligation. Any transmission of personal data is at your own risk.

Children's Privacy

Edelman understands the need to protect the privacy of children.  The Site is not intended for use by individuals under 16 years of age.  Edelman does not knowingly collect or maintain personal data from children under the age of 16 at our Site.

Links to Other Websites

Our Site contains links to other websites. Edelman 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.

Transfers of data outside the European Economic Area (EEA)

Information provided through this Site may be uploaded to a cloud and transferred to or accessed globally. By providing information to this Site, you consent to the transfer, processing and/or use of the information globally throughout Edelman. Wherever the information is transferred or accessed within Edelman it will be processed and used in accordance with this privacy policy. We do not authorise any third party to use your personal data for their own purposes. Non EEA countries may not provide an adequate level of protection in relation to personal data.

In respect of transfers to our U.S. entities Edelman 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 Edelman’s certification, please visit http://www.privacyshield.gov.

Notification of Changes

As we provide more services and/or functionality on our Site and as privacy laws and regulations evolve, it may be necessary to revise or update our Privacy Policy.  We will put an “Updated” note on the link to the Privacy Policy on the Site’s home page so that you will be able to check regarding changes which may be of particular relevance to you.

Members of the Media, Social Media Influencers/Users, Subject Matter Experts, Stakeholders

Edelman maintains lists of publicly available information regarding media contacts, journalists, social media influencers, social media users, subject matter experts and other stakeholders and individuals who make their personal and/or professional information and/or opinions publicly available.  These lists are accessed and/or used by Edelman for specific business purposes in conducting its own business and in conducting business on behalf of potential and existing clients.  Edelman 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.

Jobs and Internships

The Edelman jobs and internships website can be linked to from this Site. A separate Privacy Policy governs information collected by Edelman related to potential employment and/or internship matters

Your rights relating to personal data

As an individual person, you have the following rights under the GDPR, in certain circumstances and subject to certain exemptions, in relation to your personal data:

• right to access the data – you have the right to request a copy of the personal data that we hold about you, together with other information about our processing of that personal data.

• right to rectification- you have the right to request that any inaccurate data that is held about you is corrected, or if we have incomplete information you may request that we update the information such that it is complete.

• right to erasure – you have the right to request us to delete personal data that we hold about you. This is sometimes referred to as the right to be forgotten.

• right to restriction of processing or to object to processing – you have the right to request that we no longer process your personal data for particular purposes, or to object to our processing of your personal data for particular purposes.

•. Right to data portability – you have the right to request us to provide you, or a third party, with a copy of your personal data in a structured, commonly used machine-readable format.

  • Where the furnishing of your personal data is a statutory or contractual requirement, we may not be able to perform the contract between us without such data.
  • Automated decision-making and profiling – we do not use any personal data for the purpose decision making based solely on automated processing.

 

In order to exercise any of the rights set out above, please contact us at the contact details contained in this Policy.

 

If we are processing personal data based on your consent, you may withdraw that consent at any time. This does not affect the lawfulness of processing which took place prior to its withdrawal.

If you are unhappy with how we process personal data, we ask you to contact us as soon as possible so that we can attempt to rectify the situation.

 

You may lodge a complaint with a supervisory authority. The Irish supervisory authority is the Data Protection Commission.

How to Contact Us

If you ever have any questions about this Privacy Policy, please contact us at compliance@djeholdings.com.

  1. Contact details for the Irish Data Protection Commissioner’s Office are as follows:

Postal Address:

Data Protection Officer, Canal House, Station Road, Portarlington, Co. Laois, Ireland

Website: www.dataprotection.ie

Email: info@dataprotection.ie

Telephone: +353 76 1104800

LoCall: 1890 252231

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