HAVAS SO Global Limited - DATA PROTECTION POLICY
HAVAS SO Global Limited (‘HSO’) is committed to ensuring that your privacy is protected. This Policy explains when and why we collect personal information about you, how we use it, the conditions under which we may disclose it to others and how we keep it secure.
HSO may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes.
Any questions regarding this Policy and our privacy practices should be sent by e-mail to email@example.com or by writing to our Group Data Protection Officer: Havas, HKX Building, 3 Pancras Square, London N1C 4AG, UK, t: +44 (0) 203 196 9000.
Who are we?
Havas SO is a PR and marketing communications group that focuses on ‘life communications’ – encompassing health, wellbeing and lifestyle. Through the four complementary arms of our business (SO Healthy, SO Creative, SO Patient and SO Active), we bring together the brightest industry talent from PR, advertising, advocacy and scientific engagement to deliver outstanding multi-channel communication solutions which grow brands. We’re part of Havas Health and You, a global network of industry-leading media communications agencies.
How do we collect information about you?
Personal data, or personal information, means any information about an individualfrom which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect personal information in the following ways:
Directly from you. For example, we collect your personal data if you submit your details directly on our website, provide us with business cards or other information, registerfor our events and/or as a result of your relationship with one or more of our staff or clients. This information could include your name, e-mail address and/or mobile number. For furtherinformation about what kind of data we have about you, please e-mail firstname.lastname@example.org.
From third parties. We collect personal information about you indirectly from our clients, suppliers, partners or other industry/market contacts. We may also collect information about you from public sources, including social media sites such as LinkedIn, as well as via your subscriptions to third party contact databases, newsletters and/or publications.
Please e-mail email@example.com if you require any further information about what personal data we have about you.
How is your information used?
HSO respects the rights of each individual, employee, candidate or client to have theirprivacy and personal data protected.
We may engage with journalists and other individuals who work in the media sphere on behalf of clients as an integral part of the services we provide. Where we obtainthe personal information of journalists and others in the media sphere, we use this information to:
Send you communications which you have requested and that may be of interest to you
Respond to direct questions or queries made to us
Carry out obligations arising from any contracts between us and you, withclients, with suppliers or with third parties
Invite you to events and briefings that we run for our clients
Process a job application
Send company press releases
Share insights with respect to possible areas of interest and topics that we think may be relevant.
Data processing principles
HSO will observe the following principles when processing your personal information:
Processing your personal information fairly, lawfully and in a transparent manner
Collecting your personal information for specified, legitimate purposes and not processing further in ways incompatible with those purposes
Collecting your personal information which is relevant to and not excessive for the purposes for which it is collected and used. We may render information anonymous when feasible and appropriate, depending on the nature of the data and the risks associated with the intended uses
Maintaining your personal information accurate, and where necessary, kept up-to-date. We will take reasonable steps to rectify or delete data that is inaccurate or incomplete
Keeping your personal information only as long as it is necessary for the purposes for which it was collected and processed
Processing your personal information in accordance with the individual’s legal rights
Taking appropriate technical, physical and organisational measures to keep your data safe and prevent unauthorized access, unlawful processing, and unauthorised or accidental loss, destruction, or damage to personal information
Processing your personal information based on one or more of the following legal bases:
- You have unambiguously given your consent
- The processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract
- The processing is necessary for compliance with a legal obligation to which HSO is subject
- The processing is necessary in order to protect your vital interests or the vital interest of another natural person
- The processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in HSO
- The processing is necessary for the purposes of the legitimate interests pursued by HSO or by a third party except where such interests are overridden by your interests or your fundamental rights and freedoms
Information submitted by you is stored on secure servers. If you want to see the data we hold about you on this database, simply e-mail firstname.lastname@example.org.
We review our retention periods for personal information on a regular basis. We will hold your personal information on our systems for as long as is necessary for the relevant activity, or as long as is set out in any relevant contract you hold with us.
A cookie is a small file which asks permission to be placed on your computer's hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
Links to third-party websites
We may also provide social media links that enable you to share information with your social networksand to interact with HSO on various social media sites. Your use of these links may result in the collection or sharing of information about you, depending on the feature. We encourage you to review the privacy policies and settings on the social media sites with which you interact to make sure you understand the information that may be collected, used, and shared by those sites.
If you post, comment, indicate interest, or share personal information, including photographs, to any public forum, social network, blog, or other such forum, please be aware that any personal information you submit can be read, viewed, collected, or used by other users of these forums, and could be used to contact you, send you unsolicited messages, or for purposes that neither you nor HSO have control over. HSO is not responsible for the personal information you choose to submit in these forums.
Who has access to your information?
If you do provide personal information to us, either directly or through a reseller or other business partner, we will:
Take commercially reasonable precautions to protect the information from loss, misuse and unauthorised access, disclosure, alteration and destruction
Not use or disclose the information except in the following circumstances:
- We may pass your information to our third party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf. However, when we use third party service providers, we disclose only the personal information that is necessary to deliver the service and we have a contract in place that requires them to keep your information secure and not to use it for their own direct marketing purposes
- In other ways described in this Policy or to which you have otherwise consented
- In the aggregate with other information in such a way so that your identity cannot reasonably be determined (for example, statistical compilations)
- As required by law, for example, in response to a subpoena or search warrant
- To outside auditors who have agreed to keep the information confidential
- As necessary to enforce the Terms of Service
- As necessary to protect the rights, safety, or property of HSO, its users, or others; this may include (for example) exchanging information with other organisations or public authorities for identification, fraud protection and/or risk reduction
For more information, please e-mail email@example.com.
By providing us with your personal information and/or using the websites and/or entering into a contract with us, you consent to our processing your personal data for the above purposes. You also consent to our transferring your information to countries or jurisdictions which do not provide the same level of data protection as the EU, if necessary, for the above purposes. If we do make such a transfer, we will provide appropriate safeguards to ensure that your information is duly protected. If you provide us with information about another person, you confirm that they have appointed you to act for them, to consent to the processing of their personal data, including sensitive personal data, and that you have informed them of our identity and the purposes (as set out above) for which their personal data will be processed. We do not process personal data of minors under 16 without the express consent of their parents or legal representatives.
Your Data Protection rights
Right of access. As data subjects, you may enquire as to the nature of the personal data stored or processed about you by HSO. You will be provided access to your personal data regardless of the location of the data processing and storage.
Right to rectification. If your personal data is inaccurate or incomplete, you may request that the data be amended.
Right to object. You have the right to object at any time to the processing of your personal data for the purposes of HSO legitimate interests or for direct marketing purposes.
Right to erasure. You can ask for the deletion of your personal data when it is allowed by applicable data protection laws and regulations.
Right to restriction of processing. You have the right to require a restriction of the processing of your personal data when it is authorised by applicable data protection laws and regulations.
Right to data portability. If you meet the conditions settled by the applicable data protection laws and regulations, you have the right to receive a subset of your personal data and to transmit them from HSO to another Data Controller. You can also require the direct transmission from HSO to another Data Controller when it is technically feasible.
Right to lodge a complaint. You have the right to lodge complaint with the competent supervisory authority.
Review of this Policy
HSO reserves the right to update this Policy regularly and at any time, and we will provide you with access to a new document when we make any substantial updates. This Policy was last updated on15 March 2019.