HAVAS SO Global Limited - DATA PROTECTION POLICY

PRIVACY 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 data.protectionuk@havas.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 individual
from 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, register
    for 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 further
    information about what kind of data we have about you, please e-mail contact@havasso.com.  

  • 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.

  • Through your use of our website. We use cookies and other technologies, such as pixel
    tags on our websites and in our e-mails to collect information about your usage.

  • E-mail response information. In relation to e-mails we send you, we may use cookies
    and other technologies, such as pixel tags to collect information on how you respond to such
    emails (for example, the number of times the e-mail is opened or the links inside them are clicked, etc.).
    We partner with third parties who may also use such cookies and other technologies in our e-mails.
    All e-mails that you have requested will have an option to unsubscribe. Unsubscribe requests are
    fulfilled within minutes and no further communications will be sent to users who have stated that
    they do not wish to receive the specified information.

  • Please e-mail contact@havasso.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 their
privacy 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 obtain
the 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
contact@havasso.com.  

Data retention

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.

How we use cookies

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

HSO websites, social channels or services may provide links to third party applications, products,
services, or websites for your convenience and information. If you access those links, you will leave
the HSO website. HSO does not control those third-party websites or their privacy practices, which
may differ from our practices. We do not endorse or make any representations about third party
websites. The personal information you choose to provide to or that is collected by these third
parties is not covered by the HSO Data Protection Policy. We encourage you to review the privacy
policy of any website you interact with before allowing the collection and use of your personal information.

We may also provide social media links that enable you to share information with your social networks
and 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 contact@havasso.com.  

Your consent

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.

All requests for access, rectification, limitation, erasure, restriction or portability of your
personal data, and any questions regarding this Employee Privacy Policy, may be sent to:
contact@havasso.com.  

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.