PRIVACY POLICY (General)

TYPE OF PERSONAL INFORMATION COLLECTED

We use the term “personal information” – also called “personal data” under the laws of some jurisdictions – to refer to information that reasonably identifies, relates to, describes, or can be associated with you. Data that has been deidentified or that otherwise cannot reasonably be related back to a specific person is not considered personal information. The precise definition of personal information may vary depending on your place of residence, but we take the same general approach to protecting your privacy, subject to any additional measures that may be required by applicable laws.

Categories of personal information we collect include:

• contact information (g. name, physical address, telephone number, email address),
• device and online identifiers and related information, including internet protocol (IP) address, mobile ad identifiers, data collected from cookies, beacons, and pixel tags, and similar unique identifiers;
• internet or other electronic network activity information, including, but not limited to browsing history, search history, and information regarding your interaction with an internet website, application, mobile app, or advertisement;
• information about your interests or affiliations,
• information for hiring and human resources (e.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.

Additional information about the personal information we collect is described in the next section HOW WE USE PERSONAL INFORMATION and COOKIE POLICY.

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
• as otherwise required or permitted by law.

The following describes the more specific ways that we may use personal information that we collect through the Services:

• 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.

• 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.

• Promotions.

  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 data bases 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 publicly 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 under the age of 13. When we become aware that personal information (or other information that is protected under applicable law) from a child under 13 has been collected, we will use all reasonable efforts to delete such information from our databases. If you believe we might have any personal information from or about a child under 13, please contact us by using the information the section below titled Contact Details.

SHARING YOUR PERSONAL 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 may share your personal information with third parties who partner with us to promote products and services, provide marketing and advertisements, conduct data analytics, or use the data for other commercial purposes. We do not control how these third parties use and share your personal information once they receive it. You will need to contact such third parties directly for information about their privacy practices or to exercise any rights you may have (including if you would like to opt-out of marketing messages).

We may also disclose personal information and other information as we believe necessary or appropriate: (e) under applicable law, including laws outside your country of residence; (f) to comply with legal process; (g) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (h) to enforce our Terms and Conditions; (i) to protect our operations or those of any of our affiliates; (j) to protect our rights, privacy, safety or property, and/or that of our affiliates, you, or others; and (k) to allow us to pursue available remedies or limit the damages that we may sustain.

Lastly, we may share your personal information and other information with third parties in connection with the sale, merger, divestiture, restructuring, reorganization, dissolution, or transfer of some or all of the assets of Emanate or one of its affiliates, in which the assets transferred may include information about the users of our Services.

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. You can verify this by looking for a closed lock icon at the bottom of your web browser, or looking for “https” at the beginning of the URL. Only employees or third parties who need the information to process a specific request are granted access to personally identifiable information.

However, no method of safeguarding information is completely secure, and we cannot guarantee that our safeguards will be effective or sufficient. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us of the problem using the contact information in the section entitled CONTACT DETAILS.

ONWARD TRANSFERS

We may transfer the personal information we collect about you to recipients in countries other than the country in which the information originally was collected, including the U.S. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to recipients in other countries (such as the U.S.), we will protect that information as described in this Privacy Policy and will comply with applicable legal requirements providing adequate protection for the transfer of personal information to recipients in countries other than the one in which you provided the information. Where applicable, we may use model clauses approved by the laws of your jurisdiction (such as Standard Contractual Clauses approved by the European Commission) for cross-border data transfers.

U.S. STATE PRIVACY RIGHTS

The Virginia Consumer Data Protection Act, the Colorado Privacy Act, the Connecticut Data Privacy Act, the Utah Consumer Privacy Act, and similar laws in other U.S. states ("State Privacy Laws") provide consumers in those states with specific rights regarding their personal data. To the extent that you are a resident of one of these states, this notice describes your rights under the State Privacy Laws and explains how you may exercise these rights.

The categories of personal data we process, our purposes for processing your personal data, the categories of personal data that we share with third parties, and the categories of third parties with whom we share it are set forth in this Policy above.

• Right to Know. You have the right to know whether we process your personal data and to access such personal data.
• Right to Data Portability. You have the right to obtain a copy of your personal data that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another business without hindrance, where the processing is carried out by automated means. You may request such personal data up to twice annually, subject to certain exceptions.
• Right to Delete. You have the right to delete personal data that you have provided by or that we have obtained about you. Please note that we may deny such request if the requested deletion falls under an exception as set forth in the State Privacy Laws. Additionally, if you request deletion of your personal data and we have obtained such information from a third-party source, we may retain such data by keeping a record of the deletion request and the minimum data necessary to ensure that your personal data remains deleted from our records and that such retained data is not used for any other purpose, or we may opt you out of the processing of such personal data for any purpose except for those allowed under the State Privacy Laws.

• Right to Opt-Out. You have the right to opt out of the processing of your personal data for purposes of: (i) targeted advertising; (ii) the sale of personal data; or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. As of the latest date of this Policy:

  • We process personal data for the purposes of targeted advertising;
  • We sell your personal data in exchange for monetary or other valuable consideration; and
  • We DO / DO NOT engage in profiling decision based on your personal data that produce legal or similarly significant effects concerning you.

  If you wish to opt out of the processing of your personal data for any of the above purposes, please email [email protected]. For residents of Colorado and Connecticut, we will also treat opt-out preference signals as valid opt-out requests.

• Right to Correct. You have the right to correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes for which we process it.

• Right to Non-Discrimination. You have the right not to receive discriminatory treatment by us for the exercise of your privacy rights. Unless permitted by the State Privacy Laws, we will not:

  • Deny you goods or services;
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
  • Provide you a different level or quality of goods or services; or
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

• How to Exercise Your Rights; Verifying Your Identity. To exercise any of your privacy rights, or if you have any questions about your privacy rights, you may contact us by emailing us at [email protected].

  After submitting a request, we will take steps to verify your identity in order for us to properly respond and/or confirm that your request is not fraudulent. We may contact you for additional information as reasonably necessary to authenticate your request, but if we are ultimately unable to authenticate your request using reasonably commercial efforts, then we may not be able to comply with it.

  Only you may make a verifiable request related to your personal data. If you are making a request as the parent or legal guardian of a known child regarding the processing of that child’s personal data, we may ask you to submit reliable proof of your identity.

• Response Time; Your Right to Appeal. We will make every effort to respond to your request within 45 days from when you contacted us. If you have a complex request, State Privacy Laws allow us up to 90 days to respond. We will contact you within 45 days from when you contacted us to inform you of the need for additional time and the reason for such extension. We may charge you a reasonable fee to cover administrative costs if your requests are manifestly unfounded, excessive, or repetitive.

  If we decline to take action on a request that you have submitted, we will inform you of our reasons for doing so, and provide instructions for how to appeal the decision. You will have the right to appeal within a reasonable period of time after you have received our decision. Within 60 days (45 days for residents of Colorado) of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If we deny your appeal, we will provide you with a method for contacting your state attorney general’s office to submit a complaint.

• If you are a resident of Nevada, you have the right to opt out of the sale of certain personal information that we have collected (or may collect) from you to data brokers or other third parties. You can exercise this right by emailing us at [email protected] with the subject line “Nevada Do Not Sell Request.”