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PRIVACY POLICY (General)

Updated: [19-March-2021]

We at Interfuse Inc. and its affiliated companies (“we”, “us” or “our”) respect your privacy.

This privacy policy applies to the processing of personal data by Interfuse Inc. in the United States and [insert any non-U.S. entity names].

Please see our European privacy notice for how we (to the extent we are subject to the General Data Protection Regulation) and our European affiliates process your personal data.

PURPOSE OF THIS POLICY

This privacy policy (“Policy”) explains our approach to any personal information that we might collect from you using this website (the “Site”) and in other situations or interactions with us, as well as the purposes for which we process your personal information. This Policy also sets out your rights in respect of our processing of your personal information.

This Policy will inform you of the nature of the personal information about you that is processed by us and how you can request that we delete, update, transfer and/or provide you with access to it or otherwise cease processing it for a specific purpose.  This Policy is intended to assist you in making informed decisions when using this Site.

This privacy notice is not intended to apply to the processing of personal information of [insert agency name] employees which is dealt with under our separate workplace privacy policy.

TYPE OF PERSONAL INFORMATION COLLECTED

Personal information is information that identifies you as an individual. Categories of personal information we collect include:

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

WAYS OF OBTAINING PERSONAL INFORMATION

We may collect and receive your personal information using different methods:

Personal information you provide to us.  You may give us your personal information directly. This will be the case when, for example, you contact us with enquiries, complete forms on our Site or in hard copy or participate in a survey, subscribe to receive our marketing communications or provide feedback to us otherwise through your interactions with us.

Personal information we collect from you automatically.  When you access and use our Sites, we will automatically collect certain technical information about your equipment, browsing actions and patterns. We collect this personal information by using cookies and other similar technologies (see Cookie Policy section below).

Personal information received from third parties. From time to time, we will receive personal information about you from third parties. Such third parties may include analytics providers, payment providers, hotel and transport providers and third parties that provide technical services to us so that we can operate our Site and provide our services.

Publically available Personal information.  From time to time we may collect personal information about you from publically available sources or media reports or personal information about you that you or a third party may make publically available to us (for example through speaking at events or publishing articles or other news stories).

HOW WE USE PERSONAL INFORMATION

Our primary goal in collecting personal information from you is to:

USES OF PERSONAL INFORMATION COLLECTED THROUGH THIS SITE

The following describes how we use personal information that we collect through this Site:

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.

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.

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.

We use cookies and similar other technologies to collect information from the computer hardware and software you use to access the Site, or from your mobile.  Please see our Cookie Policy for additional information.

The information you provide to us may be archived or stored periodically by us according to our standard backup processes and our document retention policy.

OTHER USES OF PERSONAL INFORMATION

We may also collect information in other contexts other than this Site as described above. That information may be used in the manner described above and in other ways, such as:

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.

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.

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 publically 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.

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.

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.

If we have engaged you or the organisation you represent to provide us with products or services (for example, if you or the organisation 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 organisation you represent, to receive products and services from you or the organisation you represent and, where relevant, to provide our Services to others.

We may use your personal information for the following business administration and legal compliance purposes:

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.

SHARING YOUR 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 will not sell your personal information to other companies and we will not share it with other companies for them to use without your consent, except in in the circumstances listed above or in connection with the sale or merger of [insert agency name] or the division or office responsible for the services.

OBTAINING YOUR CONSENT

Where our use of your personal information requires your consent, you can provide such consent:

Please note that if you specifically consent to additional uses of your personal information, we may use your personal information in a manner consistent with that consent.

ACCESS

We provide you with reasonable access to the personal information maintained about you. We also provide you with a reasonable opportunity to correct, amend or delete the information where it is inaccurate. We may limit or deny access to personal information where the burden or expense of providing access would be disproportionate to the risks to your privacy in the case in question, or where the rights of third persons would be violated.

CHOICE AND MEANS

We generally offer you the opportunity to choose whether your personal information may be (a) disclosed to third-party controllers or (b) used for a purpose that is materially different from the purposes for which the information was originally collected or subsequently authorized by you. Unless we offer you an appropriate choice, we use personal information only for purposes that are materially the same as those indicated in this Policy. To exercise your choices you may contact us as indicated in this Policy.

We may share personal information with our affiliates as described above under SHARING YOUR INFORMATION. We may disclose personal information without offering an opportunity to opt out, and we may be required to disclose such information (a) to third-party processors we have retained to perform services on our behalf and pursuant to our  instructions, (b) if we are required to do so by law or legal process, or (c) in response to lawful requests from public authorities, including to meet national security, public interest or law enforcement requirements. We also reserve the right to transfer personal information in the event of an audit or if we sell or transfer all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, dissolution or liquidation).

SECURITY

We take reasonable and appropriate measures to protect personal data 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 data. Also see CONFIDENTIALITY AND SECURITY OF YOUR INFORMATION below.

THIRD PARTY LINKS AND SERVICES

Our Site contains links to third party websites and services. Please remember that when you use a link to go from our Site to another website or you request a service from a third party, this Policy no longer applies.

Your browsing and interaction on any other websites, or your dealings with any other third-party service provider, is subject to that website’s or third party service provider’s own rules and policies. We do not monitor, control, or endorse the privacy practices of any third parties.

This Site may integrate with social networking services.  You understand that we do not control such services and are not liable for the manner in which they operate.  While we may provide you with the ability to use such services in connection with our Site, we are doing so merely as an accommodation and, like you, are relying upon those third-party services to operate properly and fairly.

This Policy does not apply to these third-party websites and third party service providers.

OPT OUT AND UNWANTED COMMUNICATIONS

To opt-out of any future promotional or marketing communications or any other communications from us, you should send a request to us at the contact information in the section entitled CONTACT DETAILS.  We will process your request within a reasonable time after receipt.  Please note that if you opt out in this manner, certain aspects of this Site may no longer be available to you.

CONFIDENTIALITY AND 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.

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.

OUR COOKIE POLICY

We use cookies and similar technologies to collect personal information from the computer or other device you use to access the Site. “Cookies” are pieces of information that may be placed on your device for the purpose of collecting data to facilitate and enhance your communication and interaction with our Site.  We may also allow certain third parties to place cookies as described below.

We use cookies and other technologies on all our sites to ensure the best possible experience on our Site. These uses include:

You can review your Internet browser settings to exercise choices you have for certain cookies. If you disable or delete certain cookies in your Internet browser settings, you might not be able to access or use important functions or features of this Sites, and you may be required to re-enter your log-in details.

To learn more about the use of cookies for Google Analytics, please visit the Google Analytics Opt-Out Brower Add-on at https://tools.google.com/dlpage/gaoptout/.

CHANGES TO THIS PRIVACY POLICY

We may make changes to this Policy from time to time.  This Site includes a date on which it was last updated.

To ensure that you are always aware of how we use your personal information, we will update this Policy from time to time to reflect any changes to our use of your personal information. We encourage you to review this Policy periodically to be informed of how we use your personal information.

HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?

We retain personal information only for as long as is necessary for the purposes described in this Policy, after which it is deleted from our systems.

Regarding personal information we have processed in connection with the supply of our services to clients, we may retain personal information relevant to our services for up to five years from the date of supply and in compliance with our obligations under the EU General Data Protection Regulation (or similar legislation around the world). We may then destroy such files without further notice or liability.

Regarding any other personal information we have processed, we may retain relevant personal information for up to three years from the date of our last interaction with the relevant individual and in compliance with our obligations under the EU General Data Protection Regulation (or similar legislation around the world). We may then destroy such files without further notice or liability.

If any personal information is only useful for a short period (e.g. for a specific event or marketing campaign or in relation to recruitment), we may delete it at the end of that period.

If you have opted out of receiving marketing communications from us, we will need to retain certain personal information on a suppression list indefinitely so that we know not to send you further marketing communications in the future.

CONTACT DETAILS

For questions or concerns about this Policy, or to ask questions or express concerns about our collection, management and processing of personal information, Consumers may by contact us by:

Our corporate headquarters:

Attn: General Counsel
Interfuse
1285 6th Avenue, #401
New York, NY 10019

Our office in the EU:

Attn: Data Protection Responsible
Interfuse
Bankside 3
90 Southwark St
London
SE1 OSW

California Consumer Privacy Statement

Effective: January 1, 2020

This California Consumer Privacy Statement supplements the Interfuse, Inc. Online Privacy Notice and applies solely to California consumers.  This section provides information about our online and offline privacy practices.  This Statement does not apply to our personnel.

This California Consumer Privacy Statement uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 and its implementing regulations (the “CCPA”).

  1. Notice of Collection and Use of Personal Information
We may collect the following categories of personal information about you:

We may use the categories of personal information listed above for the purposes described in our Online Privacy Notice. In addition, we may use these categories of personal information for certain business purposes specified in the CCPA, as described in this table:

Purposes Categories of Personal Information
Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services [Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]
Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance [Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information;  Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]
Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction [Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information;  Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]
Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity [Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information;  Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]
Debugging to identify and repair errors that impair existing intended functionality [Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information;  Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]
Undertaking internal research for technological development and demonstration [Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information;  Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]
Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us [Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information;  Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]
 

In addition, we may also use the following categories of personal information for purposes of managing our career opportunities: [Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80;

  1. Our Prior Collection, Use and Disclosure of Personal Information
We may have collected and used your personal information, as described in section 1 above, during the 12-month period prior to the effective date of this California Consumer Privacy Statement.  For the personal information collected during that timeframe, we describe below: (a) the categories of sources from which we may have obtained the personal information, (b) the categories of third parties with whom we may have shared the information, [(c) the categories of personal information we may have sold,] and (d) the categories of personal information we may have disclosed for a business purpose.

a) Sources of Personal Information

We may have obtained personal information about you from various sources, as described below.

Categories of Sources of Data Collection Categories of Personal Information
Directly from you, such as when you contact us with a [question or comment]

 

[Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]
From your devices, such as when you visit our Site [Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information;  Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]
Your family or friends, such as [when they provide us with your contact information so we can send information that may interest you] [Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information;  Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]
Our affiliates and subsidiaries [Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information;  Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]
Vendors who provide services on our behalf [Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information;  Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]
Social networks [Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information;  Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]
Online advertising companies [Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information;  Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]
Government entities [Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information;  Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]
Consumer data resellers [Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information;  Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]
 

b) Sharing of Personal Information

We may have shared your personal information with certain categories of third parties, as described below.

Categories of Third Parties Categories of Personal Information
Our affiliates and subsidiaries [Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information;  Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]
Vendors who provide services on our behalf [Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information;  Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]
Professional services organizations, such as auditors and law firms [Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information;  Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]
Our joint marketing partners [Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information;  Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]
Our business partners [Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information;  Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]
Advertising networks [Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information;  Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]
Internet service providers [Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information;  Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]
Data analytics providers [Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information;  Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]
Government entities [Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information;  Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]
Operating systems and platforms [Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information;  Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]
Social networks [Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information;  Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]
Consumer data resellers [Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information;  Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]
 

c) Sale of Personal Information

[We do not sell your personal information in exchange for monetary compensation.].

During the 12-month period prior to the effective date of this California Consumer Privacy Statement, we may have sold the following categories of personal information:

We do not sell the personal information of minors under 16 years of age without affirmative authorization if we have actual knowledge of the individual’s age.

d) Disclosure of Personal Information for a Business Purpose

We may have disclosed to third parties the following categories of personal information for a business purpose:

  1. California Consumer Privacy Rights
You have certain choices regarding our use and disclosure of your personal information, as described below.

Access: You may have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed and sold about you during the past 12 months.

Deletion: You have the right to request that we delete certain personal information we have collected from you.

Opt-Out of Sale: You have the right to opt-out of the sale of your personal information.

[Shine the Light Request: You also may have the right to request that we provide you with (1) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and (2) the identity of those third parties.]

How to Submit a Request: To submit an access or deletion request, to  [opt out of the sale of your personal information][if you sell consumer information] or to submit a Shine the Light request, please email us at:  [contact information needed here]

Verifying Requests: To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request If you request access to or deletion of your personal information, we may require you to provide any of the following information: [insert data elements to be used for verification].  In addition, if you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.  If you designate an authorized agent to make an access, deletion or opt-out of sale request on your behalf (1) we may require you to provide the authorized agent written permission to do so, and (2) for access and deletion requests, we may require you to verify your own identity directly with us (as described above).

Additional Information: If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us.  To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.  This Statement is available in alternative formats upon request.  Please contact [insert email address] to request this Statement in an alternative format.

[Metrics: Click here [insert link to metrics PDF] for information about the number of requests we received in [insert previous calendar year] and how we responded to those requests.]

GDPR PRIVACY POLICY

Updated: [19-March-2021]

We at Interfuse (“we”, “us” or “our”) respect your privacy.

This privacy policy (“Policy”) is intended to meet the requirements of the Regulation (EU) 2021/79 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (known as “GDPR”).

WHO PROCESSES YOUR PERSONAL DATA

Interfuse is a company located in the United States. Interfuse Austria, Interfuse Belgium, Interfuse Germany, and Interfuse United Kingdom are affiliates of Interfusecomms. This privacy policy applies to the processing of personal data by Interfuse’s affiliates in the European Union, namely; Interfuse Austria, Interfuse Belgium, Interfuse Germany and Interfuse United Kingdom.

This privacy policy also applies to Interfuse North America, Interfuse Russia, Interfuse Asia Pacific, Interfuse Latin America and Interfuse Middle East to the extent those entities are subject to the General Data Protection Regulation.

For the purpose of this Policy and the GDPR, to the extent any of the above entities process your personal data in connection with use cases identified in this Policy, each will be considered a “data controller” of your personal data.  Please note that in some cases we may carry out the activities referred to in this Policy in our capacity as a data processor acting on behalf of our clients. We have made this distinction clear in the Policy.

PURPOSE OF THIS POLICY

This Policy explains our approach to any personal data that we might collect from you using this website (the “Site”) and any personal data about you we might collect/process in other situations or interactions with us, and the purposes for which we process your personal data.

This Policy also sets out your rights in respect of our processing of your personal data.

This Policy will inform you of the nature of the personal data about you that is processed by us and how you can request that we delete, update, transfer and/or provide you with access to it or otherwise object to our processing of it for a specific purpose. This Policy is intended to assist you in making informed decisions when using the Site or otherwise providing personal data to us or in other situations where we may process your personal data.

Please note this Policy is not intended to apply to our processing of Interfuse staff personal data which is dealt with under our separate workplace privacy policy.

TYPE OF PERSONAL DATA WE COLLECT/PROCESS

When we talk about personal data we mean any information which relates to an identified or identifiable living individual. Individuals might be identified by reference to a name, an identification number, location data, an online identifier (such as an IP address) or to other factors that are specific to them, such as their physical appearance. Categories of personal data we may collect and process about you include:

For more information about the personal data we collect please refer to section HOW WE USE PERSONAL DATA below and the COOKIES section

PERSONAL DATA OF CHILDREN

We do not intend to or knowingly collect personal data from children.

WAYS OF OBTAINING PERSONAL DATA

We may collect and receive your personal data using different methods:

HOW WE USE PERSONAL DATA

Our primary goals in collecting personal data from you are to:

We set out in more detail below the specific ways in which we may use your personal data

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.

Our legal basis for processing

It is in our legitimate interests (and those of our clients) to process personal data in this way to ensure we provide the services requested by our clients in an effective and efficient way.

Who do we share personal data with for this purpose?

We may share such personal data with our third party vendors (such as our payment service providers or IT providers), financial institutions, group companies, affiliates, professional advisors, regulatory bodies or other law enforcers or such other third parties as indicated in DATA SHARING section below in connection with this purpose.

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.

Our legal basis for processing

It is in our legitimate interests (and those of our clients) to process personal data in this way  to ensure we provide the services requested by our clients in an effective and efficient way and that we provide the right information to those who request it.

Who do we share personal data with for this purpose?

We may share such personal data with our clients, group companies, affiliates, media partners or agents, third party vendors (such as our IT providers) or professional advisers or such other third parties as indicated in DATA SHARING section below in connection with this purpose.

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.

What is our legal basis? Where we use personal data in connection with recruitment and talent management it will be in connection with us entering into a legal contract with them or it is in our legitimate interest to use personal data in such a way to ensure that we can make the best recruitment and talent management decisions for Interfuse or it is our legal obligation to use such personal data to comply with any legal obligations imposed upon us.  We will not process any special data except where we are able to do so under applicable legislation or with the individual’s explicit consent.

Who do we share your data with for this purpose?

We may share such personal data with our group companies, affiliates, third party vendors or professional advisers or such other third parties as indicated in DATA SHARING section below in connection with this purpose.

Cookies

We use cookies and similar other technologies to collect information from the computer hardware and software you use to access the Site, or from your mobile.  Please see our Cookie Policy for additional information.

The information you provide to us may be archived or stored periodically by us according to our standard backup processes and our document retention policy.

Our legal basis for processing

We will only drop non-essential cookies and other similar tracking technologies on devices with user consent.  It is in our legitimate interest to process any personal data collected via the cookie or other similar tracking technology to ensure that we can improve our services and tailor our marketing.

Who do we share personal data with for this purpose?

We may share such personal data with our group companies, affiliates, third party vendors (such as our analytics providers or other IT providers) or professional advisers or such other third parties as indicated in DATA SHARING section below in connection with this purpose.

OTHER USES OF PERSONAL INFORMATION

We may also collect information in other contexts other than this Site as described above. That information may be used in the manner described above and in other ways, such as:

Surveys and voting.

We may collect personal data from individuals via surveys or voting polls. Participation in such polls is voluntary and you will have the opportunity to decide whether or not to disclose personal data. Certain personal data such as contact details may be required to register to vote or to take part in a survey. We would only use that information to report the results of the survey or vote.

Our legal basis for processing

It is in our legitimate interests (and those of our clients) to process personal data in this way to provide the services requested by our clients in an effective and efficient way and to understand how our clients and their products are received in the market. Where we do this on behalf of our clients as a data processor we do not require a legal basis for such processing.

Who do we share personal data with for this purpose?

We may share such personal data with our clients, group companies, affiliates, survey partners or agents, third party vendors (such as our IT providers) or professional advisers or such other third parties as indicated in DATA SHARING section below in connection with this purpose.

Promotions

We may conduct promotions, contests or giveaways which may require that individuals register to enter. We collect personal data from individuals in order to conduct the promotion, contest or giveaway and to deliver prizes or notices. Participation in these events and providing us with personal data is voluntary.

Our legal basis for processing

It is in our legitimate interests (and those of our clients) to process personal data in this way in order to enable individuals to participate in the promotion, contest or giveaway or we may do so in order to perform an obligation owed to individual.  Where we do this on behalf of our clients as a data processor we do not require a legal basis for such processing.

Who do we share personal data with for this purpose?

We may share such personal data with our clients, group companies, affiliates, third party vendors (such as our IT providers), competition partners or professional advisers or regulatory bodies or such other third parties as indicated in DATA SHARING section below in connection with this purpose.

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 to contact those individuals to discuss our clients’ goods and services.  We may also use this information for our own internal administrative and promotional purposes.

Our legal basis for processing

It is in our legitimate interests (or those of our client) to process personal data in this way so that we can provide the services requested by our clients in an effective and efficient way.  Where the personal data collected is considered special personal data, we rely on the fact that the personal data has been manifestly made public by individual in order to process their personal data.

Who do we share personal data with for this purpose?

We may share such personal data with our clients, group companies, affiliates, third party vendors (such as our IT providers) or professional advisers or such other third parties as indicated in DATA SHARING section below in connection with this purpose.

Interactive areas.

We may provide interactive areas, such as message boards, chat rooms or other forums or other closed communities.  Participation in these areas by users is voluntary.  Although we discourage individuals from submitting any information that may identify them personally when participating in these areas, we may inevitably process their personal data in connection with these interactive areas.

Our legal basis for processing

To the extent we do process personal data in connection with this purpose, it is in our legitimate interests to do so to help us understand industry issues, share content and generally provide services to our client and users. Where we do this on behalf of our clients as a data processor we do not require a legal basis for such processing.

Who do we share personal data with for this purpose?

We may share such personal data with our clients, group companies, affiliates, partners or agents (such as Facebook), third party vendors (such as our IT providers) or professional advisers or such other third parties as indicated in DATA SHARING section below in connection with this purpose.

Marketing communications.

We may carry out marketing activities using an individual’s personal data.  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.

Our legal basis for processing

We rely on our legitimate interest to process personal data in this way for marketing purposes (except where consent is required by local law in which case we will obtain consent).  Where the individual is a consumer, we will only send electronic marketing communications or event invitations to such individual with their consent.

We also provide individuals with opt out choices regarding personal data uses, particularly around marketing and advertising. To see how you can opt out of marketing communications, please see the section entitled  OPT OUT AND UNWANTED COMMUNICATIONS.

Please note if a third party asks us to share personal data so that they can send electronic marketing communications to particular individuals, we will obtain the relevant individual’s consent prior to sharing the personal data for such purpose.

Who do we share personal data with for this purpose?

We may share your data with our group companies, affiliates, promotions agents, third party vendors (such as our IT providers) or professional advisers or such other third parties as indicated in DATA SHARING section below in connection with this purpose.

Receipt of services.

If we have engaged an organisation to provide us or our client with products or services (for example, IT support or financial advice), we will collect and process your personal data if you are a contact within the relevant organisation in order to manage our relationship or our clients with the organization, to receive products and services from the organisation and, where relevant, to provide our services to others including our clients.

Our legal basis for processing

It is necessary for us to use personal data in this way to perform our obligations in accordance with any contract that we may have with the organisation or it is in our legitimate interest to use personal data in such a way to ensure that we have an effective working relationship with the organisation and are able to provide our services to others in an effective way.  Where we do this on behalf of our clients as a data processor we do not require a legal basis for such processing.

Who do we share personal data with for this purpose?

We may share such personal data with our clients, group companies, affiliates, partners, agents, third party vendors or professional advisers or such other third parties as indicated in DATA SHARING section below in connection with this purpose.

Business administration and legal compliance.

We may use an individual’s personal data for the following business administration and legal compliance purposes:

Our legal basis for processing

Where we use personal data in connection with a business transition, to enforce our legal rights or to protect the rights of third parties, it is in our legitimate interest to do so. For all other purposes described in this section, we will rely on our obligation to comply with law, such as a court order, to process such personal data.

We will not process any special (or sensitive) categories of personal data or personal data relating to criminal convictions or offences except where we are able to do so under applicable legislation or with the individual’s explicit consent.

Who do we share personal data with for this purpose?

We may share personal data with our clients, group companies, affiliates, agents, partners, third party vendors or professional advisers, emergency service providers or law enforcers or other regulatory bodies (including tax and social security authorities) or such other third parties as indicated in DATA SHARING section below in connection with this purpose.

Visiting our premises

If an individual visits any of our premises we may collect contact information as part of our sign in process.  We may also capture their image on our surveillance camera or CCTV.

Our legal basis for processing

It is in our legitimate interests to process personal data in this way for security reasons.

Who do we share personal data with for this purpose?

We may share such personal with our clients, group companies, affiliates, recruitment partners or agents, third party vendors (such as our IT providers) or advisers or law enforcers or such other third parties as indicated in DATA SHARING section below in connection with this purpose.

SHARING YOUR PERSONAL DATA

We may share your personal data with any of our group affiliates, or with our agents, partners, clients, contractors, professional advisors or government or regulatory bodies for the following purposes: (a) provide our services to clients or otherwise receive assistance in processing transactions; (b) fulfilment of requests for information, receiving and sending communications, updating marketing lists, analysing data; (c) provision of IT and other support services; (d) to facilitate the operation and effective management of our group of businesses; (e) comply with a legal obligation or in connection with a legal claim or dispute or to otherwise protect our legal rights; (f) assistance in other ancillary to the operation of tasks, from time to time. Our agents, partners and contractors will use your personal data to the extent necessary to perform their functions.  For more details about how we may share your personal data in connection with a particular use case, please refer to the relevant use case above

We will not sell your personal data to other companies and we will not share it with other companies for them to use without your consent, except in the circumstances listed above or in connection with the sale or merger of Interfuse or the division or office responsible for the services.

Please note, the types of third parties we share your personal data with set out above is non-exhaustive and there may be circumstances where we need to share personal information with other third parties in order to operate our Site and to provide our services.  We will notify you of any other circumstances where we would share your information on a case by case basis.

OBTAINING YOUR CONSENT

Where our use of your personal data requires your consent, you can provide such consent:

Please note that if you specifically consent to additional uses of your personal data, we may use your personal data in a manner consistent with that consent.

DATA TRANSFERS OUTSIDE THE EEA

We may transmit personal data outside the EEA to certain categories of third parties (as listed above in HOW WE USE YOUR PERSONAL DATA) and more specifically to: (1) our headquarters in New York, United States (“US”); (2) our different offices in the US and other locations globally; (3) our affiliated entities in the US or in other locations globally.

In particular when transferring your personal data outside the EEA, we will ensure that, where required by applicable law, at least one of the following safeguards is implemented: (1) we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; (2) where we use certain service providers, we may use specific contracts approved by the European Commission referred to as the “model clauses” which give personal data the same protection it has in Europe.

CONFIDENTIALITY AND SECURITY OF YOUR PERSONAL DATA

We are committed to keeping the personal data you provide to us secure and we will take reasonable precautions to protect your personal data from loss, misuse or alteration.

To safeguard against unauthorized access to personal data by third parties outside our organization, all electronic personal data held by us is maintained on systems that are protected by up-to-date secure network architectures that contain firewalls and intrusion detection devices. The data saved in servers is “backed up” (i.e. the data are recorded on separate media) to avoid the consequences of any inadvertent erasure, destruction or loss otherwise. The servers are stored in facilities with high security, access protected from unauthorized personnel, fire detection and response systems. The location of these servers is known to a limited number of our employees.

We have implemented information security policies, rules and technical measures to protect the personal data that we have under our control from:

All of our employees and data processors (i.e. those who process your personal data on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal data, are obliged to respect the confidentiality of the personal data of all users of our services.

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.

YOUR DATA PROTECTION RIGHTS

You have the following rights in relation to the personal data we hold about you under certain circumstances:

Data subjects may exercise these rights verbally or in writing using our contact information provided in the section below entitled CONTACT DETAILS.  We will endeavour to promptly respond to your requests.  Where you ask us to provide a copy of your personal data we are legally obliged to respond within one month of such request. If your request is denied, we will inform you about the reasons for denial.

Please note that in order for you to assert these rights, we may need to verify your identity to confirm your right to access your personal data.  This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. In order to verify your identity, we may need to gather more personal data from you than we currently have.

OPT OUT AND UNWANTED COMMUNICATIONS

To opt-out of any future promotional or marketing communications or any other commercial communications from us, you should send a request to us at the contact information in the section entitled CONTACT DETAILS.

ENFORCEMENT RIGHTS AND MECHANISMS

We will ensure that this Policy is observed and duly implemented. Violations of the applicable data protection legislation in the EEA may lead to penalties and/or claims for damages.

If at any time you believe that your personal data has been processed in violation of this Policy, or if you have any inquiries or complaints about the use or limitation of use of your personal data, you may contact the relevant  individuals in CONTACT DETAILS section:

Please note that if you have a complaint about our privacy practices, you may contact your local EU Data Protection Authority (“DPA”).  We are committed to cooperating with DPAs and to comply with their dispute resolution procedures in cases of complaints.  We are also committed to complying with any regulations or guidelines that DPAs may issue from time to time in accordance with EEA and Member State data protection legislation. We undertake to register and/or keep our registration updated as a data controller and/or processor in all jurisdictions where we maintain entities in the EEA.

We are also subject to the investigatory and enforcement powers of the U.S. Federal Trade.

THIRD PARTY LINKS AND SERVICES

This Site contains links to third party websites and services. Please remember that when you use a link to go from our Site to another website or you request a service from a third party, this Policy no longer applies to these third-party websites and third-party service providers unless we are acting as joint controllers in respect of your personal data with such third party.

Your browsing and interaction on any other websites, or your dealings with any other third-party service provider, is subject to that website’s or third-party service provider’s own rules and policies. We do not monitor, control, or endorse the privacy practices of any third parties.

This Site may integrate with social networking services. You understand that we do not control such services and are not liable for the manner in which they operate.  While we may provide you with the ability to use such services in connection with our Site, we are doing so merely as an accommodation and, like you, are relying upon those third-party services to operate properly and fairly.

COOKIES

We use cookies and similar technologies to collect personal data from the computer or other device you use to access the Site. “Cookies” are pieces of information that may be placed on your device for the purpose of collecting data to facilitate and enhance your communication and interaction with our Site. We may also allow certain third parties to place cookies as described below.

We use cookies and other technologies on all our sites to ensure the best possible experience on our Site. These uses include:

You can review your Internet browser settings to exercise choices you have for certain cookies. If you disable or delete certain cookies in your Internet browser settings, you might not be able to access or use important functions or features of this Site, and you may be required to re-enter your log-in details.

HOW LONG DO WE KEEP YOUR PERSONAL DATA?

We retain personal data only for as long as is necessary for the purposes described in this Policy, after which it is deleted from our systems.

Regarding personal data we have processed in connection with the supply of our services to clients, we may retain personal data relevant to our services for up to six years from the date of supply and in compliance with our obligations under the GDPR (or similar legislation around the world). We may then destroy such files without further notice or liability.

Regarding any other personal data we have processed, we typically retain relevant personal data for up to three years from the date of our last interaction with the relevant individual and in compliance with our obligations under the GDPR (or similar legislation around the world) although we may keep it for longer if we have a justifiable reason to do so.

If any personal data is only useful for a short period (e.g. for a specific event or marketing campaign or in relation to recruitment), we will delete it at the end of that period.  Please note that if you are an unsuccessful candidate we may keep your information for a short period.

If you have opted out of receiving marketing communications from us, we will need to retain certain personal data on a suppression list so that we know not to send you further marketing communications in the future.

MODIFICATIONS TO THE POLICY

We reserve the right to modify this Policy as needed, for example, to comply with changes in laws, regulations or requirements introduced by DPAs. Changes must be approved by our privacy points of contact, the office of the corporate legal department, or their designees who will seek input as they reasonably deem appropriate from corporate executives for the amended Policy to enter into force. If we make changes to the Policy, this amended Policy will be submitted for renewed approval according to the relevant applicable provisions of the law. We will inform data subjects of any material changes in the Policy. We will post all changes to the Policy on relevant internal and external websites.

Effective with the implementation of this Policy, all existing and applicable EU company privacy guidelines relating to the collection and/or processing of personal data will, where in conflict, be superseded by the terms of this Policy. No other internal policy that conflicts with this Policy shall be applicable with respect to the protection of personal data handled by us in the EU. We encourage you to review this Policy periodically to be informed of how we use your personal data.

CONTACT DETAILS

For questions or concerns about this Policy, or to ask questions or express concerns about our collection, management and processing of personal data, or to exercise your rights, you may contact us by:

Email: privacy.policy@Interfusecomms.com

Or by sending us a letter to:

Our corporate headquarters:

Attn:  General Counsel
Interfuse
1285 6th Avenue, #401
New York, NY 10019

Our office in the EU:

Attn: Data Protection Responsible
Interfuse
Bankside 3
90 Southwark St
London
SE1 OSW