This policy describes the privacy practices for our website. By visiting our website you agree to allow us to collect and use the information described below for the purposes and in the manner described below. We have the right to change this policy, and your continued use of the site will constitute consent to the change.
We do not collect personal or corporate e-mail addresses, or any personally identifiable information on visitors to our site, without your permission. We do not use our site for any commercial transactions. We may collect operational information, including through reliance on “cookies,” such as the pages you access or visit, your IP address, your domain name, the last URL you visited before clicking to our site, and your browser and platform type (e.g., a Netscape browser on a Macintosh computer). This information may be used to measure usage, number of visits, average time spent on the site, pages viewed, etc., and to improve the content of our site. None of the foregoing would allow us or a third party to identify you or contact you. It is used for internal review only and not shared with other organizations for commercial purposes without first providing notification to you.
Our website uses links that allow visitors to contact us via e-mail for a variety of purposes. We cannot guarantee or warrant the security of any data you submit to us. Except for human resources information, we shall treat any data or information transmitted to us through this site as non-confidential and non-proprietary. We may elect to save such information, share it with third parties, or discard it entirely. However, we will use reasonable efforts to treat as confidential any e-mails, resumes, applications or inquiries sent to us for the purpose of inquiring into potential employment with us. Any e-mail, resume or submission you send to us will be used only for internal purposes. Please be aware that submission of your resume or application may not be considered, and we are under no obligation to respond to such solicitations. We are an equal opportunity employer.
We do not collect personally identifiable information from children under the age of 13. Guests who are 13 to 17 years of age should seek parental consent before providing any personally identifiable information on our site.
EUROPEAN UNION SAFE HARBOR AND SWISS SAFE HARBOR PRIVACY POLICY
We recognize that the European Union and Switzerland have implemented “omnibus” data protection regimes established pursuant to the European Data Protection Directive (95/46/EC) and the Swiss Federal Act on Data Protection, respectively (collectively, “Data Protection Law”). Among other obligations, Data Protection Law generally requires “adequate protection” for the transfer of certain individually identifiable data about individuals in the Europe to FCB operations in the United States and Canada. FCB Worldwide, Inc.’s agencies of Area 23, Neon, Prohealth, FCB Health, FCB Garfinkel, FCB Toronto, FCB Montreal, FCB/SIX, and Fuel Advertising (collectively, “FCB Safe Harbor Agencies”) accordingly adhere to the requirements of the U.S.-EU and the U.S.–Swiss Safe Harbor Frameworks as set forth by the by the United States Department of Commerce (“Safe Harbor”) with respect to certain Canadian, EU and Swiss Personal Data received in the United States about its client contacts (“European Client Contact Information”) and consultants and certain other thirds parties it has engaged (“European Consultant Information”) in the EU and Switzerland (collectively, “European Personal Information”) (such individuals, “European Data Subjects”) for the purposes described below.
FCB Safe Harbor Agencies may use European Client Contact Information for the following purposes: providing services for clients; marketing products and services to clients, fulfilling client requests, responding to client inquiries, tracking payment for advertising or marketing support services, creating materials for clients, managing client relationships, general communications, collecting payment for services, and compliance with company policies and applicable law. FCB Safe Harbor Agencies may use European Consultant Information for the following purposes: general communications; managing engagements and relationships, contracting, providing payment for services, and compliance with company policies and applicable law.
FCB Safe Harbor Agencies may disclose European Personal Information to its affiliates, subsidiaries, business partners, and service providers for the purposes listed above. In situations where FCB Safe Harbor Agencies disclose European Personal Information to any recipients acting as service providers or “agents” on behalf of FCB Safe Harbor Agencies, such recipients will be required to protect the disclosed European Personal Information in accordance with the relevant Safe Harbor Principles, or otherwise take steps to ensure that the European Personal Information is appropriately protected.
Data Security, Integrity and Access. FCB Safe Harbor Agencies take reasonable precautions to protect European Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction. FCB Safe Harbor Agencies make reasonable efforts to keep European Personal Information reliable for its intended use, accurate, complete, and current to the extent necessary for the purposes for which we use the European Personal Information. FCB Safe Harbor Agencies also provide European Data Subjects with a reasonable opportunity to review, correct or delete their own European Personal Information in accordance with Safe Harbor rules. European Data Subjects may contact the FCB Safe Harbor Privacy Contact identified below to review European Personal Information about them. FCB Safe Harbor Agencies reserve the right to take reasonable steps to authenticate the identity of any such individual seeking access to European Personal Information.
Other Disclosures. FCB Safe Harbor Agencies may disclose European Personal Information as necessary in connection with the sale or transfer of all or part of the business, where required or permitted by law, where the FCB Safe Harbor Agencies believe that such disclosures are appropriate in connection with a law enforcement request or otherwise permitted by Safe Harbor, or in order to investigate, prevent or take action regarding illegal activities or suspected fraud or enforce or apply FCB agreements.
SAFE HARBOR QUESTIONS
Any questions regarding this Safe Harbor section of this Privacy Policy or requests for access to European Personal Information should be directed to the Safe Harbor Privacy Contact listed in this section. Additional information, including information on the Safe Harbor certification of the FCB Safe Harbor Agencies, may be obtained on the United States Department of Commerce website at http://www.export.gov/safeharbor. In addition, if any individual located in the EU or Switzerland who experiences an issue regarding the European Personal Information that the FCB Safe Harbor Agencies hold about him or her that he or she cannot resolve directly with the FCB agency, the individual may contact the DMA Safe Harbor Dispute Resolution Program per the contact information listed in this section. The DMA will then serve as a liaison to us to resolve your concerns.
FCB Safe Harbor Privacy Contact:
Attention: Data Security Officer100 West 33rd Street
New York, NY 10001-2900
Phone: 212-885-3000
E-mail: mb.datasecurity@fcb.com
DMA Safe Harbor Dispute Resolution Program Contact Information:
Safe Harbor LineDMA Safe Harbor
Direct Marketing Association
Attn: Safe Harbor Program
1615 L St, NW Ste 1100
Washington, DC 20036-5624
E-mail: safeharbor@the-dma.org
Website
PRIVACY POLICY CHANGES
This policy may be changed from time to time, consistent with the requirements of Safe Harbor. You can determine when this policy was last revised by referring to the “Last update” date at the bottom of this page. Unless otherwise required by law, any changes to this policy will become effective upon our posting of a revised policy on the Site.
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