\legals

Updated:  January 2020

VOX Global LLC (“we”, “us” or “our”) respect your privacy. We are committed to safeguarding your privacy and protecting your information against unauthorized use.

WHO PROCESSES YOUR PERSONAL INFORMATION

This privacy policy (“Policy”) applies to the processing of personal information by VOX Global LLC.

If you are a California consumer and would like information about our online and offline privacy practices and your privacy rights, please see the section of this Privacy Policy called “California Consumer Privacy Statement” by clicking here

PURPOSE OF THIS POLICY

This Policy explains our approach to any personal information that we might collect from you using this website (the “Site”) and any personal information about you we might collect/process in other situations or interactions with us, and the purposes for which we process 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 exercise your rights. This Policy is intended to assist you in making informed decisions when using the Site or otherwise providing personal information to us or in other situations where we may process your personal information.

UNLESS PROHIBITED BY LAW, BY USING OR ACCESSING THE SITE, YOU SIGNIFY YOUR AGREEMENT TO BE BOUND BY OUR PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, YOU MAY NOT ACCESS OR OTHERWISE USE THE SITE.

TYPE OF PERSONAL INFORMATION WE COLLECT/PROCESS

When we talk about personal information 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, an online identifier (such as an IP address) or to other factors that are specific to them. Categories of personal information we may collect and process about you include:

• contact information (e. name, physical address, telephone number, email address);
• your date of birth;
• information about your employment or education history;
• information about your interests or affiliations or publicly stated positions on political matters, corporate matters and similar;
• information about articles (or similar) that you may have published;
• information for hiring talent and human resources (g. work eligibility status, financial account information, government-issued identification information or dietary requirements);
• your image;
• your online identifier (e.g. cookie ID); or
• any additional data that may identify you which you submit to us.

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

PERSONAL INFORMATION OF CHILDREN

We do not intend to or knowingly collect personal information from children under the age of 16.

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, provide services to us or otherwise through your interactions with us.
• Personal information we collect from you automatically. When you access and use our Site, 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 tracking technologies (see COOKIES section ).
• Personal information received from third parties. From time to time, we may receive personal information about you from third parties. For example, we may receive your contact details from an industry contact or our client, or we may receive your CV or resume from your agent or recruitment service provider, or we may receive information about your dietary requirements from your agent or our hospitality provider. We may also use third parties to collect personal information about your interactions with our Site.
• Publicly available personal information. From time to time, we may collect personal information about you (including your contact details, biography, interests or affiliations) from publicly available sources (including open source data sets) or media reports or personal information about you that you or a third party may make publicly available (for example through speaking at events or publishing articles or other news stories or posting on social media platforms).

HOW WE USE PERSONAL INFORMATION

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

• verify your identity;
• provide our services to clients;
• help us improve our Site, 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;
• carry out recruitment activities; and
• use as otherwise required or permitted by law.

We set out in more detail the specific ways in which we may use your personal information below. Please note that these examples are non-exhaustive and may be subject to local rules and restrictions – we will only carry out these activities to the extent permitted by local law. If local law requires us to obtain consent in order to process the data as described then we will do so.

Client administration.
We may collect personal information about our client and potential client contacts to enable us to respond to client requests, to administer client accounts with us, to conduct credit checks (if permitted by applicable law), and to verify and carry out financial transactions for payments made to us.

Who do we share personal information with for this purpose?
We may share such personal information 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 SHARING YOUR PERSONAL INFORMATION below in connection with this purpose.

Media and informational inquiries.
We may collect personal information about journalists, client contacts or industry contacts for interviews requests, for media questions, or requests for information about VOX Global LLC. We may also provide individuals with the opportunity to sign up for newsletters or to receive copies of blogs and other information that we make available.  Where an individual signs up to receive such information, 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 individual requests or media requests.

Who do we share personal information with for this purpose?
We may share such personal information 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 SHARING YOUR PERSONAL INFORMATION below in connection with this purpose.

Market research and focus groups.
As part of our service to our clients, we may collect an individual’s contact details, records of communications, health data, opinion data, age range, nationality, image, and education history for the purposes of carrying out market research through focus groups, interviews and user testing.  We may do this on behalf of our clients or for our own purpose.

Who do we share personal information with for this purpose?
We may share such personal information with our clients, group companies, affiliates, market research partners or agents, third party vendors (such as our IT provider) or professional advisers or such other third parties as indicated in SHARING YOUR PERSONAL INFORMATION below in connection with this purpose.

Media monitoring.
As part of our service to our clients, we may monitor media sites (including social media sites) and collect information about individuals from these sites directly or using a third party social listening provider including their opinions on how a particular client campaign was received or a client offering or on a topic that is relevant to our client more generally.

Who do we share personal information with for this purpose?
We may share such personal information with our clients, group companies, affiliates, or partners, third party vendors (such as our IT providers) or professional advisers or such other third parties as indicated in SHARING YOUR PERSONAL INFORMATION below in connection with this purpose.

Campaign reporting.
As part of our service to our clients, we may collect information about individuals through third party providers or directly from the individual or through social media or other media outlets such as their contact details and opinions on how a particular client campaign was received or other feedback they may have about a campaign or a client offering.

Who do we share personal information with for this purpose?
We may share such personal information with our clients, group companies, affiliates, partners or agents, third party vendors (such as our IT providers) or professional advisers or such other third parties as indicated in SHARING YOUR PERSONAL INFORMATION below in connection with this purpose.

Surveys and voting.
We may collect personal information from individuals via surveys or voting polls for the purposes of obtaining feedback on our own or our clients’ products and surveys. Participation in such polls is voluntary and individuals will have the opportunity to decide whether or not to disclose personal information. Certain personal information 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.

Who do we share personal information with for this purpose?
We may share such personal information 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 SHARING YOUR PERSONAL INFORMATION below in connection with this purpose.

Promotions.
We may conduct promotions, contests or giveaways on our own behalf (or on behalf of our clients), which may require that individuals register to enter. We collect personal information 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 information is voluntary.

Who do we share personal information with for this purpose?
We may share such personal information 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 SHARING YOUR PERSONAL INFORMATION 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.

Who do we share personal information with for this purpose?
We may share such personal information 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 SHARING YOUR PERSONAL INFORMATION below in connection with this purpose.

Social media.
We may collect or process individuals’ personal information who engage with us through our social media channels (including by visiting our social media pages or otherwise communicating with us via social media).  We may also operate our clients’ social media pages, accounts or channels acting on their behalf.

Who do we share personal information with for this purpose?
We may share such personal information 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 SHARING YOUR PERSONAL INFORMATION below in connection with this purpose.

Interactive areas and fan pages.
We may provide interactive areas, such as message boards, fan pages, chat rooms or other forums or other closed communities.  Participation in these areas by users is voluntary.  We may provide these interactive areas (including fan pages) in conjunction with third parties such as Facebook or other social media platforms. Although we discourage individuals from submitting any information that may identify them personally when participating in these areas, we may inevitably process their personal information in connection with these interactive areas.

Who do we share personal information with for this purpose?
We may share such personal information 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 SHARING YOUR PERSONAL INFORMATION below in connection with this purpose.

Events.
From time to time, we may organise and host road shows and other industry events to promote our services or on behalf of clients. For this purpose we may process individuals’ names and contact information (including email address, postal address and telephone number) to communicate with them about such events where they have specifically requested information about such events or where we have another lawful basis for sending that information to them.

If you attend one of our events, we may use your personal information to record your attendance at the event and for related record-keeping purposes and, if relevant, we may collect and process any dietary or other requirements you may have. You may also feature in photographs taken at our events and such photographs may appear in publications we send to our clients and/or publish on our Site, in print or other media.

Who do we share personal information with for this purpose?
We may share such personal information with our clients, group companies, affiliates, event and ticketing partners or agents, third party vendors (such as our IT providers) or professional advisers or event organisers or such other third parties as indicated in SHARING YOUR PERSONAL INFORMATION below in connection with this purpose.

Insight and analysis.
We may analyse individuals’ contact details with other personal information that we observe about them from their interactions with our Site, our email communications and/or with our services.

We may use cookies, log files and other tracking technologies to collect personal information from the computer hardware and software used to access the Sites, or from mobile devices. This may include the following:

• an IP address to monitor Site traffic and volume;
• a session ID to track usage statistics on our Sites; and
• information regarding your personal or professional interests, demographics, experiences with our services and contact preferences.

Our web pages and emails may contain cookies, web beacons and pixel tags (“Tags”). Tags allow us to count users who have visited a web page or opened an email and collect other types of aggregated information. Once a recipient clicks on an email that contains a Tag, their contact information may subsequently be cross-referenced to the source email and/or the relevant Tag. In some of our email messages, we use a “click-through URL” linked to certain websites administered by us or on our behalf. We may track click-through data to assist in determining interest in particular topics and measure the effectiveness of these communications.

This information is used to create insights about our visitors’ browsing habits on our Site. By using this information, we are able to measure the effectiveness of our content and how visitors use our Site and services. This allows us to learn what pages of our Site are most attractive to our visitors, which parts of our Site are the most interesting and what kind of features and functionalities our visitors like to see.

We also use this information for marketing purposes (see the MARKETING COMMUNICATION section below for further details).

Who do we share personal information with for this purpose?
We may share such personal information 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 SHARING YOUR PERSONAL INFORMATION below in connection with this purpose.

Marketing communications.
We may carry out marketing activities using an individual’s personal information.  In particular, we may use personal information to form a view on what we think the individual may want or need, or what may be of interest to the individual.  We may use that information to provide individuals with marketing information about our events and services we feel may be of interest. We may also provide individuals with information about media and public relations events.

We also provide individuals with opt out choices regarding personal information 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 information so that they can send electronic marketing communications to particular individuals, we will obtain the relevant individual’s consent prior to sharing the personal information for such purpose.

Who do we share personal information 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 SHARING YOUR PERSONAL INFORMATION below in connection with this purpose.

Talent databases
As part of our services to clients, we maintain talent databases which include contact details, biography, dietary requirements, and personal preferences of individuals we may use for a particular campaign.  We use this information for the purpose of selecting talent for a particular campaign and working with that talent.  We may obtain this information directly from the individual or via third party recruiters or agents or publicly available sources.

Who do we share your personal information with for this purpose?
We may share such personal information with our clients, group companies, affiliates, recruitment partners or agents, third party vendors (such as our IT providers and production companies) or professional advisers or such other third parties as indicated in SHARING YOUR PERSONAL INFORMATION below in connection with this purpose.

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

Who do we share personal information with for this purpose?
We may share such personal information with our clients, group companies, affiliates, partners, agents, third party vendors or professional advisers or such other third parties as indicated in SHARING YOUR PERSONAL INFORMATION below in connection with this purpose.

Recruitment
If individuals apply for a job with us or otherwise express an interest in working for us, we will collect contact details and CV or resume information from the individual.  We use such personal information to:

• assess the individual’s suitability for any position for which they applied (or future positions for which we think the individual may be suitable) including employment or freelance positions, summer placements or internships and also any business support or services role whether such application has been received by us online, via email or by hard copy or in person application;
• to take any steps necessary to enter into any contract of employment (or otherwise) with the individual;
• to comply with any regulatory or legal obligations in relation to any such application; and
• to review our equal opportunity profile in accordance with applicable legislation. We do not discriminate on the grounds of gender, race, ethnic origin, age, religion, sexual orientation, disability or any other basis covered by local legislation.

Who do we share your personal information with for this purpose?
We may share such personal information with our group companies, affiliates, third party vendors or professional advisers or such other third parties as indicated in SHARING YOUR PERSONAL INFORMATION 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.

Who do we share personal information with for this purpose?
We may share such personal information 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 SHARING YOUR PERSONAL INFORMATION below in connection with this purpose.

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

• to facilitate the operation or effective management of our group of businesses;
• to comply with our legal obligations (including regarding information security);
• to enforce or protect our legal rights;
• to deal with complaints;
• to protect the rights of third parties (including where health or security of an individual is endangered (e.g. a fire)); and
• in connection with a business transition or sale such as a merger, re-organisation, acquisition by another company, or sale of all or a portion of our assets.

Who do we share personal information with for this purpose?
We may share personal information 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 SHARING YOUR PERSONAL INFORMATION below in connection with this purpose.

SHARING YOUR PERSONAL INFORMATION

We may share your personal information with any of our group affiliates, or with our agents or  partners (such as other PR agencies we outsource work to) clients, contractors (for example who we engage on specific client projects), services providers (for example who provide us with IT systems or support), professional advisors (such as our lawyers) or government or regulatory bodies. Your data may be shared for the following purposes:

• to provide our services to clients or otherwise receive assistance in processing transactions;
• fulfilment of requests for information, receiving and sending communications, updating marketing lists, analysing data;
• provision of IT and other support services;
• to facilitate the operation and effective management of our group of businesses;
• to comply with a legal obligation or in connection with a legal claim or dispute or to otherwise protect our legal rights; and
• assistance in other ancillary to the operation of tasks, from time to time.

Our agents, partners and contractors will use your personal information to the extent necessary to perform their functions.  For more details about how we may share your personal information in connection with a particular use case, please refer to the relevant use case above. Please note that these third parties may be located in other jurisdictions.

Please note, the types of third parties we share your personal information 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.

For situations which may be considered the sale of your information, please see Sale of Personal Information below.

OBTAINING YOUR CONSENT

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

• at the time that we collect your personal information following the instructions provided; or
• by informing us by e-mail, post or phone using the contact details set out in this Policy.

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.

Your consent is provided on a voluntary basis. However, if you do not provide us with your personal information, we may not be able to process your applications, handle your requests, respond to your inquiries or provide you with our services.

SECURITY AND CONFIDENTIALITY 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.

ACCESS

To the extent required by applicable law, we will provide you with reasonable access to the personal information maintained about you and a reasonable opportunity to correct, amend or delete the information where it is inaccurate or has been processed erroneously, as appropriate. We may limit or deny access to personal information where permitted by law  (such as where the burden or expense of providing access would be disproportionate or where the rights of third parties would be violated).

You may exercise these rights verbally or in writing by using our contact information provided in the section below entitled CONTACT DETAILS.  We will endeavor to promptly respond to your requests and will respect time frames set by local legislation where applicable.

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 information.  This is a security measure to ensure that personal information 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 information 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. 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.

ENFORCEMENT RIGHTS AND MECHANISMS

We will ensure that this Policy is observed and duly implemented.  If at any time you believe that your personal information 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 information, you may contact the relevant individuals in CONTACT DETAILS section.

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 process your data jointly with such third parties.

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 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:

• analytical cookies to recognize and count users of our Site, measure the effectiveness of our content, and understand how visitors use our Site.  We currently use Google Analytics for this purpose; or
• placing, or allowing a third party to place, functional cookies to make a website easier to use, such as cookies that maintain a user’s session.

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 INFORMATION?

Where applicable law imposes restrictions on the length of time for which personal information can be retained, we will generally comply with this by retaining personal information only for as long as is necessary for the purposes described in this Policy, after which it will be deleted from our systems. The principle may be departed from where required by law.

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.  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 information 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 applicable data protection authorities. 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 post all changes to the Policy on relevant internal and external websites.

We encourage you to review this Policy periodically to be informed of how we use your personal information.

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, or to exercise your rights, you may contact: [email protected]

ALTERNATIVE DISPUTE RESOLUTION

If your complaint cannot be resolved through our internal processes, we will cooperate with the alternative dispute resolution mutually agreed upon by the parties

CALIFORNIA CONSUMER PRIVACY STATEMENT

This California Consumer Privacy Statement supplements this Policy 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”).

Notice of Collection and Use of Personal Information

We may collect the following categories of personal information about you.

• Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, and other similar identifiers
• Additional Data Subject to Cal. Civ. Code § 1798.80: such as signature, physical characteristics or description, education, financial information
• Protected Classifications: characteristics of protected classifications under California or federal law, such as race, color, national origin, religion, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, medical condition, ancestry, genetic information, disability, citizenship status, and military and veteran status
• Commercial Information: commercial information, such as records of products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies
• Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements
• Geolocation Data
• Sensory Information: audio, electronic, visual, and similar information
• Employment Information: professional or employment-related information
• Education Information: education information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99)
• Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behaviour, attitudes, intelligence, abilities, and aptitudes.

We may use the categories of personal information listed above for the purposes described in this Policy.  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; 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; 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; Commercial Information;  Online Activity; Geolocation Data; 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; Commercial Information;  Online Activity; Geolocation Data; Employment Information; Education Information and Inferences
Undertaking internal research for technological development and demonstration	Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; 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 and to improve, upgrade, or enhance the service	Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; 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; Protected Classifications; Sensory Information; Employment Information; Education Information and Inferences

Our Prior Collection, Use and Disclosure of Personal Information

We may have collected and used your personal information, as described 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; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences
Our clients	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; 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; 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; 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; 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; 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
Our clients	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; 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; 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; 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; 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; 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; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences

c. Sale of Personal Information

We have previously and will collected information about you for the purpose of providing it to our clients in situations described above under HOW WE USE PERSONAL INFORMATION.  These situations include, for example, when we collect information about individuals for market research and focus groups; promotions; surveys and voting; media monitoring; and industry information.  These services are provided at our clients’ request for monetary consideration.  This may be considered the sale of personal information for purposes of the CCPA.  

We may sell your personal information in connection with the sale of VOX GLOBAL LLC or the division or office responsible for the services.

You have the right to opt out of this disclosure of your information, as detailed below. 

During the 12-month period prior to the effective date of this California Consumer Privacy Statement, we may be considered to have sold the following categories of personal information for the purposes described above: 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.

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: 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.

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, click here or call us at 1-833-520-0506. To submit a Shine the Light request, email us at [email protected]. To opt-out of the sale of your personal information, click here or call us at 1-833-520-0506.

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 us with information about you to verify your identity.  The type of information that we ask for may vary depending on the type and sensitivity of the personal information we hold about you or that you request.  If additional information is required to verify your request, we may contact you to provide us with that information before responding to your request for access or deletion.  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 [email protected] to request this Statement in an alternative format.