Updated: January 2022
FleishmanHillard and our FleishmanHillard branded companies (“we”, “us” or “our”) respect your privacy. We are committed to safeguarding your privacy and protecting your information against unauthorized use.
This privacy policy (“Policy”) is intended to meet the requirements of the Regulation (EU) 2016/679 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”), and the UK GDPR.
This Policy applies to the processing of personal data by Fleishman-Hillard Group Limited, Fleishman Hillard Germany GmbH, Fleishman-Hillard S.A., Fleishman-Hillard International Communications Limited, Fleishman-Hillard Sp.z.o.o. and Fleishman-Hillard s.r.o., and Fleishman-Hillard Inc., and to the extent any other non-European FleishmanHillard entities are subject to the GDPR.
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.
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 FleishmanHillard staff personal data which is dealt with under our separate workplace privacy policy.
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.
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:
Our primary goals in collecting personal data from you are to:
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.
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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.
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.
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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.
It is in our legitimate interests (and those of our clients) to process personal data in this way to ensure that we provide the services requested by our clients in an effective and efficient way. Where we process special category data that was collected from an individual directly in connection with this purpose, we will only do so with the individual’s explicit consent. Where we obtain this information from publicly available sources, we will rely on the fact that the individual made such information manifestly public. Please note where we do this on behalf of our clients as a data processor we do not require a legal basis for such processing.
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We may share such personal data 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 DATA SHARING section below in connection with this purpose.
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. Where we do this on behalf of our clients as a data processor we do not require a legal basis for such processing.
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We may share such personal data 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 DATA SHARING section below in connection with this purpose.
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 provide our client’s with insight into the performance of a campaign or client offering. Please note where we do this on behalf of our clients as a data processor we do not require a legal basis for such processing.
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We may share such personal data 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 DATA SHARING section below in connection with this purpose.
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.
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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.
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.
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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.
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. Where we do this on behalf of our clients as a data processor we do not require a legal basis for such processing.
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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.
It is in our legitimate interests to process personal data in this way so that we can market ourselves and engage with the public. Where we carry out this activity on behalf of our clients as a data processor we do not require a legal basis for such processing.
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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.
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.
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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.
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 individual, or it is in our or our client’s legitimate interest to use personal data in such a way to ensure that we provide our services in an effective and efficient way. If we specifically ask your permission to use your photographs, quotes, testimonials or other content, then our processing of such personal data will be based on consent. Where we put on events solely at the specific request of our clients we do so in our capacity as our client’s data processor and therefore do not require a legal basis to process personal data.
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We may share such personal data 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 DATA SHARING section below in connection with this purpose.
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.
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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.
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.
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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.
It is in our legitimate interests (or those of our client) to process talent personal data in this way to enable us to provide our services. Where we process special data in connection with this purpose that was collected from you directly, we will only do so with your explicit consent. Where we obtain this information from publicly available sources, we will rely on the fact that the individual made such information manifestly public. Where we do this on behalf of our clients as a data processor we do not require a legal basis for such processing.
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We may share such personal data 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 DATA SHARING section below in connection with this purpose.
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.
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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.
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 FleishmanHillard 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.
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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.
It is in our legitimate interests to process personal data in this way for security reasons.
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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.
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.
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.
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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.
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 FleishmanHillard 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.
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.
We may transmit personal data outside the UK and/or 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 St. Louis, Missouri, 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 UK and/or 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 (or the UK Government); or (2), we may use specific contracts approved by the European Commission referred to as the “model clauses”, or we may use a service provider’sBinding Corporate Rules, which give personal data the same protection it has in Europe,to enable us to make international transfers of personal information within our group of companies or to certain service providers in compliance with data protection laws of the UK and EU, in particular the GDPR (and UK GDPR).
If you have any questions or would like further details about transfers of your personal data, please contact us at yourprivacy@fleishman.com.
Please note that while FleishmanHillard no longer relies on the EU-U.S. Privacy Shield to transfer personal information to the U.S (see DATA TRANSFERS OUTSIDE THE UK AND/OR THE EEA above for more information), FleishmanHillard US complies with the Privacy Shield Principles of the EU-US Privacy Shield framework (“Privacy Shield”) as set forth by the U.S Department of Commerce regarding the collection, use and retention of personal data transferred from the European Union to the United States. FleishmanHillard has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/
Further FleishmanHillard US has adopted a separate Global Privacy Policy describing our compliance with Privacy Shield Principles for data transferred from the EU to the US. This Global Privacy Policy can be accessed at: www.fleishman.com.
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.
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.
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 ensure that this Policy is observed and duly implemented. Violations of the applicable data protection legislation in the UK and/or 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 or UK 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 UK, 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 UK and the EEA.
We are also subject to the investigatory and enforcement powers of the U.S. Federal Trade.
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.
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.
For more information about how we use cookies please see our COOKIE POLICY available on the Site.
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.
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 or UK 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 or the UK. We encourage you to review this Policy periodically to be informed of how we use your personal data.
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 the persons listed below
General Contact in the EEA and in the UK:
Ann Coyne
Finance Director
15 Fitzwilliam Quay
Dublin 4
Ireland
Email: yourprivacy@fleishman.com
Contact at our corporate headquarters:
Joe Robertson
Senior Vice President
FleishmanHillard
200 No. Broadway
St. Louis, Missouri 63102
Email: yourprivacy@fleishman.com
Bankside 2, 100 Southwark Street
London SE1 0SW
+44 (0)20 8618 2807
