Effective Date: May 25, 2018
We may collect more or different Personal Data about you in connection with some Services than others. We also may provide your Personal Data to third parties in order to provide the Services that you request, to carry out the purposes for which you provide your Personal Data to us, or otherwise in accordance with our legitimate business interests.
“Processing” (and variations such as “Process”) means any and all of the following operations that relate to Personal Data : collecting, receiving, accessing (or barring access), verifying, storing, disclosing, combining, displaying, sharing, making available, transferring, erasing, destroying, correcting , and otherwise voluntarily or involuntarily using or dealing with Personal Data.
“Personal Data” means information that directly or indirectly identifies you or your computing device.
“Sensitive Personal Data” means Personal Data that reveals your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union memberships, genetic or biometric data used to uniquely identify you and data concerning health, sex life or sexual orientation.
Personal Data We May Collect
Personal Data that we collect or receive from you or others in order to provide our Services or otherwise in connection with your use of our Site is described below. Please do not provide us with more or different Personal Data than we request (for example, do not include Sensitive Personal Data or other private information like a government identification number in a resume – wait until we ask for such information).
Contact information for you (e.g., from you or your CV, resume, business cards and communications to us; or from forms you complete such as to obtain a newsletter or to be included in our database). Typical examples include name, title, postal and email address, telephone, mobile phone and fax numbers.
Job applications and other professional information: if you apply for employment using the Site’s online job application process, you will be required to create an online profile that you can then access using your login name and password. We will collect the following Personal Data from you to create your profile: name, home and work telephone numbers, e-mail address, mailing address, years of experience, and any other Personal Data that you provide us in a cover letter, comments or your resume or CV. We use the Personal Data you provide for your profile to help evaluate whether you are qualified for employment. As part of the application and evaluation process, we may obtain Personal Data about you from third parties, such as background checks, information from LinkedIn, and verifications of your references, work history, and other professional information. To the extent that we are required to do so, we may ask you to separately consent to such communications (e.g., by providing us with your written authorization to obtain a credit report or background check from a consumer reporting agency). We may keep job application and professional information to notify you of other open positions for which you may be a good fit, or to inform you of other positions if you so choose. We may be obligated to keep certain information (personal and/or demographic data) in order to comply with law. If you apply for a position in Germany, for the purpose to defend ourselves in court in the event of an action based on equal employment opportunity law, we store your application data for up to four months after the end of the application process. We do not sell or share applicant data for any other purpose.
Sensitive Personal Data: Depending upon the Service, and subject to applicable law, we may ask you to provide us with Sensitive Personal Data. We only will use and Process such Sensitive Personal Data for the purpose(s) for which you provided it to us or for such purposes as you subsequently may affirmatively authorize.
Publicly Available Personal Data: We might obtain Personal Data about you from public records and/or other publicly available sources, such as newspapers, press releases, industry or trade organization directories, the Internet, lawfully accessible social media, and so on.
Joinder or sign-up information: You can engage in some activities through the Site without providing any Personal Data. However, in connection with other activities, Waggener Edstrom may ask you to provide certain information about yourself by filling out and submitting a form. It is optional for you to engage in these activities. If you elect to engage in these activities, however, Waggener Edstrom may ask that you provide certain Personal Data, such as your first and last name, mailing address (including ZIP code), country of residence, e-mail address, employer, job title and department, and telephone and facsimile numbers. In addition, some Services require activation, which means that we must track certain Personal Data (e.g., whether you have accepted an applicable License Agreement) in order to verify that you have activated and remain eligible to use the Service.
Security Data: We might also collect or receive Personal Data about you for security purposes to the extent that you interact with us physically. For example, if you go to one of our offices for an in-person interview, your image might be captured on a security camera or we might ask you to provide Personal Data in order to verify your identity and/or to provide you with an access badge or identification card.
Fraud Control Data: We may also ask you to provide information about other persons in connection with investigations of suspected piracy or other fraud. In this case, we will ask for the person’s or company’s name and their contact information, so that we may conduct our investigation.
Site Usage Data: As discussed in more detail below under “Cookies and Other Technologies” we may obtain Personal Data about you in connection with your use of our Site by using cookies and other tracking technologies. As a general matter, we will collect Personal Data about you through the Site if you choose to contact us through the Site or to utilize the Site’s online job application process. By doing so, we will receive your e-mail address, your name and any other Personal Data you provide in your message. If you contact us through the Site, we will use the Personal Data you provide to respond to your e-mail inquiry.
Public Relations Data: We also may collect and store limited amounts of Personal Data regarding certain individuals, including media representatives (“Influentials”), in our public relations database. This information may include Personal Data such as: name, telephone number, e-mail address, employer and other non-personal publicly available information, including professional achievements and articles published. We use this data to provide Influentials with information about Waggener Edstrom’s clients and related matters in connection with our public relations campaigns, research, and other related purposes. Influentials whose Personal Data is stored in our database who either do not wish to be included in the database or to receive the information described above may opt-out of receiving further information by sending an email to the address provided in the email communication received from Waggener Edstrom or by using the contact information provided below to request removal from our database.
Cookies and Other Data Collection Technologies
If you use the Site, it may collect certain Personal Data about you and/or your computer or other access device through the use of “cookies” and other tracking software or tracking mechanisms (collectively, “Technologies”). In general, a cookie is a small text file that is saved to the hard drive of your access device (such as a computer, phone, tablet etc.) in order for us and/or our service providers or business partners to collect data about your use of the Site and/or other webpages that you have visited. To the extent required by law, we may separately solicit your affirmative consent to the placement of cookies or other Technologies on your computer or other access device and/or for the collection of Personal Data through such Technologies.
This section describes the Technologies that we use on the Site. For information about cookies and other Technologies that may be used by third parties, see “Third Party Services” below.
The Technologies that we may use include:
Session Cookies: These are cookies that allow our Site to collect information about what you do during a browsing session each time you visit the Site. When connecting to our server, your device will be allocated a session ID, which enables our server to identify your device during the session and facilitates Site usability. These cookies are temporary and are set to be deleted when you leave the Site.
Persistent Cookies: These are cookies that are stored by your browser for more than a session and are set to expire in a set number of days. Persistent cookies enable us to remember your settings and information, so you do not have to keep re-entering them whenever you visit our Site. They also measure how you use and interact with the Site and enable us to personalize the Site. For example, they may allow us to alter the rotation of images on the Site so that different images will be displayed on your next visit. For those purposes, we may collect your IP address, information about your browser, including whether you are accessing the Site through a mobile device, and other usage information. We generally use session cookies instead of persistent cookies, but third parties also might use some persistent cookies, as discussed in more detail below under “Third Party Services.”
The Technologies that we may use may differ depending upon the device that you use to access the Site and may change as Technologies and access channels develop or change.
The types of Personal Data that we and/or third parties may automatically collect through cookies or other Technologies may include, but are not limited to, your IP address and information about your browser, including whether you are accessing the site through a mobile device. We generally may use or otherwise Process this information in order to enable Third Party Services, to provide Services to you, and for purposes of Site functionality (e.g. to remember your login information), but we generally reserve the right to use and Process Personal Data obtained through Technologies for any lawful purpose.
For example, we may collect certain kinds of information about your computer to facilitate, evaluate and verify your use of the Site or our Services, including the frequency with which you visit the Site, the times and dates of your visits, the pages you reviewed, types of Services used, and how many users we receive daily. This information is generally collected in aggregate form without identifying any user individually, although IP addresses and session IDs may be tracked in relation to your purchase activity as part of Waggener Edstrom’s customer order review and fraud prevention efforts. We also use the IP Address of your computer to identify server problems, administer the Site, and compile aggregated statistics for marketing and research purposes. We use navigational data, including log files and click-stream data, to identify information about your web browser and operating system, and the time period in which you visit the Site or a portion of the Site. This information is used to administer the Site, improve Site content, and compile aggregated statistics for research purposes.
California Disclosure. CA Bus. & Prof. Code § 22575 requires us to disclose our how Site responds to Web browser “do not track” signals and/or other mechanisms that seek to provide consumers with the ability to control the collection of their Personal Data through online tracking Technologies for certain purposes, such as targeted or behavioral advertising.
Uses and Disclosures of Personal Data
We may use and Process Personal Data to provide Services to you, to administer the Site, and otherwise to perform obligations, exercise rights, and further the activities for which the Personal Data was provided to us.
Subject to applicable law, other reasons that we may use or Process your Personal Data include, but are not limited to:
- to fulfill your requests, such as to include your resume in our database(s) or to register you as a newsletter subscriber, etc.;
- to evaluate your application for employment;
- to create de-identified, anonymized, aggregated or similar non-personally identifiable data, which we may use for any lawful business purpose;
- to engage in routine business uses and Disclosures that an ordinary and reasonable person should expect in the context of the Services that we provide, the reasons for which we collect Personal Data, and/or the ways that similar businesses ordinarily operate, including, for example, uses and Disclosures:
- to meet our obligations and enforce our rights, to make Disclosures to third parties who help us (e.g., service providers, information technology providers, mailing and other business process providers, outsourcing providers and so on) and to operate and improve our business;
- for security, anti-fraud, authentication and verification purposes;
- to respond to questions or requests or to contact you for lawful purposes, including for surveys;
- to vendors and their service providers who reasonably need the Personal Data to do their jobs;
- to verify your identity, authority, professional history, or other information;
- to respond to or participate in commercial disputes (e.g., lawsuits or investigations);
- to persons appearing to have a lawful interest in the Personal Data (e.g., to an insurance company processing an insurance claim involving you); or
- to comply with applicable law;
- in connection with a merger or other business combination or separation (including, but not limited to, a voluntary or involuntary change in our business or structure, reorganization, sale of all or part of our stock or asset, spinoff, bankruptcy, or dissolution);
- to respond to legal process or regulatory authorities (such as subpoenas; warrants; investigative demands from law enforcement, regulators or others; national or international security letters or demands; etc.);
- to protect against fraud, claims, or other liability or harm to you, us, or others;
- to exercise or perform a legal, ethical, contractual or other right or obligation, including enforcing agreements you have made;
- to Third Party Services, including (without limitation) analytic data service providers (see “Third Party Services” below); and
- for such lawful purposes as may be disclosed or evident at the time that you provide Personal Data to us (e.g., when you provide Personal Data in response to a survey, to sign up for an event, or to register for a newsletter).
We may obtain separate consents from you (or provide separate disclosures to you) regarding particular uses or Disclosures of Personal Data, to the extent that we are required to do so.
Cross Border Data Transfers
Sharing of information sometimes involves cross-border data transfers to or from the United States of America and other jurisdictions. For example, where the Services are available to individuals in the European Economic Area ("EEA"), personal information is transferred to the United States. We use the EU-US and Swiss-US Privacy Shield and standard contractual clauses approved by the European Commission to validate transfers of EEA residents’ personal information from the EEA to other countries. For more information about our Privacy Shield certification, please read our Privacy Shield Policy. Standard contractual clauses are commitments between companies transferring personal information of EEA residents to protect the privacy and security of the transferred personal information.
Security and Data Retention
We use what we believe to be commercially reasonable measures intended to protect your Personal Data from loss, misuse, or unauthorized access, disclosure, alteration or destruction.
Nevertheless, please be advised that no security measure, system, or control is infallible. We accordingly do not guarantee the security or confidentiality of Personal Data and disclaim any express or implied warranties, duties or conditions in that regard. Please also note that you also have a role in the security of your Personal Data. For example, you should not provide us with Personal Data that we do not request, you are responsible for controlling access to any personal computing device through which your Personal Data may be stored or accessed, and you are responsible for safeguarding any passwords or other log-in credentials to may be used to access to your Personal Data.
The criteria used to determine our retention periods include:
- The length of time we have an ongoing relationship with you and provide services to you (for example, for as long as you have an account with us)
- Whether a legal obligation to which we are subject applies (for example, certain laws require us to keep client records for a certain period of time before we can delete them)
- Whether retention is advisable considering our legal position (such as, for statutes of limitations, litigation or regulatory investigations).
Your Choices about Your Personal Data
If you would like to review, correct, update, suppress, restrict or delete Personal Data that we have about you or if you would like to receive an electronic copy of your Personal Data for purposes of transmitting it to another company (if this right to data portability is provided to you by law), you can contact us at:
Waggener Edstrom Worldwide, Inc.,
225 108th Avenue NE, Suite 600
Bellevue, WA 98004
In your request, please make clear the Personal Data that you would like us to change, whether you would like your Personal Data removed from our database or other limitations you would like to put on our use of your Personal Data. For your protection, we only fulfill requests for the Personal Data associated with the particular email or other contact information that you use to send us your request. We may need to verify your identity before fulfilling your request. We will comply with your request as soon as reasonably practicable.
Please note that we often need to retain certain data for recordkeeping purposes and/or to complete any transaction that you began prior to requesting a change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the Personal Data provided until after the completion of such purchase or promotion). Our databases and other records may have residual data which will not be removed. In addition, we also may not allow you to review certain data for legal, security or other reasons.
Complaints and Dispute Resolution
Waggener Edstrom Worldwide, Inc.,
225 108th Avenue NE, Suite 600
Bellevue, WA 98004
Please include your name, address, and/or e-mail address when you contact us. In your correspondence, please indicate with as much detail as possible the location on this Site or otherwise where you provided your Personal Data.