Communications Consultancy Network
EU/UK Privacy Notice
Last Updated July 2023
- PURPOSE OF THIS PRIVACY NOTICE
This Privacy Notice (“Privacy Notice”) sets out how Communications Consultancy Network (herein referred to as “CCN”, “we”, “us” or “our”) processes your personal data in connection with our business, including the provision of our website (“Site”) and the services we offer (“Services”).
In particular, this Privacy Notice explains our approach to any personal data that we might collect from you (i) when you use our Site or Services (ii) during any other interactions with us, or (iii) which we might otherwise process when providing Services to our clients (including the personal data we collect, why we collected it and your rights in respect of our processing of your personal data).
This Privacy Notice is intended to assist you in making informed decisions when using the Site and our Services. Please take a moment to read and understand this Privacy Notice. It is intended to be read in conjunction with our Cookie Notice.
Finally, this Privacy Notice is intended to meet the requirements of the Regulation (EU) 2016/79 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (known as “GDPR”), as well as the “UK GDPR” (as defined in the UK Data Protection Act 2018). When we say GDPR, we mean both the EU and UK versions.
- SCOPE OF THIS PRIVACY NOTICE
This Privacy Notice only applies to the use of your personal data obtained by us, whether from you directly or from a third party. It does not apply to personal data collected by third parties during your communications with those third parties or your use of their products or services (for example, where you follow links on our Site to third party websites over which we have no control).
- CHANGES TO THIS NOTICE
We will update this Privacy Notice from time to time to reflect any changes or proposed changes to our use of your personal data, or to comply with changes in applicable law or regulatory requirements. We may notify you by email of any significant changes to this Privacy Notice, but we encourage you to review this Privacy Notice periodically to keep up to date on how we use your personal data. If we update this Privacy Notice, we will update the ‘Last Updated’ date at the top of the page.
- ABOUT US
The Site and Services are made available by CCN
CCN is a corporation with the registered company name of Marina Maher Communications LLC with its registered office at 6th Foor, 1285 6th Ave, New York, NY 10019, USA
For the purpose of this Privacy Notice and the GDPR, unless we state otherwise we shall be considered a data controller of your personal data in connection with use cases identified in this Privacy Notice. Please note that in many cases where we process data in relation to Services that we provide, we may carry out the activities referred to in this Privacy Notice in our capacity as a data processor acting on behalf of our clients. We have made this distinction clear in the Privacy Notice.
- HOW TO CONTACT US
If you have any questions about this Privacy Notice or want to exercise ‘your rights as a data subject’ set out in this Privacy Notice, you can contact us using the following methods:
| Send us an email at: [email protected] | |
| Post | Write to us at: Communications Consultancy Network 1285 6th Ave, New York, NY 10019, USA |
- TYPE OF PERSONAL DATA WE COLLECT/PROCESS
When we talk about personal data, we mean any information which relates to an identified or identifiable living individual. Individuals might be identified by reference to a name, an identification number, location data, an online identifier (such as an IP address) or to other factors that are specific to them, such as their physical appearance. Categories of personal data we may collect and process about you include:
| Identity Data | First name; last name. |
| Contact Data | Delivery address; billing address; email address; telephone number; social media handle. |
| Applicant Data | Date of birth; gender; country; nationality; resumes; work experience; dietary requirements any other personal data that you may provide in advance of/during your supply of services to us. |
| Image Data | Photos; video recordings. |
| Financial Data | Bank account details; partial payment card details. |
| Transaction Data | Details about payments made between you and us; details of services purchased from us. |
| Profile Data | Interests and preferences; contact/marketing preferences; feedback and survey responses. |
| Behavioral Data | Data relating to your browsing activity, obtained through the use of cookies, pixel tags and other similar technologies; information about when your current or previous sessions started; details about any services you viewed or purchased through the Site. |
| Technical Data | IP address; browser type and operating system; geolocation, to ensure we’re showing you the correct notices and information; any other unique numbers assigned to a device. |
| Publicly Available Data | Information about articles (or similar) that you may have published; information about your interests or affiliations or publicly stated positions on political matter, corporate matters and similar. |
For more information about the personal data we collect please refer to section ‘How we use Personal Data‘ below.
- HOW WE COLLECT PERSONAL DATA
We may collect and receive your personal data using different methods:
| Personal data you provide to us | You may give us your personal data directly, for example, when you obtain services via our Site, contact us with enquiries, complete forms on our Site, subscribe to receive our marketing communications or provide feedback to us. |
| Personal data we collect using cookies and other similar technologies | When you access and use our Site, we may collect certain Behavioral Data and Technical Data. We collect this personal data by using cookies and other similar technologies (see the ‘website insight and analysis‘ section below). |
| Personal data received from third parties | We may receive personal data about you from third parties. Such third parties may include analytics providers, data brokers, third party directories and third parties that provide technical services to us so that we can provide our Site and our Services. |
| Publicly available personal data | From time to time, we may collect personal data about you (Identity Data, Contact Data, or Publicly Available Data) that is contained in publicly available sources (including open source data sets or media reports) or that you or a third party may otherwise make publicly available (for example through speeches at events or publishing articles or other news stories or posts on social media platforms). |
- WHO WE COLLECT PERSONAL DATA ABOUT
We collect and process personal data from the following people:
| Site visitors | We will collect and process your personal data in connection with your interaction with us and our Site. |
| People who contact us with enquiries | If you contact us with an enquiry through our Site, submit a complaint or provide any feedback to us in our surveys and feedback forms, we will collect and process your personal data in connection with your interaction with us and our Site. |
| Client personnel | We may collect and process your personal data in connection with the supply of services to you and/or your organization. |
| Talent | If you supply services and/or content to us and/or work with us to provide services to our client (including featuring in content we produce), we may collect or process your personal data, such as your Identity Data, Contact Data, Financial Data, and Resumes in connection with such supply of services and/or content to us and our clients. |
| Partner/supplier personnel | If you (or your organization) supply products or services to us or otherwise partner with us, we may collect and process your personal data in connection with our receipt of those products and services and/or partnership. This may include personal data included in any email or telephone communications or recorded on any document relating to an order for the products or services, such as your Contact Data. |
| Visitors to our offices or other locations | If you attend one of our physical offices or other locations, we may process personal data that you volunteer in connection with your visit and any enquiries you make. For example, you may volunteer personal data when signing in as a guest, or when you register for and access our guest Wi-Fi network at our premises. CCTV footage may also be collected for security purposes. |
| Event attendees | If you attend one of our events, we will process personal data about you in connection with your attendance at the event. For example, we may ask you to complete a registration or feedback form, or other documents relating to the event. |
| Job applicants | If you apply for a job with us, whether through the Site or otherwise, we will collect and process your personal data in connection with your application. |
| Members of the public | We may process your data in connection with the provision of the Services to our clients. |
- HOW WE USE PERSONAL DATA
- OPERATION OF SITE, PROVISION OF SERVICES AND MARKETING
- Operation of the Site
If you browse our Site
When you browse our Site, we may collect and process Behavioral Data and Technical Data to help us understand how you are using and navigating our Site. We do this so that we can better understand which parts of our Site are more or less popular and improve the structure and navigation of our Site.
Our legal basis for processing
It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you for the Services or it is in our legitimate interest to use personal data in such a way to ensure that we provide access to our Site in a secure and effective way and so that we can make improvements to our Site.
Website insight and analysis
We and our third-party partners might use cookies, web beacons, pixel tags and other similar technologies (which we generically refer to as “Cookies”) to collect data from the devices that you use to access our Site. The data that is collected could include Behavioral Data and Technical Data, and certain Profile Data. Please see our Cookie Notice for further information, including details of our third-party partners.
We and our third-party partners use this data to analyze how you use our Site and our Services and the effectiveness of our Site and Services, including:
- to analyze how you use, and the effectiveness of, our Site and Services;
- to count users who have visited our Site and collect other types of information, including insights about visitor browsing habits, which helps us to improve our Site and Services;
- to measure the effectiveness of our content;
- to learn what parts of our Site are most attractive to our users, which parts of our Site are the most interesting and what kind of features and functionalities our visitors like to see;
- to help us understand the type of marketing content that is most likely to appeal to our visitors and customers.
Our legal basis for processing
Where your data is collected through the use of cookies that are not strictly necessary, we rely on consent to collect your personal data and for the onward processing purpose. Please see our Cookie Notice for further details.
In certain circumstances, we may rely on another lawful basis when we use your personal data collected via the use of cookies. For example, where we use personal data collected through the use of performance cookies to analyze how you use our Site, it is in our legitimate interest to use your personal data in such a way to improve our Site and Services.
If you use the interactive features on our Site
We will collect and use personal data about you when you use certain features on our Site. For example, depending on the nature of your enquiry, we may process your Identity Data, Contact Data, Registration Data, Profile Data and certain Behavioural Data and Technical Data when you use the Enquiry Form or Chat function to get in touch with us or other account holders, or so that you can be searched for by other account holders.
Our legal basis for processing
It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you for the Services, or it is in our legitimate interest to use personal data in such a way to ensure that we can respond to your enquiries, provide access to our Site in a secure and effective way and make improvements to our Site.
If you link to social media sites and interact with our social media pages
If you click on one of the social media links on our Site or otherwise interact with our social media pages such as on Facebook or Instagram (including interacting with any ‘like’ or similar embedded features on our Site or social media accounts), we and the relevant social media platform may receive information relating to such interaction and may share your personal data in connection with this purpose, such as certain Behavioural Data and Technical Data. For more information about how we use this personal data, please see the ‘Website insight and analysis‘ section below.
The relevant social media platform may also be a controller in respect of the personal data that is collected via your use of our social media pages and may use that personal data for additional purposes. For details of how the relevant social media platform uses your personal data, please see the privacy notice of the relevant social media platform.
Our legal basis for processing
It is in our legitimate interest to use personal data in the ways described above to ensure that we provide the Site in an effective way and to promote our Site via social media.
- Provision of our Services
Provision of client facing services
We may, acting on our own behalf and on behalf of our clients, collect personal data (including the types of personal data we set out in Section 6 in the ‘Types of personal data we collect/process‘ about you in connection with the provision of our Services.
Our legal basis for processing
To the extent the above involves personal data, it is in our legitimate interests (or those of our client) to process personal data in this way to enable us to provide our services. Where we do this on behalf of our clients as a data processor, we do not require a legal basis for such processing.
Where your data is collected through the use of cookies that are not strictly necessary, we rely on consent to collect your personal data and for the onward processing purpose. Please see our Cookie Notice for further details.
Social media
We may collect or process individuals’ personal data (including Contact Data, Identity Data and some Profile and Publicly Available Data) 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 client’s social media pages, accounts or channels acting on their behalf.
Our legal basis for processing
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.
- Marketing and Media Enquiries
Marketing
We may use your Identity Data, Contact Data and Profile Data to send you (or the organization you represent) marketing communications by email or via phone. Our marketing will include press releases and information about us.
Our legal basis for processing
It is in our legitimate interest to use your personal data in this way to ensure the promotion of our services is tailored and/or appealing to you and/or the organization you work for although sometimes we may also obtain your consent.
Media and informational inquiries
We may collect personal data (including Identity Data, Contact Data and Publicly Available Data) about journalists, client contacts or industry contacts for interviews requests, for media questions, or requests for information about CCN. 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 Data may be requested in each case, together with details of other personal data that is relevant to these inquiries. This information is used in order to enable us to respond to individual requests or media requests.
Our legal basis for processing
It is in our legitimate interests (and those of our clients) to process personal data in this way to ensure we provide the services requested by our clients in an effective and efficient way and that we provide the right information to those who request it.
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 data including Identity Data and Contact Data (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 data 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.
Our legal basis for processing
It is necessary for us to use personal data in this way to perform our obligations in accordance with any contract that we may have with the 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.
Industry Mapping.
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 Identity Data, Contact Data, 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 Publicly Available Data to provide our Services to our clients including ensuring we and our clients are fully up to speed on public opinion in any particular area and are fully briefed when it comes to dealing with the press. We may also use this information to contact those individuals to discuss our clients’ goods and services. We may also use this information for our own internal administrative and promotional purposes.
Our legal basis for processing
It is in our legitimate interests (or those of our client) to process personal data in this way so that we can provide the services requested by our clients in an effective and efficient way. Where the personal data collected is considered special personal data, we rely on the fact that the personal data has been manifestly made public by individual in order to process their personal data. Where we do this on behalf of our clients as a data processor we do not require a legal basis for such processing.
- BUSINESS ADMINISTRATION, FINANCIAL AND LEGAL
Receipt of services
If we have engaged an organization to provide us or our client with services (for example, IT support or financial advice), we will collect and process your personal data (including Contact and Identity Data) if you are a contact within the relevant organization in order to manage our relationship or our clients with the organization, to receive services from the organization and, where relevant, to provide our services to others including our clients.
Our legal basis for processing
It is necessary for us to use personal data in this way to perform our obligations in accordance with any contract that we may have with the organization, 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 organization 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.
Business administration, finance, and legal compliance
We may use an individual’s personal data (including Identity Data, Contact Data, Financial Data, Transaction Data, Publicly Available Data) for the following business administration and legal compliance purposes:
- to facilitate the operation or effective management of our group of businesses;
- for financial, accounting and tax purposes;
- to comply with our legal obligations;
- to enforce or protect our legal rights;
- to deal with complaints;
- to protect the rights of third parties;
Our legal basis for processing
Where we use personal data in connection with a business transition, to enforce our legal rights or to protect the rights of third parties, it is in our legitimate interest to do so. For all other purposes described in this section, we will rely on our obligation to comply with law (including any court order) to process such personal data.
We will not process any special (or sensitive) categories of personal data or personal data relating to criminal convictions or offences except where we are able to do so under applicable legislation or with the individual’s explicit consent.
- IF YOU FAIL TO PROVIDE YOUR PERSONAL DATA
Where we are required by law to collect your personal data, or we need to collect your personal data under the terms of a contract we have with you, and you fail to provide that personal data when we request it, we may not be able to perform the contract we have or are trying to enter into with you. This may apply where you do not provide the personal data that we need in order to provide the Services you have requested from us or to process an application for employment with us. In this case, we may have to cancel your application or the provision of the relevant Services to you, in which case we will notify you.
We only share personal data with others when we are legally permitted to do so. When we share personal data with others, we put contractual arrangements and security mechanisms in place to protect the personal data shared and to comply with our data protection, confidentiality and security standards and obligations.
We may share data (subject to the above) with our partner agencies and other Omnicom Group companies. For more information about the Omnicom Group, please see here: Advertising and Marketing Agencies | Omnicom Group
Further (again subject to the above) we may share your personal data with third parties as set out in the table below. This list is non-exhaustive and there may be circumstances where we need to share personal data with other third parties.
| Our Clients | We may share personal data with our clients for the purposes of providing them with Services. |
| Our specialist suppliers/partners | We use various specialist suppliers including external subject matter experts and/or partners in order to provide our services including, communications, promotions and events. |
| Third-party IT suppliers | We may share personal data with third parties who support us in providing our Site and help provide, run, and manage our internal IT systems. Such third parties may also include, for example, providers of information technology, cloud-based software-as-a-service providers, identity management, website design, hosting and management, data analysis, data back-up, security, and storage services. The servers powering and facilitating that cloud infrastructure are located in secure data centers around the world, and personal data may be stored in any one of them. We may also share your personal data with third-party service providers to assist us with insight analytics. These providers are described in our Cookie Notice. |
| Payment providers and banks | We may share personal data with third parties who assist us with our invoicing and/or making/receiving payments. |
| Third-party post/email marketing and CRM specialists | We may share personal data with specialist suppliers who assist us in managing our marketing database and sending out email marketing communications. |
| Recruitment agencies and related organizations | We may share personal data with external recruiters, third-party providers that undertake background checks on our behalf and other entities within our group of companies for recruitment purposes |
| Auditors, lawyers, accountants and other professional advisers | We may share personal data with professional services firms who advise and assist us in relation to the lawful and effective management of our organisation and in relation to any disputes we may become involved in. |
| Law enforcement or other government and regulatory agencies and bodies | We may share personal data with law enforcement or other government and regulatory agencies or other third parties as required by, and in accordance with, applicable law or regulation. |
| Other third parties | Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, or to establish, exercise or defend legal rights. We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation. |
- DATA TRANSFERS OUTSIDE THE UK AND THE EEA
As we are a company based in the United States you acknowledge and agree that any data that is provided directly to us may be stored in the United States. We may also transmit your personal data to other third parties outside of the United States (as listed above in ‘Sharing your personal data‘) and more specifically to the offices of other global Omnicom Group entities, networks or partners agencies.
Non-EEA countries do not have the same data protection laws as the UK and the EEA. In particular, non-EEA countries may not provide the same degree of protection for your personal data, may not give you the same rights in relation to your personal data and may not have a data protection supervisory authority to help you if you have any concerns about the processing of your personal data.
To the extent our processing of your personal data is caught by the requirements of the GDPR and/or UK GDPR, when transferring your personal data to territories outside the EEA or UK, 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) where we use certain service providers, we may use specific contracts approved by the European Commission or the UK Government referred to as the “Standard Contractual Clauses” or “SSCs” which give personal data the same protection it has in the EU or UK.
To find out more about the SCCs we use, please see: Standard contractual clauses for international transfers | European Commission (europa.eu) or email us at the address provided in the ‘how to contact us’ section above.
- OBTAINING YOUR CONSENT
Where our use of your personal data requires your consent, you can provide such consent:
- at the time that we collect your personal data following the instructions provided; or
- by informing us by e-mail, post or phone using the contact details set out in this Privacy Notice.
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.
- CONFIDENTIALITY AND SECURITY OF YOUR PERSONAL DATA
We are committed to keeping the personal data you provide to us secure and we have implemented information security policies, rules and technical measures to protect the personal data under our control from unauthorized access, improper use or disclosure, unauthorized modification and unlawful destruction or accidental loss. In addition, all our employees and data processors (i.e. those who process your personal data on our behalf) are obliged to respect the confidentiality of the personal data of all users of our Site and those who purchase our Services.
- YOUR DATA PROTECTION RIGHTS
You have the following rights in relation to the personal data we hold about you under certain circumstances:
- To obtain the confirmation that we process personal data about you, to access and obtain copies of the information, as well as information relating to the processing we carry out.
- To request your personal data be corrected where appropriate.
- If personal data we hold about you is inaccurate or incomplete, you may request that data be amended. However, please be aware that it is every person’s responsibility to provide us with accurate personal data and to inform us of any changes (e.g. new home address or change of name).
- To request your personal data be deleted, where appropriate.
- If you demonstrate that the purpose for which the personal data is being processed is no longer legal or appropriate, the data will be deleted, unless we can demonstrate that we are required to retain the personal data by applicable law or otherwise.
- If we have shared your personal data with others, we will let them know about the deletion where possible. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal data with so that you can contact them directly.
- To request that we restrict the processing of your personal data in some circumstances, such as where you contest the accuracy of the personal data, while we investigate your concern.
- It will not prevent us from storing your personal data.
- We will tell you before we lift any restriction.
- If we have shared your personal data with others, we will let them know about the restriction where it is possible for us to do so.
- If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal data with so that you can contact them directly
- Where processing is based on your consent, to receive your personal data in a commonly used electronic format or ask that we move your personal data in that format to another provider, where your request relates to the personal data that you gave us directly and where technically possible.
- To object to your personal data being processed where we are relying on ours or a third party’s legitimate interest to do so or for the purpose of direct marketing.
- To withdraw your consent at any time when processing relies upon consent.
Data subjects may exercise these rights verbally or in writing using our contact information provided in the section below entitled ‘how to contact us‘ above. We will endeavour to promptly respond to your requests. Where you ask us to provide a copy of your personal data, we are legally obliged to respond within one month of such request. If your request is denied, we will inform you about the reasons for denial.
Please note that in order for you to assert these rights, we may need to verify your identity to confirm your right to access your personal data. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. In order to verify your identity, we may need to gather more personal data from you than we currently have.
- OPT OUT AND UNWANTED COMMUNICATIONS
To opt-out of any future promotional or marketing communications or any other commercial communications from us, you should send a request to us at the contact information in the section entitled ‘how to contact us’ above.
- 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 Privacy Notice 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.
- HOW LONG DO WE KEEP YOUR PERSONAL DATA?
We retain personal data only for as long as is necessary for the purposes described in this Privacy Notice, after which it is deleted from our systems.
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.
- PERSONAL DATA OF MINORS
Our Site is not intended for use by, or targeted at, minors (individuals under the age of 18) and we do not knowingly collect personal data of minors. However, due to the nature of our organization and the Services we provide, we may from time-to-time collect and process personal data relating to minors. If we do collect personal data of minors, we will comply with all applicable laws and regulations relating to the processing of personal data of minors.