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Privacy Statement

Havas Health, Inc., Havas PR North America, Inc., Havas PR Arizona, LLC, Havas Gemini, LLC, Symbiotix, LLC, and the Havas Life Toronto, Health4Brands Toronto, and Sciterion divisions of Havas Canada Holdings, Inc. (“Havas”), like you, value privacy. This Privacy Statement sets forth Havas’ privacy principles with respect to personal data, including the implementation of privacy procedures and technical security measures to keep personal data private and secure. It explains:

  • What types of personal data we collect and process
  • Security
  • Data integrity and purpose limitation
  • The choices we offer you, including how to access, update and delete personal data
  • Our acknowledgement of participation in the EU-US and Swiss-US Privacy Shield Frameworks and your rights thereunder
  • Our acknowledgement of our obligations under the Canadian Personal Information Protection and Electronic Documents Act and its Principles of Fair Information Practices and your rights thereunder pertaining to your personal information

This Privacy Statement applies to personal data (and personal information) received by Havas on our websites, from customers, consumers, contractors, vendors, business partners, regulatory authorities and others, in any format, including electronic and paper, as part of Havas’ business operations, subject to applicable laws.

 

Types of Personal Data We Collect and Process

Havas complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information transferred from the EU/EEA or Switzerland to the United States. Havas has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/

Havas obtains personal data in a variety of ways, and takes care to protect its privacy in compliance with the Privacy Shield Principles.

On our websites we may invite inquiries from consumers or potential customers which may, in some circumstances, include collection of personal data (particularly if a response from us is requested). This is discussed further below.

We may at times process personal data on behalf of our customers, who entrust Havas with it as part of their engagement with us. Sometimes we receive such data simply as part of overseeing a process or website managed by Havas or a third-party vendor authorized by the customer, and it simply passes through our systems.

Finally, we often engage third‑party vendors and engage in other types of business transactions including acquisitions of businesses or assets, which can involve the exchange of personal data in the regular course of managing those business relationships and transactions.

Havas is part of a global family of companies, affiliates and subsidiaries, and in certain circumstances we work together and share personal data with entities that belong to that global Havas family.

We will share your personal information with third parties only in the ways that are described in this privacy statement. We do not sell your personal information to third parties. We may provide your personal information to companies that provide services to help us with our business activities like offering services for our clients. These companies are authorized to use your personal information only as necessary to provide these services to us.

Third parties to whom we disclose information are required by law and contractual obligations to keep your personal data confidential and secure, and to use and disclose it for purposes that a reasonable person would consider appropriate in the circumstances, in compliance with applicable law, including

  • To provide the products and services you have requested
  • To notify you, or allow our affiliated companies or customers to notify you of certain products or services offered by them
  • Protecting against fraud, suspicious or other illegal activities
  • Compiling statistics for analysis of our sites and our business, or the sites and businesses of our customers
  • For legal, regulatory and related purposes, or
  • To process transactions through data processing service providers

Most of the personal data collected and processed by Havas is stored inside the United States where it is under the jurisdiction of United States law, and the United States government, courts, law enforcement or regulatory agencies may be able to obtain disclosure of your personal data under United States laws.

Subject to certain legal or contractual restrictions and reasonable notice, you may withdraw your consent to Havas’ processing of your personal data at any time. Havas will inform you of the consequences of withdrawing your consent. In some cases, refusing to provide personal data or withdrawing consent for Havas to use or disclose your personal data could mean that you cannot participate in particular services or information for which it was collected. If you wish to withdraw your consent please refer to the contact information section below. However, there are a number of instances where Havas does not require your consent to engage in the processing or disclosure of personal data. Havas may not solicit your consent for the processing of personal data for those purposes which have a statutory basis, such as:

  • To facilitate responding to an inquiry you have submitted
  • The transfer or processing is necessary for the performance of a contract between you and Havas (or one of its affiliates)
  • The transfer or processing is necessary for the performance of a contract, concluded in your interest, between Havas (or one of its affiliates) and a third party
  • The transfer or processing is necessary, or legally required, on important public interest grounds, for the establishment, exercise, or defense of legal claims, or to protect your vital interests, or
  • The transfer or processing is required by applicable law

 

Havas Websites

We do not collect identifying information about you (such as your name, address, telephone number, or email address) unless you voluntarily submit that information to us through our Contact page, or through our Facebook, Twitter, Instagram or LinkedIn pages, or other electronic means.

Please do not provide any confidential information (including health information) about you or anyone to us via electronic communication. Any information you do submit will not be sold to any third parties. If we publish any information you provide to us on the website, we will not disclose personally identifiable information.

We collect non‑personal information about your use of our website through the use of cookies. The information collected by cookies allows us to statistically monitor how many people are using our website. We may use cookie information to determine the popularity of certain content and how long visitors stay on the site.

Most browsers offer instructions on how to reset the browser to reject cookies in the “Help” section of the toolbar. You do not have to accept our cookies in order to productively use our site. We do not use cookies to collect or store personal health information about you.

When you visit the site, we may automatically collect certain non‑identifying information about you, such as the type of browser or computer operating system you use or the domain name of the site from which you linked to us.

Notwithstanding any other statements or representations here or elsewhere on our site, we reserve its right to disclose any information in its possession if it is required to do so by law, or we believe, in good faith, that such a disclosure is necessary to comply with the law, defend our rights or property, or to respond to an emergency situation.

Our websites are not intended for children and we do not knowingly solicit, collect or process personal data from, or communicate with, children under the age of 13.

 

Onward Transfer

We may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the provisions in this Privacy Statement regarding notice and choice and the service agreements with our clients and our service providers. Havas complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.

 

Security

Havas takes reasonable and appropriate measures to protect 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 data.

 

Data Integrity

Havas limits the personal data it processes to that which is relevant for the purposes of the particular processing. Havas does not process personal data in ways that are incompatible with the purposes for which the information was collected or subsequently authorized by the relevant data subject. In addition, to the extent necessary for these purposes, Havas takes reasonable steps to ensure that the personal data the company processes is reliable for its intended use and accurate, complete and current. You may contact Havas as indicated below to request that Havas update or correct your personal data. Subject to applicable law, Havas retains personal data in a form that identifies or renders the individual identifiable only for as long as it serves a purpose that is compatible with the purposes for which it was collected or subsequently authorized by the data subject.

 

Access and Choice

In compliance with the EU-U.S. and Swiss-U.S. Privacy Shield Framework, Havas will provide you with reasonable access to your Data so that you may review what information we may have about you. If you have provided us with personal information, or it has come to us through third-parties, you may request a copy of your personal information, you may request that it be updated, modified or deleted, or you may request that its use and disclosure be limited, except where the burden or expense of providing access would be disproportionate to the risks to your privacy, or where the rights of other persons would be violated. Requests may be sent to: 

hh‑privacyadmin@havashealth.com.

There may be other circumstances in which we may limit, or prevent, your access to your Data, which is more fully described on the Privacy Shield website, at: https://www.privacyshield.gov/article?id=6-ACCESS. Havas will keep track of individuals’ choices and changes to those choices to ensure they are honored on a continuing basis.

 

Personal Data from the European Union and Switzerland

Havas complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. Havas complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions. Havas 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 statement 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/

 

Enforcement and Dispute Resolution Regarding EU Personal Data

In compliance with the Privacy Shield Principles, Havas commits to resolve complaints about our collection or use of your personal information. EU individuals with questions or complaints should first contact Havas at: hh‑privacyadmin@havashealth.com

Alternatively, letters may be sent to the following address:

Bill Gallagher
Data Protection Officer
Havas
200 Madison Avenue
New York, New York 10016
Attn: Privacy

Any requests to opt-out of future communications from Havas, or to opt-out of a particular Havas program should be directed to Havas by email hh‑hh‑privacyadmin@havashealth.com. All communications to Havas should include the individual’s name and contact information (such as email address, phone number, or mailing address), and a detailed explanation of the request. Email requests to delete, amend, or correct personal data should include “Deletion Request” or “Amendment/Correction Request,” as applicable, in the subject line of the email. Havas will endeavor to respond to all reasonable requests in a timely manner and, in any case, within any time limits prescribed by applicable local law.

Havas will promptly investigate and respond to complaints within 30 days of their receipt. Havas will attempt to resolve complaints, disputes and requests to revoke consent regarding collection, processing, transfer and disclosure of personal data in accordance with the principles contained in this Privacy Statement, and the Privacy Shield Principles. If we are unable to remedy any such complaints and disputes, we may be subject to the investigatory and enforcement powers of the Federal Trade Commission. In certain situations, Havas may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Havas will conduct periodic compliance audits of its relevant privacy practices to verify adherence to this Privacy Statement.

 

Independent Recourse Mechanism Regarding EU Personal Data

If you have any Privacy Shield complaints that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback‑form.truste.com/watchdog/request.

 

Binding Arbitration Regarding EU Personal Data

You may also submit a complaint to the Data Protection Authority of your residence, which will communicate it to the US Department of Commerce. In the event that you cannot fully resolve your complaint through the Department of Commerce, it is possible that you may invoke binding arbitration through the Privacy Shield Panel as a final resort. In order to invoke this arbitration option you must take the following steps prior to initiating an arbitration claim: (1) raise the claimed violation directly with Havas and afford us an opportunity to respond to the issue within 30 days; (2) make use of the independent recourse mechanism, which is at no cost to you; and (3) raise the issue through your Data Protection Authority to the US Department of Commerce and afford the US Department of Commerce an opportunity to use best efforts to resolve the issue.

This arbitration option may not be invoked if your same claimed violation (1) has previously been subject to binding arbitration; (2) was the subject of a final judgment entered in a court action to which you were a party; or (3) was previously settled by you and us. In addition, you may not invoke this option where the Data Protection Authority of the country of your residence already has jurisdiction to resolve your complaint.

You may initiate binding arbitration through the Privacy Shield Panel, subject to the prearbitration requirements provision above, by delivering a “Notice” to Havas. The Notice shall contain a summary of steps taken to resolve the claim, a description of the alleged violation, and, at the choice of the individual, any supporting documents and materials and/or a discussion of law relating to the alleged claim. For more information on how to invoke arbitration under the Privacy Shield Framework, please visit

https://www.privacyshield.gov/article?id=ANNEX-I-introduction.

Finally, you may only use binding arbitration to ensure Havas follows the data handling practices set out in this privacy statement. No other form of remedy is available by any arbitration under this section.

 

Personal Information from Canada

Havas operates in Canada and has Canadian customers, which results in the collection and processing of Canadian citizens’ personal information in the same ways as described above from other jurisdictions, including that of our contractors, vendors, customers and consumers. Havas takes seriously its obligations to protect such personal information and to comply with Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”) and PIPEDA’s Principles of Fair Information Practices, subject to the oversight of the Office of the Privacy Commissioner of Canada.

Canadian individuals with questions or complaints regarding the collection, processing and transfer of their personal information in compliance with PIPEDA should first contact Havas at: hh‑privacyadmin@havashealth.com

Havas will promptly investigate and respond, and will attempt to resolve complaints, disputes and requests to revoke consent regarding collection, processing, transfer and disclosure of personal data in accordance with the principles contained in this Privacy Statement, and the Principles of Fair Information Practices.

Havas will conduct periodic compliance audits of its relevant privacy practices to verify adherence to this Privacy Statement.

 

Independent Recourse Mechanism Regarding Canadian Personal Information

If you have an unresolved, PIPEDA-related privacy or data use concerns that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback‑form.truste.com/watchdog/request.

 

Canada Personal Data Contact Information

Any questions or concerns regarding handling of personal data under Canada’s PIPEDA, or related to revocation of consent to collect, process, transfer, or disclose their Personal Data should be directed by email to hh‑privacyadmin@havashealth.com.

Any requests to opt‑out of future communications from Havas, or to opt‑out of a particular Havas program should be directed to Havas by email at hh‑privacyadmin@havashealth.com.

Alternatively, letters may be sent to the following address:

Bill Gallagher
PIPEDA Privacy Official
Havas
200 Madison Avenue
New York, New York 10016
Attn: Privacy

All communications to Havas should include the individual’s name and contact information (such as e‑mail address, phone number, or mailing address), and a detailed explanation of the request. E‑mail requests to delete, amend, or correct personal data should include “Deletion Request” or “Amendment/Correction Request,” as applicable, in the subject line of the e‑mail. Havas will endeavor to respond to all reasonable requests in a timely manner and, in any case, within any time limits prescribed by applicable local law.

Changes to Havas Privacy Statements

This Privacy Statement may change. Any reduction of your rights under this Privacy Statement cannot be enforced without your express consent. We will post any changes to the privacy statement on this page and, in the case of significant changes, we will issue a prominent disclaimer (including, for certain services, by e-mail notification). Previous versions of this Privacy Statement will be archived and made available to users.

Last Updated: April 2018