Privacy Policy

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

• What information we collect
• How we collect your information
• How we use your information
• Who we share your information with
• Cookies and other technologies
• Jurisdiction-specific provisions:
  • California
  • European Union and Switzerland
  • Canada
• Security
• How to contact us

This Privacy Policy applies to personal information collected by Havas on the websites where this Privacy Policy appears or where this Privacy Policy is referenced. Your use of this site indicates you agree to acknowledge our collection, use and disclosure of your information as described in this Privacy Policy. If you disagree with the way we collect or handle your data, please do not use this website. If you have any questions regarding our use of data, please contact hh-privacyadmin@havashealth.com.

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 data 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/

WHAT INFORMATION DOES HAVAS COLLECT?

We collect contact information. For example, we might collect your name, email address, and phone number.

We collect information you submit. We may collect information when you contact us, RSVP for an event, download a white paper, or submit an inquiry or job application, such as your current company, title, or resume.

We collect demographic information and education information. If you apply for a job, you may volunteer to submit information like your gender, race, ethnicity, veteran status, or disability status.  We may also collect your mailing address, zip code or postal code.

We collect browsing and usage information. When you use our site, we may automatically collect information about your interactions with the site, your IP address, or and the browser you’re using. We might look at what site you came from, or what site you visit when you leave us. We might collect device identifiers.

We collect information about your location. We collect your general location using your IP address.  We may also collect your precise location, using different types of technologies, including GPS and Wi-Fi.

HOW DOES HAVAS COLLECT YOUR INFORMATION?

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

We collect information directly from you. For example, we may collect information when you contact us or submit an inquiry or job application.

We collect information from you passively. We use tracking tools like browser cookies and web beacons to collect information about users over time when you use this site or our mobile site. We may have third parties collect information this way. To learn more about these tools and how you can control them, please see the “Cookies and Other Technologies” section below.

We get information about you from other parties. Our business partners, such as clients, service providers, and parent, affiliate and/or subsidiary agencies may give us information about you. Social media platforms may also give us information about you.

We combine information. For example, we may combine information that we have collected offline with information we collect online. Or we may combine information we get from a third party with information we already have.

HOW DOES HAVAS USE YOUR INFORMATION?

We use information for marketing purposes. For example, we might provide you with information or serve you ads about our events or services. We might tell you about new features or updates to our offerings. These might be third party offers or products we think you might find interesting. We might send you emails or call you by phone. To stop receiving our marketing emails, email us at hh-privacyadmin@havashealth.com or follow the instructions in any marketing message you get from us. Even if you opt out of getting marketing messages, we will still send you transactional messages, such as responses to your questions or feedback.

We use information to respond to requests or questions. We may use information to respond to your inquiry, job application, or feedback.

We use information to communicate with you. We might contact you about this Privacy Policy, our Terms and Conditions of Use, or other aspects of our relationship with you.

We use information to improve our products and services. We may use information to make our site better or enhance our product and service offerings.

We use information for security purposes. We may use your information to protect our agency and our sites. We may also use your information to protect our users or clients.

We use information as otherwise permitted by law or as we may notify you.

WHO WILL HAVAS SHARE YOUR INFORMATION WITH?

We may share information within the Havas family of agencies. This may include parent, affiliate, and/or subsidiary agencies.

We will share information with vendors that perform services on our behalf. For example, we may share information with the companies that operate our site or conduct analytics for us.  You can contact us if you want to learn more about how our service providers use your information.

We may share information with our business partners. We may share information with third parties who collaborate on projects or co-host events with us.

We may share information with third parties for their marketing purposes. These third parties may include our clients and partners. They may also include third parties in whose products or services we believe you may be interested. These third parties may also share your information with others. These third parties may use the information for their own marketing purposes or the marketing purposes of others. This may include the delivery of interest based advertising.

We will share information if we think we have to in order to comply with the law or to protect ourselves. For example, we may share information to respond to a court order or subpoena. We may share it if a government agency or investigatory body requests.

We may share information with any successor to all or part of our business. For example, if part of our agency was sold, we may give our client and potential client list as part of that transaction.

We may share information for other reasons that we may describe to you at the time of collection.

COOKIES AND OTHER TECHNOLOGIES

You can control cookies and tracking tools. For more information about cookies and how to control them, please see our Cookie Notice.

The Self-Regulatory Program for Online Behavioral Advertising provides consumers with the ability to opt-out of having their online behavior recorded and used for online behavioral advertising purposes.  Click here or here to opt out of having your online behavior collected for advertising purposes and receiving behaviorally targeted advertisements from our advertising partners.  Selections you make are device-specific and browser-specific, meaning that you may need to make your selections on each browser on each device you use to access the website.

Our Do Not Track Policy: Some browsers have “do not track” features that allow you to tell a website not to track you. These features are not all uniform. We do not currently respond to those signals. If you block cookies, certain features on our sites may not work. If you block or reject cookies, not all of the tracking described here will stop.

You can control tools on your mobile devices. For example, you can turn off the GPS locator on your phone or device.

PERSONAL INFORMATION FROM CALIFORNIA

For purposes of the California Consumer Privacy Act of 2018 (the “CCPA”), we are generally a service provider to our clients.  In rare instances in which we have not collected or processed personal information as a service provider, if you reside in California, you have the right to make the following requests with respect to your personal information:

• Access – You have the right to request that we disclose to you the categories of personal information we collected about you, the categories of sources from which we collected the personal information, the categories of personal information we sold or disclosed, our business or commercial purpose for collecting and selling the personal information, the categories of third parties with whom we shared the personal information, and the specific pieces of personal information we collected about you over the past 12 months.
• Deletion – You can request that we delete your personal information that we maintain about you, subject to certain exceptions.

Havas will not discriminate against you because you exercised any of these rights.

Note that for purposes of these rights, personal information does not include information about job applicants, employees and other of our personnel; information about employees and other representatives of third-party entities we may interact with; or information we have collected as a service provider to our clients.

California residents can exercise these rights online by using the following web form: https://privacyportal-de.onetrust.com/webform/82ba7b7d-abd1-4e2a-80e7-ca5a587402b5/2495bdc7-604f-402c-b661-93c7c51b0f3f. 
We may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations. For example, we may retain personal information as permitted by law, such as for tax or other record keeping purposes, to maintain an active account, and to process transactions and facilitate customer requests.  We will take reasonable steps to verify your identity prior to responding to your requests.  The verification steps will vary depending on the sensitivity of the personal information and whether you have an account with us.  California residents may designate an authorized agent to make a request on their behalf.  When submitting the request, please ensure the authorized agent is identified as an authorized agent.

For purposes of exercising these rights, please note the following regarding how we collect and use your personal information as described in this policy, including in the previous 12 months:

• We may collect, and use for our business and commercial purposes, the following categories of personal information as set forth in applicable California law: Identifiers; characteristics of protected classifications under California or federal law; education information; professional or employment information; internet or other electronic network activity information; geolocation data; and inferences. We collect this personal information from the sources described above.
• We may disclose each of the foregoing categories of personal information for the business purposes described in this Privacy Policy to the extent permitted by applicable law.
• We share personal information with third parties in various ways as described in this Privacy Policy. We do not currently consider the ways we share your personal information to comprise the “sale” of your information as defined in the CCPA. You can learn about ways in which you can control the collection of information about you through cookies and other tracking tools by reviewing the “Cookies and Other Technologies” section above.

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 data 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 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/

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.

1. Onward Transfer

We may transfer personal data to companies that help us provide our service. Transfers to subsequent third parties are covered by the provisions in this Privacy Policy 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.

2. 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.

3. 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 data, or it has come to us through third-parties, you may request a copy of your personal data, 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.

If you are in the EU, you may withdraw your consent to Havas’ processing of your personal data at any time, subject to certain legal or contractual restrictions and reasonable notice.  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 in the “Enforcement and Dispute Resolution Regarding EU Personal Data” 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

4. 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 dat. 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
Chief Information 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-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 Policy, 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 Policy.

5. 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://www.jamsadr.com/eu-us-privacy-shield.

6. 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 Policy.  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 by 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 Policy, and the Principles of Fair Information Practices.

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

1. Canada Personal Information Contact Information

Any questions or concerns regarding handling of personal information under Canada’s PIPEDA, or related to revocation of consent to collect, process, transfer, or disclose their personal information 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 information 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.

THESE SITES ARE NOT INTENDED FOR CHILDREN

Our websites are meant for adults. We do not knowingly collect personal information from children under 18 without permission from a parent or guardian. If you are a parent or legal guardian and think your child under 18 has given us information, you can email us at hh-privacyadmin@havashealth.com.

You can also write to us at the address listed at the end of this policy. Please mark your inquiries “COPPA Information Request.”

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 information.

We will keep your personal information as long as it is necessary or relevant for the practices described in this Privacy Notice and in accordance with our internal data retention policies. We also keep information as otherwise required by law.

WE MAY LINK TO THIRD PARTY SITES OR SERVICES WE DON’T CONTROL

If you click on a third-party link, you will be taken to a platform we do not control. This policy does not apply to the privacy practices of those third-party platforms. Read the privacy policy of other platforms carefully. We are not responsible for these third party platforms.

ANY QUESTIONS?

If you have any questions or concerns about our use of your information, please email us at: hh‑privacyadmin@havashealth.com

You can also write to us or call at:

Havas Health, Inc.
Attn: Privacy
200 Madison Avenue
New York, NY 10016
(212) 884-1000

UPDATES TO THIS POLICY

This Privacy Policy may change. Any reduction of your rights under this Privacy Policy cannot be enforced without your express consent. We will post any changes to the Privacy Policy 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 Policy will be archived and made available to users.

Last Updated: March 2020