Privacy Shield Policy

Effective Date: June 19, 2019

This Privacy Shield Policy of Waggener Edstrom Worldwide, Inc. (“Waggener Edstrom,” “we” or “us”) explains how Waggener Edstrom complies with and has certified that it adheres to the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Frameworks (together “Privacy Shield”) as set forth by the U.S. Department of Commerce regarding the collection, use and retention of Personal Data (as defined below) transferred from European Union member countries and Switzerland to the United States. If the terms of this Privacy Shield Policy and data subject rights under the Privacy Shield Principles conflict, then the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program and to view our certification page, please visit https://www.privacyshield.gov/.

With respect to Personal Data received, transferred to otherwise processed pursuant to the Privacy Shield Frameworks, Waggener Edstrom is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.

Please also see the https://www.we-worldwide.com/privacy-policy for more information regarding our Personal Data handling practices.

 

Definitions

In this Privacy Shield Policy:

  • “Personal Data” means any information relating to a User that identifies or can be used to identify that User, either separately or in combination with other readily available data that is received by Waggener Edstrom in the U.S. from the EEA or Switzerland in connection with the Sites, including information provided offline, including Sensitive Personal Data.
  • “Sensitive Personal Data” means Personal Data regarding an individual's racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, physical or mental health, or sexual life.
  • “Sites” means www.we-worldwide.com, www.we-worldwide.de, we-worldwide.us, we-worldwide.co.uk and plus-worldwide.com.
  • “User” means an individual who accesses and uses the Sites and who resides in the EU or Switzerland.

 

Scope

Waggener Edstrom commits to comply with the Privacy Shield Principles with respect to Personal Data received from Users in connection with the use of the Sites.  This Privacy Shield Policy does not apply to Personal Data transferred under Standard Contractual Clauses or any approved derogation under EU data protection law.

 

Privacy Shield Principles

Waggener Edstrom commits to processing Personal Data in accordance with the Privacy Shield Principles as follows:

  1. Notice
  • Waggener Edstrom’s Privacy Policy notifies Users covered by this Waggener Edstrom Privacy Shield Policy about the categories of Personal Data that Waggener Edstrom collects and the purposes for collection and use of their Personal Data.  Waggener Edstrom only will process Personal Data in ways that are compatible with the purpose for which Waggener Edstrom collected it or for purposes later authorized. The types of Personal Data the Waggener Edstrom collects from Users depends on the purpose for which each User chooses to use the Sites.

  • We collect contact information, include name, title, postal and email address, telephone, mobile phone and fax numbers, to communicate with Users who are our clients about the professional services that we offer and to send information that they request.

  • We collect information from and about media representatives, such as name, telephone number, e-mail address, employer, professional achievements and articles published. 

  • We collect Personal Data about influencers (such as bloggers who maintain a social media presence and provide testimonials about certain products and experiences for the general public) and media representatives (such as journalists and other individuals who have active public profiles). The information collected from or about these individuals includes name, telephone number, e-mail address, employer and publicly-available information, such as social media posts, professional achievements and articles published. We use all of this information for public relations campaigns on behalf of Waggener Edstrom’s clients.

  • We collect and use Personal Data from public records and other publicly-available sources, such as newspapers, press releases and industry or trade organization directories, and combine it with other information (including Personal Data) that we have.  We use all of this information for public relations campaigns, research and other related purposes on behalf of Waggener Edstrom’s clients.

  • When a User submits a request for information, Waggener Edstrom collects name, email address and other information that the User chooses to give us to respond to the request.

  • Waggener Edstrom automatically collects the date and time of the User’s access to the Sites. Depending on the settings of a User’s computer or mobile device (“Device”), Waggener Edstrom also automatically collects: Internet Protocol (IP) address; MAC address; Device make, model and operating system version; mobile network information; internet service provider; browser type and language; country and time zone in which the Device is located; and metadata stored on the Device.

  • Waggener Edstrom shares Personal Data collected through the Sites with third-party service providers that Waggener Edstrom engages to provide marketing, billing and similar administrative services as described in Section 3 below.

All Personal Data is collected to operate, manage and improve the Sites and ensure the technical functionality and security of the Sites.  Before Waggener Edstrom uses Personal Data for a purpose that is materially different from the purpose for which Waggener Edstrom collected it or that was later authorized, Waggener Edstrom will provide Users with the opportunity to opt out.

In rare circumstances, we may receive Sensitive Personal Data from our clients or others.  If we do receive Sensitive Personal Data, we only will use and process it for the specific purpose for which it was provided to us or otherwise with explicit consent.

Please see the https://www.we-worldwide.com/privacy-policy for more information.

 

  1. Choice

If Waggener Edstrom collects Personal Data, we will obtain opt-in consent whenever Privacy Shield requires, including if we disclose Personal Data to third parties as described in this Privacy Shield Policy or before Personal Data is used for a different purpose than that purpose for which it was collected or later authorized.

Please see Section 6 below to learn more about choices about Personal Data.

 

  1. Accountability for Onward Transfer

Waggener Edstrom may share Personal Data as follows:

  • Service Providers: We share information with service providers that:
    • help us operate and improve the Sites;
    • provide customer service and respond to your inquiries;
    • support our marketing efforts, including for our email marketing and targeted advertising and our public relations data base.  We may share information collected through cookies and other data collection tools with advertisers for their targeted advertising purposes.;
    • testing our cyber security measures and other security, anti-fraud, authentication and verification purposes; and
    • verify your identity, professional history or other information (where permitted by law) for employment and other lawful purposes. 

We also use a third-party service provider to operate our “Careers” portal, which has its own privacy policy and practices that apply to information you submit when you apply for a position at Waggener Edstrom.  This service provider shares your information with us so that we can evaluate your candidacy.

Waggener Edstrom will ensure that any service provider with which we share Personal Data agrees to use measures to safeguard it.

  • Our Clients:  We share information that we collect about influencers with our clients for their public relations campaigns, research and other related purposes described in our agreements with them.  If you are an influencer and wish to opt out of these disclosures, please see Section 6 below.

  • Legal Compliance: Under certain circumstances, Waggener Edstrom may be required to disclose Personal Data in response to valid requests by public authorities, including for national security or law enforcement requirements.  We also share use and share information to protect against fraud, claims or other liability or harm to Users, us or others; and to exercise or perform a legal, ethical, contractual or other right or obligation, including enforcing agreements.

  • Corporate Transaction: We may share and transfer personal data if we are involved in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control by Waggener Edstrom or any affiliated company (in each case, whether in whole or in part).

Please see the https://www.we-worldwide.com/privacy-policy for more information.

 

  1. Security

Waggener Edstrom takes appropriate measures to protect Personal Data covered by this Waggener Edstrom Privacy Shield Policy from loss, misuse and unauthorized access, disclosure, alteration, unavailability and destruction.  In determining these measures, Waggener Edstrom takes into account the risks involved in the processing and the nature of the Personal Data.

 

  1. Data Integrity and Purpose Limitation

Waggener Edstrom takes reasonable steps to ensure that such Personal Data is reliable for its intended use, accurate, complete and current.  Waggener Edstrom adheres to the Privacy Shield Principles for as long as it retains Personal Data in identifiable form.  Waggener Edstrom takes reasonable and appropriate measures to comply with the requirement under the Privacy Shield to retain Personal Data in identifiable form only for as long as it serves a purpose of processing.

Waggener Edstrom limits the collection of Personal Data covered by this Waggener Edstrom Privacy Shield Policy to information that is relevant for processing.  Waggener Edstrom does not process Personal Data in a way that is incompatible with the purpose for which it was collected or subsequently authorized by a User.

 

  1. Access

A User whose Personal Data is covered by this Waggener Edstrom Privacy Shield Policy has the right to access his or her Personal Data and to correct, amend, limit use of or delete the Personal Data if the Personal Data is inaccurate or processed in violation of the Privacy Shield Principles.  Waggener Edstrom is not required to grant the rights to access, correct, amend and delete Personal Data if the burden or expense of providing access, correction, amendment or deletion is disproportionate to the risks to the User’s privacy or if the rights of persons other than the User are or could be violated.

Please submit requests for access, correction, amendment or deletion to:

Waggener Edstrom Worldwide, Inc.
Attn: Privacy
225 108th Avenue NE, Suite 600
Bellevue, WA 98004
Privacy@we-worldwide.com

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 record keeping 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.

 

  1. Recourse, Enforcement, and Liability

In compliance with the Privacy Shield Principles, Waggener Edstrom commits to resolve complaints about your privacy and our collection or use of your Personal Data transferred to the United States pursuant to Privacy Shield. European Union and Swiss individuals with Privacy Shield inquiries or complaints should first contact Waggener Edstrom at Privacy@we-worldwide.com

Waggener Edstrom has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you.

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms.  See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction.

Waggener Edstrom commits to periodically review and verify its compliance with the Privacy Shield Principles and to remedy any issues arising out of failure to comply with the Privacy Shield Principles. Waggener Edstrom acknowledges that its failure to provide an annual self-certification to the U.S. Department of Commerce will remove it from the Department’s list of Privacy Shield participants.

 

Changes to this Waggener Edstrom Privacy Shield Policy

Waggener Edstrom may amend this Waggener Edstrom Privacy Shield Policy consistent with the requirements of the Privacy Shield, including notice about any amendment.

 

How to Contact Waggener Edstrom

If you have any questions about this Waggener Edstrom Privacy Shield Policy or would like to request access to your Personal Data, please contact us as follows:

Waggener Edstrom Worldwide, Inc.,
Attn: Privacy
225 108th Avenue NE, Suite 600
Bellevue, WA 98004
Privacy@we-worldwide.com