Privacy Policy

5th of October 2019

 

This privacy policy will help you understand what information we (“SERVICEPLAN GROUP”, “us”, or “our”) may collect from you and how we may use and share that information. BY USING THE WEBSITE OR SERVICES, YOU ARE HEREBY CONSENTING TO OUR COLLECTION, USE, DISCLOSURE, TRANSFER AND STORAGE OF INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY. We may update this Privacy Policy from time to time as our services and privacy practices change, or as required by law.

 

Information We Collect

We collect several different types of information generated through your use of the website.

 

Categories of Data Collected

We collect the following categories of personal data about visitors to our website, suppliers, and other third parties:

 

Identifiers:

Name, gender, title, organization, job responsibilities, phone number, mailing address, email address, IP address, account name, contact details and information about family life (excluding special categories of data) including family, children, hobbies and interests.

 

Customer Record Information:

Name, signature, physical characteristics or description, phone number, mailing address, passport number, driver’s license or state identification card number, education, employment history, bank account number, credit card number, debit card number, or financial information.

 

Internet or Network Activity:

browsing history, search history, Computer Internet Protocol (IP) address, unique device identifier (UDID), cookies and other data linked to a device, or other information regarding your usage or interaction with a website, application, or advertisement. 

 

Legally Protected Characteristics:

In some circumstances, where you have provided us with such information as it is necessary for a specific service we are providing to you: religious or other beliefs, racial or ethnic origin, sexual orientation, health data, and details of trade union membership.

 

Registration data:

Newsletter requests, event/seminar registrations, dietary preferences (excluding special categories of data), subscriptions, downloads, and username/passwords.

 

Client service data:

Personal information received from customers in respect of employees, customers or other individuals known to customers, invoicing details and payment history, and client feedback.

 

Marketing data:

Data about individual participation in conferences and in-person seminars, credentials, associations, product interests, and preferences. 

 

Compliance data:

Government identifiers, passports or other identification documents, dates of birth, beneficial ownership data, and due diligence data.

 

 Job applicant data:

Data provided by job applicants or others on our website or offline means in connection with employment opportunities, which also may be subject to an additional relevant local recruitment privacy policy. This may include employment and education information.

 

Inferences Drawn from the Above Information

 

Personal Data

 

While using our website, we may ask you to provide us with certain personally identifiable information or personal data that can be used to contact or identify you. We collect personal data only when such information is voluntarily provided to us, in connection with inquiries about our services through the use of the contact form or in the process of your business transactions with us. This information may include, first and last name, billing information, a password and a valid email address.

From time to time, we may obtain information about you or your contacts from third-party sources, such as Google Analytics, public databases, social media platforms, third-party data providers and our joint marketing partners. We take steps to ensure that such third parties are legally or contractually permitted to disclose such information to us.

Where we receive data from you about your employees, customers, or other individuals, it is your responsibility to ensure that any such data is transferred to us in compliance with applicable data protection laws.

 

Usage Data

 

 We may also collect information on how the website is accessed and used. We     automatically collect certain information about your device, including   information about your web browser, mobile device, IP address, unique device   identifiers, software and hardware attributes (including the type of operating   system you use), approximate geographic location, time zone, and some of the cookies that are installed on your device. This is a technical requirement to allow us showing you our website.  Additionally, we collect information about how you use our services, such as the date and time you logged in, the individual web pages or products that you view, what websites or search terms referred you to us, and information about how you interact with our website and other users.

 

Other Sensitive Information

 

 We ask that you not send us, and you not disclose, any sensitive personal   information that we have not requested.  Examples of such information include   social security numbers, information related to racial or ethnic origin, political   opinions, religion or other beliefs, health, biometrics or genetic characteristics,   criminal background or trade union membership.

 

Use of Data Collected

 

We may access and use the collected data for various purposes including:

- to provide and maintain our website;

- to provide our services to you;

- to respond or verify service, security, and customer support issues;

- to monitor the usage of our website;

- to detect, prevent, or otherwise address fraud, security, unlawful, or technical issues;

- as required by law to comply with applicable legal requirements and to enforce this privacy policy;

- internal research and development; and  

- to provide analysis or valuable information to improve and enhance our services. 

We may aggregate and/or de-identify the personal information, usage information, or device information you provide or we collect, so the information no longer identifies any specific person. Afterwards, we may use, disclose, and otherwise process such information without restriction for our legitimate business purposes which may include historical and statistical analysis, marketing, and business planning. However, if we do combine or connect any aggregated data with your personal data so that it can directly or indirectly identify you, we will treat this combined data as personal information and apply the protections outlined under this privacy notice.

 

Communications

 

When you provide us consent to send you communications, either by contacting us through our website or through our normal marketing communications, we may send general marketing communications to you by email.  You must affirmatively opt-in to receive these communications before you receive them. 

We will make sure to get your express opt-in consent before we share your personal information with any company outside the House of Communications group of companies (or other third parties listed herein) for marketing purposes. No matter where you live, you may opt-out of our marketing communications at any time by following the instructions provided through this link.  Please note that even if you opt-out of receiving marketing communications, you may still receive-business related communications, such as transactional emails. 

 

Analytics, Cookies and Other Web Site Technologies

 

Google Analytics

 

We use Google Analytics to analyze and improve the use of our website. Google Analytics uses technologies such as cookies to help analyze how users use this website. The information generated by the cookie about your use of this website (such as your IP address, the URL visited, the date and time the page was viewed) will be transmitted and stored by Google on servers in the United States. Google will use this information to monitor your use of this website, compiling reports on website activity for website operators and providing other services related to website activity and internet usage. Google may transfer this information to third parties where required by law, or where such third parties process information on Google’s behalf. For more information about Google’s privacy policy in respect of Google Analytics, please refer to https://support.google.com/analytics/answer/6004245. You may opt out of Google Analytics by visiting https://tools.google.com/dlpage/gaoptout.

 

Cookies

 

We use cookies and similar tracking technologies to track the activity on our website and we hold certain information. A cookie is a small data file that certain websites write to your browser when you visit them. Cookies are sent to your browser from the website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information. We also use cookies to track user traffic patterns and improve the user experience on our website.

 

You have a variety of tools available to you that let you control the data collected by cookies, web beacons, and similar technologies. For example, you may use your Internet browser controls to limit how the websites you visit are able to use cookies and to withdraw your consent by clearing or blocking certain non-strictly necessary cookies. Just note that if you disable cookies, there may be parts of our website or other services that may not function properly.

 

For more information about the use of cookies for Google analytics and to exercise choice regarding such cookies, please visit the Google Analytics Opt-out Browser Add-on

 

For more information about certain cookies used for interest-based advertising by third parties, including through cross-device tracking, and to utilize certain cookie option choices, please visit the Digital Advertising Alliance, Network Advertising Initiative, Digital Advertising Alliance-Canada, European Interactive Digital Advertising Alliance or your device settings.

 

 Transfer of Data

 

We are based in the United States and we process and store information on servers located in the United States. Your personal information may be stored and processed in any country where we have facilities or in where we engage service providers. By using our website, you understand that your information may be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country.  In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your personal information. By accessing or using this website or otherwise providing information to us, you consent to the processing, transfer and storage of information in and to the U.S. and other countries where you may not have the same rights as you do under local law.

 

We will take commercially reasonably measures to ensure that your data is treated securely and in accordance with this privacy policy, and that no transfer of your personal data will take place to an organization or a country without controls in place to provide protection for the security of your data and other personal information.

 

Retention of Personal Data

 

We will retain your personal data for as long as is necessary for the purposes set out in this privacy policy. We will retain and use your personal data to the extent necessary to comply with our legal obligations, to comply with applicable laws or demands from applicable legal authorities, resolve disputes and enforce our legal agreements and policies.

 

Our Policy on "Do Not Track" Signals

 

We do not support Do Not Track ("DNT"). Do Not Track is a preference you can set in your web browser to inform Websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

 

Your Data Protection Rights under the General Data Protection Regulation (GDPR)

 

Citizens of the European Economic Area and Switzerland have the right to request access to, rectification of, or erasure of their personal data; to data portability in certain circumstances; to request restriction of processing; to object to processing; and to withdraw consent for processing where they have previously provided consent. For a full review of these rights, please see https://www.serviceplan.com/en/footer/privacy-policy.html.  These rights can be exercised using the contact information provided at the end of this document.

 

Please note that we may ask you to verify your identity before responding to such requests. You have the right to contact a Data Protection Authority about our collection and use of your personal data. For more information, please contact your local data protection authority in the European Economic Area (EEA) and Switzerland.

 

Information Sharing

 

We do not share your personal information with third parties except as described in this privacy policy. We may share your personal information with (a) third party service providers; (b) business partners; (c) affiliated companies within our corporate structure; (d) vendors such as financial institutions in connection with invoicing and payments; and (e) as needed for legal purposes. Third party service providers have access to personal information only as needed to perform their functions and they must process the personal information in accordance with this Privacy Policy.

 

Examples of how we share information with third party service services include

 - providing customer support and services;

 - sending marketing/advertising communications; and

- conducting research and analysis.

Examples of how we may disclose data for legal reasons include

 - as part of a merger, sale of company assets, financing or acquisition of all or a portion of our business by another company where customer information will be one of the transferred assets; and 

 - as required by law, for example, to comply with a valid subpoena or other legal process; when we believe in good faith that disclosure is necessary to protect our rights; 

 - to protect your safety (or the safety of others);

 - to investigate fraud; or

 - to respond to a government request

 

Children's Privacy

 

This website is not intended for use by children under 16. We do not knowingly collect personally identifiable information from anyone under the age of 16. If you are a parent or guardian and you are aware that your child has provided us with personal data, please contact us immediately so appropriate steps may be taken to remove such information from our database.

 

California Privacy Rights

 

Residents of California have the right to access, delete, or request we stop collecting their personal information. California residents may receive certain information regarding their personal information’s collection, use, and disclosure in the previous calendar year, as well as certain information regarding third parties involved with these matters.   

Applicable persons may obtain this information or submit erasure requests up to twice in a twelve-month period, free of charge, by contacting us with their request:

Through our website at: https://www.house-of-communication.us/en/contact/contact.html

By telephone at: +1 212 380 2500

Please note that we are required to collect information from you to verify your identity and ability to access this information. We will respond to your request for personal information within 45 days of receiving it. We do not discriminate against users for exercising their rights under these laws. We reserve our right to respond to requests submitted outside the mechanisms specified in this section.

 

Links to Other Websites

 

Our website may contain links to other websites that are not operated by us. If you click a third-party link, you will be directed to that third party's website. This Privacy Policy does not apply to such third-party websites.  When you visit a third-party website, you will be subject to that website’s privacy practices. We strongly advise you to review the Privacy Policy of every website you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party websites or services.

 

Changes to This Privacy Policy

 

We may change or update this privacy policy to reflect changed to our information practices. All updates and amendments are effective immediately upon notice, which we may give by any means, including, but not limited to, by posting a revised version of this privacy policy or other notice on this website. We encourage you to periodically review this page for the latest information our privacy practices. If you continue to use the website after those changes are in effect, you agree to the revised policy. BY USING OUR WEBSITE, YOU ACCEPT ANY AMENDMENTS TO, AND THE MOST RECENT VERSION OF, OUR PRIVACY POLICY.

 

Contact Us

 

If you have any questions about this privacy policy, please contact us by email at info@serviceplan.com. You may send questions you may have about data privacy to our data protection officer at any time at info@serviceplan.com. Postal address: 102 Madison Ave, Floor 10, New York, NY 10016.