This policy was last modified on January 28, 2019.
1. Collection of Data
a. We collect personal data when you voluntarily provide it to us.
We collect personal data from you in several different ways on the Site. Personal data means information that can reasonably be used to identify you personally (such as your name, phone number, address, and email address). We collect this personal data when you voluntarily provide it to us (such as when you submit an inquiry or apply for a job online). You can choose not to provide the requested data, but you might not be able to take advantage of certain Site features.
b. We automatically collect data about your browser or device and your use of the Site.
When you access and use the Site, our technology and tools may automatically collect and record certain data (which does not identify you as an individual) about your use of the Site (your IP address, browser type, the make and model of device used to view the Site, unique device identifiers, the referring web page, pages visited, search terms and other information relating to your use of the Site, browser or device).
We also use various tracking technologies (such as cookies, clear GIFs, and/or pixel tags) to collect data about your use of and access to the Site. Cookies are small bits of information that may be placed on your computer by websites you visit, applications you use, or advertisements you view. Cookies alone tell us nothing about who you are. Pixel tags generate a generic notice of a visit to the Site. Pixel tags are used in conjunction with cookies to anonymously track the activity on the Site by a particular browser on a particular site.
c. Third-parties may also automatically collect data about you.
d. Our “Do Not Track” (DNT) Policy
Some websites have “do not track” features that allow you to tell a website not to track you. We do not currently respond to those signals or similar mechanism transmitted by web browsers. To learn more about browser tracking signals and DNT, please visit http://allaboutdnt.org.
2. Use of Collected Data
We collect and use the types of data described above to assist in the administration and operation of the Site and to provide you an efficient, meaningful, and customized experience. We may use the data to:
· Fulfill our obligations with respect to the reason you volunteered the data (e.g., to respond to an inquiry, evaluate your job application, etc.);
· Allow you to participate in certain features of the Site;
· Improve the Site or our products, events and services;
· Optimize your experience on the Site (e.g., troubleshooting technical programs, storing your preferences, etc.);
· Carry out our obligations and enforce our rights arising from arrangements between you and us; and
· For any other purpose with your consent or as permitted by law.
Additionally, we may use the data for marketing purposes to:
· Provide you with additional information regarding products, events and services from VaynerX, and its subsidiaries and affiliated companies via email or through advertising on various social media platforms or websites (both desktop and mobile) that you may visit; and
· Develop, improve, and target our promotional messaging to you and others via retargeting, online behavioral advertising, and use of social media platform tools for advertising (such as creation of Facebook Lookalike Audiences).
3. Legal Basis for Processing Personal Data
To the extent you provide us with personal data, we are processing your personal data under the following lawful basis:
b. Processing necessary for compliance with legal obligations.
4. Third-Party Websites and Third-Party Embedded Content
5. How We Share Data
a. Affiliates and Subsidiaries. We may share your data collected on this Site with our subsidiaries or affiliated companies.
b. Service Providers. We may provide collected data to our service providers. They may use your data to perform services for us and may have access to, store and process your personal data to provide services on our behalf.
c. Sponsors or Event Partners. In the instance of ticketed events, we may share your personal data with sponsors or event partners.
e. Business Transfer. In the event that VaynerX undergoes a merger, acquisition by another company or sale of its assets, your data will, in most instances, be part of the assets transferred.
6. Your Rights under the GDPR
If you are accessing the Site from the European Economic Area, which includes the European Union, Iceland, Liechtenstein, and Norway, you have the following rights under the General Data Protection Regulation (GDPR).
a. Right to be informed about the collection and use of your personal data
b. Right to access your personal data
c. Right to have any inaccurate personal data corrected
d. Right to have your personal data erased
e. Right to restrict use of your personal data
f. Right to personal data portability
g. Right to object to the processing of your personal data
If you wish to exercise any of these rights under the GDPR, please email us at firstname.lastname@example.org or write to us at the address below with such request. We will respond to any requests without undue delay and no later than one-month after receipt of your request.
7. Opting-Out of Data Use or Withdrawing Consent
As described above, we collect personal data about you when you voluntarily provide it to us, collect other data about you and your use of the Site automatically when you interact with us. If you do not want us to use your collected data as described above or if you wish to withdraw your consent to permit us to process your personal data, please email us at email@example.com or write us at the address below with such request.
If you no longer wish to receive communications from VaynerX, you can opt-out from receiving such messages in the future by following the instructions in the emails or contacting us at firstname.lastname@example.org.
You may remove certain tracking technologies and opt-out of online behavioral advertising messaging by using the opt-out tools available from the Digital Advertising Alliance (DAA Opt-Out Tool) and the Network Advertising Initiative (NAI Opt-Out Tools). Please note that these opt-out tools are device and browser specific, so you must repeat the opt-out from each of your browsers and devices.
You may also adjust your advertising preferences on various social media websites by adjusting your Settings on the platform (for example, you may adjust the types of Facebook ads you receive HERE).
8. Protection and Retention of Data
We use appropriate technical and organizational measures to ensure a level of security appropriate to the risk and to safeguard your data in our possession. However, no data transmission over the Internet is completely secure and no security mechanism is impenetrable. Therefore, although we take steps to protect your data, we cannot guarantee the security of the data that we collect from you or the security of our servers or the Site. By accessing the Site, any transmission of data is at your own risk and you agree to assume all risk in connection with data sent to us or collected by us.
9. Foreign Jurisdictions; Personal Data Transfers
10. Children and Parents
We respect children’s privacy. We do not target or knowingly or intentionally collect personally identifiable information from children under the age of 13. By using the Site, you have represented and warranted that you are either at least 18 years of age or using the Site with the supervision of a parent or guardian. If you are under the age of 13, you may not use the Site. If you become aware that your child has provided us with personal information without your consent, please email us at email@example.com.
11. Your California Privacy Rights
If you are a resident of California, California law permits you to request certain information regarding the disclosure of your personal data by VaynerX, or its affiliates and subsidiaries, to a third-party for direct marketing purposes. To make such a request, please email us at firstname.lastname@example.org or write to us at:
Attention: California Privacy Rights
10 Hudson Yards, 25th Floor
New York, NY 10001
12. Data Controllers
If you live in the United States, the data controller for the personal data that you provide or that is collected by VaynerX or its affiliates is VaynerMedia, LLC, 10 Hudson Yards, 25th Floor, New York, New York 10001.
If you live outside of the United States, the data controller for the personal data that you provide or that is collected by VaynerX or its affiliates is VaynerMedia Limited, Runway East Shoreditch, 58 City Road, EC1Y, 2AL, London, United Kingdom.
14. Contact Us
10 Hudson Yards, 25th Floor
New York, NY 10001
Runway East Shoreditch
58 City Road, EC1Y, 2AL
London, United Kingdom