UK & EU PRIVACY POLICY
This policy was last modified September 26, 2024.
1. About this UK and EU Privacy Policy
This UK and EU the Privacy Policy (this “UK and EU Policy”) supplements the information contained in the Privacy Policy of VaynerX with additional information (e.g. the rights afforded to individuals) as required under both the UK and the EU General Data Protection Regulation (the “GDPR”) that applies to individuals located in either the United Kingdom (“UK”), the European Union (“EU”) and/or the European Economic Area (“EEA”). Any terms defined in the Privacy Policy or in the GDPR have the same meaning when used in this UK and EU Privacy Policy. In instances where the information contained in the Privacy Policy and this UK and EU Privacy Policy differs, then this UK and EU Privacy Policy takes precedence.
We may, from time to time, update this UK and EU Privacy Policy. To stay informed of all changes, you should periodically check this UK and EU Privacy Policy. If we make any material changes to this UK and EU Privacy Policy, and where required, we will endeavour to notify you of these material updates. Updates will be referenced by the “Last Modified” date shown above.
We will only collect and process your personal data in accordance with the GDPR. We may process your personal data in the capacity of either a data controller or a data processor. When we are processing your personal data in the capacity of a data controller, then the data controller for the personal data that you provide or that is collected by VaynerX or its affiliates is either VaynerX, LLC, 10 Hudson Yards, 25th Floor, New York, New York 10001) and/or VaynerMedia Limited, 42 Saint John’s Square, London EC1M 4EB, United
Kingdom.
2. Your GDPR Rights
If you are located in the UK, EU and/or EEA, and subject to certain exemptions, the GDPR provides you with the following rights regarding the processing of your personal data:
- Right to be informed about the collection and use of your personal data
- Right to access your personal data
- Right to have any inaccurate personal data corrected
- Right to have your personal data erased
- Right to restrict use of your personal data
- Right to personal data portability
- Right to object to the processing of your personal data
- Right to object to automated decision making
Your right to withdraw consent
Where you have provided your consent for us to process your personal data for a specific purpose, then you also have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your personal data for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law. Please note that the withdrawal of your consent will not affect the lawfulness of any processing carried out by us before you withdraw your consent. You can withdraw your consent at any time by using this form or by contacting us using the contact details provided below in Section 5 of this UK and EU Privacy Policy.
How to exercise your rights and what we may need from you
To exercise any of these rights, please submit a request by completing this form or contact us by using the contact details provided below in Section 5 of of this UK and EU Privacy Policy. Please note that requests submitted through the form provided may be responded to more efficiently than requests submitted by email or mail. We will respond to any requests within the time required by the GDPR. After you submit your request, you will be sent a confirmation email with will contain information on next steps, if any, necessary for us to process your request. Please note that we may need additional information from you to verify your identity before we process your request.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of your other rights). However, we may charge a ‘reasonable fee’ for administrative costs if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
Right to submit a complaint
If you have any concerns regarding the processing of your personal data, then you have the right to lodge a complaint with the appropriate regulator. We would always appreciate the opportunity to resolve a complaint before you contact a regulator and so we encourage you to contact us initially before you submit a complaint to a regulator. Please see our contact details below in Section 5 of this UK and EU Privacy Policy.
In the United Kingdom, the regulator is the Information Commissioner’s Office (“ICO”). Please see the ICO’s contact details below.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
ICO Helpline Phone Number: 0303 123 1113
ICO Website: https://www.ico.org.uk
In the European Union and/or the European Economic Area, you may contact your local supervisory authority.
3. Legal Basis for Processing Personal Data
To the extent that you provide us with or we collect your personal data, we are processing your personal data under one of the following lawful bases:
- Consent. By opting-in, you consent to permit us to process your personal data for the purposes set forth in our Privacy Policy in so far as this processing complies with GDPR.
- Compliance with Legal Obligations. We may process your personal data in order to comply with certain legal obligations that apply to us.
- Legitimate interests. We may process your personal data relying on legitimate interest grounds.
To the extent required by applicable law, we will obtain your consent before collecting data using cookies, pixel tags, and other similar tracking technologies on the Site. If you have accepted our use of cookies, pixel tags, and other tracking technologies, we will collect your data in accordance with our Privacy Policy based on your affirmative informed consent, which you may withdraw through the methods provided herein. Please also see the cookies settings preference tool at the bottom of the following webpage to update your preferences: VaynerMedia. If you have not provided your consent, then we only collect your personal data based on our legitimate interests. To view additional information about behavioral advertising and manage your preferences, you can do so by visiting Your Online Choices.
4. Do we transfer your personal data outside of the UK, EU or EEA?
We may share your personal data with our affiliates or other third party entities that are located outside of the UK, EU or EEA. If we do transfer your personal data outside of the UK, EU or EEA, then we will ensure that it is protected to the same extent that it is protected in the UK, EU or EEA. For example, we may use one of the safeguards listed below:
- Only transfer it to a country outside of the UK, EU or EEA with privacy laws that afford the same protections as the UK, EU or EEA such as a country deemed adequate by the UK government and/or European Commission; or
- Put in place contractual terms with the recipient that requires them protect your personal data to the same standards as it is protected in the UK, EU or EEA (e.g. the EU Standard Contractual Clauses or the UK International Data Transfer Agreement).
5. How to Contact Us
If you have any questions or concerns how we process your personal data or about this UK and EU Privacy Policy, please email us at privacy@vaynerx.com or write to us at one of the following addresses:
VaynerX, LLC
Attention: Legal Department; UK and EU Privacy Policy Enquiry
10 Hudson Yards, 25th Floor
New York, New York 10001
United States of America
VaynerMedia Limited
Attention: Legal Department; UK and EU Privacy Policy Enquiry
42 Saint John’s Square
London EC1M 4EB
United Kingdom
