Last Updated: June 23, 2023
PMG Worldwide, LLC (“PMG”, "us", “we“ or “our”) has created this Privacy Policy (“Policy”) in order to comprehensively inform individuals about our privacy practices and to demonstrate our firm commitment to privacy. This Privacy Policy along with our Cookies Policy and our International Privacy Policy (collectively, this “Policy”) describes how we collect, use, disclose, transfer, store, retain or otherwise process your personal information in the course of performing our general business activities, which includes the administration of the pmg.com website and their related sub-domains (the “Website”) and in email, text, and other electronic messages between you and us (collectively, our “Services”).
When we refer to “you” or “your,” we mean the person about whom we collect personal information or data. If the person accessing the Website does so on behalf of, or for the purposes of, another person, including a business or other organization, “you” or “your” also means that other person, including a business organization, if applicable.
We generally provide our Services to businesses and not to individual consumers. However, in the course of providing our Services, we may collect personal information of individuals, as will be described in this Policy.This may include personal information that we collect about you when you visit our Website, your business contact information if we provide our Services to a company that you work with, or if you are a sole proprietorship and you engage with our Services.
Please read this Policy carefully. Our Policy includes:
General Disclosures
What Information We Collect And Disclose And For What Purposes
Personal Information Relating To Children
How Long We Retain Your Information
Marketing And Promotional Communications
Links To Other Sites
Security
Your Data Rights
Data Rights For California Consumers
Changes To This Privacy Policy
Contact Us
This Policy includes and hereby incorporates by reference the following:
International Privacy Policy
Cookies Policy
Our data centers and Website are hosted in the United States. If you are visiting this Website from outside of the United States, please note that by providing us your information it is being stored or processed in the United States where our data center and servers are located and operated. If you are outside the United States and do not wish to allow the collection and storage of your personal information within the United States, you should not use this Website and you should opt-out of the collection of cookies by following the guidelines in our section titled “How can I disable or remove cookies?” in our Cookies Policy.
This Policy sets forth our data policies and practices for the United States. If you are outside of the United States, please also review the provisions of our International Privacy Policy. Depending on your country of residence, applicable privacy laws may provide you with a right to additional disclosures as well as special data subject rights with regards to your personal information.
This Policy applies only to our Website and Services, and not to other companies’ or organizations’ websites, mobile applications and services to which we link. We are not responsible for the privacy practices of other businesses or the content of other websites, including any websites that may indicate a special relationship or partnership with us (such as co-branded pages or “in cooperation with” relationships). To ensure protection of your privacy, always review the privacy policy of the companies with whom you engage.
In the course of performing our Services, we collect a variety of different kinds of personal information from a variety of different individuals. What information we collect and the purposes for which it is collected will depend on the context of our activities or the Service that is being performed. Therefore, just because this Policy lists a particular data collection practice does not mean that we have necessarily collected that data from you. Instead, please review the applicable disclosures below to learn about how we may have collected personal information from you depending on how you have interacted with us.
When You Visit Our Website
The personal information we collect may include: Identifier Information, Geolocation Information, Internet or Other Electronic Network Activity Information, and/or Device Information. More information can be found below.
Identifier Information (The personal information we collect may include your name, email address, address, internet protocol (IP) address, device IDs, cookie IDs, and other similar identifiers.)
Sources of Collection - We may collect your personal information from: you directly
Business Purpose of Collection - The purposes of collection include:
facilitating your use of our Website
enforcing any applicable terms of service or other applicable agreements or policies
securing our networks, systems and databases against external threats
Categories of Third Parties to Which Personal Information is Disclosed - We may disclose your personal information to:
our service providers (We may disclose your personal information to our security monitoring providers, data analytics providers, database hosting vendors and our auditors.
our affiliates
other entities during a corporate transaction
courts, litigants, regulators, arbitrators, administrative bodies or law enforcement for legal purposes
Business Purpose of Disclosure - The purposes of disclosure include:
facilitating your use and our provision of the Website
Website
enforcing any applicable terms of service or other applicable agreements or policies
preventing attacks and intrusions on our systems
securing our networks, systems and databases against external threats
conducting audits of our systems, policies and procedures
as part of sale, assignment, merger or other transfer of all or a portion of our organization or assets to other entities
as required by law or to resolve, investigate or manage actual or suspected legal claims
Is this Information Sold Or Used for Target Advertising?:
yes, we may sell this information to our marketing and analytics vendors for the purposes of online marketing.
we also may share this information with our marketing vendors for the purposes of targeted advertising or cross-contextual behavioral advertising.
Geolocation Information (The information we collect may include your geolocation.)
Sources of Collection - We may collect your personal information from:
you directly
Business Purpose of Collection - The purposes of collection include:
personalizing and facilitating your use of our Website
measuring, tracking and analyzing trends and usage in connection with your use or the performance of our Website
Categories of Third Parties to Which Personal Information is Disclosed - We may disclose your personal information to:
our service providers (We may disclose your personal information to our security monitoring providers, data analytics providers, database hosting vendors and our auditors.)
our affiliates
other entities during a corporate transaction
courts, litigants, regulators, arbitrators, administrative bodies or law enforcement for legal purposes
Business Purpose of Disclosure - The purposes of disclosure include:
facilitating your use and our provision of the Website
measuring, tracking and analyzing trends and usage in connection with your use or the performance of our Website
securing our networks, systems and databases against external threats
conducting audits of our systems, policies and procedures
as part of sale, assignment, merger or other transfer of all or a portion of our organization or assets to other entities
Is this Information Sold Or Used for Target Advertising?:
yes, we may sell this information to our marketing and analytics vendors for the purposes of online marketing.
we also may share this information with our marketing vendors for the purposes of targeted advertising or cross-contextual behavioral advertising.
Internet or Other Electronic Network Activity Information (The information we collect may include your time zone setting, auth0 logs, pages visited, pages viewed, events and page loads, browser plug-in types and versions.)
Sources of Collection - We may collect your personal information from:
you directly
Business Purpose of Collection - The purposes of collection include:
maintaining and improving our Website
personalizing and facilitating your use of our Website
measuring, tracking and analyzing trends and usage in connection with your use or the performance of our Website
providing marketing and advertising services
Categories of Third Parties to Which Personal Information is Disclosed - We may disclose your personal information to:
our service providers (We may disclose your personal information to our marketing services vendors, security monitoring providers, data analytics providers, database hosting vendors and our auditors.)
our affiliates
other entities during a corporate transaction
courts, litigants, regulators, arbitrators, administrative bodies or law enforcement for legal purposes
Business Purpose of Disclosure - The purposes of disclosure include:
facilitating your use and our provision of the Website measuring, tracking and analyzing trends and usage in connection with your use or the performance of our Website
engaging in marketing and advertising securing our networks, systems and databases against external threats
conducting audits of our systems, policies and procedures
as part of sale, assignment, merger or other transfer of all or a portion of our organization or assets to other entities
as required by law or to resolve, investigate or manage actual or suspected legal claims
Is this Information Sold Or Used for Target Advertising?:
yes, we may sell this information to our marketing and analytics vendors for the purposes of online marketing.
we also may share this information with our marketing vendors for the purposes of targeted advertising or cross-contextual behavioral advertising.
Device Information (The information we collect may include your operating system and platform, device ID, and other technology on the devices you use to access the Website.)
Sources of Collection - We may collect your personal information from:
you directly
Business Purpose of Collection - The purposes of collection include:
maintaining and improving our Website
personalizing and facilitating your use of our Website
measuring, tracking and analyzing trends and usage in connection with your use or the performance of our Website
Categories of Third Parties to Which Personal Information is Disclosed - We may disclose your personal information to:
our service providers (We may disclose your personal information to our security monitoring providers, data analytics providers, database hosting vendors and our auditors.)
our affiliates
other entities during a corporate transaction
courts, litigants, regulators, arbitrators, administrative bodies or law enforcement for legal purposes
Business Purpose of Disclosure - The purposes of disclosure include:
facilitating your use and our provision of the Website measuring, tracking and analyzing trends and usage in connection with your use or the performance of our Website
engaging in marketing and advertising securing our networks, systems and databases against external threats
conducting audits of our systems, policies and procedures
as part of sale, assignment, merger or other transfer of all or a portion of our organization or assets to other entities
as required by law or to resolve, investigate or manage actual or suspected legal claims
Is this Information Sold Or Used for Target Advertising?:
yes, we may sell this information to our marketing and analytics vendors for the purposes of online marketing.
we also may share this information with our marketing vendors for the purposes of targeted advertising or cross-contextual behavioral advertising.
Deidentified and Aggregated Information
We may process your personal information into aggregated, anonymized or de-identified form for any purpose. Aggregated, anonymized or de-identified information is information that can no longer reasonably identify a specific individual and is no longer “personal information.” We will only maintain and use this type of information in deidentified form and we will not attempt to reidentify this information, except for the purposes of validating our deidentification process.
Our Website is not intended for children under 13 years of age. No one under age 13 may provide any personal information to or on our Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website or on or through any of its features, use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us using the information provided under the section titled Contact Us. Please delete all PMG related cookies and restrict further collection of cookies using the methods outlined in our Cookies Policy.
We may retain your personal information for a period of time that is consistent for us to perform our Services, as well as to comply with applicable law, applicable statute of limitations and our data retention practices. We may also retain your personal information as we believe is reasonably necessary to comply with legal process or governmental request, to detect or prevent fraud, to collect fees owed, to resolve disputes, to address problems, to assist with investigations, to enforce other applicable agreements or policies or to take any other actions consistent with applicable law.
You may opt-out of receiving marketing and promotional messages from us, if those messages are powered by us, by following the instructions in those messages. If you decide to opt-out, you will still receive non-promotional communications that are necessary in the performance of our Services.
Transparency and Choice
People have different privacy concerns. Our goal is to be clear about what information we collect and how we use it, so that you can make meaningful choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your personal information:
Tracking Technologies. You can set your browser to refuse all or some browser cookies (including cookies associated with our services), or to alert you when cookies are being sent. To learn how you can manage your cookies on our Website, please see our Cookies Policy.
Google Ads. View and edit your preferences about the Google ads shown to you on Google and across the web, such as which categories might interest you, using Ads Settings. You can also visit that page to opt out of certain Google advertising services.
Profile Information. Take out any of your personal information associated with any PMG profile.
Personalized Advertising. If you do not want us to use personal information that we collect or that you provide to us to deliver advertisements according to our target-audience preferences, you can opt-out by selecting “decline” on our cookie notice banner. If you previously accepted cookies on our website and want to opt-out, please clear your cookies and select “decline” on our cookie notice banner. For browser-specific cookie settings and instructions please see our Cookies Policy.
We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI“) on the NAI’s website at optout.networkadvertising.org.
At times, our Website may provide interactive areas. You are not required to provide any personal information when using these areas, but you may choose to do so. We strongly recommend that you DO NOT use your personal information as your user name and DO NOT post any personally identifiable information on line, since such information will be publicly available. We cannot ensure the security of any information you choose to make public in a chat room, forum, or message board. Also, we cannot ensure that parties who have access to such publicly available information will respect your privacy. Please exercise caution when deciding to disclose personal information in these areas.
We use remarketing services to advertise on third party websites to you after you visited the Website. We and our service providers use cookies to inform, optimize and serve ads based on your past visits to our Website. You can opt-out of this marketing by deleting all PMG related cookies and restrict further collection of cookies using the methods outlined in the section “How can I disable or remove cookies?” in our Cookies Policy.
This Website has links to other websites. Once you link to another site, you are subject to the privacy policy of the new site and its operator. We encourage you to carefully review the privacy policy of each entity to which you provide information.
We understand that the safety of your personal information is extremely important to you. Accordingly, we work hard to protect PMG and individual’s about whom we collect personal information from unauthorized access to or unauthorized alteration, disclosure or destruction of information we hold. We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.
What Data Rights Do You Have?
There are a number of U.S. states that provide specific data rights to residents of those jurisdictions regarding their personal information. This section of this Policy describes the rights available to those individuals who are entitled to them. If you have questions, or want more information about how to exercise your data rights, please contact us using the information provided under the section titled Contact Us.
If you a resident of California, you have access to special data rights and disclosures that are described in this Policy under a separate section titled Data Rights For California Consumers.
If you are a consumer living in Colorado, Connecticut, Nevada or Virginia, you have the following rights with regards to your personal information. These rights are explained in further detail below.
Confirmation of Personal Information Processing: Colorado, Connecticut, Virginia
Access to Personal Information: Colorado, Connecticut, Virginia
Correction of Personal Information: Colorado, Connecticut, Virginia
Portability of Personal Information: Colorado, Connecticut, Virginia
Opt-Out of Targeted Advertising using Personal Information: Colorado, Connecticut, Virginia
Opt-Out of Sale of Personal Information:Colorado, Connecticut, Nevada, Virginia
Opt-Out of Certain Profiling Using Personal Information: Colorado, Connecticut, Virginia
Right to Confirmation and Access: You have the right to confirm whether or not we are processing your personal information and to access such personal information. The general categories of personal information that we collect, process and disclose are listed in the general Policy under the section: What Information We Collect And Disclose And For What Purposes. If you wish to access the specific pieces of personal information that we process about you, please submit a request as directed in the section titled How To Submit A Data Rights Request.
Right to Correct: You have the right to request that we correct inaccurate personal information that we maintain about you, taking into account the nature of the personal information and the purposes of the processing of the personal information.
Right to Delete: You have the right to request that we delete the personal information that we maintain about you.
Right to Portability: You have the right to request to receive your personal information that you have requested in a portable and readily usable format, to the extent technically feasible.
Right to Opt-Out of Targeted Advertising: You have the right to request to opt out of our processing of your personal information for purposes of targeted advertising. “Targeted advertising” generally means displaying advertisements where the advertisement is selected based on personal information obtained from your activities over time and across non-PMG websites or online applications to predict your preferences or interests. However, please note that if you opt-out, you may still see our ads because we may advertise through other methods that are not based upon your online behavior.
Right to Opt-Out of Sale:You have the right to request to opt out of our sale of your personal information. We do sell some personal information, as this term is defined by applicable law. Please review the disclosures in the section titled What Information We Collect And Disclose And For What Purposes for more information.
Right to Opt-Out of Profiling: You have the right to request to opt out of automated profiling of you that produce legal or similarly significant effects concerning you. Applicable state laws allow you to opt out of the application of automated profiling when it relates to substantive decision making, such as denial of financial or lending services, housing, insurance, education enrollment or opportunity, criminal justice, employment opportunities, health-care services, or access to essential goods or services. However, we do not profile individuals in manner that produces legal or similarly significant effects on those individuals. Therefore, we do not offer a way to opt-out of profiling and neither do we look for or process any online browser preference or opt-out signals that purport to opt-out of profiling.
How To Submit A Request
You can submit your request to exercise a data right through either of the below:
E-mailing us at dataprivacy@pmg.com.
Calling us toll-free number at [insert toll-free number].
We recognize the Global Privacy Control (GPC) browser setting that allows individuals to automatically signal their opt-out of the sale of their personal information or sharing of their personal information for the purposes of targeted advertising. You can opt-out of this sale or share by activating the opt-out preference signal or Global Privacy Control (GPC) on your browser. More information regarding GPC is available here.
How We Process Data Rights Requests
Once we receive your request to exercise a right, we will confirm receipt and begin to evaluate, and if appropriate, process the request. Please note that:
We may require that you provide additional information to confirm your identity, including providing us with at least two or more pieces of personal information to match against personal information that we currently maintain about you. We reserve the right to reject your request if we are unable to verify your identity to a sufficiently high level of certainty. The information you provide to verify your identity will only be used for verification purposes, and a record of your request, including certain information contained within it, will be maintained by us for our files.
To authenticate any request to correct personal information, you may be required to provide authentication information.
Certain laws or other legal requirements might prevent some personal information from being deleted.
If you fail or refuse to provide the necessary information, we may not be able to process your request.
If we reject a request for any reason, we will inform you of the basis of the rejection. We may not be able to comply with your request for a number of reasons, including:
you do not live in a state that grants you the specific right that you have requested;
the information that you’ve requested is not subject to the regulation that grants you the right to make a request in relation to your personal information;
we are prevented or exempted by law, regulation or rule from complying with your request;
we do not maintain your personal information in a manner that is connected to your identity;
we are not able to comply with your request without incurring disproportionate burden or expense; or
if complying with your request conflicts with the integrity of our Services, the ability to administer our Website, to administer our business and related relationships or to establish, defend or administer legal claims.
If any of the above reasons apply, we will let you know in our response to your request.
Submitting A Request Through Browser Controls Or An Authorized Agent
We recognize the Global Privacy Control (GPC) browser setting that allows individuals to automatically signal their opt-out of the sale of their personal information or sharing of their personal information for the purposes of targeted advertising. You can opt-out of this sale or share by activating the opt-out preference signal or Global Privacy Control (GPC) on your browser. More information regarding GPC is available here.
Further, you may designate an authorized agent to make a request to “out-opt” of sale, profiling or targeted advertising, as those rights are described above. An authorized agent should make a request through the same mechanisms that are available to individuals as described in this policy. The request should clearly identify that the request is being made by an authorized agent and must include evidence of authorization. If we receive a request from an individual or an entity purporting to making the request on behalf of another individual, we can only comply with the request if we are able to sufficiently authenticate both the identity of the individual as well as the authorized agent’s authority to act on that individual’s behalf. California has special rules regarding submitting requests through agents, so please review the appropriate disclosure in the section titled Data Rights For California Consumers.
Appeals And Complaints
If you disagree with our decision to reject your request or to any portion of our request, you have the right to appeal our refusal within a reasonable period of time. If you wish to appeal, please clearly and plainly describe your basis of disagreement with our decision by responding through the same means by which we communicated our refusal or by submitting your appeal through the information provided under Contact Us. We will review your appeal and either change our decision or reject your appeal, and in either case, we will provide a written explanation of the reason for the decision. This decision will be final.
However, if you still disagree with our decision, you have the right to submit a complaint to your attorney general of your state of residence. Your attorney general will have an online portal with details regarding how to submit complaints:
If you are a resident of Colorado, the Colorado Attorney General can be contacted through the means described here.
If you are a resident of Connecticut, the Connecticut Attorney General can be contacted through the means described here.
If you are a resident of Virginia, the Virginia Attorney General can be contacted through the means here.
The California Consumer Privacy Act (“CCPA”) provides the residents of California with the right to request the data rights as described in this section. For more information, or if you have questions, you can contact us using the information provided under Contact Us.
Right to Know: California residents have the right to know what personal information we have collected about them, including the categories of personal information, the categories of sources from which the personal information is collected in the past 12 months, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about them.The categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for which we collect personal information and the categories of third parties to whom we disclose personal information are found in the general Policy under the section titled What Information We Collect And Disclose And For What Purposes.California residents have a right to know if we are “selling” or “sharing” their personal information, what categories of personal information are “sold” or “shared,” and to whom.
“Sell,” “selling,” “sale,” or “sold,” means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business a third party for monetary or other valuable consideration.
“Share,” “shared,” or “sharing,” means sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged
We do sell and share some personal information, as these terms are defined by California law. Please review the disclosures in the section titled What Information We Collect And Disclose And For What Purposes for more information.
Right to Delete: California residents have the right to request the deletion of their personal information maintained by us.
Right to Correct: California residents have the right to request that we correct inaccurate personal information that we maintain about them.However, we reserve the right to delete your inaccurate personal information instead of correcting it, if permitted by the CCPA.
Right to Non-Discrimination: California residents have the right to not be discriminated against due to the exercise of their CCPA privacy rights. However, note that the exercise of certain privacy rights may make it so that we are no longer able to provide you with certain services or communications. For example, if we delete all of your personal information, we cannot send you e-mails or other communications.
Right to Opt-Out: California residents have the right to opt-out of the “sale” or “sharing” of their personal information (as those terms are defined above). We recognize the Global Privacy Control (GPC) browser setting that allows individuals to automatically signal their opt-out of the sale of their personal information or sharing of their personal information for the purposes of targeted advertising. You can opt-out of this sale or share by activating the opt-out preference signal or Global Privacy Control (GPC) on your browser. More information regarding GPC is available here.
Right to Limit Use and Disclosure of Sensitive Personal Information: California residents have the right to direct a business to limit its use and disclosure of their “sensitive” personal information. California residents can request that a business limit its use or disclosure of their “sensitive” personal information to that use or disclosure which is necessary to perform the services or provide the goods reasonably expected by an average consumer, or to those uses or disclosures otherwise authorized by California law. However, we do not use or disclose your “sensitive” personal information for any purpose other than for the specific purposes described under the CCPA regulation § 7027(m) and always in a manner reasonably necessary and proportionate for these permitted purposes. For information on how we use or disclose your “sensitive” personal information, please see the applicable disclosures in the section titled: What Information We Collect From You And For What Purposes.
Right to Make Requests Through an Authorized Agent: California residents can designate an authorized agent to make a request under the CCPA on their behalf.California residents can designate an authorized agent to make requests under the CCPA on their behalf relating to the residents’ personal information. Only you as a California resident, or a person you have designated in writing as your authorized agent, may make a consumer request related to your personal information. If you wish to have an authorized agent make a verifiable consumer request on your behalf, they will need to provide us with sufficient written proof that you have designated them as your authorized agent, such as a power of attorney pursuant to California Probate Code sections 4000 to 4465. We will still require you to provide sufficient information to allow us to reasonably verify that you are the person about whom we have collected personal information. We can deny any request made by a purported authorized agent who does not submit proof that they has been authorized by the California resident to act on the California resident’s behalf.
Do Not Track (“DNT”): DNT is an optional browser setting that allows you to express your preferences regarding tracking across websites. Most modern web browsers give you the option to send a Do Not Track signal to the websites you visit, indicating that you do not wish to be tracked. However, there is no accepted standard for how a website should respond to this signal, so we do not take any action in response to this signal. We do not have a mechanism in place to respond to DNT signals. Instead, in addition to publicly available third-party tools, we offer you the choices described in this Privacy Policy to manage the collection and use of information about you.
As we provide more services and/or functionality on our Website and as privacy laws and regulations evolve, it may be necessary to revise or update our Privacy Policy. It is our policy to post any changes we make to our Policy with a notice that the Policy has been updated on the Website home page. If we make material changes to how we treat our users’ Personal Information, we will notify you through a notice on the Website home page. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for periodically visiting our Website and this Privacy Policy to check for any changes. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the Privacy Policy periodically for updates.
To submit questions or to inquire about or submit a request relating to data rights, you can contact us by:
E-mailing us directly at dataprivacy@pmg.com.
Calling us toll-free number at [insert toll-free number].
The above general Policy still applies to those individuals who reside outside of the United States or who have had personal information collected by PMG Worldwide, LLC or its agents (“PMG”, “us,” “we” or “our”) in a country other than the United States. However, due to various international regulations, those individuals may be entitled to additional disclosures and rights. This International Privacy Policy (the “International Policy”) supplements the above general Policy, but where the provisions of the general Policy and this International Policy cannot be construed consistently, this International Policy will govern.
Please note that by visiting the Website or by having personal information collected by us, your personal information is being stored or processed in the United States where our data center and servers are located and operated. The United States may not have privacy laws that are as strong or comprehensive as the privacy laws in your own country. Your personal information may also be stored in a multi-tenant cloud environment hosted by our service providers.
Depending on your country of residence, you may have data rights as provided by various laws, regulations and codes, which can include the Canadian Personal Information Protection and Electronic Documents Act, the European Union General Data Protection Regulation, the UK Data Protection Act 2018, the Swiss Revised Federal Act on Data Protection 1992 and Ordinance on the Federal Act on Data Protection, the New Zealand Privacy Act 2020, the Japanese Amended Act on Protection of Personal Information or the Australian Privacy Act 1988, among others. An interactive map showing the various privacy and protection laws around the world can be found here.
THIS INTERNATIONAL POLICY APPLIES TO ALL PERSONAL INFORMATION ABOUT YOU THAT WE COLLECT, HOLD, USE AND DISCLOSE, REGARDLESS OF THE WAY IN WHICH WE COLLECT IT (I.E. WHETHER THROUGH THE WEBSITE, THE SERVICES OR OTHERWISE).
Our International Policy includes:
1. Collection Of Personal Information
2. How We Use Personal Information
3. The Basis On Which We Process Your Personal Information
4. Obtaining Consent
5. Third-Parties
6. Limitations
7. Retention Of Personal Information
8. Access And Rights To Your Personal information
9. Response Time
10. Costs
11. Identifying You In Connection With Requests
12. Opt-Out And Unsubscribe
13. Accuracy
14. Safeguards
15. Contact Us
You can find specific details about the personal information that we collect about you in the section titled What Information We Collect And Disclose And For What Purposes of the general Policy.
Where we are the data controller with regards to the personal information that we process, you may exercise your rights as a data subject, including the right to object to the processing of your personal information when it is processed based on legitimate interests, as described in this International Policy. However, when providing services to our customers, we primarily collect and process your personal information as a processor or service provider on behalf of our customers. This means that we collect, process and disclose your personal information at the direction of our customers. Where we are collecting your personal information on behalf of another entity (i.e., we are not the data controller), we will provide you with the identity of the data controller to the extent we are required to do so by law.
As a general matter, we collect your personal information to perform our Services and administer our Website. You can find specific details about the purposes for which we collect personal information about you in the section titled What Information We Collect And Disclose And For What Purposes.
We will only collect and process your personal information as is reasonably necessary for, or directly related to, one or more of our functions or activities, including for administering our Website or providing our Services to you or our customers. You can find specific details about the purposes for which we collect personal information about you in the section titled: What Information We Collect From You And For What Purposes of the general Policy.
Except when otherwise permitted by law or binding regulation, we will obtain the requisite consent from you prior to collecting and, in any case, prior to using or disclosing your personal information for any purpose other than as disclosed in this International Policy. You may provide your consent to us orally, in writing, by electronic communication, through your actions or any other means reasonably capable of conveying your consent.
Generally, we will seek to obtain your explicit consent if we collect, use or disclose sensitive personal information about you. However, your refusal to provide consent for collection (or your withdrawal of previously given consent) or to give your personal information when requested, can have negative consequences. For example, if you do not give consent for our collection of cookies, then the Website will not remember your preferences. In another example, if you do not provide your personal information when requested we may not be able to provide you with requested materials, disclosures or Services.
We remain responsible for all personal information communicated to other entities for processing on our behalf. As such, we ensure that other entities that are engaged to provide products or services on our behalf and are provided with personal information are required to observe the intent of this International Policy by having comparable levels of security protection or, when required, by assuring us (through a confidentiality agreement) that they will not use or disclose the personal information for any purpose other than the purpose for which the personal information was communicated. You can find specific details about to whom we disclose your personal information in the section titled What Information We Collect And Disclose And For What Purposes.
We only collect the personal information necessary to fulfill the purposes identified to you prior to or at the time of collection, or any other reasonable and legitimate purposes or as required by law.
We do not use or disclose your personal information, except for the purposes for which it was collected, or new purposes to which you have consented, or as required or otherwise permitted by applicable law.
We do not, as a condition of providing the Website or performing the Services, or as an administrative or management requirement, require consent to the collection, use or disclosure of personal information beyond what is reasonably required for such purposes, or to comply with our obligations under applicable law or regulation.
We may keep a record of your personal information, including correspondence or comments, in a file specific to you. We will utilize, disclose, or retain your personal information only for as long as necessary to fulfill the purposes for which it was collected and for legal or business requirements. We will establish minimum and maximum retention periods and procedures for maintaining and destroying your personal information. When personal information is retained to make a decision about you, we will retain such information for the period required in order to comply with our internal data retention policies.
There are a number of data privacy laws that provide specific data subject rights to residents of certain jurisdictions. This section of this International Policy describes the rights available to those individuals who are entitled to them. Not all individuals about whom we possess information will have access to these rights and we may not be able to provide these rights to everyone due to legal and jurisdictional limitations. We may not be able to comply with your request for a number of reasons, including:
you do not live in a jurisdictions that grants you the specific right that you have requested;
the information that you’ve requested is not subject to the regulation that grants you the right to make a request in relation to your personal information;
we are prevented by law, regulation or rule from complying with your request;
we are not able to comply with your request without incurring disproportionate burden or expense; or
if complying with your request conflicts with the integrity of our services or the ability to administer our business, to administer our business and related relationships or to establish, defend or administer legal claims.
If any of the above reasons apply, we will let you know in our response to your request. Note that we may be required to gather additional information from you in order to process your request. We will only use this information in the context of evaluating and responding to your request. If you fail or refuse to provide the necessary information, we may not be able to process your request.
Subject to the exceptions provided by applicable law or regulation, and depending on your country of residence, you may have the following rights regarding your personal information:
if we process your personal data based on your consent, you have the right to withdraw your consent at any time for further processing;
you have the right to request access to, rectification or deletion of your personal data;
you have the right to object to the processing of your personal data;
you have the right to request us to transfer your personal data to another controller; and
you have the right to request us to restrict the processing of your personal data.
Finally, you have the right to raise a complaint with us or the appropriate data protection authority of your country of residence if you feel that our processing of your personal information violates your individual rights, is not in line with this International Policy or violates the privacy principals, laws or regulations of your country of residence.
You can contact our privacy officer by using the information provided under Contact Us. We will promptly investigate any complaint and will respond within the timeframes describe in this International Policy.
If you are a resident of the European Union, you can find your appropriate data protection authority by following this link.
If you are a resident of Switzerland, you can contact your data protection authority through the information provided in this link.
If you are a resident of the United Kingdom, you can contact your data protection authority through the information provided in this link.
If you are a resident of Canada, you can contact your data protection authority through the information provided in this link.
You can request to exercise these rights by using the information provided under Contact Us. Please be as specific as possible in your request so that we can meet the applicable handling timelines.
We will make every reasonable effort to respond to your written request not later than 30 days after receipt of such request. We will advise you in writing if we cannot meet your request within this time limit. When applicable, you have the right to make a complaint to the appropriate supervisory authority, as detailed in this International Policy, with respect to this time limit.
We expect to be able to respond to your request without charge as a general matter. However, where allowed by law, we reserve the right to collect a reasonable charge when you request the transcription, reproduction or transmission of such information. We will notify you, following your request of the appropriate amount that will be charged. You will then have the opportunity to withdraw your request.
We may require that you provide to us additional information to identify yourself before we provide information about the existence, use or disclosure of your personal information in our possession. Any such information that you provide to us shall be used only for this purpose.
You may opt-out of receiving marketing and promotional messages from us, if those messages are powered by us, by following the instructions in those messages. If you decide to opt-out, you will still receive non-promotional communications that are necessary to maintain the existing business relationship between you and us, to the extent there is one.
We use remarketing services to advertise on third party websites to you after you visited the Website. We and our service providers use cookies to inform, optimize and serve ads based on your past visits to our Website. We only engage in remarketing with your consent through the acceptance of a cookie banner when you access appropriate webpages. You can opt-out of this marketing by deleting all PMG related cookies and restrict further collection of cookies using the methods outlined in the section “How can I disable or remove cookies?” in our Cookies Policy.
We will use reasonable efforts to ensure that your personal information is kept as accurate, complete and up to date as possible. We do not routinely update your personal information in our possession, unless such a process is necessary. In order to help us maintain and ensure that your personal information is accurate and up to date, you must inform us, without delay, of any change in the data that you have provided to us.
You can at any time, challenge the accuracy or completeness of the personal information we have about you, subject to the exceptions provided by applicable law. If you demonstrate that the personal information we have on you is inaccurate or incomplete, we will amend the personal information as required. Where appropriate, we will transmit the amended data to third parties to whom we have communicated your personal information.
We use security safeguards appropriate to the sensitivity of personal information to protect it from loss or theft, as well as unauthorized access, disclosure, copying, use or modification. These safeguards include physical measures, such as restricted access to offices and equipment, organizational measures, such as security clearances and publishing this policy to appropriate personnel with instructions to act in accordance with its principles (for example, limiting access on a “need to know” basis), and technological measures, such as the use of passwords and/or encryption.
To submit questions or to inquire about or submit a request relating to data rights, our privacy office can be contacted at dataprivacy@pmg.com.
Effective Date: December 5, 2016Last modified: June 23, 2023