PMG Worldwide, LLC Privacy Policy
Last Updated: December 29, 2019
Introduction
PMG Worldwide, LLC (“PMG” or “we“ or “us”) respects your privacy and is committed to protecting it through our compliance with this Privacy Policy.
This Privacy Policy applies to pmg.com (the “Website”) which is owned and operated by PMG. This Privacy Policy describes the types of information we may collect from you or that you may provide when you visit our Website, and our practices for using, maintaining, protecting, and disclosing that information. This Privacy Policy also explains your options regarding the use, access and correction of your personal information. The use of information collected through this Website shall be limited to the following purposes of: (i) the reason for which you signed up to receive communications from PMG, and (ii) providing a service to you and other users of the Website (“Users”).
This Privacy Policy applies to information we collect:
- On or through this Website.
- In email, text, and other electronic messages between you and this Website.
- When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this Privacy Policy.
This Privacy Policy does not cover:
- Any information we collect offline;
- Any information collected by a website operated by a third party which PMG may link to or be accessible fromthe Website or;
- Any activities PMG takes on behalf of its clients – in which it acts as a data processor. If you wish to inquire about the data processing, we undertake for any of our clients, or wish to assert your data protection rights regarding that processing, please contract the releveant client directly. If you do not know who our client is, you can contact us directly with your request. Please click on the following link if you want to understand how PMG works with our clients and processes information on behalf of our clients.
Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this Privacy Policy. This Privacy Policy may change from time to time. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.
Information We Collect
We collect information to provide better experiences to the Users of this Website – from figuring out basic stuff like which language you speak, to more complex things like which ads you’ll find most useful, the products and services that matter most to you, or which digital experiences you may not yet be aware of but might enjoy.
PMG collects and processes two basic types of information from and about Users:
- Personal information: This is information that personally identifies one individual from another or enables you to be individually contacted (for example, names, e-mail addresses and other contact information). This information is voluntarily provided to us by Users and is used by us for the purpose of responding to user submissions and fulfilling requests for further information about our services.
- Aggregate user and tracking information: This information gives us insights on how Users use our Website. This data is anonymous and does not contain any personal information. We use this information to ensure that our Website, e-mails and marketing efforts continue to appeal to Website visitors and clients.
This information is collected in the following ways:
- Information you Voluntarily Provide to PMG. PMG only collects personal information that you voluntarily provide, for example, when you use our “contact us” feature, sign up for a newsletter, post content within our forums or other interactive features. Examples of such personal information that you provide to us may include, among other information, your name, physical address and email address. Under such circumstances you consent to our use/processing of the information you provide consistent with this Privacy Policy.
- Cookies and Similar Tracking Technologies. When you visit the Website, PMG and its partners may use cookies or similar technologies to collect analytical information to analyze trends, administer the Website, track Users’ interaction with the Website, and to gather demographic information about our User base as a whole. Our Website uses cookies to distinguish you from other Users of our Website. This helps us to provide you with a positive experience when you browse our Website and also allows PMG to improve its Website and services. Cookies are a common part of many commercial websites that allow small text files to be sent by a website, accepted by a web browser and then placed on your hard drive as recognition for repeat visits to the Website. Every time you visit our Website Site, our servers, through cookies, pixels and/or GIF files, collect basic technical information such as your domain name, the address of the last URL visited prior to clicking through to the Site, and your browser and operating system. We may also use third party analytical tools (e.g. Google Analytics) to analyze activities on the Website and use of the Website. You do not need to enable cookies to visit the Website; however, some parts of the website and some services may be more difficult or impossible to use if cookies are disabled. Some PMG cookie files remain on your computer’s hard drive unless and until you manually delete the file. PMG cookie files do not contain personal information. Please see PMG’s Cookie Policy for more information on PMG’s use of cookies on this Website and how you can disable or restrict the use of cookies.
Employment
For visitors to PMG’s website who are interested in working for us, PMG collects the personal information that you provide when applying for open positions through our online career center. You may receive additional information from PMG regarding your application at the address you provide.
We do not use any of the personal information you provide to PMG to request information about PMG’s or its client’s products and services as part of your application for employment or for any other purpose. We do not sell or rent such information.
Any personal information collected by PMG is controlled by PMG at its Fort Worth, Texas headquarters.
How We Use Information We Collect
We use information that we collect about you or that you provide to us, including any personally identifiable information:
- To present our Website and its contents to you.
- To provide, maintain, protect and improve our services, to develop new ones, and to protect our Users.
- To offer you tailored content – like giving you a more relevant ad experience and improving our businesses to better anticipate and meet your needs and desires.
- To fulfill any other purpose for which you provide it.
- To notify you about changes to our Website or any services we offer or provide through it.
- In any other way we may describe when you provide the information.
We store the personal information you provide in a secure database in order to provide you with the information, products, and/or services you request and may be used to provide you with additional information about our services we believe may be of interest to you. The information is stored for a time period and in a manner relevant to responding to your request unless you request that it be removed. The information you provide us will be shared with PMG employees and service providers to the extent necessary to administrate our systems and/or accommodate your request.
As discussed above, we use information collected from cookies and other technologies, like pixel tags, to improve your user experience and the overall quality of our services. For example, by saving your language preferences, we’ll be able to have our services appear in the language you prefer. When showing you tailored ads, we will not associate an identifier from cookies or similar technologies with sensitive categories, such as those based on race, religion, sexual orientation or health.
We will ask for your consent before using information for a purpose other than those that are set out in this Privacy Policy.
Information We Share
We may disclose aggregated information about our Users, and information that does not identify any individual (non-personally identifiable information), without restriction, including with our partners – like publishers, advertisers or connected sites. For example, we may share information publicly to show trends about the general use of our services.
PMG does not share, sell or distribute personal information collected from Users with companies, organizations and individuals outside of PMG unless one of the following circumstances applies:
- For external processing. We may provide personal information to our subsidiaries and affiliates or other trusted businesses or persons to process it for us based on our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures.
- For legal reasons. We will share personal information with companies, organizations or individuals outside of PMG if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:
- comply with any applicable law, regulation, legal process or enforceable governmental request.
- enforce applicable terms of service, including investigation of potential violations.
- detect, prevent, or otherwise address fraud, security or technical issues.
- protect against harm to the rights, property or safety of PMG, our Users, our customers or the public as required or permitted by law. This includes exchanging information with other companies and organizations for the purposes of fraud protection.
- In connection with a PMG sale transaction. We may share personal information with a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of PMG’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by PMG about our Website Users is among the assets transferred. If PMG is involved in such a transaction, we will continue to ensure the confidentiality of any personal information and give affected Users notice before personal information is transferred or becomes subject to a different privacy policy.
- To fulfill the purpose for which you provide it.
- For any other purpose disclosed by us when you provide the information.
- With your consent.
We may transfer the personal information we collect about you to recipients in countries other than the country in which the information originally was collected. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to recipients in other countries (such as the U.S.), we will protect that information as described in this Privacy Policy.
If you are located in the European Economic Area (“EEA”), the United Kingdom (“UK”) or Switzerland, we will comply with applicable legal requirements providing adequate protection for the transfer of personal information to recipients in countries outside of the EEA, the UK or Switzerland. With respect to transfers of personal information to the U.S., PMG will comply with the level of privacy protection as is required by the EU-U.S. Privacy Shield Framework and the Swiss-US Privacy Shield Framework administered by the U.S. Department of Commerce , regarding the transfer of personal information from the EEA, UK or Switzerland to the U.S. Click http://www.pmg.com/privacy-policy/#privacy-shield-policy/ to view our Privacy Shield Policy.
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 Cookie 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.
- Targeted 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 Cookie Policy.
Notwithstanding anything contained herein, you may ask us to delete any information about you and cease further contact at any time by sending us a request http://www.pmg.com/contact/ marked “Privacy-Urgent”.
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 times, our Website may provide interactive areas, such as chat rooms, forums and message boards available to Users. 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.
Accessing and Correcting your Information
You may contact us at http://www.pmg.com/contact/ to request access to, to correct, to update or to delete any personal information that you have provided to us. To protect your privacy and security, we will also take reasonable steps (including seeking additional information or documentation) to verify your identity before updating or removing your information. Upon receiving your email with the request to update or remove your information, our privacy team will log the receipt of your request and will contact the appropriate data holder within PMG in order to enable them to process your request. The information you provide us may be archived or stored periodically by us according to backup processes conducted in the ordinary course of business. Information stored as part of this backup process will be deleted in due course on a regular schedule. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
Information Security
PMG understands that the safety of your personal information is extremely important to you. Accordingly, we work hard to protect PMG and our Users 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. In particular:
- All personally-identifiable information is hashed using the SHA-256 algorithm immediately upon receipt.
- PMG relies upon the Amazon Web Services infrastructure for continuous auditing by security accreditation bodies, including ISO 27001, FedRAMP, DoD CSM, and PCI DSS.i.
- Personally-identifiable information is securely stored in an encrypted, distributed database, protected with Amazon’s Key Management Service.
- Data stored on Amazon S3 is encrypted both at rest and in transmission using AES-256
- Access to hashed personally-identifiable information is limited to PMG’s engineering group. Outside of engineering, only our proprietary applications may access hashed bulk files on behalf of PMG employees. Human access to raw personally-identifiable information is prohibited and restricted by our software.
Due to the nature of the Internet and related technology, we cannot guarantee the security of your personal information and PMG expressly disclaims any such obligation.
Links to Other Websites
Our Website may contain links to other websites of interest. However, once you have used these links to leave our Website, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the privacy practices and the protection and privacy of any information which you provide while visiting such sites. Such sites are not governed by this Privacy Policy. You should exercise caution and carefully review the privacy policy applicable to the website in question.
When this Privacy Policy Applies
Our Privacy Policy applies to your use of the Website and all of the services offered by PMG and its affiliates but excludes services that have separate privacy policies that do not incorporate this Privacy Policy.
Our Privacy Policy does not apply to services offered by other companies or individuals, including products or sites that may be displayed to you in search results, on social media, sites that may include display advertising, or other sites linked from our services. Our Privacy Policy does not cover the information practices of other companies and organizations who advertise our services, and who may use cookies, pixel tags and other technologies to serve and offer relevant ads.
Compliance and Cooperation with Regulatory Authorities
We regularly review our compliance with our Privacy Policy. We also adhere to several self-regulatory frameworks, including those identified in our Privacy Shield Policy http://www.pmg.com/privacy-policy/#privacy-shield-policy/. When we receive formal written complaints, we will contact the person who made the complaint to follow up. We will work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that we cannot resolve with our Users directly.
Provisions Applicable to International Users
Information provided through this Website may be uploaded to a cloud and transferred to or accessed globally. By providing information to this Website, you consent to the transfer, processing and/or use of the information globally throughout PMG. Wherever the information is transferred or accessed within PMG it will be processed and used in accordance with this privacy policy.
PMG complies with the level of privacy protection as is required by the EU-U.S. Privacy Shield Framework and the Swiss-US Privacy Shield Framework administered by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from EEA member countries, the UK and Switzerland. To learn more about these Privacy Shield programs, please visit http://www.privacyshield.gov. To review PMG’s privacy shield policies, please visit http://www.pmg.com/privacy-policy/#privacy-shield-policy/.
In compliance with the Privacy Shield Policy, PMG commits to resolve complaints about our collection or use of your personal information. With respect to citizens to the EEA, the UK and Switzerland, PMG will cooperate in investigations by, and comply with the advice of, the Federal Trade Commission and appropriate EU data protection authorities, the UK Information Commissioner or the Swiss Federal Data Protection and Information Commissioner in managing and resolving any dispute or complaint and provide such authorities with written confirmation of the action taken. If you have questions or complaints regarding the use or disclosure of personal information in compliance with the principles of this privacy policy, you should contact us first at http://www.pmg.com/contact/ and we will contact you promptly to attempt to resolve your concerns or complaint. If contacting us does not resolve your concern or complaint, you may raise your complaint with the relevant data protection authorities where you live or work. As further explained in PMG’s Shield Policy, a binding arbitration option is available in the event that residual complaints are not resolved by any other means.
Changes to our Privacy Policy
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 Privacy Policy on this page with a notice that the Privacy 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.
Children Under the Age of 13
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 at http://www.pmg.com/contact/.
Applicable Law
This Privacy Policy will be governed by, and construed in accordance with, the laws of the state of Texas, without regard to principles of conflict of laws, and the EU-U.S. Privacy Shield Framework and the Swiss-US Privacy Shield Framework where applicable.
Disputes
Unless the EU-U.S. Privacy Shield Framework or the Swiss-US Privacy Shield Framework requires otherwise, you and Company (a) will submit any dispute relating to this Privacy Policy exclusively to a federal, state or local court located in Tarrant County, Texas and having subject matter jurisdiction over such dispute, and (b) consent to any such court being a proper venue, and waive any objection to its not being a proper venue (including, but not limited to, any such objection based on convenience), for such dispute. For any dispute relating to personal information covered by the EU-U.S. Privacy Shield Framework or the Swiss-US Privacy Shield Framework, an independent recourse mechanism may be available to you to investigate any unresolved complaints regarding Company’s compliance with those frameworks. If you have a complaint, or desire additional information, regarding Company’s handling of personal information or otherwise relating to this Privacy Policy, you should promptly contact Company as set forth below.
Severability
Whenever possible, each provision of this Privacy Policy shall be interpreted to be effective and valid under applicable law. If, however, any such provision shall be prohibited by or invalid under such law, it shall be deemed modified to conform to the minimum requirements of such law, or if for any reason it is not so modified, it shall be prohibited or invalid only to the extent of such prohibition or invalidity without the remainder of such provision, or any other provision of this Privacy Policy, being prohibited or invalid.
Contact Us
If you have any questions, complaints or desire additional information regarding PMG’s handling of personal information or otherwise relating to this Privacy Policy, please promptly contact us at: http://www.pmg.com/contact/
PMG Worldwide, LLC
Privacy Shield Policy
This Privacy Shield Policy (“Policy”) describes how PMG Worldwide, LLC and its subsidiaries and affiliates in the United States (“US”) (“PMG,” “we,” or “us”) collect, use, and disclose certain personally identifiable information that we receive in the US from the European Economic Area (“EEA”), the United Kingdom (“UK”) and Switzerland (“Personal Data”). This Policy supplements our Website Privacy Policy located at http://www.pmg.com/privacy-policy/#privacy-policy, and unless specifically defined in this Policy, the terms in this Policy have the same meaning as the Website Privacy Policy.
PMG recognizes that the EEA, the UK and Switzerland have established strict protections regarding the handling of Personal Data, including requirements to provide adequate protection for Personal Data transferred outside of the EEA, the UK and Switzerland. To provide adequate protection for certain Personal Data about consumers, clients, business, job applicants and employees received in the US from the EEA, the UK and Switzerland, PMG has elected to comply with the level of privacy protection as is required by the EU-U.S. Privacy Shield Framework and the Swiss-US Privacy Shield Framework administered by the U.S. Department of Commerce (“Privacy Shield”). PMG adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement, and Liability.
For purposes of enforcing compliance with the Privacy Shield, PMG is subject to the investigatory and enforcement authority of the US Federal Trade Commission. For more information about the Privacy Shield, see the US Department of Commerce’s Privacy Shield website located at: https://www.privacyshield.gov.
Personal Data Collection and Use
Our Website Privacy Policy located at http://www.pmg.com/privacy-policy/#privacy-policy describes the categories of Personal Data that we may receive in the US as well as the purposes for which we use that Personal Data. We process Personal Data for the following purposes: business-intelligence analytics and targeted advertising. PMG will only process Personal Data in ways that are compatible with the purpose that PMG collected it for, or for purposes the individual later authorizes. Before we use your Personal Data for a purpose that is materially different than the purpose we collected it for or that you later authorized, we will provide you with the opportunity to opt out. PMG maintains reasonable procedures to help ensure that Personal Data is reliable for its intended use, accurate, complete, and current.
Data Transfers to Third Parties
Third-Party Agents or Service Providers. We may transfer Personal Data to our third-party agents or service providers who perform functions on our behalf as described in our Website Privacy Policy, including: business-intelligence analytics, data matching with other consumer-based databases, and targeted advertising. Where required by the Privacy Shield, we enter into written agreements with those third-party agents and service providers requiring them to provide the same level of protection the Privacy Shield requires and limiting their use of the data to the specified services provided on our behalf. We take reasonable and appropriate steps to ensure that third-party agents and service providers process Personal Data in accordance with our Privacy Shield obligations and to stop and remediate any unauthorized processing. Under certain circumstances, we may remain liable for the acts of our third-party agents or service providers who perform services on our behalf for their handling of Personal Data that we transfer to them.
Third-Party Data Controllers. In some cases, we may transfer Personal Data to unaffiliated third-party data controllers. These third parties do not act as agents or service providers and are not performing functions on our behalf. We may transfer your Personal Data to third-party data controllers for the following purposes: business-intelligence analytics, data matching with other consumer-based databases, and targeted advertising. We will only provide your Personal Data to third-party data controllers where you have not opted-out of such disclosures, or in the case of sensitive Personal Data, where you have opted-in if the Privacy Shield requires consent. We enter into written contracts with any unaffiliated third-party data controllers requiring them to provide the same level of protection for Personal Data the Privacy Shield requires. We also limit their use of your Personal Data so that it is consistent with any consent you have provided and with the notices you have received. If we transfer your Personal Data to one of our affiliated entities within our company group, we will take steps to ensure that your Personal Data is protected with the same level of protection the Privacy Shield requires.
Disclosures for National Security or Law Enforcement. Under certain circumstances, we may be required to disclose your Personal Data in response to valid requests by public authorities, including to meet national security or law enforcement requirements.
Security
PMG maintains reasonable and appropriate security measures to protect Personal Data from loss, misuse, unauthorized access, disclosure, alteration, or destruction in accordance with the Privacy Shield.
Access Rights
You may have the right to access the Personal Data that we hold about you and to request that we correct, amend, or delete it if it is inaccurate or processed in violation of the Privacy Shield. These access rights may not apply in some cases, including where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of someone other than the individual requesting access. If you would like to request access to, correction, amendment, or deletion of your Personal Data, you can submit a written request to the contact information provided below. We may request specific information from you to confirm your identity. In some circumstances we may charge a reasonable fee for access to your information.
Questions or Complaints
You can direct any questions or complaints about the use or disclosure of your Personal Data to us at http://www.pmg.com/contact/. We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of your Personal Data within 45 days of receiving your complaint. For any unresolved complaints, we agree to cooperate with the EU data protection authorities, the UK Information Commissioner or the Swiss Federal Data Protection and Information Commissioner. If you are unsatisfied with the resolution of your complaint, you may contact the EU data protection authorities, the UK Information Commissioner or the Swiss Federal Data Protection and Information Commissioner for further information and assistance.
Binding Arbitration. You may have the option to select binding arbitration for the resolution of your complaint under certain circumstances, provided you have taken the following steps: (1) raised your complaint directly with PMG and provided us the opportunity to resolve the issue; (2) made use of the independent dispute resolution mechanism identified above; and (3) raised the issue through the relevant data protection authorities and allowed the US Department of Commerce an opportunity to resolve the complaint at no cost to you. For more information on binding arbitration, see US Department of Commerce’s Privacy Shield Framework: Annex I (Binding Arbitration). [https://www.privacyshield.gov/article?id=ANNEX-I-introduction]
Contact Us
If you have any questions about this Policy or would like to request access to your Personal Data, please contact us as follows: http://www.pmg.com/contact/
Changes to this Policy
We reserve the right to amend this Policy from time to time consistent with the Privacy Shield’s requirements.
Privacy Statement – California
This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Statement of PMG Worldwide, LLC and its subsidiaries (collectively, “we,” “us,” or “our”) and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.
Information We Collect
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:
Category |
Examples |
Collected |
| A. Identifiers. | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. | YES |
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. | YES |
| C. Protected classification characteristics under California or federal law. | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). | YES |
| D. Commercial information. | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | YES |
| E. Biometric information. | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. | NO |
| F. Internet or other similar network activity. | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. | YES |
| G. Geolocation data. | Physical location or movements. | YES |
| H. Sensory data. | Audio, electronic, visual, thermal, olfactory, or similar information. | NO |
| I. Professional or employment-related information. | Current or past job history or performance evaluations. | YES |
| J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | NO |
| K. Inferences drawn from other personal information. | Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | YES |
Personal information does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
- Information excluded from the CCPA’s scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from our clients or their agents.
- Indirectly from our clients or their agents. For example, through information we collect from our clients in the course of providing services to them.
- Directly and indirectly from activity on our website (www.pmg.com). For example, from submissions through our website portal or website usage details collected automatically.
- From third-parties that interact with us in connection with the services we perform.
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
- To fulfill or meet the reason for which the information is provided.
- To provide you with information, products or services that you request from us.
- To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
- To carry out our obligations and enforce our rights arising from contracts.
- To improve our website and present its contents to you.
- For testing, research, analysis, and product development.
- For analysis on behalf of our clients.
- As necessary to evaluate you for employment opportunities.
- As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category C: Protected classification characteristics under California or federal law.
Category D: Commercial Information.
Category F: Internet or other similar network activity.
Category G: Geolocation data.
Category I: Professional or employment-related information.
Category K: Inferences drawn from other personal information.
We disclose your personal information for a business purpose to the following categories of third parties:
- Our affiliates.
- Our clients.
- Service providers.
In the preceding twelve (12) months, we have not sold any personal information.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 ).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
- Calling us at 1.866.982.2586
- Emailing us at: deletionrequest@pmg.com
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. If making a request on behalf of another, you must provide us with sufficient information to establish that you are authorized to make such request.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. At a minimum, please provide us with your name, telephone number, physical address, and email address.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Changes to Our Privacy Notice
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you through a notice on our website homepage.
Effective Date: December 5, 2016
Last modified: December 29, 2019