This Privacy Notice (“Privacy Notice”) sets out how GMR Marketing LLC (“GMR”) processes your personal data in connection with our business, including the provision of our websites at www.gmrmarketing.com, and www.gmrstaffing.com, and other GMR websites that link to this Policy (“Sites”) and the services we offer (“Services”).
In particular, this Privacy Notice explains our approach to any personal data that we might collect from you (i) when you use our Sites or Services (ii) during any other interactions with us, or (iii) which we might otherwise process when providing Services to our clients (including the personal data we collect, why we collected it and your rights in respect of our processing of your personal data).
This Privacy Notice is intended to assist you in making informed decisions when using the Sites and our Services. Please take a moment to read and understand this Privacy Notice. It is intended to be read in conjunction with our Terms of Use and Cookie Policy.
Finally, this Privacy Notice is intended to meet the requirements of:
For ease of reference, in this Privacy Notice we use the term “GDPR” to collectively refer to the EU GDPR, UK GDPR and Swiss Data Protection Laws.
This Privacy Notice only applies to the use of your personal data obtained by us, whether from you directly or from a third party. It does not apply to personal data collected by third parties during your communications with those third parties or your use of their products or services (for example, where you follow links on our Sites to third-party websites over which we have no control).
Further, this Privacy Notice is not intended to cover the processing of workplace personal data. Accordingly, if you are engaged as a worker for us, please see our Workplace Privacy Notice Notice which sets out further information about how we may process your personal data in connection with your employment and/or engagement.
We will update this Privacy Notice from time to time to reflect any changes or proposed changes to our use of your personal data, or to comply with changes in applicable law or regulatory requirements. We may notify you by email of any significant changes to this Privacy Notice, but we encourage you to review this Privacy Notice periodically to keep up to date on how we use your personal data. If we update this Privacy Notice, we will update the effective date at the top of the page.
The Sites and Services are made available by GMR Marketing LLC (“GMR”, “we”, “us, “our”). GMR is the data controller responsible for your personal data. GMR is an USA headquartered company with its registered office at 5050 S. Towne Drive, New Berlin, WI 53151, USA.
For the purpose of this Privacy Notice and the GDPR, unless we state otherwise, we shall be considered a data controller of your personal data in connection with use cases identified in this Privacy Notice. Please note that in many cases where we process data in relation to Services that we provide, we may carry out the activities referred to in this Privacy Notice in our capacity as a data processor acting on behalf of our clients. We have made this distinction clear in the Privacy Notice.
If you have any questions about this Privacy Notice or want to exercise your rights as a data subject set out in this Privacy Notice, you can contact us using the following methods:
Send us an email at: [email protected]
Post
Write to us: GMR Marketing LLC, Attn: Privacy Officer, 5050 S. Towne Drive, New Berlin, WI 53151, USA.
When we talk about personal data, we mean any information which relates to an identified or identifiable living individual. Individuals might be identified by reference to a name, an identification number, location data, an online identifier (such as an IP address), or other factors that are specific to them, such as their physical appearance. Categories of personal data we may collect and process about you include:
Identity Data
First name; last name.
Contact Data
Delivery address; billing address; email address; telephone number; social media handle.
Applicant Data
Date of birth; gender; country; nationality; CVs, work experience; dietary requirements any other personal data that you may provide in advance of/during your supply of services to us.
Image Data
Photos; video recordings.
Financial Data
Bank account details; partial payment card details.
Transaction Data
Details about payments made between you and us; details of services purchased from us.
Profile Data
Interests and preferences; contact preferences; whether you have participated in any promotions or competitions; feedback and survey responses; the content of any messaging you send using any Enquiry Form or Chat function on the Site.
Behavioural Data
Data relating to your browsing activity, obtained through the use of cookies, pixel tags, and other similar technologies; information about when your current or previous sessions started; details about any services you viewed or purchased through the Sites.
Technical Data
IP address; browser type and operating system; geolocation, to ensure we’re showing you the correct notices and information; any other unique numbers assigned to a device.
Marketing and Communications Data
Marketing preferences; service communication preferences.
Publicly Available Data
Information about articles (or similar) that you may have published; Information about your interests or affiliations or publicly stated positions on political matter, corporate matters, and similar.
For more information about the personal data, we collect please refer to the "HOW WE USE PERSONAL DATA" section.
We may collect and receive your personal data using different methods:
Personal data you provide to us
You may give us your personal data directly, for example, when you obtain services via our Site, contact us with inquiries, complete forms on our Site, subscribe to receive our marketing communications, or provide feedback to us.
Personal data we collect automatically, including using cookies and other similar technologies
When you access and use our Sites, we may collect certain Behavioural Data and Technical Data automatically, including through our use of cookies and other similar technologies (see the “Website insight and analysis” section).
Personal data received from third parties
We may receive personal data about you from third parties. Such third parties may include analytics providers, data brokers, third-party directories, and third parties that provide technical services to us so that we can provide our Site and our Services.
Publicly available personal data
From time to time, we may collect personal data about you (Identity Data, Contact Data, or Publicly Available Data) that is contained in publicly available sources (including open-source data sets or media reports) or that you or a third party may otherwise make publicly available (for example through speeches at events or publishing articles or other news stories or posts on social media platforms).
We collect and process personal data from the following people:
Sites visitors
We will collect and process your personal data in connection with your interaction with us and our Site.
People who contact us with inquiries
If you contact us with an enquiry through our Site, submit a complaint, or provide any feedback to us in our surveys and feedback forms, we will collect and process your personal data in connection with your interaction with us and our Sites.
Client personnel
We may collect and process your personal data in connection with the supply of services to you and/or your organization.
Talent
If you supply services and/or content to us and/or work with us to provide services to our clients (including featuring in the content we produce), we may collect or process your personal data, such as your Identity Data, Contact Data, Financial Data, CVs in connection with such supply of services and/or content to us and our clients.
Partner/supplier personnel
If you (or your organization) supply products or services to us or otherwise partner with us, we may collect and process your personal data in connection with our receipt of those products and services and/or partnership. This may include personal data included in any email or telephone communications or recorded on any document relating to an order for the products or services, such as your Contact Data.
Visitors to our offices, studios, production sites
If you attend one of our physical offices or other locations, we may process personal data that you volunteer in connection with your visit and any inquiries you make. For example, you may volunteer personal data when signing in as a guest, or when you register for and access our guest Wi-Fi network at our premises. CCTV footage may also be collected for security purposes.
Event attendees
If you attend one of our events, we will process personal data about you in connection with your attendance at the event. For example, we may ask you to complete a registration or feedback form, or other documents relating to the event.
Job applicants
If you apply for a job with us, whether through the Sites or otherwise, we will collect and process your personal data in connection with your application.
Members of the public
We may process your data in connection with the provision of the Services to our clients.
If you browse our Sites
When you browse our Sites, we collect and process Behavioural Data and Technical Data, including through our use of essential cookies and other similar technologies, to help us understand how you are using and navigating our Sites. We do this so that we can better understand which parts of our Sites are more or less popular and improve the structure and navigation of our Sites.
Our legal basis for processing:
It is necessary for us to use your data to perform our obligations in accordance with any contract that we may have with you for the Services, or it is in our legitimate interest to use data in such a way to ensure that we provide access to our Sites in a secure and effective way.
If you link to social media sites and interact with our social media pages
If you click on one of the social media links on our Sites or otherwise interact with our social media pages such as on YouTube or Vimeo (including interacting with any ‘like’ or similar embedded features on our Sites), we and the relevant social media platform may receive information relating to such interaction and may share your personal data in connection with this purpose. Where that data is collected through your use of our Sites, the data may include certain Behavioural Data and Technical Data. For more information about how we use this personal data, please see the “Website insight and analysis.” section.
The relevant social media platform may also be a controller in respect of the personal data that is collected via your use of our social media pages and may use that personal data for additional purposes. For details of how the relevant social media platform uses your personal data, please see the privacy notice of the relevant social media platform.
Our legal basis for processing:
It is in our legitimate interest to use personal data in the ways described above to ensure that we provide the sites in an effective way and to promote our sites via social media.
WebSite insight and analysis
We and our third-party partners use cookies, web beacons, pixel tags, and other similar technologies (which we generically refer to as “Cookies”) to collect data from the devices that you use to access our Sites. The data that is collected includes Behavioural Data and Technical Data, and certain Profile Data. Please see our Cookie Policy for further information, including details of our third-party partners.
We and our third-party partners use this data to analyze how you use our Sites and our Services and the effectiveness of our Sites and Services, including:
to analyze how you use, and the effectiveness of, our Sites and Services;
to improve our Sites and Services;
to count users who have visited our Sites and collect other types of information, including insights about visitor browsing habits, which helps us to improve our Sites and Services;
to measure the effectiveness of our content;
to learn what parts of our Sites are most attractive to our users, which parts of our Sites are the most interesting and what kind of features and functionalities our visitors like to see;
to help us understand the type of marketing content that is most likely to appeal to our visitors and customers.
Our legal basis for processing
Where your data is collected through the use of non-essential Cookies, we rely on consent to collect your personal data and for the onward processing purpose. Please see our Cookie Policy for further details.
In certain circumstances, we may rely on another lawful basis when we use your personal data collected via the use of Cookies. For example, where we use personal data collected through the use of analytics cookies to analyse how you use our Sites, it is in our legitimate interest to use your personal data in such a way to improve our Sites and Services.
Promotions
We collect or process personal data from individuals who participate in promotions, contests, or giveaways and deliver prizes or notices. Participation in these events and providing personal data is voluntary.
Our legal basis for processing
It is necessary for us to use personal data to perform our obligations in accordance with any contract that we may have (e.g., the promotion terms and conditions) or it is in our legitimate interests (and those of our clients) to process personal data in this way in order to enable individuals to participate in the promotion, contest, or giveaway or we may do so in order to perform an obligation owed to the individual. Where we do this on behalf of our clients as a data processor, we do not require a legal basis for such processing.
Content creation and managing talent.
As part of our content creation services to clients, we maintain talent databases which includes Identity Data, Contact Data, Applicant Data and Publicly Available Data as well as biography and personal preferences of individuals we may use for a particular campaign. We use this information for the purpose of selecting talent for a particular campaign and working with that talent. We may obtain this information directly from the individual, via third party recruiters or agents, or publicly available sources.
As part of creating the content featuring the talent, we will process their Image Data as well as Identity and Applicant Data.
Our legal basis for processing
It is in our legitimate interests (or those of our clients) to process talent personal data in this way to enable us to provide our services.
Where we process special category data in connection with this purpose that was collected from you directly, we will only do so with your explicit consent. Where we obtain this special category from publicly available sources, we will rely on the fact that the individual made such information manifestly public. Where we do this on behalf of our clients as a data processor, we do not require a legal basis for such processing.
Client data insight and analysis.
We may, acting on our own behalf and on behalf of our clients, collect data about you in connection with the provision of our Services to carry out insight and analysis on an anonymized and/or aggregate basis (“Aggregate Data”) in compliance with applicable laws, so that we can improve our Services and help our client to better understand their own customers’ interests and improve their products/ services. The data that is collected includes Behavioural Data, Technical Data, certain Profile Data, and Aggregate Data. GMR will own all rights, titles, and interests in all intellectual property of any user experience research, benchmarking, performance optimization, analytics, or other information derived from the Aggregate Data.
Our legal basis for processing
To the extent the above involves personal data, it is in our legitimate interests (or those of our client) to process personal data in this way to enable us to provide our Services. Where we do this on behalf of our clients as a data processor, we do not require a legal basis for such processing.
Please note that often such services will relate to anonymous data sets (aggregated data sets, statistical data sets, and similar) and are used for high-level market analytics or understanding macro consumer habits (amongst other things). When we do this, we and our clients are not processing personal data.
Surveys and voting
We may collect personal data (including Identity Data, Contact Data, and Profile Data) from individuals via surveys or voting polls for the purposes of obtaining feedback on our own or our clients’ products and surveys. Participation in such polls is voluntary and individuals will have the opportunity to decide whether to disclose personal data. Certain personal data such as Contact Data may be required to register to vote or to take part in a survey. We would only use that information to report the results of the survey or vote.
Our legal basis for processing
It is in our legitimate interests (and those of our clients) to process personal data in this way to provide the Services requested by our clients in an effective and efficient way and to understand how our clients and their products are received in the market. Where we do this on behalf of our clients as a data processor, we do not require a legal basis for such processing.
Social Media
We may collect or process individuals’ personal data (including Contact Data, Identity Data, and some Profile and Publicly Available Data) who engage with us through our social media channels (including by visiting our social media pages or otherwise communicating with us via social media). We may also operate our client’s social media pages, accounts or channels acting on their behalf.
Our legal basis for processing
It is in our legitimate interests to process personal data in this way so that we can market ourselves and engage with the public. Where we carry out this activity on behalf of our clients as a data processor, we do not require a legal basis for such processing.
We will only share personal data with the third-party providers of the Social Platforms so that we can advertise our Services when the individual is using those Platforms, where they have provided their consent]
Events
From time to time, we may organize and host road shows and other industry events to promote our Services or on behalf of clients. For this purpose, we may process data including Identity Data and Contact Data (including email address, postal address, and telephone number) to communicate with them about such events where they have specifically requested information about such events or where we have another lawful basis for sending that information to them.
If you attend one of our events, we may use your personal data to record your attendance at the event and for related record-keeping purposes, and, if relevant, we may collect and process any dietary or other requirements you may have. You may also be featured in photographs taken at our events and such photographs may appear in publications we send to our clients and/or published on our Sites, in print, or in other media.
Our legal basis for processing
It is necessary for us to use personal data in this way to perform our obligations in accordance with any contract that we may have with the individual, or it is in our or our client’s legitimate interest to use personal data in such a way to ensure that we provide our Services in an effective and efficient way.
If we specifically ask your permission to use your photographs, quotes, testimonials, or other content, then our processing of such personal data will be based on consent.
Where we put on events solely at the specific request of our clients we do so in our capacity as our client’s data processor and therefore do not require a legal basis to process personal data.]
Market research and focus groups
As part of our service to our clients, we may collect individual personal data including Identity Data, Contact Data, Registration Data, Preference Data records of communications, health data, opinion data, age range, nationality, image, and education history for the purposes of carrying out market research through focus groups, interviews, and user testing. We may do this on behalf of our clients or for our own purpose.
Our legal basis for processing
It is in our legitimate interests (and those of our clients) to process personal data in this way to ensure that we provide the services requested by our clients in an effective and efficient way. Where we process special category data that was collected from an individual directly in connection with this purpose, we will only do so with the individual’s explicit consent. Where we obtain this information from publicly available sources, we will rely on the fact that the individual made such information manifestly public. Please note where we do this on behalf of our clients as a data processor, we do not require a legal basis for such processing.
Industry Mapping
We collect and maintain databases containing, information about journalists, talent, social media influencers, social media users, and other professionals in the public relations, news, or media industry collected by us or by our trusted third-party media analytics service providers. Such information may include Identity Data, Contact Data, and Publicly Available Data. This information may be information that is voluntarily supplied to us by those individuals through our Site or in other situations (such as public speaking events) or information that is public or available in third-party databases or via third-party content platforms (including social media platforms). Further, we may collect and/or review other publicly available news stories and other journalistic content including content made available through public news sites and social media sites to understand what people are saying about us and our clients. We use this information to provide our services to our clients including ensuring we and our clients are fully up to speed on public opinion in any particular area and are fully briefed when it comes to dealing with the press. We may also use this information to contact those individuals to discuss our clients’ goods and services. We may also use this information for our own internal administrative and promotional purposes.
Our legal basis for processing
It is in our legitimate interests (or those of our clients) to process personal data in this way so that we can provide the services requested by our clients in an effective and efficient way. Where the personal data collected is considered special personal data, we rely on the fact that the personal data has been manifestly made public by individuals to process their personal data. Where we do this on behalf of our clients as a data processor, we do not require a legal basis for such processing.
Marketing
We may use your Identity Data, Contact Data, and Marketing and Communications Data to send you (or the organization you represent) marketing communications by email or via phone. Our marketing will include press releases and information about us.
Our legal basis for processing
It is in our legitimate interest to use your personal data in this way to ensure the promotion of our services is tailored and/or appealing to you and/or the organization you work for. Please note that we will only send you marketing with your consent.
Media and informational inquiries.
We may collect personal data (including Identity Data, Contact Data, and Publicly Available Data) about journalists, client contacts or industry contacts for interview requests, for media questions, or requests for information about GMR. We may also provide individuals with the opportunity to sign up for newsletters or to receive copies of blogs and other information that we make available. Where an individual signs up to receive such information, Contact Data may be requested in each case, together with details of other personal data that is relevant to these inquiries. This information is used in order to enable us to respond to individual requests or media requests.
Our legal basis for processing
It is in our legitimate interests (and those of our clients) to process personal data in this way to ensure we provide the Services requested by our clients in an effective and efficient way and that we provide the right information to those who request it.
Receipt of services
If we have engaged an organization to provide us or our clients with services (for example, IT support or financial advice), we will collect and process your personal data (including Contact and Identity Data) if you are a contact within the relevant organization in order to manage our relationship or our clients with the organization, to receive services from the organization and, where relevant, to provide our services to others including our clients.
Our legal basis for processing
It is necessary for us to use personal data in this way to perform our obligations in accordance with any contract that we may have with the organization, or it is in our legitimate interest to use personal data in such a way to ensure that we have an effective working relationship with the organization and are able to provide our services to others in an effective way. Where we do this on behalf of our clients as a data processor, we do not require a legal basis for such processing.
Recruitment
If individuals apply for a job with us or otherwise express an interest in working for us, we will collect contact details and CV or resume information from the individual. We use such personal data for the following purposes: a) to assess the individual’s suitability for any position for which they applied (or future positions for which we think the individual may be suitable) including employment or freelancer positions, summer placements or internships and also any business support or services role whether such application has been received by us online, via email or by hard copy or in person application; b) to take any steps necessary to enter into any contract of employment (or otherwise) with the individual; c) to comply with any regulatory or legal obligations in relation to any such application; and d) to review our equal opportunity profile in accordance with applicable legislation. We do not discriminate on the grounds of gender, race, ethnic origin, age, religion, sexual orientation, disability, or any other basis covered by local legislation.
Our legal basis for processing
Where we use personal data in connection with recruitment and talent management it will be in connection with us entering into a legal contract with them or it is in our legitimate interest to use personal data in such a way to ensure that we can make the best recruitment and talent management decisions for GMR, or it is our legal obligation to use such personal data to comply with any legal obligations imposed upon us. We will not process any special data except where we are able to do so under applicable legislation or with the individual’s explicit consent.
Visiting our premises, studios, or production sites
If an individual visits any of our premises, studios, and/or production sites we may collect personal data including Identity or Contact Data as part of our sign-in process. We may also capture their image on our surveillance camera or CCTV. We may also collect data relating to Covid-19 vaccination or testing in accordance with government regulation or guidance.
Our legal basis for processing
It is in our legitimate interests to process personal data in this way for security reasons and we collect data relating to Covid-19 in order to comply with our legal obligations in relation to health and safety, or other legal obligations introduced in relation to the Covid-19 pandemic.
Business administration, finance, and legal compliance
We may use an individual’s personal data (including Identity Data, Contact Data, Financial Data, Transaction Data, Publicly Available Data) for the following business administration and legal compliance purposes:
to facilitate the operation or effective management of our group of businesses;
for financial, accounting, and tax purposes;
to comply with our legal obligations;
to enforce or protect our legal rights;
to deal with complaints;
to protect the rights of third parties (including where health or security of an individual is endangered (e.g., a fire); and
in connection with a business transition or sale such as a merger, re-organization, acquisition by another company, or sale of all or a portion of our assets.
Our legal basis for processing
Where we use personal data in connection with a business transition, to enforce our legal rights or to protect the rights of third parties, it is in our legitimate interest to do so. For all other purposes described in this section, we will rely on our obligation to comply with law (including any court order) to process such personal data.
We will not process any special (or sensitive) categories of personal data or personal data relating to criminal convictions or offences except where we are able to do so under applicable legislation or with the individual’s explicit consent.
Where we are required by law to collect your personal data, or we need to collect your personal data under the terms of a contract we have with you, and you fail to provide that personal data when we request it, we may not be able to perform the contract we have or are trying to enter with you. This may apply where you do not provide the personal data, we need in order to provide the Services you have requested from us or to process an application for employment with us. In this case, we may have to cancel your application or the provision of the relevant Services to you, in which case we will notify you.
We only share personal data with others when we are legally permitted to do so. When we share personal data with others, we put contractual arrangements and security mechanisms in place to protect the personal data shared and to comply with our data protection, confidentiality, and security standards and obligations.
We are part of the Omnicom Group of marketing and advertising firms and (subject to the above) may share data within Omnicom Group companies, Omnicom Networks, or with our partner agencies. For more information about the Omnicom Group, please see here: Advertising and Marketing Agencies | Omnicom Group
Further (again subject to the above) we may share your personal data with third parties, as set out in the table below. This list is non-exhaustive and there may be circumstances where we need to share personal data with other third parties.
Our clients
We may share personal data with our clients for the purpose of providing them with Services.
Third-party IT suppliers
We may share personal data with third parties who support us in providing our Sites and help provide, run, and manage our internal IT systems. Such third parties may also include, for example, providers of information technology, cloud-based software-as-a-service providers, identity management, websites design, hosting and management, data analysis, data back-up, security, and storage services. The servers powering and facilitating that cloud infrastructure are located in secure data centres around the world, and personal data may be stored in any one of them. We may also share your personal data with third-party service providers to assist us with insight analytics. These providers are described in our Cookie Policy
Payment providers and banks
We may share personal data with third parties who assist us with our invoicing and/or making/receiving payments.
Third-party post/email marketing and CRM specialists
We may share personal data with specialist suppliers who assist us in managing our marketing database and sending out email marketing communications.
Recruitment agencies and related organizations
We may share personal data with external recruiters, third-party providers that undertake background checks on our behalf, and other entities within our group of companies for recruitment purposes.
Auditors, lawyers, accountants, and other professional advisers
We may share personal data with professional services firms who advise and assist us in relation to the lawful and effective management of our organization and in relation to any disputes we may become involved in.
Law enforcement or other government and regulatory agencies and bodies
We may share personal data with law enforcement or other government and regulatory agencies or other third parties as required by, and in accordance with, applicable law or regulation.
Other third parties
Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, or to establish, exercise or defend legal rights. We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.
Delivery and courier companies
We may share personal data with suppliers who assist us in the delivery of our Services to our clients.
Advertising partners
We may share personal data with third-party advertising partners, including those within the Omnicom Group.
Third-party suppliers who assist us in administering our promotions
We share personal data with specialist suppliers who assist us in administering our prize draws, prize competitions, and other promotions.
Event partners and suppliers
When we run events, we will share your personal data with third-party service providers that are assisting us with the operation and administration of that event. If we are running an event in partnership with other organizations, we will share your personal data with such organizations for use in relation to the event.
Hotel and transport suppliers
We may share your personal data with various hotel and/or transport providers in connection with the provision of our Services.
Production suppliers
When we work on a particular production or otherwise create content, we may share your personal data with our various production and/or content creation suppliers including without limitation production companies, art workers, editors, creatives, post-production houses, venue suppliers, and caterers.
Transfers by us – where we disclose personal data
We may transmit personal data to certain third parties (as listed in the ‘“SHARING YOUR PERSONAL DATA”’ section) that are located in countries that do not protect personal data to the same standard as the GDPR, including to: (1) our different global offices; and (2) our different offices in the Omnicom Group entities, networks or partners agencies.
These countries may not give you the same rights in relation to your personal data and may not have a data protection supervisory authority to help you if you have any concerns about the processing of your personal data.
However, when transferring your personal data, we will ensure that, where required by the GDPR, at least one of the following applies: (1) we will only transfer your personal data to countries or organizations that have been deemed to provide an adequate level of protection for personal data by the UK Government or the European Commission; or (2) we may use specific contracts approved by the UK Government or the European Commission referred to as the “Standard Contractual Clauses” or “SSCs” which give personal data the same protection it has in the UK and EU.
To find out more about the SCCs we use, please see: Standard contractual clauses for international transfers | European Commission (europa.eu) or please email us at [email protected].
In addition, where we disclose personal data that we process in connection with our participation in the EU-U.S. Data Privacy Framework, the UK Extension to that framework, and/or the Swiss-U.S. Data Privacy Framework, we remain liable under those frameworks in relation to our onward transfer of personal data to these countries, unless we can show that we are not responsible for the event giving rise to the damage.
Transfers to us – where we receive personal data
As we are headquartered in Wisconsin, USA, any data that you provide directly to us, or that we receive from third parties, may be stored in the USA. In addition, it may be transferred by us to other countries (as described above).
GMR Marketing LLC complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. GMR Marketing LLC has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. GMR Marketing LLC has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. Please review the Omnicom Data Privacy Framework Privacy Policy for details. GMR Marketing LLC is certified under the Omnicom Data Privacy Framework certification.
If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.
Where our use of your personal data requires your consent, you can provide such consent:
at the time that we collect your personal data following the instructions provided; or
by informing us by e-mail, post, or phone using the contact details set out in this Privacy Notice.
Please note that if you specifically consent to additional uses of your personal data, we may use your personal data in a manner consistent with that consent.
We are committed to keeping the personal data you provide to us secure, and we have implemented information security policies, rules, and technical measures to protect the personal data under our control from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss. In addition, all our employees and data processors (i.e. those who process your personal data on our behalf) are obliged to respect the confidentiality of the personal data of all users of our Sites and those who purchase our Services.
You have the following rights in relation to the personal data we hold about you under certain circumstances:
To obtain the confirmation that we process personal data about you, to access and obtain copies of the information, as well as information relating to the processing we carry out.
To request your personal data be corrected where appropriate.
If personal data we hold about you is inaccurate or incomplete, you may request that data be amended. However, please be aware that it is every person’s responsibility to provide us with accurate personal data and to inform us of any changes (e.g., new home address or change of name).
To request your personal data be deleted, where appropriate.
If you demonstrate that the purpose for which the personal data is being processed is no longer legal or appropriate, the data will be deleted, unless we can demonstrate that we are required to retain the personal data by applicable law or otherwise.
If we have shared your personal data with others, we will let them know about the deletion where possible. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal information with so that you can contact them directly.
To request that we restrict the processing of your personal data in some circumstances, such as where you contest the accuracy of the personal data, while we investigate your concern.
It will not prevent us from storing your personal information.
We will tell you before we lift any restriction.
If we have shared your personal information with others, we will let them know about the restriction where it is possible for us to do so.
If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal information with so that you can contact them directly.
Where processing is based on your consent, to receive your personal data in a commonly used electronic format, or ask that we move your personal data in that format to another provider, where your request relates to the personal data that you gave us directly and where technically possible.
To object to your personal data being processed where we are relying on ours or a third party’s legitimate interest to do so or for the purpose of direct marketing.
To withdraw your consent at any time when processing relies upon consent.
Data Subject Rights
Data subjects may exercise these rights verbally or in writing using our contact information provided in the section “HOW TO CONTACT US”. We will endeavour to promptly respond to your requests. Where you ask us to provide a copy of your personal data, we are legally obliged to respond within one month of such request. If your request is denied, we will inform you about the reasons for denial.
Please note that for you to assert these rights, we may need to verify your identity to confirm your right to access your personal data. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. In order to verify your identity, we may need to gather more personal data from you than we currently have.
Lodging complaints
In addition, you may have the right to lodge certain complaints in relation to our processing of your personal data with regulators in your jurisdiction.
If you have a concern about any aspect of our privacy practices, including the way we have handled your personal data, we encourage you to first contact us using our contact information provided in the “HOW TO CONTACT US” section.
If the GDPR applies, you can report your concerns to the following organizations:
European Economic Area
You can find a list of supervisory authorities and their contact details for the EEA at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm
United Kingdom
The Information Commissioner’s Office (“ICO”) is the supervisory authority in the United Kingdom. Contact details for the ICO can be found at https://ico.org.uk.
Switzerland
The Federal Data Protection and Information Commissioner (“FDPIC”) is the supervisory authority in Switzerland. Contact details for the FDPIC can be found at https://www.edoeb.admin.ch/.
United States of America
In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF,GMR Marketing LLC commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF to JAMS, an alternative dispute resolution provider based in the United States.
If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://www.jamsadr.com/dpf-dispute-resolution for more information or to file a complaint. The services of JAMS are provided at no cost to you.
Following the dispute resolution process, JAMS or you may refer the matter to the U.S. Federal Trade Commission, which has investigatory and enforcement powers over us. Under certain circumstances, you also may be able to invoke binding arbitration to address complaints about our compliance with DPF Principles.
To opt out of any future promotional or marketing communications or any other commercial communications from us, you should send a request to us at the contact information in the “HOW TO CONTACT US” section.
The Sites contain links to third-party websites and services. Please remember that when you use a link to go from our Sites to another website or you request a service from a third party, this Privacy Notice no longer applies to these third-party websites and third-party service providers unless we are acting as joint controllers in respect of your personal data with such third party.
Your browsing and interaction on any other websites, or your dealings with any other third-party service provider is subject to that websites’s or third-party service provider’s own rules and policies. We do not monitor, control, or endorse the privacy practices of any third parties.
The Sites may integrate with social networking services. You understand that we do not control such services and are not liable for the manner in which they operate. While we may provide you with the ability to use such services in connection with our Sites, we are doing so merely as an accommodation and, like you, are relying upon those third-party services to operate properly and fairly.
We retain personal data only for as long as is necessary for the purposes described in this Privacy Notice, after which it is deleted from our systems.
If any personal data is only useful for a short period (e.g., for a specific event or marketing campaign or in relation to recruitment), we will delete it at the end of that period. Please note that if you are an unsuccessful candidate, we may keep your information for a short period.
If you have opted out of receiving marketing communications from us, we will need to retain certain personal data on a suppression list so that we know not to send you further marketing communications in the future.
Our Sites are not intended for use by, or targeted at, minors (individuals under the age of 18) and we do not knowingly collect personal data of minors. However, due to the nature of our organization and the Services we provide, we may from time to time collect and process personal data relating to minors. If we do collect personal data of minors, we will comply with all applicable laws and regulations relating to the processing of personal data of minors.