Privacy Policy

YOUR USE OF OUR SITES AND APPLICATIONS IS SUBJECT TO YOUR AGREEMENT TO THE TERMS OF THIS PRIVACY POLICY. Rubenstein Public Relations, Inc. (“we”, “us”, “our”) respects your privacy and is committed to protecting the personal information that you may provide while using our Site, and Applications (as defined below). We are committed to protecting your privacy. This Privacy Policy provides you with details on the information we collect from you and the uses we make of your personal information. If you do not want us accessing and/or using your personal information as described herein, please do not provide us with any personal information. This Privacy Policy may be updated from time to time without prior notice. If you continue to use our Sites and Applications, you hereby provide your consent to the updates.

We encourage you to read this Privacy Policy to learn more about what personal information of yours we collect, how we use that personal information, and how you can “opt-out” of receiving further communications from us. Additionally, this Privacy Policy includes information about how we endeavor to protect your personal information. If you have any questions about this Privacy Policy, please contact us.

If you are a California consumer and would like information about our online and offline privacy practices and your privacy rights, please see the section of this Privacy Policy called “California Consumer Privacy Statement.”


PURPOSE OF THIS POLICY

This privacy policy (“Policy”) explains our approach to any personal information that we might collect from you using this website (the “Site”) and in other situations or interactions with us, as well as the purposes for which we process your personal information. This Policy also sets out your rights in respect of our processing of your personal information.

This Policy will inform you of the nature of the personal information about you that is processed by us and how you can request that we delete, update, transfer and/or provide you with access to it or otherwise cease processing it for a specific purpose. This Policy is intended to assist you in making informed decisions when using this Site.

This privacy notice is not intended to apply to the processing of personal information of Rubenstein Public Relations, Inc. employees which is dealt with under our separate workplace privacy policy.

We respect your concerns about privacy. We participate in the EU-U.S. Privacy Shield framework (“Privacy Shield”) issued by the U.S. Department of Commerce. We commit to comply with the Privacy Shield Principles with respect to any personal information that we receive from the European Union.


TYPE OF PERSONAL INFORMATION COLLECTED

Personal information is information that identifies you as an individual. Categories of personal information we collect include:

  • contact information (e.g.name, physical address, telephone number, email address),
  • information about your interests or affiliations,
  • information for hiring and human resources (e.g. employment and education history, work eligibility status, date of birth, financial account information, government-issued identification information), and
  • additional information you submit to us.
 

Additional information about the personal information we collect is described in the next section HOW WE USE PERSONAL INFORMATION below.

We may collect and receive your personal information using different methods:

Personal information you provide to us. You may give us your personal information directly. This will be the case when, for example, you contact us with enquiries, complete forms on our Site or in hard copy or participate in a survey, subscribe to receive our marketing communications or provide feedback to us otherwise through your interactions with us.

Personal information received from third parties. From time to time, we will receive personal information about you from third parties. Such third parties may include analytics providers, payment providers, hotel and transport providers and third parties that provide technical services to us so that we can operate our Site and provide our services.

Publicly  available Personal information. From time to time we may collect personal information about you from publicly available sources or media reports or personal information about you that you or a third party may make publicly available to us (for example through speaking at events or publishing articles or other news stories).


HOW WE USE PERSONAL INFORMATION

Our primary goal in collecting personal information from you is to:

  • verify your identity,
  • provide our services to clients;
  • help us improve our products and services and develop and market new products and services,
  • carry out requests made by you to us,
  • investigate or settle inquiries or disputes,
  • comply with any applicable law, court order, other judicial process, or the requirements of a regulator,
  • enforce our agreements with you,
  • protect the rights, property or safety of us or third parties, including our other clients and users  of the Site,
  • provide support for the provision of our Services, and
  • use  as otherwise required or permitted by law.


USES OF PERSONAL INFORMATION COLLECTED

The following describes how we use personal information that we collect through this Site:

  • Client information.
    • Information we collect with respect to our clients and potential clients is used to enable us to respond to client requests, to administer client accounts with us, to conduct credit checks, and to verify and carry out financial transactions for payments made to us.
  • Media and informational inquiries.
    • We may collect information for interviews requests, for media questions, or requests for information about our company. We may also provide you with the opportunity to sign up for newsletters or to receive copies of blogs and other information that we make available. Contact information may be requested in each case, together with details of other personal information that is relevant to these inquiries. This information is used in order to enable us to respond to your requests or media requests.
  • Career Opportunities.


INFORMATION COLLECTED; SHARING OF INFORMATION

Personally Identifiable Information. If you contact us, we may keep a record of that correspondence. We may collect personally identifiable information (“Personal Information”) such as your name, address, telephone number, and e-mail address from you. Personal Information is collected via voluntary submissions from you such as but not limited to those pertaining to your registration on our site and interaction on our social media applications, and Sites and Applications inquiries both online and offline. If you choose to submit content to public areas of our Sites and Applications, your content will be considered “public” and will not be subject to the privacy protections set forth herein or any applicable law, rule or regulation. We encourage you to exercise caution when making decisions about what information you disclose in such public areas. Furthermore, except as otherwise described in this Privacy Policy, any content you post to a public area of our Sites and Applications may be used by us for any purpose. Your Personal Information may be used by us (i) to process your registration to the Sites and Applications and any entries to promotions as well as inquiries via the Sites and Applications; (ii) to communicate with you and receive feedback; (iii) to fulfill requests and notify you of new Sites and Applications or upgrades to our Sites and Applications; and (iv) as required by applicable laws, rules or regulations, or any policies applicable to this Sites and Applications. We may share your Personal Information with third parties to further the purpose for which you provided such information to us, for example, in order to fulfill a prize, purchase, or confirm eligibility. We also share your Personal Information with third parties if we believe that the law requires us to do, or to protect our own property or the property of our affiliates. Additionally, in the event of a corporate restructuring (such as, a sale, merger or other asset transfer), we may share your Personal Information with a third party. 


NON-PERSONALLY IDENTIFYING INFORMATION

We may collect certain general, aggregated, demographic and non-personally identifiable information (“Non-Personal Information”) about our visitors by the standard operation of our Internet servers and through the use of “cookies”. A “cookie” is a small amount of data sent to your browser from a web server and stored by your computer. Generally, cookies are used to enable us to deliver to you a better and more personalized service, assist us in tracking visits to the Sites and Applications and to measure visitor patterns. The information we collect through the use of cookies is not personally identifiable and is used by us only to improve the Sites and Applications. We do not use cookies to retrieve Personal Information from your computer, or use cookies to retrieve other information from your computer for purposes that are unrelated to your interaction with the Sites and Applications. We reserve the right to disclose or utilize any of this information in aggregate form, for any purpose, in our sole judgment. The Non-Personal Information we collect may include information that you have provided to us through surveys, polls, etc., but will not be tied to any personal information, without your consent. This information is used by us to improve the content of our Sites and Applications and enhance your experience. Third party advertisers that serve ads on the Sites and Applications may also use their own cookies. By modifying your browser preferences, you can accept or reject all cookies. If you choose to reject all cookies, you will not be able to access the portions of the Sites and Applications that require you to register with the Sites and Applications, including without limitation any promotions in connection therewith. In order to create a better electronic community, we may keep track of patterns of use in the emails we send out. We note which links are clicked in our e-mail communications as specific user profile information to tell us what areas are of most interest to our email recipients. We may use this information to better personalize the content and promotions that visitors and mail recipients will see in our mailings. You may have certain rights under the Communications Act, Federal Trade Commission Act, and other state and federal statutes that may apply, and by accepting the terms of this Privacy Policy and using the Sites and Applications, including by entering any promotion, you are waiving all of these rights as to collection, use, disclosure and storage of your Personal Information and Non-Personal Information collected by us. 


USE OF INFORMATION

Personal information which we collect for a particular purpose will be saved and used for that purpose, unless you have agreed to allow us to use it for some other purpose, as described in this Privacy Policy. We may disclose any of your personal information to law enforcement or other appropriate third parties in connection with criminal investigations, investigation of fraud, infringement of intellectual property rights, or other suspected illegal activities, or as otherwise may be required by applicable law, or, as we deem necessary in our sole discretion, in order to protect our legitimate legal and business interests. We may use the information we collect from you for the purpose of providing you with technical support, customer service, and account maintenance. We use the information we collect to learn what you like, tailor your experience accordingly, and to improve our Sites and Applications. We will sometimes send promotional or community e-mail to our members and to the general public who want to receive e-mail from us. We sometimes share general, demographic, or aggregated (not personal) information with third parties about our user base, but that information does not include any personal information. You will be deemed to have consented to the disclosure to, and use by, a subsequent owner or operator of the Sites and Applications, of any personal information contained in the our database for such site, if we assigns all of our rights and obligations regarding the use of your personal information at the time of a bankruptcy, merger, acquisition, sale of all or substantially all of our assets to a subsequent owner or operator, or similar event.


PROTECTION FOR CHILDREN AND MINORS

The Sites and Applications are not intended for, and we have no intention of collecting personally identifiable information from persons under the age of 13. If we have knowledge that a person under the age of 13 has provided us with Personal Information, we will use all reasonable efforts to delete such Personal Information from our database. If you are under the age of 13, you are not authorized to access or submit any content or information, including Personal Information, to the Sites and Applications. If you are under the age of 18, including those children under the age of 13, you are not authorized to access or submit any content or information to the Sites and Applications.


OPT-OUT

If you do not want to receive email from us in the future, please send an email to us at the address below requesting to be removed from our e-mail list. You will also have the option of clicking on a link included in email correspondence you receive from us in order to remove yourself from our mailing list.

Email Contact Please note that there might be a brief delay between when you submit your request to “opt-out” and when it is processed and reflected in our systems; accordingly you may continue to receive communications from us for a limited time after you submit your request. We appreciate your patience.


SECURITY

We are committed to using our best efforts to maintaining the security of your Personal Information. To prevent unauthorized access, maintain data accuracy, and ensure the appropriate use of your Personal Information, we adhere to industry standard practices and procedures to help safeguard and secure the Personal Information we collect from you. Although we use our best efforts to protect the security of your Personal Information and our system, due to the inherently open nature of the Internet, no transmission via the Internet can be guaranteed to be 100% secure. As a result of this and other factors beyond our control, we cannot guarantee the security of the information that you transmit to or through our Sites and Applications. Therefore, by accepting the terms of this Privacy Policy (including as updated) and using the Sites and Applications, including by entering any promotions in connection therewith, you hereby agree to assume all risk relating to the security of that information by using the Sites and Applications. 


JURISDICTION

Our computer systems are currently based in the United States, so your personal data will be processed by us in the United States where data protection and privacy regulations may not offer the same level of protection as in other parts of the world, such as the European Union. If you create a user account with the Site as a visitor from outside the United States, by using the Site, you agree to this Privacy Policy and you consent to the transfer of all such information to the United States, which may not offer an equivalent level of protection of that required in the European Union or certain other countries, and to the processing of that information as described in this Privacy Policy.

 

LINKS TO OTHER WEBSITES

The Sites and Applications may contain links to other websites for the purchase of products and Sites and Applications. Please be aware that we are not responsible for such other websites in any manner including without limitation, the privacy practices of other websites. We encourage you to be aware when you access any such links to other sites and to read the privacy policies of each website that you access. This Privacy Policy applies only to information collected by us by the Sites and Applications. 


OFFERS AND PROMOTIONS

We may from time to time offer you opportunities that are sponsored or co-branded with third parties. Such content may include contests, sweepstakes or promotions. In connection with such opportunities, the relevant third parties may obtain Personal Information that you voluntarily submit to participate in such opportunity. We have no control over these third parties’ use of such information. 


HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?

We retain personal information only for as long as is necessary for the purposes described in this Policy, after which it is deleted from our systems.

Regarding personal information we have processed in connection with the supply of our services to clients, we may retain personal information relevant to our services for up to five years from the date of supply and in compliance with our obligations under the EU General Data Protection Regulation (or similar legislation around the world). We may then destroy such files without further notice or liability.

Regarding any other personal information we have processed, we may retain relevant personal information for up to three years from the date of our last interaction with the relevant individual and in compliance with our obligations under the EU General Data Protection Regulation (or similar legislation around the world). We may then destroy such files without further notice or liability.

If any personal information is only useful for a short period (e.g. for a specific event or marketing campaign or in relation to recruitment), we may delete it at the end of that period.

If you have opted out of receiving marketing communications from us, we will need to retain certain personal information on a suppression list indefinitely so that we know not to send you further marketing communications in the future.


RECOURSE ENFORCEMENT AND LIABILITY

We are subject to the investigatory and enforcement powers of the Federal Trade Commission. We have mechanisms in place designed to effect compliance with the Privacy Shield Principles. We conduct an annual self-assessment of personal information handling practices to verify that the attestations and assertions we make about our Privacy Shield privacy practices are true and that such privacy practices have been implemented as represented and in accordance with the Privacy Shield Principles.

Consumer Recourse: You may file a complaint concerning our processing of your personal information. We will take steps to remedy issues arising out of any alleged failure to comply with the Privacy Shield Principles. You may contact us as specified below about complaints regarding our personal information handling practices.


CALIFORNIA CONSUMER PRIVACY STATEMENT

Effective: August 2020

This California Consumer Privacy Statement supplements the Rubenstein Public Relations (General) and applies solely to California consumers. This section provides information about our online and offline privacy practices. This Statement does not apply to our personnel.

This California Consumer Privacy Statement uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 and its implementing regulations (the “CCPA”).

1.   Notice of Collection and Use of Personal Information

We may collect the following categories of personal information about you:

· Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, account name, Social Security number, driver’s license number, passport number, and other similar identifiers

  • Additional Data Subject to Cal. Civ. Code § 1798.80: signature, physical characteristics or description, state identification card number, insurance policy number, education, bank account number, credit card number, debit card number, and other financial information, medical information, and health insurance information
  • Protected Classifications: characteristics of protected classifications under California or federal law, such as race, color, national origin, religion, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, medical condition, ancestry, genetic information, disability, citizenship status, and military and veteran status
  • Commercial Information: commercial information, including records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies
  • Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements
  • Geolocation Data
  • Sensory Information: audio, electronic, visual, and similar information
  • Employment Information: professional or employment-related information.
  • Education Information: education information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99)
  • Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.\

We may use the categories of personal information listed above for the purposes described in our Privacy Policy (General). In addition, we may use these categories of personal information for certain business purposes specified in the CCPA, as described in this table:


Purposes

Categories of Personal Information

Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services

[Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]

Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, and auditing compliance

[Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]

Short-term, transient use

[Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]

Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity

[Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]

Debugging to identify and repair errors that impair existing intended functionality

[Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]

Undertaking internal research for technological development and demonstration

[Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]

Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us

[Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]

In addition, we may also use the following categories of personal information for purposes of managing our career opportunities: [Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]

2.       Our Prior Collection, Use and Disclosure of Personal Information

We may have collected and used your personal information, as described in section 1 above, during the 12-month period prior to the effective date of this California Consumer Privacy Statement. For the personal information collected during that timeframe, we describe below: (a) the categories of sources from which we may have obtained the personal information, (b) the categories of third parties with whom we may have shared the information, and (c) the categories of personal information we may have disclosed for a business purpose.

1.        a.       Sources of Personal Information

We may have obtained personal information about you from various sources, as described below.


Categories of Sources of Data Collection

Categories of Personal Information

Directly from you, such as when you contact us with a question or comment

[Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]

From your devices, such as when you visit our Site

[Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]

Your family or friends, such as when they provide us with your contact information so we can send information that may interest you

[Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]

Our affiliates and subsidiaries

[Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]

Vendors who provide services on our behalf

[Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]

Social networks

[Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]

Government entities

[Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]

Consumer data resellers

[Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]


1.        b.      Sharing of Personal Information

We may have shared your personal information with certain categories of third parties, as described below.


Categories of Third Parties

Categories of Personal Information

Our affiliates and subsidiaries

[Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]

Vendors who provide services on our behalf

[Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]

Professional services organizations, such as auditors and law firms

[Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]

Our business partners

[Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]

Internet service providers

[Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]

Data analytics providers

[Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]

Government entities

[Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]

Operating systems and platforms

[Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]

Social networks

[Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]

Consumer data resellers

[Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]


1.        c.       Disclosure of Personal Information for a Business Purpose

We may have disclosed to third parties the following categories of personal information for a business purpose:

  •  Identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, account name, Social Security number, driver’s license number, passport number, and other similar identifiers
  • Signature, physical characteristics or description, state identification card number, insurance policy number, education, bank account number, credit card number, debit card number, and other financial information, medical information, and health insurance information
  • Characteristics of protected classifications under California or federal law, such as race, color, national origin, religion, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, medical condition, ancestry, genetic information, disability, citizenship status, and military and veteran status
  • Commercial information, including records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies
  • Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements
  • Geolocation Data
  • Audio, electronic, visual, and similar information
  • Professional or employment-related information
  • Education information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99)
  • Inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

3.       California Consumer Privacy Rights

You have certain choices regarding our use and disclosure of your personal information, as described below.

Access: You may have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed and sold about you during the past 12 months.

Deletion: You have the right to request that we delete certain personal information we have collected from you.

We do not sell, and have not sold in the previous 12 months, consumers’ personal information.

How to Submit a Request: To submit an access or deletion request, click here or call us at 1-800-306-7508.

Verifying Requests: To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request If you request access to or deletion of your personal information, we may require you to provide us with information about you to verify your identity. The type of information that we ask for may vary depending on the type and sensitivity of the personal information we hold about you or that you request. If additional information is required to verify your request, we may contact you to provide us with that information before responding to your request for access or deletion. In addition, if you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. If you designate an authorized agent to make an access, deletion or opt-out of sale request on your behalf (1) we may require you to provide the authorized agent written permission to do so, and (2) for access and deletion requests, we may require you to verify your own identity directly with us (as described above).

Additional Information: If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request. This Statement is available in alternative formats upon request. Please contact privacy@omnicomprgroup.com to request this Statement in an alternative format.

In addition, we may also use the following categories of personal information for purposes of managing our career opportunities: [Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences]

2.       Our Prior Collection, Use and Disclosure of Personal Information

We may have collected and used your personal information, as described in section 1 above, during the 12-month period prior to the effective date of this California Consumer Privacy Statement. For the personal information collected during that timeframe, we describe below: (a) the categories of sources from which we may have obtained the personal information, (b) the categories of third parties with whom we may have shared the information, and (c) the categories of personal information we may have disclosed for a business purpose.

a.       Sources of Personal Information

We may have obtained personal information about you from various sources, as described below.   

b. Sharing of Personal Information

We may have shared your personal information with certain categories of third parties, as described below.

c. Disclosure of Personal Information for a Business Purpose

We may have disclosed to third parties the following categories of personal information for a business purpose:

Identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, account name, Social Security number, driver’s license number, passport number, and other similar identifiers

· Signature, physical characteristics or description, state identification card number, insurance policy number, education, bank account number, credit card number, debit card number, and other financial information, medical information, and health insurance information

  •  Characteristics of protected classifications under California or federal law, such as race, color, national origin, religion, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, medical condition, ancestry, genetic information, disability, citizenship status, and military and veteran status
  • Commercial information, including records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies
  • Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements
  • Geolocation Data
  • Audio, electronic, visual, and similar information
  • Professional or employment-related information
  • Education information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99)
  • Inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

3.  California Consumer Privacy Rights

You have certain choices regarding our use and disclosure of your personal information, as described below.

Access: You may have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed and sold about you during the past 12 months.

Deletion: You have the right to request that we delete certain personal information we have collected from you.

We do not sell, and have not sold in the previous 12 months, consumers’ personal information.

How to Submit a Request: To submit an access or deletion request, click here or call us at 1-800-306-7508.

Verifying Requests: To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request If you request access to or deletion of your personal information, we may require you to provide us with information about you to verify your identity. The type of information that we ask for may vary depending on the type and sensitivity of the personal information we hold about you or that you request. If additional information is required to verify your request, we may contact you to provide us with that information before responding to your request for access or deletion. In addition, if you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. If you designate an authorized agent to make an access, deletion or opt-out of sale request on your behalf (1) we may require you to provide the authorized agent written permission to do so, and (2) for access and deletion requests, we may require you to verify your own identity directly with us (as described above).

Additional Information: If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request. This Statement is available in alternative formats upon request. Please contact privacy@omnicomprgroup.com to request this Statement in an alternative format.


CONTACT US

If you have any questions, comments or concerns regarding this Privacy Policy and/or the practices described herein, please email us at privacy@rubensteinpr.com. 

To ask questions or express concerns about our collection, management and processing of personal information, Consumers may by contact us by:

  • sending an e-mail to privacy@rubensteinpr.com; or
  • sending us a letter:

Attn: General Counsel

Rubenstein Public Relations, Inc.

1301 Avenue of the Americas

New York, NY 10019


MISCELLANEOUS

This Privacy Policy and our legal obligations hereunder are subject to the laws of New York, New York, U.S.A., regardless of your location. You hereby consent to the exclusive jurisdiction of and venue in the federal and state courts located in New York County, New York, New York, U.S.A. in all disputes arising out of or relating to this Privacy Policy and/or the Sites and Applications. Our performance under this Privacy Policy is subject to existing laws and legal process, and nothing contained in this Privacy Policy is in derogation of our right to comply with governmental, court and law enforcement requests or requirements relating to your use of the Sites and Applications or information provided to or gathered by us with respect to such use. If any part of this Privacy Policy is determined to be invalid or unenforceable pursuant to applicable law, then the invalid or unenforceable provision will be deemed superseded by a valid, enforceable provision that most closely matches the intent of the original provision, and the remainder of this Privacy Policy shall continue in full force and effect.  Your use of the Sites and Applications is also governed by, and subject to, all the provisions of the Terms of Use (Link to Terms of Use). By accepting the terms of this Privacy Policy (including as updated) and using the Sites and Applications, you hereby agree to be bound by all the provisions contained in the Terms of Use and all the provisions contained in this Privacy Policy.  This Privacy Policy was last updated on March 1, 2021.