HOTWIRE PUBLIC RELATIONS LIMITED
PRIVACY AND COOKIES POLICY

Effective: February 4th, 2020

As the operators of the website (“Website”), Hotwire Public Relations Limited (“We“, “our”, “Us”) is committed to protecting and respecting your privacy. This Privacy and Cookies Policy (“Policy”) (together with and any other documents referred to therein) sets out the basis on which the personal data collected from you, or that you provide to Us will be processed by Us. Please read the following carefully to understand our views and practices regarding your personal data and how We will treat it.

For the purpose of the General Data Protection Regulation (“GDPR”, from the GDPR implementation date) or, until GDPR implementation date, the Data Protection Act 1998, (collectively the “Data Protection Laws”) the Data Controller is Hotwire Public Relations Limited, Hotwire Public Relations Group LLC, Hotwire Public Relations Germany GmbH, Hotwire Public Relations France SARL, Hotwire Public Relations Spain SL, Hotwire Public Relations Italy Srl and Hotwire Australia Pty Ltd.

YOUR PERSONAL INFORMATION

Information we collect from you

We collect and process some or all of the following types of information from you in the course of your use of the website and/or providing our services:

  • Information that you provide by filling in forms on the Website or filing in forms as part of any registration process. This includes information provided at the time of registering to use the Website, subscribing to a component of our services, or requesting further information or using or accessing our services. We may also ask you for information when you report a problem with the Website.
  • Specifically, personal details such as name, email address, postal address, date of birth or any information input by when using the Website or using or accessing our services.
  • If you contact Us, We may keep a record of that correspondence.
  • We may also ask you to complete surveys that We use for research purposes, although you do not have to respond to them.
  • Details of your visits to the Website including, but not limited to, traffic data, location data, weblogs and other communication data, and the resources that you access.

The provision of certain personal data may be required from you to enable Us to provide you use or access of our services. We will inform you at the point of collecting information from you, whether you are required to provide the information to Us.

Information We Collect From Other Sources

We will also obtain personal data from other sources as follows:

  • Publicly available listings including but not limited to:
    • Trade show attendee listings / directories
    • Press release contact details / other publicly published contact information
    • LinkedIn or other directory listings
    • External websites

USES MADE OF YOUR INFORMATION

Lawful basis for processing

We rely on the following lawful basis for processing:

  • your consent as provided when you sign up to using our services on our website.
  • to fulfil our contractual obligations to You.
  • to fulfil our legal obligations.
  • certain legitimate business purposes which may include some or all of the following:
    • for direct marketing purposes;
    • where it is necessary to protect Your vital interests;
    • We are transferring between different parts of the organisational group for internal administrative purposes;
    • Where there is a direct appropriate relationship, such as where You or your employer is a client;
    • We have a reasonable expectation that You consent to your data being processed; or
    • processing for the purposes of ensuring network and information security, including preventing unauthorised access to electronic communications networks and stopping damage to computer and electronic communication systems.

Purposes of processing

We use information held about you in the following ways:

  • To provide you with our services.
  • To ensure that content on the Website is presented in the most effective manner for you and for the device(s) you use to access and view the Website;
  • To provide you with information and offers that you request from Us or which We feel may interest you.
  • To carry out our obligations arising from any contracts entered into between you and Us.
  • To allow you to participate in interactive features of our service, when you choose to do so.
  • To notify you about changes to our service.
  • To provide you with information that will help you select us as a possible partner for your future integrated communications needs.

Marketing

In addition to the above uses We may use your information (and, where you have consented, permit selected third parties to use your information), to notify you about goods or services which may be of interest to you. Where We do this, We will contact you by electronic means (e-mail or SMS) only if you have consented to such communication. If you do not want Us to use your data in this way please either (i) tick the relevant box situated on the form on which We collect your data (for example, the registration form); (ii) unsubscribe from our electronic communications using the method indicated in the relevant communication; or (iii) inform Us at any time by contacting Us at the contact details set out below.

Industry Information

We maintain databases and lists of publicly available information regarding media contacts, journalists, social media influencers, social media users, subject matter experts and other stakeholders and individuals who make their personal and/or professional information and/or opinions publicly available. These lists are accessed and/or used by us for specific business purposes in conducting its own business and in conducting business on behalf of potential and existing clients. We take reasonable measures to limit the information processed to be relevant to legitimate business purposes and to minimize any risks to individuals associated with the use of such information.

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.

DISCLOSURE OF YOUR INFORMATION

We may pass your personal information to our third party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf, for example to host our servers.

We may share your Personal Data with third party service providers to:

  • provide you with the services that we offer you through the Site;
  • to conduct quality assurance testing;
  • to conduct business on your behalf;
  • to facilitate creation of Accounts;
  • to provide technical support; and/or
  • to provide other services to us.

For example, the personal information we may send contains your email address, phone number, company name and full name to a publication or media outlet as it applies to our services.

These third-party service providers are required not to use your Personal Data other than to provide the services requested by us.

We may disclose your personal data to any member of our corporate group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006 (where applicable).

We may also disclose your personal data to third parties:

  • in the event that We sell or buy any business or assets, in which case We may disclose your personal data to the prospective seller or buyer of such business or assets; or
  • if We or substantially all of our assets are acquired by a third party, in which case personal data held by Us about our customers will be one of the transferred assets; or
  • if We are under a duty to disclose or share your personal data in order to comply with any legal obligation; or
  • Where we are required to respond to lawful requests by public authorities, including to meet national security or law enforcement requirements; or
  • to protect Our rights, property, or safety or that of our affiliated entities and our users and any third party We interact with the to provide the Website; or
  • in relation to selected third parties only, only to the extent that you have consented to such selected third parties notifying you about certain goods or services, which may be if interest to you.

Other than as set out above, and save insofar as is necessary in order for Us to carry out our obligations arising from any contracts entered into between you and Us, We will not share your data with third parties unless We have procured your express consent to do so.

Hotwire Public Relations Group LLC

STORING YOUR PERSONAL DATA

Security

We take appropriate measures to ensure that any personal data are kept secure, including security measures to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. Where We process payment transactions, these will be encrypted using SSL technology. Where We have given you (or where you have chosen) a password which enables you to access certain parts of the Website or any website we host, you are responsible for keeping this password confidential.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where We are legally required to do so.

Unfortunately, the transmission of information via the internet is not completely secure. Although We will do our best to protect your personal data, We cannot guarantee the security of your data transmitted to the Website; any transmission is at your own risk. Once We have received your information, We will use strict procedures and security features to try to prevent unauthorised access.

The Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and terms of use and that we do not accept any responsibility or liability for these policies and terms of use. Please check these policies before you submit any personal data to these websites.

Keeping your personal data up to date

If your personal details change you may update them by contacting Us using the contact details below. If you have any questions about how We use data collected which relates to you, please contact Us by sending a request by email to the contact details below.

We will endeavour to update your personal data within seven (7) working days of any new or updated personal data being provided to Us, in order to ensure that the personal data We hold about you is as accurate and up to date as possible.

How long we keep your personal data

The time periods for which we retain your personal data is dependent upon the purposes for which we use it. We will retain it for as long as you are a registered subscriber or user of our services or for as long as we have another business purpose to do so. Thereafter, for no longer than is required or permitted by law, by our Retention Policy, reasonably necessary for internal reporting and reconciliation purposes, or to provide you with feedback or information you might request.

Where we store your personal data

All information We hold about you is stored on our secure servers within the EEA.

The data that We collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”), or the United KingdomIt may also be processed by staff operating outside the EEA who work for Us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your orders, the processing of your payment details and the provision of support services.

Such countries do not have the same data protection laws as the United Kingdom, and the EEA . Whilst the European Commission has not given a formal decision that such countries provide an adequate level of data protection similar to those which apply in the United Kingdom and EEA, any transfer of your personal data will be subject to EU-U.S. Privacy Shield or under a European Commission approved contract or through a series of intercompany agreements based on the Standard Contractual Clauses authorized under the EU Data Protection Directive 95/46/EC and (as permitted under Article 46(5) of the General Data Protection Regulation that are designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal data.

If you would like further information please contact Us OR our Data Protection Officer (see ‘Contact’ below). We will not otherwise transfer your personal data outside of the United Kingdom OR EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.

YOUR RIGHTS

Under the General Data Protection Regulation, you have a number of important rights free of charge. In summary, those include rights to:

  • access to your personal data and to certain other supplementary information that this Policy is already designed to address
  • require Us to correct any mistakes in your information which We hold
  • require the erasure of personal data concerning you in certain situations
  • receive the personal data concerning you which you have provided to Us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
  • object at any time to processing of personal data concerning you for direct marketing
  • object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
  • object in certain other situations to our continued processing of your personal data
  • otherwise restrict our processing of your personal data in certain circumstances
  • claim compensation for damages caused by our breach of any data protection laws.

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please:

  • email, call or write to Us OR Catherine Hoyle our Data Protection Officer;
  • let Us have enough information to identify you, for example your name, employer, or registration details;
  • let Us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
  • let Us know the information to which your request relates, including any client account or reference numbers, if you have them.

HOW TO COMPLAIN

We hope that We or our Data Protection Officer can resolve any query or concern you raise about our use of your information.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. A list of Supervisory Authorities is available here:  https://edpb.europa.eu/about-edpb/board/members_en

The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.

EU-US PRIVACY SHIELD

Hotwire Public Relations Group, LLC complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries, and the United Kingdom transferred to the United States pursuant to Privacy Shield. (For purposes of this Privacy Shield section only, “We“, “our”, “Us” refers exclusively to our US entity, Hotwire Public Relations Group, LLC). Hotwire Public Relations Group, LLC has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Hotwire Public Relations Group, LLC is subject to the regulatory and enforcement powers of the U.S. Federal Trade Commission.

Pursuant to the Privacy Shield Frameworks, EU, and UK individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to gdpr@enero.com. If requested to remove data, we will respond within a reasonable timeframe.

We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to gdpr@enero.com.

In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Hotwire Public Relations Group, LLC’s accountability for personal data that it receives in the United States under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Hotwire Public Relations Group, LLC remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process personal data on its behalf do so in a manner inconsistent with the Principles, unless Hotwire Public Relations Group, LLC proves that it is not responsible for the event giving rise to the damage.

In compliance with the Privacy Shield Principles, Hotwire Public Relations Group, LLC commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union, and UK individuals with Privacy Shield inquiries or complaints should first contact Hotwire Public Relations Group, LLC by email at gdpr@enero.com

Hotwire Public Relations Group, LLC has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit http://www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you.

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction.

 

CHANGES TO OUR PRIVACY POLICY

We reserve the right to modify this Policy at any time. Any changes We may make to our Policy in the future will be notified and made available to you using the Website. Your continued use of the services and the Website shall be deemed your acceptance of the varied privacy policy.

INFORMATION ABOUT OUR USE OF COOKIES AND IP ADDRESSES

We may collect information about your mobile phone, computer or other device from which you access the Website including where available your IP address, operating system and browser type, for systems administration and to report aggregate information to third parties affiliates. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual. We may, however, use such information in conjunction with the data We have about you in order to track your usage of our services.

Our Website uses cookies to distinguish you from other users of our Website. This helps Us to provide you with a good experience when you browse our Website and also allows Us to improve the Website. By using our Website you agree to our use of cookies as more specifically set out below.

A cookie is a small file of letters and numbers that We store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

The cookies We use include:

  • Analytical” cookies. They allow Us to recognise and count the number of visitors and to see how visitors move around the Website when they are using it. This helps Us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily.
  • Strictly necessary” cookies. These are cookies that are required for the operation of our Website. They include, for example, cookies that enable you to log into secure areas of our Website, use a shopping cart or make use of e-billing services.
  • Functionality” cookies. These are used to recognise you when you return to our Website. This enables Us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
  • Targeting” cookies. These cookies record your visit to our Website, the pages you have visited and the links you have followed to our affiliates websites. We will use this information to make our Website, offers e-mailed to you and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

Please note that third parties’ affiliates may also use cookies, over which We have no control.

You may block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies as soon as you visit our Website.

CALIFORNIA CONUMER PRIVACY ACT 2018

This section is specific and applies only to web visitors who are California residents, under the meaning of Section 17014 of Title 18 of the Cal. Code of Regulations.

For the purpose of the California Consumer Privacy Act 2018 (“CCPA”) the business is Hotwire Public Relations Limited, Hotwire Public Relations Group LLC, Hotwire Public Relations Germany GmbH, Hotwire Public Relations France SARL, Hotwire Public Relations Spain SL, Hotwire Public Relations Italy Srl and Hotwire Australia Pty Ltd.

We are complying with the CCPA and considering its underlying principles in how we think about customer trust and data privacy as a core pillar of our business. We are providing this CCPA-specific privacy notice to supplement the information and disclosures already contained above.

The personal information which we collect is noted above under the “Your Personal Information” heading.

The purposes for the collection and use of the personal information are detailed above under the “Use We Make of Your Personal Information” heading. The disclosure of your personal information is detailed under the “Disclosure of your Personal Information” heading.

 

What Personal Information Do We Sell?

 

WE DO NOT SELL YOUR PERSONAL INFORMATION

Under the definitions of “Sell” and “Sale” in the CCPA, we do not sell your personal information, nor do we sell the personal information of minors under 16 years of age, without affirmative authorization.

 

YOUR RIGHTS

Under the California Consumer Privacy Act 2018 you have a number of important rights. In summary, those include rights to:

  • Right to Know and Access. You may submit a request up to two times in a 12 month period for information regarding the:
    • categories of Personal Information collected or disclosed by us;
    • purposes for which categories of Personal Information are collected by us;
    • categories of sources from which we collect Personal Information; and
    • specific pieces of Personal Information we have collected about you during the past twelve months.
  • Right to Delete. Subject to certain exceptions, you have the option to delete Personal Information about you that we have collected from you.
  • Verification. Requests for access to or deletion of Personal Information are subject to our ability to reasonably verify your identity in light of the information requested and pursuant to relevant CCPA requirements, limitations, and regulations.
  • Right to Equal Service and Price. You have the right not to receive discriminatory treatment for the exercise of your CCPA privacy rights, subject to certain limitations.
  • Shine the Light. We do not rent, sell, or share your Personal Information with non-affiliated companies for their direct marketing purposes, unless we have your permission.

For further information on each of those rights, see the CCPA Fact Sheet from the Office of the Attorney General California: https://oag.ca.gov/system/files/attachments/press_releases/CCPA%20Fact%20Sheet%20%2800000002%29.pdf

If you would like to exercise any of those rights, please:

  • email, call or write to Us OR our Data Protection Officer gdpr@enero.com;
  • let Us have enough information to identify you, for example your name, employer, or registration details;
  • let Us have proof of your identity and address; and
  • let Us know the information to which your request relates, including any client account or reference numbers, if you have them.

Personal Information Collected in the previous 12 months.

The chart below outlines the categories of Personal Information (which are defined by the CCPA, not us) that we have collected and/or disclosed for a business purpose in the preceding twelve months. The examples of Personal Information provided for each category are taken from the CCPA and are included to help you understand what the categories mean.

 

To summarize, we collect, and have collected personal information about our visitors in the preceding 12 months in the following categories:

 

 

Category We Collect We disclose We sell
Identifiers

Examples:

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 YES NO
Categories of Personal Information

Examples:

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.

 

NO NO NO
Characteristics of Protected Classifications under California

Examples:

Race or colour, ancestry or national origin, religion or creed, age (over 40), mental or physical disability, sex (including gender and pregnancy, childbirth, breastfeeding or related medical conditions), sexual orientation, gender identity or expression, medical condition, genetic information, marital status, military and veteran status.

 

NO NO NO
Commercial Information

Examples:

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

 

NO NO NO
Biometric Information

Examples:

Physiological, biological, or behavioral characteristics, including DNA, that can be used, singly or in combination with each other or with other identifying data, to establish individual identity, such as imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.

 

NO NO NO
Internet or Other Electronic Network Activity Information

Examples:

Browsing history, search history, and information regarding a consumer’s interaction with an internet website, application or advertisement.

 

NO NO NO
Geolocation Data

Examples:

Precise physical location.

 

NO NO NO
Sensory Information

Examples:

Audio, electronic, visual, thermal, olfactory, or similar information.

 

NO NO NO
Professional or Employment Related Information

Examples:

Job application or resume information, past and current job history, and job performance information.

 

YES NO NO
Non-Public Education Information

Examples:

Records that are directly related to a student maintained by an educational agency or institution or by a party acting for the agency or institution.

 

NO NO NO
Inferences drawn from Personal Information

Examples:

Consumer profiles reflecting a consumer’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

 

YES YES NO

 

 

 

CONTACT

All questions, comments and requests regarding this Privacy and Cookies Policy should be addressed to gdpr@enero.com or write to Us at Hotwire, Level 4, 69 Wilson St, London EC2A 2BB, UK.