无忧传媒 Global Privacy Statement

Last Updated: April 2025

1. Introduction and Definitions

This Privacy Statement broadly explains how and why 无忧传媒 Hamilton collects and uses Personal Information (as defined below). It also describes the rights you have with respect to your Personal Information.

In this Privacy Statement, 鈥溛抻谴解 refers to 无忧传媒 Hamilton, Inc. and its subsidiaries and affiliates (collectively, 鈥溛抻谴,鈥 鈥淲e鈥 or 鈥淐ompany鈥). Personal Information (or 鈥淧I鈥) refers to information that can identify an individual, either on its own or when combined or associated with other information. PI includes Sensitive PI (or 鈥淪PI鈥) and Protected Health Information (or 鈥淧HI鈥).

SPI refers to certain categories of PI, such as:

  • Social Security numbers
  • government identification cards or numbers
  • citizenship or immigration status associated with a particular individual
  • financial information related to an individual鈥檚 financial account
  • precise geolocation
  • biometric or genetic data identifiable to an individual
  • medical information identifiable to an individual
  • criminal convictions or offenses identifiable to an individual
  • racial or ethnic origin identifiable to an individual
  • religious or philosophical beliefs identifiable to an individual
  • union membership identifiable to an individual
  • sex life or sexual orientation identifiable to an individual

PHI refers to individually identifiable health information created or received by a Covered Entity (for example, health plan, health care clearinghouse, or health care provider conducting electronic transactions) or Business Associate (for example, a service provider which must use, access, or create Protected Health Information to provide services to 无忧传媒).

无忧传媒 policies limit the collection, use, retention, and disclosure of PI to what is reasonably necessary and proportionate to achieve the purposes for which it was originally collected or processed. 无忧传媒 policy also limits 鈥渟econdary uses or disclosures鈥 to that which is compatible with the original purpose of the PI collection.听

2. Scope of this Global Privacy Statement

3. Your Rights in Relation to Personal Information (or 鈥淧I") We Collect and Process About You

Depending on where you reside, you might have the following rights related to your PI:

  • right to request access to your PI stored by 无忧传媒
  • right to request that 无忧传媒 amend, update or correct your PI
  • right to request that 无忧传媒 delete your PI
  • right to receive a copy of your PI in a structured, commonly used and machine-readable format to transfer to another company
  • right to request information about or to opt-out of automated decision-making
  • right to opt-out of marketing communications from 无忧传媒 at any time
  • right to restrict or to object to the processing of your PI by 无忧传媒
  • right to withdraw consent if you have voluntarily provided PI or have consented to provide your PI
  • right to complain to a data protection authority

Note that these rights are not absolute. They are dependent upon, and subject to, certain conditions and exceptions under applicable laws and regulations. Please also note that evolving state laws impact your rights based on your residence. To exercise any of the above rights, please contact us at [email protected] or call 877-927-8278.

In your request, please include the following:

  • the nature of the request 鈥 that is, the specific right you are asserting (see the Your Rights in Relation to the PI We Collect and Process About You section above)
  • the specific PI you seek to access, amend, delete, restrict, transmit to another company, or withdraw your consent to process - or if you wish to exercise one or more of these rights with respect to all of your PI.

For your protection and to mitigate the risk of fraud, we must verify your identity, in accordance with applicable law(s) and regulation(s), before processing your request. Thus, we will only respond to your request if we have enough information about you to verify your identity and your relationship to 无忧传媒 (e.g., employee, former employee, client).

We will comply with your request as soon as reasonably practicable and within the timeframe set forth in applicable law(s) and regulation(s).

Please also note that we may need to retain certain information to comply with legal or regulatory obligations or to complete any transactions that you began prior to submitting your request. Residual PI may also remain in backup copies. Such residual PI will not be removed until the applicable retention period ends, per 无忧传媒鈥檚 records retention policy, unless otherwise required by law.听

A. California Specific Notice of Rights

1. Right of access and data portability: You may request that 无忧传媒 disclose to you information about our collection and use of your Personal Information (or 鈥淧I鈥) PI and Sensitive Personal Information (or 鈥淪PI鈥) in the preceding 12 months, including:

  • categories and specific pieces of PI and SPI that we collected about a California resident
  • categories of sources from which we collect PI or SPI
  • business or commercial purpose for which we collect PI or SPI
  • categories of PI or SPI that we share and the categories of third parties with whom we share the PI or SPI
  • business or commercial purpose for which we share PI or SPI
  • categories of PI or SPI that we have disclosed for a business purpose
  • length of time, or criteria for determining the length of time, that 无忧传媒 intends to retain each category of PI and SPI

2. Right to request deletion of PI: You may request that 无忧传媒 delete your PI or SPI. This request is subject to 无忧传媒鈥檚 right to maintain PI and SPI for purposes permitted under applicable law. If we cannot comply with your request, we will notify you.

3. Right to request correction of your PI and SPI: You may request that 无忧传媒 correct inaccurate PI.

4. Right to opt-out of the sale or sharing of your PI for behavioral advertising purposes: You may request that your PI not be sold or shared for behavioral advertising purposes as indicated above. To make this request, click on the Do Not Sell or Share My Information link at the bottom of the Website.

5. Right to limit the use and disclosure of SPI: You may request to direct 无忧传媒 to limit the use of your SPI to that which is necessary to perform the services or provide the goods as reasonably expected and to only use and disclose SPI as permitted by the CCPA. At this time, 无忧传媒 only discloses SPI for purposes permitted by the CCPA. If this changes, 无忧传媒 will notify you of the right to limit the use and disclosure of SPI.

6. Right to non-discrimination: You have the right to exercise any of your rights listed above and any other rights under the CCPA without discrimination by 无忧传媒. This includes the right of employees, applicants, and independent contractors not to be retaliated against for the exercise of their CCPA rights.听

4. Information We Collect and for What Purposes

Information that Individuals Provide to 无忧传媒

We collect information that you voluntarily provide, such as when completing an online form, registering for a 无忧传媒 sponsored event, subscribing to a 无忧传媒 white paper or newsletter, or providing contact information to receive 无忧传媒 communications, such as emails, or engaging with 无忧传媒 social media posts.

无忧传媒 does not collect Sensitive Personal Information (or 鈥淪PI鈥) from our clients (organizations who engage 无忧传媒 for services and organizations who purchase 无忧传媒 products or packaged solutions), service providers, or Website visitors unless it is provided to us. We strongly encourage you not to share SPI in open text fields, emails, or other places. If you do, you consent to our collection and processing of such SPI. Likewise, if while visiting our Website(s), communicating with us or posting on a social media page related to 无忧传媒, you share any Personal Information (or 鈥淧I鈥) or SPI relating to other people, you represent that you have the authority to do so and to permit us to use such information in a manner consistent with this Privacy Statement.

If you elect to opt-out of receiving 无忧传媒 publications and/or marketing communications, your name, email address, country, employer, and subscription status will be placed on our opt-out list.

Information you might choose to provide includes:

  • name
  • job title
  • company/organization or employer
  • email address
  • contact information, including email address and business telephone number
  • state and country
  • communication preferences
  • information relating to events captured through event-related forms, such as dietary restrictions, hotel and flight information, registration/participation status, previous event experience
  • information related to providing services, products, or packaged solutions to our clients
  • any other information that an individual, entity or organization chooses to provide to us
Information Collected Automatically from Our Website Visitors

If you visit a 无忧传媒 Website, the Website server(s) might collect certain information automatically from your device. For example, the server(s) might collect:

  • broad geographic location (e.g. country, city-level, or zip location)
  • Internet Protocol (IP) address
  • pixel identifier
  • device type
  • how the device interacts with the Website, including the pages viewed, time visited, current universal resource locator (URL), and any links you have clicked听

If you visit a 无忧传媒 Website, here is why we might collect and process information about you or about your device:

  • to administer and manage the Website
  • to personalize and improve your browsing experience by displaying content and advertising that may be of particular interest to them
  • to provide news or information that may interest you
  • to analyze data related to Website traffic information and Website visits
  • to determine the Website visitor鈥檚 employer or affiliation with an organization
  • to develop our business strategy and service offerings
  • to provide marketing communications and materials
  • to monitor and enforce compliance with applicable Terms of Use/terms and conditions/license agreements
  • to conduct quality and risk management reviews
  • to maintain data and network security
  • to provide for event and webinar registrations, management, and coordination
  • to allow content downloads
  • any other purpose for which Website visitors provide information to 无忧传媒

Note: If your internet browser鈥檚 鈥淒o Not Track鈥 setting or 鈥淕lobal Privacy Control鈥 signal is enabled, marketing or targeting cookies will be disabled by default.

Under the European Union (EU) and United Kingdom (UK) General Data Protection Regulation (GDPR), personal data about an individual can only be processed if there is a 鈥渓egal basis鈥 for processing personal data.

  • 无忧传媒鈥檚 legal bases are:
  • explicit consent of the Website visitor and/or
  • 无忧传媒鈥檚 legitimate interests in:
    • effectively delivering information and services to you;
    • developing and improving our Websites and Website visitors鈥 experience;
    • marketing our services to you or your employer

B. Information About Individuals Who Engage with 无忧传媒 on Social Media Sites

无忧传媒 uses various social media platforms, such as X (formerly Twitter) and LinkedIn, for recruitment and marketing purposes. For example, we use these platforms to provide information about 无忧传媒 job opportunities and events and to promote the 无忧传媒 brand.

无忧传媒 is responsible for the content it publishes using social media platforms but does not have control over the social media platforms themselves, nor the way they are administered. When using social media platforms, you must adhere to the social media provider鈥檚 terms of use and their privacy policies apply, not ours. If you would like to invoke your rights with respect to the Personal Information (or 鈥淧I鈥)/ Sensitive Personal Information (or 鈥淪PI鈥) that a social media provider has collected about you, you should contact the social media platform provider.

Note also that some social media platform providers provide 无忧传媒 with data collected from your engagement with our social media sites. This data is aggregated or combined with similar data from other visitors to our social media sites, such as the number of 鈥渓ikes鈥 triggered by our content, the number of posts or visitors to the Websites, information downloaded from our Websites, or the links clicked.

Other Third-Party Software

Google Maps

Our Websites use the Google Maps service via an application programming interface (API). To allow you to use Google Maps, Google鈥檚 server(s) use different types of PI, such as an IP address or saved activities. 无忧传媒 does not control Google鈥檚 collection of data. For more information, see Google鈥檚 privacy policy.

Under the European Union (EU) and United Kingdom (UK) General Data Protection Regulation (GDPR), personal data about an individual can only be processed if there is a 鈥渓egal basis鈥 for processing personal data.

无忧传媒鈥檚 legal bases are:

  • consent of the Website visitor; and/or
  • 无忧传媒鈥檚 legitimate interests in:
    • promoting 无忧传媒 services and brands;
    • attracting, identifying, and sourcing talent;
    • improving Website visitors鈥 experiences

C. Information About Individuals Who Communicate with 无忧传媒 Through Email

无忧传媒 uses various tools to protect the security of our information technology (IT) assets, including our email transmissions. Examples include:

  • software that scans incoming emails for suspicious attachments and scans website domains/URLs to prevent malware attacks
  • end-point threat detection tools that detect malicious attacks on system endpoint devices, such as laptops, computers, and mobile devices
  • software that blocks certain content or websites

So, if you send emails to 无忧传媒, please be aware that your emails will be scanned, to maintain 无忧传媒鈥檚 IT network security. This means that 无忧传媒 personnel, or its service providers鈥 personnel, might see the contents of your email even if those individuals are not the intended recipients of your email.

Under the European Union (EU) and United Kingdom (UK) General Data Protection Regulation (GDPR), personal data about an individual can only be processed if there is a 鈥渓egal basis鈥 for processing personal data.

无忧传媒鈥檚 legal bases are:

  • consent of the Website visitor; and/or
  • 无忧传媒鈥檚 legitimate interests in:
    • protecting its IT infrastructure and network against unauthorized attacks, malicious software and potential data leakage
    • maintaining telecommunications connectivity within the company

D. Information in 无忧传媒鈥檚 Customer Relationship Management (CRM) Systems

无忧传媒 processes the following types of Personal Information (or 鈥淧I鈥) about its clients, prospective clients, industry partners, and alumni in its CRM systems:

  • name, email address, country, phone听
  • name of employer or organization with whom the individual is associated
  • industry
  • data related to an individual鈥檚 direct marketing preferences, such as whether the individual has submitted an opt-out request and the individual鈥檚 email address

The PI collected in the CRM systems support 无忧传媒 business development and marketing activities.

If you have opted out of receiving future marketing or promotional communications, your basic contact details (including your email address) will remain on our opt-out list.

Under the European Union (EU) and United Kingdom (UK) General Data Protection Regulation (GDPR), personal data about an individual can only be processed if there is a 鈥渓egal basis鈥 for processing personal data.

无忧传媒鈥檚 legal bases are:

  • consent of the individual;
  • 无忧传媒鈥檚 legitimate interests in:
    • managing and nurturing relationships with its business contacts;
    • providing information about 无忧传媒 and its services;
    • thought leadership; organizing, promoting and offering events to clients and prospective clients;
    • identifying talented job candidates/recruiting;
    • processing job applications for 无忧传媒 positions;
    • hiring job candidates and onboarding new employees;
    • carrying out pre-employment background screenings;
    • complying with legal or regulatory requirements; and
    • protecting the security of 无忧传媒 personnel, buildings, and assets

E. Information About Individuals Who Attend 无忧传媒 Events

无忧传媒 processes event registrations through 无忧传媒 Websites and social media platforms. Please see the for details about Personal Information (or 鈥淧I鈥) collected and used in connection to 无忧传媒 events.听

Photographs and Video Recordings at 无忧传媒 Events

Sometimes 无忧传媒 takes photographs or records videos at 无忧传媒 sponsored or co-sponsored events. During registration or at the event, participants are asked to sign a consent form allowing 无忧传媒 to use their photographs or videos for commercial purposes. 无忧传媒 will only use photographs or videos when participants have consented to the use of their images for such purposes.

In some circumstances, 无忧传媒 might not be able to obtain prior written or electronic consent for photographs and video recordings taken at an event. In such circumstances, if photographs or videos are taken at the event, 无忧传媒 will not use these images for commercial purposes nor publicly post them, unless the persons depicted in the photographs or videos have provided prior written or electronic consent to use them for such purposes.

If you have previously consented and now would like to withdraw your consent, you can contact 无忧传媒 at the phone number and email provided above in Section 3, Your Rights in Relation to Personal Information (PI) We Collect and Process About You.听

Under the European Union (EU) and United Kingdom (UK) General Data Protection Regulation (GDPR), personal data about an individual can only be processed if there is a 鈥渓egal basis鈥 for processing personal data.

无忧传媒鈥檚 legal bases are:

  • consent of the individual when images, videos and PI are used for commercial or marketing purposes); and
  • 无忧传媒鈥檚 legitimate interests in taking photographs and video recordings related to operating its business (for non-commercial purposes)听

F. Information About 无忧传媒 Clients and Individuals Whose Personal Information (PI) We Process in Providing Services

Information About Clients

When an individual or entity interacts with 无忧传媒 to obtain 无忧传媒 services or products, 无忧传媒 collects and processes PI in connection with providing those products and services.

无忧传媒 processes PI voluntarily provided by our clients and potential clients. This PI may include:

  • names of client employees or other personnel
  • work-related contact Information, including work addresses, email addresses, and telephone numbers of employees and other personnel
  • entity name and positions/job roles of employees/personnel
  • any other information provided to 无忧传媒 so that 无忧传媒 can provide services or packaged solutions to its clients
Information About Individuals (Other than Clients) Whose PI We Process in Providing Services to Clients

In connection with certain client engagements, 无忧传媒 collects or obtains PI of individuals on behalf of its clients. In those situations, 无忧传媒 might process the PI of individuals with whom 无忧传媒 does not have a direct relationship (contractual or otherwise). For example, 无忧传媒 may conduct a research project on behalf of a client which requires 无忧传媒 employees to interact directly with individuals and collect their PI, or a client might engage 无忧传媒 to perform data analytics, cybersecurity assessments, or other services. In doing this latter type of work, 无忧传媒 might have access to the PI it collects, but which is maintained in its client鈥檚 systems.

United States Government Clients

无忧传媒 contracts with U.S. and foreign government entities at the national, state/territorial and local level. In providing services to the government, 无忧传媒 must comply with various privacy and data security laws, regulations, guidance, and policies that apply to any PI maintained in government systems. For example, if 无忧传媒 conducts a clinical research project, 无忧传媒 might need to comply with the consent requirements under the Federal Protection of Human Subjects and the Health Insurance Portability and Accountability Act. If 无忧传媒 obtains PI from or provides PI to the government, it complies with U.S. privacy laws applicable to such PI, as well as the contractual, statutory, and regulatory requirements applicable to 无忧传媒鈥檚 services.

Commercial Clients

In providing services to commercial (business) clients which involve collecting or processing PI, 无忧传媒 seeks contractual assurances from them that they have the appropriate legal authority and permissions to provide such PI to 无忧传媒. Likewise, 无忧传媒 typically provides contractual assurances that it will process the PI in a legally compliant manner and accommodate the rights of the individuals whose PI we process, as applicable.

Since 无忧传媒 provides many types of services to both government and commercial clients, it sometimes processes PI and SPI related to those services, including, but not limited to:

  • names
  • basic demographic data about an individual, such as date of birth, age, marital status, country of residence, or citizenship
  • contact information, such as phone numbers, postal addresses, and email addresses
  • employment-related data, such as employer name, role or rank, experience, and prior performance
  • health data, such as an individual鈥檚 medical diagnosis, treatment, and insurance information
  • financial data, such as financial account numbers, salary, benefits, and tax-related information
  • biometric data, such as facial images and voiceprints
  • religion, race, ethnicity, sexual orientation, gender
  • membership in a trade union or other type of worker membership organization听

Under the European Union (EU) and United Kingdom (UK) General Data Protection Regulation (GDPR), personal data about an individual can only be processed if there is a 鈥渓egal basis鈥 for processing personal data.

无忧传媒鈥檚 legal bases are:

  • consent of the individual, when required by law
  • 无忧传媒鈥檚 legitimate interests in:
    • providing services to our clients and products and packaged solutions to our clients;
    • administering contracts with our clients and managing associated services, programs and projects;
    • complying with accounting and tax-related requirements;
    • marketing its services;
    • business development;
    • complying with legal and regulatory requirements;
    • establishing, exercising, or defending its legal rights; and
    • protecting its employees and other personnel, building visitors, facilities, and assets

G. Personal Information (PI) and Anonymized Information Used for Research and Development

无忧传媒 collects, receives, and processes PI to develop and improve its products and services. 无忧传媒 also obtains data sets, which might include PI or de-identified or anonymized PI, for purposes of conducting research and developing new software, systems, technologies and services, including systems or technologies that can perform tasks typically requiring human intelligence. These tasks include, but are not limited to, understanding natural language, recognizing patterns, solving problems, making decisions, and learning from experience (鈥淎rtificial Intelligence鈥).

无忧传媒 might also obtain or process 鈥渓imited data sets鈥 where the data set only has 鈥渋ndirect鈥 identifiers, or 鈥減seudonymized鈥 data sets, where the data set is de-identified, but may be re-identified.

The types of PI that 无忧传媒 might obtain include, but are not limited to:听

  • mobile device identifiers
  • photographs
  • audio or video recordings
  • health-related data
  • videos o biometric data
  • employment-related information听

Under the European Union (EU) and United Kingdom (UK) General Data Protection Regulation (GDPR), personal data about an individual can only be processed if there is a 鈥渓egal basis鈥 for processing personal data.

无忧传媒鈥檚 legal bases are:

  • consent, when required by applicable law and when 无忧传媒 collects the PI directly from individuals or obtains it from a third party
  • 无忧传媒鈥檚 legitimate interests in:
    • conducting its own research and development activities;
    • growing 无忧传媒鈥檚 business;
    • offering new services or enhancing existing services;
    • enhancing efficiency by streamlining operations and automating repetitive tasks;
    • improving decision-making by utilizing data-driven insights; and
    • fostering innovation through new Artificial Intelligence-driven products and services.听

H. Information About Visitors to 无忧传媒 Facilities

We collect and process the following categories of Personal Information (or 鈥淧I鈥) about visitors to 无忧传媒 facilities:

Visitor Records and Access Badges

Before entering a 无忧传媒 facility, visitors must provide name, contact information, country of residence, and date of birth through an online pre-registration portal or at the door. Visitors must also show a passport or driver鈥檚 license to verify the information they have provided.

As explained in the 鈥淟egal Bases鈥 subsection below, 无忧传媒 collects this information to comply with its legal obligation to confirm that the visitor is not on a restricted 鈥渨atchlist鈥 and to protect 无忧传媒 personnel, facilities, and assets.

Visitor information is also used to investigate security incidents and for emergency purposes, such as an emergency at the facility requiring identification of all individuals on the premises.听

Wi-Fi and 无忧传媒 Information Assets

无忧传媒 monitors and logs traffic on our Wi-Fi networks. Thus, if a visitor is provided with 无忧传媒 Wi-Fi connectivity or access to its network/information systems, 无忧传媒 can see information about the visitor鈥檚 network behavior, as well as the source and destination addresses to which the individual connects.

Closed Circuit Television (CCTV)

无忧传媒 uses CCTV monitoring on facilities where permitted by law. CCTV images are securely stored and used as necessary for security purposes.

Under the European Union (EU) and United Kingdom (UK) General Data Protection Regulation (GDPR), personal data about an individual can only be processed if there is a 鈥渓egal basis鈥 for processing personal data.

无忧传媒鈥檚 legitimate interests in:

  • protecting its employees and other personnel, facilities, and assets; and
  • complying with laws and regulations related to individuals on a restricted watchlist

I. Information About Individuals Who Pose a Potential Threat or Risk

无忧传媒 collects and processes the Personal Information (or 鈥淧I鈥) of individuals who present a potential security threat to 无忧传媒 people, facilities, assets, business, or reputation.

Under the European Union (EU) and United Kingdom (UK) General Data Protection Regulation (GDPR), personal data about an individual can only be processed if there is a 鈥渓egal basis鈥 for processing personal data.

Under the European Union (EU) and United Kingdom (UK) General Data Protection Regulation (GDPR), personal data about an individual can only be processed if there is a 鈥渓egal basis鈥 for processing personal data.

无忧传媒鈥檚 legitimate interests in:

  • protecting personnel, facilities, businesses, and assets;
  • preventing and detecting crimes; and
  • establishing, exercising, and defending legal claims

J. Information About Suppliers

无忧传媒 collects and processes Personal Information (or 鈥淧I鈥) about employees and other personnel who perform work for suppliers, service providers, vendors, and subcontractors (collectively, 鈥淪upplier Personnel鈥). 无忧传媒 processes this PI to manage its contractual relationships with them and to enable them to provide services.

The PI 无忧传媒 collects and processes about Suppliers and Supplier Personnel generally includes:

  • supplier name
  • names of Supplier Personnel
  • contact information (business phone and email address) of Supplier Personnel
  • all information, which might include PI, in emails, phone calls, video meetings and any other communications between the Supplier and 无忧传媒; and
  • financial information related to payment of services

As required by applicable laws and regulations, such as those related to fraud and corruption and international trade compliance, 无忧传媒 also collects PI to check for conflicts of interest and to conduct background checks.

无忧传媒 might also collect PI in doing due diligence prior to engaging a Supplier.

Under the European Union (EU) and United Kingdom (UK) General Data Protection Regulation (GDPR), personal data about an individual can only be processed if there is a 鈥渓egal basis鈥 for processing personal data. 无忧传媒鈥檚 legal bases are:

  • performing its contractual obligations
  • 无忧传媒鈥檚 legitimate interests in
    • complying with its legal or regulatory obligations;
    • managing payments, fees, and charges related to the contract for services;
    • identifying any potential conflicts of interest;
    • protecting 无忧传媒 personnel, facilities, assets, and/or reputation; and
    • preventing our association with others鈥 criminal or fraudulent activities

K. Minors

无忧传媒 Websites are not directed to individuals under the age of eighteen (18), and we do not knowingly collect, process, disclose, or share the Personal Information (or 鈥淧I鈥) of minors. If you are a minor and believe that you have provided PI, please ask your parent(s) or legal guardian(s) to notify us, and we will delete your PI.

5. Retention of Personal Information (or 鈥淧I鈥)

无忧传媒 retains PI for only as long as needed for the reason for which it was collected and based on business and legal requirements, including the need to exercise and defend our legal rights. 无忧传媒 also maintains records for archiving and historical purposes in compliance with applicable laws.听

6. How 无忧传媒 Protects Personal Information (or 鈥淧I鈥)

无忧传媒 uses commercially reasonable organizational, technical, and administrative measures to protect the confidentiality, integrity, and availability of the PI that 无忧传媒 collects, maintains, and processes. For example, 无忧传媒 limits access to PI to those with a 鈥渘eed to know鈥 to do their jobs. 无忧传媒 also has robust policies, procedures, and technical controls to safeguard PI from unauthorized access, loss, misuse, and improper disclosure.

If you have reason to believe that your PI is no longer secure, please immediately notify us at [email protected]. Because email communications are not always secure, please do not include sensitive information in your emails to us.

7. De-Identified Data

To the extent 无忧传媒 intends to create de-identified data as defined by applicable law for the purposes of using the data in de-identified form, 无忧传媒 policy requires that the data not be re-identified, except as permitted by applicable law.

8. Transfers of Personal Information (or 鈥淧I鈥) Between 无忧传媒 Entities

无忧传媒 operates globally in several countries. If you would like a list of 无忧传媒 affiliates and where they operate, please contact 无忧传媒 at [email protected].

无忧传媒 centralizes various internal operations, including IT services, human resources and finance/accounting functions in the United States. Client engagements in jurisdictions outside the United States often involve transfers of PI outside of the client鈥檚 or client鈥檚 jurisdiction. These transfers occur due to:

  • the need to access PI by 无忧传媒鈥檚 internal operations in the United States
  • the location of 无忧传媒 employees working on the client engagement outside the client鈥檚 jurisdiction
  • the location of 无忧传媒 vendors or subcontractors who are located outside of the client鈥檚 jurisdiction

This means that your PI may be transferred and processed outside of the country where you may be located. This includes transfers of PI from the European Economic Area (EEA) or United Kingdom (UK) to countries with laws that the EEA, UK, or other jurisdictions have not deemed to provide an adequate level of protection for the processing of personal data.

无忧传媒 uses appropriate safeguards to protect the confidentiality, integrity, and availability of the PI transferred among 无忧传媒 entities. For example, where PI is collected or obtained from individuals in the United Kingdom (UK) or European Economic Area (EEA), 无忧传媒 has executed data transfer agreements that allow for global transfers within the 无忧传媒 group of entities.听

9. Disclosures of Personal Information (or 鈥淧I鈥) to Suppliers

无忧传媒 engages service providers to support our internal operations, including client contracts. We may disclose, and in some cases, transfer PI to our service providers and their affiliates and sub-processors (collectively, 鈥淪uppliers鈥). In other cases, Suppliers may collect and transfer PI on our behalf. For example, Suppliers may provide:

  • IT functions, such as information security, data storage, data analytics, business applications, and voicemail
  • general operational support, such as enterprise management software, CRM software, archiving, and event management
  • accounting, finance, and billing support
  • compliance risk reviews and assessments, legal hold services, and legal case management
  • subcontractor services when we are engaged by a client

When Suppliers provide services to 无忧传媒, they sometimes require access to PI. Thus, when engaging Suppliers, 无忧传媒 requires them to contractually agree to comply with applicable privacy and data protection laws, including those related to information security and to the transfer of PI outside the jurisdiction from which it was collected. If you would like to know more about the Suppliers 无忧传媒 engages, please contact 无忧传媒 at [email protected].

10. Other Disclosures of Personal Information (or 鈥淧I鈥)

In addition to the other reasons set forth in this Privacy Statement, 无忧传媒 might disclose PI about an individual:

  • when directed to do so by the relevant individual or with the individual鈥檚 consent
  • when the disclosure is consistent with the purposes described in this Privacy Statement
  • if and when required by applicable law, including applicable law outside the country where the PI was initially collected and/or where the individual resides
  • in connection with a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of 无忧传媒鈥檚 business assets or stock (including in connection with any bankruptcy or similar proceeding)
  • to protect, exercise, and defend 无忧传媒鈥檚 legal claims, safety, or property
  • to comply with a regulatory or government inquiry, court order, or other legal obligation, including in a country different from where the PI was collected
  • to cooperate with a law enforcement inquiry or investigation

Note also that 无忧传媒 is obligated to report certain activities or suspected criminal activity to relevant regulatory authorities and law enforcement entities. In these cases, recipients of the PI might include, for example:

  • law firms, tax advisors, or auditors
  • insurers
  • audit regulators
  • tax and customs, and excise authorities
  • regulatory bodies
  • credit reference/reporting agencies
  • courts, police, and law enforcement agencies
  • government departments and agencies
  • 无忧传媒 suppliers

无忧传媒 is sometimes legally prohibited from informing an individual about the disclosure either: 1) before the disclosure happens or 2) at any time.听

11. Contact Us or a Relevant Government Agency

To ask a question, report an alleged violation of a privacy law or regulation, or compliment us, please contact us at [email protected]. You can also reach out to the privacy team at Office of the General Counsel, 无忧传媒., 8283 Greensboro Drive, McLean, Virginia 22102. Depending on where you live, you might also have the right to submit a complaint to a national or state government agency, such as a Data Protection Authority or relevant Supervisory Authority in your country or your state Attorney General. For example, if you are in the European Economic Area (EEA), you may lodge a complaint with a Data Protection Authority for your country or region, or where an alleged infringement of applicable data protection law occurs.听

12. Revisions to This Privacy Statement

We may change this Privacy Statement to reflect changes in our data collection and processing practices and/or applicable laws. Changes will become effective when we post the revised version on this Website. Thus, we recommend checking here from time to time

Revisions to the Privacy Statement

We may change this Privacy Statement to reflect changes in our practices and services. The 鈥淟ast Updated鈥 legend at the top of this page indicates when this Privacy Statement was last revised. Any changes will become effective when we post the revised notice on this website. We recommend checking this Statement from time to time to inform yourself of any changes based on the last updated date.