Privacy Policy

CULLARI COMMUNICATIONS GLOBAL PRIVACY POLICY

At Cullari Communications Global (“CCG”), we (“we”, “us” or “our”) respect your privacy.

CCG is a company located in the United States. We have adopted global privacy principles which guide how we manage and protect personal data.

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.

THE TYPES OF INFORMATION WE COLLECT

CCG collects and processes personally identifiable information. This is information that personally identifies one individual from another or enables you to be individually contacted (for example, names, e-mail addresses and other contact information). This information is voluntarily provided to us by Site visitors and is used by us for the purpose of responding to user submissions and fulfilling requests for further information about our services.

Our Site does not use cookies and we do not track how Site visitors use our site.

WAYS WE OBTAIN PERSONAL INFORMATION

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 inquiries, 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 payment providers, hotel and transport providers and third parties that provide technical services to us so that we can 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

CCG stores the personal information you provide in a secure database in order to provide you with the information, products, and/or services you request and may be used to provide you with additional information about our services we believe may be of interest to you. The information is stored for a time period and in a manner relevant to responding to your request unless you request that it be removed. The information you provide us will be shared with CCG consultants and service providers to the extent necessary to administrate our systems and/or accommodate your request.

For example, if you provide your name, mailing address, telephone and/or email address and request more information about CCG’s services, this information will be shared with appropriate CCG personnel to fulfill your request. This information will not be shared with non-affiliated third parties without your consent.

If you are from the European Economic Area (EEA), CCG legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it. That information may be used in the manner described above and in other ways, such as:

  • Surveys and voting. We may collect personal information from you via surveys or voting polls. Participation is voluntary and you will have the opportunity to decide whether or not to disclose information. At times, you may have to register to vote or to take part in a survey. We would use that information to report the results of the survey or vote.
  • Industry information. We collect and maintain databases containing, information about journalists, talent, social media influencers, social media users and other professionals in the public relations, news or media industry collected by us or by our trusted third party media analytics service providers. Such information may include an individual’s name, business contact details, professional interests and affiliations. This information may be information that is voluntarily supplied to us by those individuals through our Site or in other situations (such as public speaking events) or information that is public or available in third-party databases or via third-party content platforms (including social media platforms). Further, we may collect and/or review other publicly available news stories and other journalistic content including content made available through public news sites and social media sites to understand what people are saying about us and our clients. We use this information to provide our services to our clients including ensuring we and our clients are fully up to speed on public opinion in any particular area and are fully briefed when it comes to dealing with the press.  We may also use this information for our own internal administrative and promotional purposes. We make efforts to minimize the use of this information to that which is strictly necessary for our legitimate business interests.
  • Interactive areas. We may provide interactive areas, such as message boards, chat rooms or other forums.  Participation in these areas by users is voluntary.  We discourage you from submitting any information that may identify you personally when participating in these areas.  Use of these public areas is not secure and we cannot ensure that your information will be protected.
  • Marketing communications. We may carry out marketing activities using your personal information.  We may send marketing information to you by mail or email.  We may also provide you with information about media and public relations events. It may be necessary to mention the purpose of other marketing communications at the point that we collect that information. We send this information and materials to you where you have consented to receive such information or materials, or where we have another lawful basis to do so to the extent required by law.
  • Receipt of services. If we have engaged you or the organization you represent to provide us with products or services (for example, if you or the organization you represent provide us with services such as IT support or financial advice), we will collect and process your personal information in order to manage our relationship with you or the organization you represent, to receive products and services from you or the organization you represent and, where relevant, to provide our Services to others.
  • Business administration and legal compliance. We may use your personal information for the following business administration and legal compliance purposes:

              – to comply with our legal obligations;
              – to enforce our legal rights;
              – to protect the rights of third parties; and
              – in connection with a business transition such as a merger, reorganization, acquisition by another company, or sale of all or a portion of our assets.

PERSONAL INFORMATION OF CHILDREN

Our Site is intended for ages 18 and older. We do not intend to or knowingly collect personal information from children.

If you are a parent or guardian who has discovered that your child has submitted his or her personal information without your permission or consent, we will take reasonable steps to remove that information from CCG’s database at your request. To request removal of your child’s information, please send us an e-mail to privacy@cullarigroup.com and be sure to include in your message your contact information.

SHARING YOUR INFORMATION

We may share your personal information with our agents, partners, clients or contractors or professional advisers or government or regulatory bodies for the following purposes: (a) provide our services to clients or otherwise receive assistance in processing transactions; (b) fulfillment of requests for information, receiving and sending communications, updating marketing lists, analyzing data; (c) provision of IT and other support or internal administrative business services; or (d) assistance in other ancillary to the operation of tasks, from time to time. Our agents, partners and contractors will only use your information to the extent necessary to perform their functions.

We will not sell your personal information to other companies and we will not share it with other companies for them to use without your consent, except in the circumstances listed above or in connection with the sale or merger of CCG.

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside United States and choose to provide information to us, please note that we may transfer the data, including Personal Data, to United States and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

CCG will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

HOW YOU CAN ACCESS OR CORRECT YOUR INFORMATION 

You may access, update or remove the information you provided to us by contacting us – see “How to Contact Us” below. Upon receiving your email with the request to update or remove your information, CCG will: 1) log the receipt of your request, including the date and time received; 2) take reasonable steps (including seeking additional information or documentation) to the extent necessary to verify your identity, 3) evaluate the request (including, to the extent necessary, contacting the appropriate data holder); 4) once the evaluation is completed, take action consistent with the evaluation; and 5) respond to your request accordingly. The information you provide us may be archived or stored periodically by us according to backup processes conducted in the ordinary course of business. Information stored as part of this backup process will be deleted in due course on a regular schedule. We will not discriminate against you for seeking to access, update or remove any information.

CHOICE AND MEANS 

We generally offer you the opportunity to choose whether your personal information may be (a) disclosed to third-party controllers or (b) used for a purpose that is materially different from the purposes for which the information was originally collected or subsequently authorized by you. To the extent required by the applicable law, we obtain opt-in consent for certain uses and disclosures of sensitive data. Unless we offer you an appropriate choice, we use personal information only for purposes that are materially the same as those indicated in this Policy. To exercise your choices you may contact us as indicated in this Policy.

We may share personal information with our network of consultants as described above under SHARING YOUR INFORMATION. We may disclose personal information without offering an opportunity to opt out, and we may be required to disclose such information (a) to third-party processors we have retained to perform services on our behalf and pursuant to our  instructions, (b) if we are required to do so by law or legal process, or (c) in response to lawful requests from public authorities, including to meet national security, public interest or law enforcement requirements. We also reserve the right to transfer personal information in the event of an audit or if we sell or transfer all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, dissolution or liquidation).

CONFIDENTIALITY AND SECURITY OF YOUR PERSONAL INFORMATION

CCG understands that the safety of your personal information is extremely important to you. Accordingly, we take reasonable and appropriate measures to protect personal data from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the personal information. Due to the nature of the Internet and related technology, we cannot guarantee the security of your personal information and CCG expressly disclaims any such obligation.

ACCESSING AND UPDATING YOUR INFORMATION; OPT OUT AND UNWANTED COMMUNICATIONS

Visitors who would like to access, correct, update or delete any personally identifiable information may contact us with a request to do so at privacy@cullarigroup.com. Similarly, to opt-out of any future promotional or marketing communications or any other communications from us, you should send a request to privacy@cullarigroup.com. We will process your request within a reasonable time after receipt. Please note that if you opt out in this manner, certain aspects of this Site may no longer be available to you. We may also ask for additional information to authenticate the request. If you request the deletion, modification or limitation of use of your personal information maintained by use wee will promptly review your request and respond. If we grant your request, such information may be retained for a period of time in our backup systems as a precaution against system failures. Some information may be retained for longer periods as required by law, contract or auditing requirements. In some circumstances we will not be able to limit use of your personal information without unsubscribing you from communications or deleting your information.

INTERNATIONAL USERS AND DATA PROTECTION RIGHTS UNDER THE GENERAL DATA PROTECTION REGULATION (GDPR)

Information provided through this Site may be uploaded to a cloud and transferred to or accessed globally. By providing information to this Site, you consent to the transfer, processing and/or use of the information globally throughout CCG. Wherever the information is transferred or accessed within CCG, it will be processed and used in accordance with this privacy policy.

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. CCG aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data. If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us at privacy@cullarigroup.com.

In certain circumstances, you have the following data protection rights:

  • The right to access, update or delete the information we have on you. Please contact us to assist you.
  • The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
  • The right to object. You have the right to object to our processing of your Personal Data.
  • The right of restriction. You have the right to request that we restrict the processing of your personal information.
  • The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
  • The right to withdraw consent. You also have the right to withdraw your consent at any time where CCG relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

NOTICE TO CALIFORNIA RESIDENTS – CALIFORNIA PRIVACY RIGHTS 

Pursuant to California law, California residents may request information from us concerning: the categories of information we have collected; the categories of sources from which the personal information is collected; the purpose for which we collect or sell the personal information; the categories of third parties with whom we share personal information; and the specific pieces of personal information we have collected. You also have the right to ask us to delete the personal information we maintain regarding you. We will not discriminate against you for exercising any of these rights.

If you are a California resident and would like to make such a request, please submit your request in writing to the address below.

CHANGES TO THIS PRIVACY POLICY

We may make changes to this Policy from time to time. This Site includes a date on which it was last updated.

To ensure that you are always aware of how we use your personal information, we will update this Policy from time to time to reflect any changes to our use of your personal information. We encourage you to review this Policy periodically to be informed of how we use your personal 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 (does this need to be specified – “no longer than is necessary” ) 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 (does this need to be specified – “no longer than is necessary” ) 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.

The file containing your personal information will be maintained on CCG’s servers or those of its service providers and will be accessible by authorized representatives and agents who require access for the purposes described in this privacy policy.

INTERNAL AND INDEPENDENT RECOURSE MECHANISMS 

CCG commits to resolve complaints about our collection or use of your personal information. CCG is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission. Further, with respect to citizens to the European Union, CCG agrees to cooperate in investigations by, and comply with the advice of, the Federal Trade Commission and appropriate EU data protection authorities (“DPA”) in managing and resolving any dispute or complaint and provide the relevant DPA with written confirmation of the action taken. If you have questions or complaints regarding the use or disclosure of personal information in compliance with the principles of this privacy policy, you should contact us first at privacy@cullarigroup.com and we will contact you promptly to attempt to resolve your concerns or complaint. If contacting us does not resolve your concern or complaint, you may raise your complaint with the relevant DPA where you live or work (see http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm for contact information).

CONTACT DETAILS 

For questions or concerns about this Policy, or to ask questions or express concerns about our collection, management and processing of personal information, please contact us at: privacy@cullarigroup.com

POLICY UPDATED: January 2020