‍

This global privacy policy explains how Flywheel Digital Limited and/or its affiliates (“Flywheel” referred to as “we”, “us” or “our”) handle your personal data, including the types of personal data we collect about you, how your personal data may be used and when it may be disclosed, how we protect your personal data and the rights you have in relation to the processing of your personal data. Flywheel respects your privacy and we are committed to protecting your personal data in accordance with applicable data privacy laws and our internal policies.

In the event of conflict between a translated version of this global privacy policy and the English version, the English version shall prevail.

1. Who is the controller of my personal data?

Unless we notify you otherwise, Flywheel is the controller of your personal data as it is the entity who alone or jointly determines how or why your personal data is being processed. Our affiliates may be the controller of your personal data in certain circumstances depending on our relationship, and the services we are providing to you.

2. How do we collect your personal data?

We use different methods to collect personal data from and about you, including: -

Collection directly from you

Most of the personal data we process about you comes directly from you. You may give us your name and contact details when filling in forms or corresponding with us by email, phone, mail, in person or otherwise including when you:

- subscribe to our services, products or email alerts; and
- buy or express an interest in our products and services (including attending an event).

Depending on the products and/or services we provide to you, you may also have the option to upload a photograph of yourself as part of your registration for such products and/or services. This is optional and your photograph can be updated at any time.

Automatic collection

We automatically collect technical information when you use our websites, for example: - IP address, log-in data, browser type, time zone setting and location and plug-in types when you interact with our websites. We also collect data through cookies. Please see our cookies policy for further details.

Collection from other sources

We may collect information about you from third parties and public sources (such as public databases and social media websites). This is to ensure we have accurate, up to date or necessary information for us to communicate with you or to provide the best possible service. The types of information we may collect includes personal details (including name, age, gender and other demographic data) and contact information (including postal address and telephone numbers).

3. For which purposes and on which legal basis do we process your personal data?

We have set out below a description of all the ways we plan to use your personal data and which legal basis we rely on to do so. We have also identified what our legitimate interests are, where appropriate.

‍

4. How do we use personal data for direct marketing purposes?

We may send you marketing communications to keep you up to date with our products and services, including those we think may be of interest to you.

Do we send targeted e-mails?

We send targeted electronic direct marketing to business contacts at our clients or other companies with whom we want to develop or maintain a business relationship in accordance with applicable marketing laws. Our electronic direct marketing typically includes web beacons, cookies, and similar technologies that allow us to know whether you open, read, or delete the message, and links you may click. When you click a link in an electronic direct marketing message, we will also use a cookie to log what pages you view and what content you download from our websites, even if you are not registered at or signed into our site. Please see our cookies policy for further details.

Do we maintain Customer Relationship Management (CRM) databases?

Like most companies, Flywheel uses customer relationship management (CRM) database technology to manage and track our marketing efforts. Our CRM databases include personal data belonging to business contacts at our clients and other companies with whom we already have a business relationship or want to develop one. The personal data used for these purposes includes relevant business information such as: contact data, publicly available information (e.g. board membership, published articles, press releases, your public posts on social media sites if relevant for business purpose), your responses to targeted electronic direct marketing (including web activity following links from our e-mails), website activity of registered users of our website and other business information included by Flywheel professionals based on their personal interactions with you.

Do we combine and analyse personal data?

We may combine data from publicly available sources, and from our different e-mail, website, and personal interactions with you (this includes information collected across our different websites such as our careers and corporate sites and information collected when you sign-up or log on to our sites or connect to our sites using your social media credentials). We combine this data to better assess your experience with Flywheel and to perform the other activities described throughout this privacy policy.

What are your rights regarding marketing communications?

You can elect to not receive marketing communications from us by, or by utilising opt-out mechanisms in e-mails we send to you. You can also object to receiving marketing communications or request that your personal data be removed from our CRM databases by contacting us at 

‍Email: Send us an email at: privacy@omnicomgroup.com 

‍Post: Write to us at
Omnicom Group Inc.
 
Attn: General Counsel
 
280 Park Avenue
 
New York, NY 10017

Telephone: 1-833-520-0506

5. What about sensitive data?

We do not generally seek to collect sensitive data (also known as special categories of personal data) from individuals and we request that you please do not submit sensitive data to us. In the limited cases where we do seek to collect such data, we will do this in accordance with data privacy law requirements and/or ask for your consent.

The term "sensitive data" refers to the various categories of personal data including racial or ethnic origin, political opinions, religious, philosophical or other similar beliefs, membership of a trade union, physical or mental health, biometric or genetic data, sexual life or orientation, or criminal convictions and offences (including information about suspected criminal activities).

6. What about persons 18 or under?

We are concerned to protect the privacy of children. We do not knowingly contact or collect information from persons under the age of 18. The website is not intended to solicit information of any kind from persons under the age of 18.

If you believe that we have received information pertaining to or from persons under the age of 18 please contact us at contacting us at privacy@omnicomgroup.com. If we become aware that a person under the age of 18 has provided us with personal information, we will take steps to delete such information.

7. Will we share your personal data with third parties?

We may share personal data with the following categories of recipients:

• Our affiliates, so they can send you communications about their products and services (as further described in section 3 above)
• Our third-party service providers, including IT service providers, marketing automation, solutions and analytics providers, marketing agencies, professional advisors, and
• Our selected partners, representatives and sponsors, for example we may share attendee lists with event sponsors so that they can better plan their sponsorship to enhance attendee experience and, where applicable, to choose invitees to private briefings, meetings or dinners, or we may make available contact details to create marketing opportunities in certain industries and markets.

We may also share your personal data with public and governmental authorities if we are required to do so, or with third parties in connection with potential corporate or commercial transaction.

Before we share your personal data with any third parties, we take the necessary steps to ensure that your personal data will be given adequate protection in accordance with relevant data privacy laws and Flywheel’s internal policies.

8. How long will your personal data be retained by us?

We retain your information for no longer than necessary for the purpose for which it was collected. We maintain specific records management and retention policies and procedures, so that in determining how long your information will be stored, we will consider:

• the purpose(s) and use of your information both now and in the future;
• our global legal and contractual obligations; and
• what information we need to manage your relationship with us and to develop and deliver our products and services.

9. Do we transfer your data internationally?

As we are a global organisation with a presence in a number of jurisdictions and countries, we may transfer your personal data to our affiliates internationally. If you are located in the EEA, this may involve transferring your data outside the EEA. To ensure that such transfers are in accordance with applicable law and carefully managed to protect your privacy rights, any inter-company transfers of personal data are covered by agreement(s) which contractually oblige(s) us to ensure adequate and consistent levels of protection wherever personal data is transferred within our group of companies.

We may also share your personal data with third parties (see section 7), some of which are based outside the EEA. Whenever we transfer your personal data outside the EEA, we ensure a similar degree of protection is afforded it by ensuring appropriate safeguards are implemented, for example we may use specific contracts approved by the European Commission.

Please contact us (see our details at section 12 below) if you would like further information on the mechanism used by us when transferring your personal data outside the EEA.

10. Data security

We maintain organizational, physical and technical security arrangements for all the personal data we hold. We have protocols, controls and relevant policies, procedures and guidance to maintain these arrangements taking into account the risks associated with the categories of personal data and the processing we undertake, including as appropriate: -

• The pseudonymisation and encryption of personal data;
• The ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services;
• The ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident; and
• A process for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures for ensuring the security of personal data.

11. Which rights do you have with respect to the processing of your personal data?

If you are based within the EEA, you may be entitled under certain circumstances to: -

• Request access to the personal data we process about you: this right entitles you to know whether we hold personal data about you and, if we do, to obtain information on and a copy of that personal data.
• Request a rectification of your personal data: this right entitles you to have your personal data corrected if it is inaccurate or incomplete.
• Object to the processing of your personal data: this right entitles you to request that Flywheel no longer processes your personal data.
• Request the erasure of your personal data: this right entitles you to request the erasure of your personal data, including where such personal data would no longer be necessary to achieve the purposes.
• Request the restriction of the processing of your personal data: this right entitles you to request that Flywheel only processes your personal data in limited circumstances, including with your consent.
• Request portability of your personal data: this right entitles you to receive a copy (in a structured, commonly used and machine-readable format) of personal data that you have provided to Flywheel, or request Flywheel to transmit such personal data to another data controller.
• Request not to be subject to any decision that significantly affects you being taken by automated processing, including profiling.

If you are based in CALIFORNIA you have many of the rights set out at section 11 and you are entitled under certain circumstances to:-

Request access to certain information about the personal data we have shared with third parties for direct marketing purposes.

If you want to initiate a data subject access request, click on this link and fill out the form. We will process any request in line with any local laws and our policies and procedures. We may ask you for additional information to confirm your identity and for security purposes, before disclosing information requested to you.

12. What if you have questions or want further information?

Any questions regarding this notice and our privacy practices should be sent to
‍
Email: Send us an email at: privacy@omnicomgroup.com 

‍Post: Write to us at
Omnicom Group Inc.
 
Attn: General Counsel
 
280 Park Avenue
 
New York, NY 10017

Telephone: 1-833-520-0506

If you wish to make a complaint about how we use your information, please contact us using the contact information above and we will do our best to help. If you are located in the EEA, you have the right to lodge a complaint with the appropriate data protection supervisory authority in your country. We would, however, appreciate the chance to deal with your concerns before you approach your local supervisory authority so please contact us in the first instance.