Last updated: November 7, 2024
TMP Worldwide Advertising & Communications, LLC d/b/a Radancy in the United States (“Radancy US”) has created this Data Privacy Framework Privacy Policy to help you learn about how we handle personal information that is collected by our clients located in the European Economic Area (the “EEA”) and Switzerland and transferred to Radancy US. This Data Privacy Framework Privacy Policy supplements our Privacy Notice at https://www.radancy.com/en/privacy/. Unless specifically defined in this policy, the terms in this Data Privacy Framework Privacy Policy have the same meaning as in that Privacy Notice.
Radancy US has certified to the EU-US Data Privacy Framework and the Swiss-US Data Privacy Framework (collectively “DPF”) for the processing of personal information received from the European Union and Switzerland and, is committed to adhering to the DPF Principles for personal information covered by the Policy. More information about the DPF, including the list of certified organizations, can be found at https://www.dataprivacyframework.gov/. This Policy applies to Radancy US and its US affiliates set forth at the end of this Privacy Policy.
Personal information that is transferred to Radancy US from the EEA and Switzerland falls into two categories: 1) personal information regarding personnel from Radancy US’s clients in the EEA and Switzerland; and 2) customer personal information that Radancy US processes on behalf of its clients (such as name, contact information, applications, and CVs for job candidates). In the case of the latter category, Radancy US acts as a data processor and processes such information only under the instructions from its clients. This information is controlled by its clients in the EEA and Switzerland.
Because the requirements of the DPF vary depending on whether Radancy US is acting as a processor on behalf of its clients or as a data controller, meaning that Radancy US makes independent decisions about how that information will be used, Radancy US’s policies and practices are described separately below.
Radancy US acting as a Processor on Behalf of its Clients
When Radancy US acts as a processor on behalf of its clients, the following policies apply to all data processing operations concerning personal information that has been transferred from the EEA and Switzerland to the United States.
Use of Personal Information
Radancy US will process the personal information only for the purposes requested by the client.
Access and Correction
Radancy US will assist the controller (the client) in responding to individuals exercising their rights under the DPF Principles.
Agents and Service Providers
Radancy US will not transfer personal information to third parties except where permitted or required by the client and then in accordance with the DPF Principles.
Notice & Choice
Because the personal information is under the control of Radancy’s clients, appropriate notice and choice to the individual are provided by Radancy’s clients. As the data processor, Radancy US typically does not have a direct relationship with the clients’ customers.
Radancy US Acting as a Data Controller
Radancy US may receive information from clients in the EEA and Switzerland regarding their employees including name, postal address, telephone number, and e-mail address (collectively, “Personal Information”).
Use of Personal Information
Any Personal Information sent to us may be used by Radancy US and its agents for the purposes indicated in Privacy Notice. If we intend to use your information for a purpose that is materially different from these purposes or if we intend to disclose it to a third party (a non-agent) not previously identified, we will notify you and offer you the opportunity to opt out of such uses and/or disclosures where it involves non-sensitive information or opt-in where sensitive information is involved.
Disclosures to Affiliates and Third Parties
Your Personal Information may be disclosed:
- To our affiliates set forth at the end of this Privacy Policy for the purposes described herein.
- To third parties, to permit them to send you marketing communications or surveys.
- To third-party sponsors of sweepstakes, contests and similar promotions.
- To a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings.
Disclosures to Agents and Service Providers
We sometimes contract with other companies and individuals to perform functions or services on our behalf such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, auditing and other services. They may have access to Personal Information needed to perform their functions but are restricted from using the Personal Information for purposes other than providing services for us or to us. Radancy US requires that its agents and service providers that have access to Personal Information received from the EEA and Switzerland provide the same level of protection as required by the DPF Principles. We are responsible for ensuring that our agents process the information in a manner consistent with our obligations under the DPF Principles.
Data Security
We use reasonable physical, electronic, and administrative safeguards to protect your Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the nature of the Personal Information and the risks involved in the processing that information.
Data Integrity and Purpose Limitation
We limit the collection and use of personal information to the information that is relevant for the purposes of processing and will not process personal information in a way that is incompatible with the purposes for which the information has been collected or subsequently authorized by you. We take reasonable steps to ensure the personal information is reliable for its intended use, accurate, complete, and current to the extent necessary for the purposes for which we use the Personal Information.
Access to Personal Data
You can ask to review and correct Personal Information that we maintain about you by sending a written request to privacy@radancy.com.
DPF Enforcement and Dispute Resolution
If you have any questions or concerns, please write to us at the address listed below. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the DPF Principles.
In the event we are unable to resolve your complaints or disputes, you may contact TRUSTe Dispute Resolution, our ADR provider in the US, and they will investigate and assist you free of charge in resolving your complaint.
As further explained in the DPF Principles, a binding arbitration option will also be made available to you in order to address residual complaints not resolved by any other means. Radancy US is subject to the investigatory and enforcement powers of the US Federal Trade Commission (FTC).
Disclosures Required by Law
We may need to disclose personal information in response to lawful requests by public authorities for law enforcement or national security reasons or when such action is necessary to comply with a judicial proceeding or court order, or when otherwise required by law.
Contact Information
If you have any questions regarding this DPF Privacy Policy, please contact us by email at privacy@radancy.com, or please write to the following address:
TMP Worldwide Advertising & Communications LLC d/b/a Radancy at:
Jesse Hernandez
CIO
TMP Worldwide Advertising & Communications LLC d/b/a Radancy
1 Battery Park Plaza, Ste 2710
New York, NY 10004
Email: privacy@radancy.com
Phone: (646) 613-2000
Privacy Policy Changes
This policy may be changed from time to time, consistent with the requirements of the Data Privacy Framework. You can determine when this Policy was last revised by referring to the “LAST UPDATED” legend at the top of this page. Any changes to our Policy will become effective upon our posting of the revised Policy on the Site.
List of Affiliates
- AIA Holdings Limited
- Ascendify Corporation
- Associates in Advertising Limited
- Brazen Technologies, Inc.
- Carve Consulting London Limited
- CKR Group, Inc.
- firstbird GmbH
- firstbird Pty Limited
- Maximum Alliances B.V.
- People in Business Limited
- PJB Associes SAS
- TMP Government, LLC
- TMP Holdings Canada GP, LLC
- TMP Holdings Canada L.P.
- TMP Intellectual Property Holdings, LLC
- TMP Worldwide (Singapore) Advertising Pte Ltd.
- TMP Worldwide Advertising & Communications (HK) Ltd.
- TMP Worldwide Advertising & Communications Co.
- TMP Worldwide Advertising & Communications, LLC
- TMP Worldwide Germany GmbH
- TMP Worldwide India Private Limited
- TMP Worldwide Publicidade Brasil Limitada