Website Privacy Policy

Effective Date: November 19, 2019

ChaseDesign, LLC (“ChaseDesign”) respects your concerns about privacy. This Website Privacy Notice describes the types of information we collect about individuals on holiday2020.10reddesign.com (the “Site”), how we use the information, with whom we share it, and the choices available regarding our use of the information. The Website Privacy Notice also describes the measures we take to safeguard personal information, how long we retain it, and how individuals can contact us about our privacy practices and to exercise their rights. 

Click on one of the links below to jump to the listed section:

• Information We Obtain
• How We Use Personal Information
• Personal Information Sharing
• Cross-Border Transfer
• Your Rights and Choices
• Other Online Services and Third-Party Features
• Retention of Personal Information
• How We Protect Personal Information
• Children’s Personal Information
• Updates to Our Website Privacy Notice
• How to Contact Us
• Additional Information Regarding the EE

Information We Obtain

Information You Provide

We may collect and store personal information (such as name and other contact details) that you choose to provide to us through the Site or when you contact us. “Personal Information” is information that identifies you as an individual or relates to an identifiable individual. The types of personal information we collect may include:

• Contact information, such as your name and e-mail address; and
• Other personal information you may submit to us, such as when you contact us.

Information We Receive About You from Other Sources

We may receive your Personal Information from other sources, such as publicly available databases and providers of demographic information.

Automated Collection of Information

When you use the Site, we may obtain certain information by automated means, such as browser cookies, beacons, device identifiers, server logs, and other technologies. The information we obtain in this manner may include your device IP address, domain name, identifiers associated with your devices, device and operating system type and characteristics, web browser characteristics, language preferences, clickstream data, your interactions with the Site (such as the web pages you visit, links you click, and features you use), the pages that led or referred you to the Site, dates and times of access to the Site, and other information about your use of the Site.  

A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. Cookie technology holds information a site may need to personalize a visitor’s experience. Cookies may also be used for security purposes. 

You may adjust your cookie settings at any time by clicking here. You can stop certain types of cookies from being downloaded on your computer by selecting the appropriate settings on your web browser. Most web browsers will tell you how to stop accepting new browser cookies, how to be notified when you receive a new browser cookie, and how to disable existing cookies. You can find out how to do this for your particular browser by clicking “help” on your browser’s menu or by visiting www.allaboutcookies.org. The Site is not designed to respond to “do not track” signals received from browsers. Please note that, without cookies or other automated tools, you may not be able to use all of the features of the Site.

We may also use Adobe Flash technology, including Flash Local Shared Objects (“Flash LSOs”) to collect and store information about your use of the Site. If you do not want Flash LSOs stored on your computer, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained in the Website Storage Settings Panel. You can also go to the Global Storage Settings Panel and follow the instructions. Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications. 

These technologies help us (1) track and understand how you use and interact with the Site; (2) measure the usability of the Site; (3) understand the effectiveness of our communications; and (4) otherwise manage and enhance the functionality of the Site. We may use the information collected through these technologies for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat such information as Personal Information under applicable law, then we may use and disclose such information for any of the purposes set out in this Website Privacy Notice.

Third-Party Web Analytics Services 

We use third-party online analytics services, such as Google Analytics. The service providers that administer these analytics services use cookies and similar technologies to collect and analyze information about use of the Site and report on activities and trends and diagnose technical issues. To learn more about Google’s practices, please visit www.google.com/policies/privacy/partners/, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout. 

 Interest-Based Advertising though Advertising Networks

You may see our ads on other websites or mobile apps because we participate in advertising networks such as Google Adwords. Ad networks allow us to target our messaging to users based on demographic data, users’ inferred interests, location, and browsing context. These networks track users’ online activities over time by collecting information through automated means, including through the use of browser cookies, web beacons, device identifiers, server logs, and other similar technologies on the Site and on third-party websites and apps. The networks use this information to show ads that may be tailored to individuals’ interests, to track users’ browsers or devices across multiple websites and apps, and to build a profile of users’ online browsing and app usage activities. The information our ad networks may collect through users’ use of the Site includes data about users’ visits to the Site and this is matched to information about users’ visits to other websites and apps that participate in the relevant ad networks, such as the pages or ads viewed and the actions taken on the websites or apps.

To learn how to opt out of ad network interest-based advertising in the U.S., please visit www.aboutads.info/choices and http://www.networkadvertising.org/choices/. In the European Union, please visit www.youronlinechoices.eu.

How We Use Personal Information

We use the Personal Information we obtain on the Site for legitimate business purposes, including to:

• Provide our services to you; process, evaluate, and respond to your requests and inquiries; and send administrative information to you, such as changes to our terms, conditions, and policies. We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.

• Market our services to you. We will engage in this activity with your consent or where we have a legitimate interest.

• Operate, evaluate, and improve our business (including developing new services; enhancing and improving our services; analyzing our services; managing our communications; performing data analytics and market research; and performing accounting, auditing, and other internal functions). We will engage in these activities to comply with a legal obligation and/or because we have a legitimate interest.

• Protect against, identify, and prevent fraud, security breaches, and other criminal activity and risks. We will engage in these activities to comply with a legal obligation and/or because we have a legitimate interest.

• Comply with and enforce applicable legal requirements, relevant industry standards, and our policies, including this Website Privacy Notice and/or Agency’s Terms and Conditions or Terms of Use. We will engage in these activities to comply with a legal obligation and/or because we have a legitimate interest.

• Aggregate and/or anonymize Personal Information so that it will no longer be considered personal information. We do so to generate other data for our use, which we may use and disclose for any purpose.

Personal Information Sharing

We share your Personal Information with:

• The Interpublic Group of Companies, Inc. (“IPG”) agencies or companies, for the purposes described in this Website Privacy Notice. You can consult the list and location of such entities here.
• Our service providers who perform services on our behalf, such as hosting this Site or data analytics. We do not authorize our service providers to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements.

We also may disclose information about you (1) if we are required to do so by law or legal process (such as a court order or subpoena), including laws outside your country of residence; (2) in response to requests by, or cooperate with, government agencies, such as law enforcement authorities, including outside of your country of residence; (3) to establish, exercise, or defend our legal rights; (4) when we believe disclosure is necessary or appropriate to protect our rights, privacy, safety, or property and/or that of our affiliates, you, or others; (5) in connection with an investigation of suspected or actual illegal activity; (6) in connection with the sale or transfer of all or a portion of our business, assets, or stock (including in the event of a reorganization, dissolution, or liquidation); or (7) otherwise with your consent.

Cross-Border Transfer

Your personal information may be processed and stored in any country where we have facilities or in which we engage service providers, and, by using the Site, you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies, or security authorities in those other countries may be entitled to access your personal information.

ADDITIONAL INFORMATION REGARDING THE EUROPEAN ECONOMIC AREA (“EEA”): Some non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here. For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission to protect your personal information. You may obtain a copy of the EU’s Standard Contractual Clauses here.

Your Rights and Choices

We offer you certain choices in connection with the personal information we obtain about you. If you would like to request to review, correct, update, suppress, restrict, or delete personal information, to object to the processing of personal information, or to receive an electronic copy of your personal information for purposes of transmitting it to another company (to the extent these rights are provided to you by applicable law), please contact us as specified in the How to Contact Us section of this Website Privacy Notice. We will respond to your request consistent with applicable law.  

To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to your information. To the extent permitted by applicable law, a charge may apply before we provide you with a copy of any of your personal information that we maintain.

You can unsubscribe from our marketing mailing lists by following the “Unsubscribe” link in our marketing emails. If you would like to unsubscribe from any other type of marketing you receive from us, please contact us as specified in the How to Contact Us section of this Website Privacy Notice.

Other Online Services and Third-Party Features

The Site may provide links to other online services and websites for your convenience and information, and may include third-party features such as apps, tools, widgets, and plug-ins (e.g., LinkedIn, Instagram, Facebook, and Twitter buttons). These services and websites may operate independently from us. The privacy practices of these third parties, including details on the information they may collect about you, are subject to their own privacy statements. To the extent any linked online services or third-party features are not owned or controlled by us, ChaseDesign is not responsible for these third parties’ information or other practices.

Retention of Personal Information

We retain personal information for as long as needed or permitted in light of the purposes for which we obtained it and consistent with applicable law. The criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you and provide the Site or our services to you;
• Whether there is a legal obligation to which we are subject; and
• Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitation, litigation, or regulatory investigations).

How We Protect Personal Information

We seek to use reasonable administrative, technical and physical safeguards designed to protect personal information within our organization. Unfortunately, no information transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the How to Contact Us section of this Website Privacy Notice.    

Children’s Personal Information

The Site is designed for a general audience and is not directed to children under the age of 16. ChaseDesign does not knowingly collect or solicit personal information from children under the age of 16 through the Site.  If you believe that a child under the age of 16 may have provided us with personal information through the Site, please contact us as specified in the How to Contact Us section of this Website Privacy Notice.

Updates to Our Website Privacy Notice

This Website Privacy Notice may be updated periodically and without prior notice to you to reflect changes in our personal information practices. We will indicate at the top of the notice when it was most recently updated. Any changes will become effective when we post the revised Website Privacy Notice on the Site.

How to Contact Us

ChaseDesign, LLC, located at 1326 New Seneca Turnpike, Skaneateles, NY 13152, is the company responsible for collection, use, and disclosure of your personal information under this Website Privacy Notice.

To contact us in relation to this Privacy Notice or any privacy matter, including our use of your personal information or to exercise other applicable privacy rights, please use the following contact details:

ATTN: Operations Team

1326 New Seneca Turnpike

Skaneateles, NY 13152

privacy@chasedesign.net

Additional Information Regarding the EEA

Our GDPR Data Protection Officer can be contacted via post or email using the following details:

GDPR DPO

Interpublic Group Limited

66 Prescott Street

London E1 8 HG

GDPR.DPO@interpublic.com

You have the right to lodge a complaint with a data protection authority for your country or region or where an alleged infringement of applicable data protection law occurs. A list of data protection authorities is available here.

LAST UPDATED: December 2, 2022

CALIFORNIA PRIVACY NOTICE

ChaseDesign, LLC and its affiliates (“ChaseDesign,” “we,” “us,” or “our”) provide this Privacy Notice, which applies to California resident employees, employee applicants, owners, directors, officers, and contractors of ChaseDesign, as well as, as applicable, those individuals’ emergency contacts and beneficiaries who are California residents.  This Privacy Notice sets forth our practices with respect to information that can reasonably be linked with an individual (“Personal Information”), as required by the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”), collectively herein referred to as the “CA Privacy Law”. 

Please note, there may be additional or different privacy notices or disclosures that govern our use of your Personal Information beyond the CA Privacy Law.  Where collection, use, and disclosure of Personal Information is subject to the CA Privacy Law, this Privacy Notice shall prevail.  For collection, use, and disclosure of Personal Information beyond the CA Privacy Law, those separate and relevant privacy notices and disclosures shall prevail.

Collection and Disclosure of Personal Information

The following chart details which categories of Personal Information we collect and process, as well as which categories of Personal Information we disclose to third parties for our operational business and employment purposes, including within the 12 months preceding the date this Privacy Notice was last updated.

Categories of Personal Information	Disclosed to Which Categories of Third Parties for Operational Business Purposes
Identifiers, such as name and government-issued identifier (e.g., Social Security number)	Our affiliates; service providers providing services such as payroll, benefits, consulting, training, expense management, medical benefits, IT, and other services; professional advisors, such as accountants, auditors, bankers, and lawyers; public and governmental authorities, such as regulatory authorities and law enforcement; business partners, such as entities that help us to provide services to you (e.g., a corporate credit card).
Personal information, as defined in the California safeguards law, including without limitation, 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	Our affiliates; service providers providing services such as payroll, benefits, consulting, training, expense management, medical benefits, IT, and other services; professional advisors, such as accountants, auditors, bankers, and lawyers; public and governmental authorities, such as regulatory authorities and law enforcement; business partners, such as entities that help us to provide services to you (e.g., a corporate credit card).
Protected Class Information, such as characteristics of protected classifications under California or federal law, including without limitation, age, gender, medical conditions, marital status, sex (including pregnancy, childbirth, breastfeeding, and related medical conditions), race, color, religion or creed, ancestry, national origin, disability, genetic information, sexual orientation, gender identity and expression, citizenship, primary language, immigration status, military/veteran status, political affiliation/activities, domestic violence victim status, and requests for leave	Our affiliates; service providers providing services such as payroll, benefits, consulting, training, expense management, medical benefits, IT, and other services; professional advisors, such as accountants, auditors, bankers, and lawyers; public and governmental authorities, such as regulatory authorities and law enforcement; business partners, such as entities that help us to provide services to you (e.g., a corporate credit card).
Commercial Information, such as transaction information and purchase history, travel expenses, including information about corporate credit card purchases, frequent flyer rewards, and other travel-related programs and expenses	Our affiliates; service providers providing services such as payroll, benefits, consulting, training, expense management, medical benefits, IT, and other services; professional advisors, such as accountants, auditors, bankers, and lawyers; public and governmental authorities, such as regulatory authorities and law enforcement; business partners, such as entities that help us to provide services to you (e.g., a corporate credit card).
Biometric Information, such as face scans, fingerprints, and voiceprints Note: biometric information is sensitive personal information also referenced below	Our affiliates; service providers providing services such as payroll, benefits, consulting, training, expense management, medical benefits, IT, and other services; professional advisors, such as accountants, auditors, bankers, and lawyers; public and governmental authorities, such as regulatory authorities and law enforcement; business partners, such as entities that help us to provide services to you (e.g., a corporate credit card).
Internet or Network Activity Information, such as browsing history and interactions with our websites and applications, access and usage information regarding websites, applications, and systems, information about online communications, including browsing and search history, timestamp information, IP address, and access and activity logs	Our affiliates; service providers providing services such as payroll, benefits, consulting, training, expense management, medical benefits, IT, and other services; professional advisors, such as accountants, auditors, bankers, and lawyers; public and governmental authorities, such as regulatory authorities and law enforcement; business partners, such as entities that help us to provide services to you (e.g., a corporate credit card).
Geolocation Data, such as latitude/longitude, precise location information, device location, approximate location derived from IP address, and GPS, WiFi, or Bluetooth Low Energy tracking	Our affiliates; service providers providing services such as payroll, benefits, consulting, training, expense management, medical benefits, IT, and other services; professional advisors, such as accountants, auditors, bankers, and lawyers; public and governmental authorities, such as regulatory authorities and law enforcement; business partners, such as entities that help us to provide services to you (e.g., a corporate credit card).
Audio, electronic, visual and similar information, such as photographs, images, call and video recordings, including voicemail and security camera footage, information about the use of electronic devices and systems, key card usage, photos on websites or in employee directories	Our affiliates; service providers providing services such as payroll, benefits, consulting, training, expense management, medical benefits, IT, and other services; professional advisors, such as accountants, auditors, bankers, and lawyers; public and governmental authorities, such as regulatory authorities and law enforcement; business partners, such as entities that help us to provide services to you (e.g., a corporate credit card).
Education Information subject to the federal Family Educational Rights and Privacy Act, such as student records and directory information	Our affiliates; service providers providing services such as payroll, benefits, consulting, training, expense management, medical benefits, IT, and other services; professional advisors, such as accountants, auditors, bankers, and lawyers; public and governmental authorities, such as regulatory authorities and law enforcement; business partners, such as entities that help us to provide services to you (e.g., a corporate credit card).
Professional or Employment Information, such as work history, prior employer, information from reference checks, background screening information, employment application, membership in professional organizations, personnel files, personal qualifications and training, eligibility for promotions and other career-related information, work preferences, business expenses, wage and payroll information, benefit information, information on leaves of absence or PTO, performance reviews, information on internal investigations or disciplinary actions	Our affiliates; service providers providing services such as payroll, benefits, consulting, training, expense management, medical benefits, IT, and other services; professional advisors, such as accountants, auditors, bankers, and lawyers; public and governmental authorities, such as regulatory authorities and law enforcement; business partners, such as entities that help us to provide services to you (e.g., a corporate credit card).
Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s preferences, characteristics, predispositions and abilities	Our affiliates; service providers providing services such as payroll, benefits, consulting, training, expense management, medical benefits, IT, and other services; professional advisors, such as accountants, auditors, bankers, and lawyers; public and governmental authorities, such as regulatory authorities and law enforcement; business partners, such as entities that help us to provide services to you (e.g., a corporate credit card).
Sensitive Personal Information: Personal Information that reveals an individual’s Social Security, driver’s license, state identification card, or passport number; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin, religious or philosophical beliefs, citizenship, immigration status, or union membership; the contents of mail, email, and text messages unless Company is the intended recipient of the communication; genetic data; The processing of biometric information for the purpose of uniquely identifying an individual; Personal Information collected and analyzed concerning an individual’s health; andPersonal Information collected and analyzed concerning an individual’s sex life or sexual orientation.	Our affiliates; service providers providing services such as payroll, benefits, consulting, training, expense management, medical benefits, IT, and other services; professional advisors, such as accountants, auditors, bankers, and lawyers; public and governmental authorities, such as regulatory authorities and law enforcement; business partners, such as entities that help us to provide services to you (e.g., a corporate credit card).

We may also disclose the above categories of Personal Information to a third party in the context of any reorganization, financing transaction, merger, sale, joint venture, partnership, 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).

We do not sell Personal Information of covered individuals, and we do not share or otherwise process Personal Information of covered individuals for purposes of cross-context behavioral advertising, as defined under the CA Privacy Law.  We have not engaged in such activities in the 12 months preceding the date this Privacy Notice was last updated. 

We do not knowingly sell or share the Personal Information of minors under 16 years of age.

Sources of Personal Information

We collect Personal Information from you and from our affiliates, your colleagues and managers, references you provide, prior employers or schools, clients, background check providers, providers of employee benefits, social networks, publicly available databases, and cooperative databases.  We collect Personal Information about our employees’ and other individuals’ emergency contacts and beneficiaries from such employees or other individuals.

Purposes for the Collection, Use and Disclosure of Personal Information

We may collect or use Personal Information for the purposes of operating, managing, and maintaining our business, managing our workforce and other employment purposes, and accomplishing our business purposes and objectives, including, for example, using Personal Information to:

• Plan and manage workforce activities and personnel generally, including for recruitment, employee onboarding, appropriate staffing, performance management, training and career development, payments and benefit administration, employee training, leaves and promotions;
• Conduct workforce assessments, including determining physical or mental fitness for work and evaluating work performance;
• Process payroll, manage wages and other awards such as stock options, stock grants and bonuses, reimburse expenses, and provide healthcare, pensions, savings plans and other benefits;
• Operate, maintain, monitor, and secure our facilities, equipment, systems, networks, applications, and infrastructure;
• Manage attendance, time keeping, leaves of absence, and vacation;
• Facilitate employee communication and workforce travel;
• Undertake quality and safety assurance measures, protect the health and safety of our workforce and others, and conduct risk and security control and monitoring;
• Conduct research, analytics, and data analysis, such as to assist in succession planning and to ensure business continuity, as well as to design and implement employee retention programs, diversity, equity, and inclusion initiatives, and environmental, social, and governance (“ESG”) initiatives;
• Perform identity verification, accounting, budgeting, audit, and other internal functions, such as internal investigations, disciplinary matters, and handling grievances and terminations;
• Operate and manage IT and communications systems and facilities, allocate Company assets and human resources, and undertake strategic planning and project management; and
• Comply with law, legal process, requests from governmental or regulatory authorities, internal policies, and other requirements, such as income tax deductions, recordkeeping, work permit and immigration regulations and reporting obligations, and the exercise or defense of legal claims.

Use and Disclosure of Sensitive Personal Information

We may use Sensitive Personal Information for purposes of performing services for our business, providing services as requested by you, and ensuring the safety, security and integrity of our business, infrastructure, and the individuals with whom we interact.  This includes, without limitation, establishing and maintaining your employment relationship with us, ensuring the safety and diversity of our workforce, designing and implementing ESG initiatives, complying with legal obligations, defending or asserting legal claims, managing payroll and corporate credit card use, administering and providing benefits, and securing the access to, and use of, our facilities, equipment, systems, networks, applications, and infrastructure.

Retention Period

We retain Personal Information including, without limitation, Sensitive Personal Information, for as long as needed or permitted in light of the purpose(s) for which it was collected.  The criteria used to determine our retention periods include: 

• The duration of your employment;
• The length of time we have an ongoing relationship with you or your dependents/beneficiaries and the length of time thereafter during which we may have a legitimate need to reference your Personal Information, such as to address issues that may arise;
• Whether there is a legal obligation to which we are subject (for example, certain laws may require us to keep your employment records for a certain period of time); and
• Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation, or regulatory investigations). 

Individual Requests

You may, subject to applicable law, make the following requests:

1. You may request we disclose to you the following information covering the 12 months preceding your request:
   1. The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
   1. The business or commercial purpose for collectingPersonal Information about you; and
   1. The categories of Personal Information about you we otherwise disclosed and the categories of third parties to whom we disclosed such Personal Information.
2. You may request to correct inaccuracies in your Personal Information.
3. You may request to have certain Personal Information you provided to us deleted.
4. You may request to receive a copy of your Personal Information, including a copy of the Personal Information you provided to us in a portable format.

We will not unlawfully discriminate against you for exercising a right conferred by the CA Privacy Law.  Without limitation, we will not retaliate against you for exercising such a right.  To make a request, please contact us at https://ncv.microsoft.com/khZ8jEBrCI or 1-888-474-8778.  We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the Personal Information subject to the request.  We may need to request additional Personal Information from you in order to verify your identity and protect against fraudulent requests.  If you maintain a password-protected account with us, we may verify your identity through our existing authentication practices for your account and require you to re-authenticate before disclosing or deleting your Personal Information.  If you make a request to delete, we may ask you to confirm your request before we delete your Personal Information.

We will verify and respond to your request consistent with applicable law.

Authorized Agents

If an agent would like to make a request on your behalf as permitted by applicable law, the agent may use the submission methods noted above.  As part of our verification process, we may request that the agent provide, as applicable, proof concerning their status as an authorized agent.  In addition, we may require that you verify your identity as described above or confirm that you provided the agent permission to submit the request.

Changes to this Privacy Notice

We may change or update this notice from time to time.  When we do, we will post the updated notice on this page with a new “Last Updated” date. 

Contact Us

If you have questions regarding this Privacy Notice, please contact your local Human Resources department, HR Privacy Champion, or email us at cdshr@chasedesign.net.