Privacy Policy

This Privacy Policy addresses our privacy practices in connection with Gannett Fleming and www.gannettfleming.com (the “Site”) and informs you of our policies regarding the collection, use and disclosure of personal information we receive from users of the Site.

About our Privacy Policy

Gannett Fleming respects your right to privacy and recognizes a responsibility with respect to the processing of personal data. We do not collect or process personal data unnecessarily. This privacy policy, together with our terms of service (the “Terms of Service”), provides important information about your rights with respect to the processing of your personal data, and the basis on which any personal data we collect from you, or that you provide to us, will be processed in connection with your use of the Site and/or the Gannett Fleming CRM platform, app or services (the “Services”). We do not knowingly attempt to solicit or receive information from children.

Controller

Under this Policy, and unless the circumstances otherwise require, we will be what’s known under the General Data Protection Regulation (EU) 2016/679 (the “GDPR”) as the “controller” of the personal data you provide to us. An example of such other circumstances would be where you enter into a contract with us to subscribe to the Services, in which case we would normally be the processor and you would be the controller within the meaning of the GDPR and this would be set out in more detail in the Terms of Service or other relevant contracts between us.

The information we collect

We will collect and process the following data about you for the following purposes:

Information you give us

Your Data. This is information about you that you give us by filling in forms on the Site or by corresponding with us by phone, e-mail, or otherwise. It includes information you provide when you use the Site, register for, subscribe to or use the Services, search for a product, place an order on the Site, participate in discussion boards or other social media functions on the Site and/or when you participate in and respond to our sign-up or other surveys or report a problem with the Site and/or the Services. The information you give us may include:

Identity Data: your full name, address, e-mail address, phone number, address, age, title, and personal description.

Financial Data: your financial and credit card information, including bank account and payment card details, billing contact email address, and VAT number.

Your End Customer Data. When using the Site and/or the Services, you may input or store the personal data of your customers, clients, suppliers, or other existing or prospective sales, sales leads, or business contacts or partners, including, for example, their names, email address, company name, job title, phone number and other contact details, appointments and other meeting arrangements (“Your End Customer Data”). We have no direct relationship with the individuals whose personal data we host as part of Your End Customer Data. You are responsible for providing notice to your customers and third persons concerning the purpose for which you collect their personal data and how this personal data is processed in or through the Services as part of Your End Customer Data. You are also responsible for the completeness and accuracy of Your End Customer Data.

The information we collect about you

Automatically Collected Information. With respect to each of your visits to the Site, we will automatically collect the following information:

Technical Data: technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your Site login information, browser type, and version, time zone setting, browser plug-in types and versions, operating system and platform, how often you use the application and other performance data which may be subject to analytics software;

Usage Data: information about your visit, including the full Uniform Resource Locators (URL), clickstream to, though, and from the Site including date and time, products you viewed or searched for, page response times, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call us; and

Public Data: publicly available data used to create a more complete customer profile and provide better customer support. The term “Public Data” is defined as the information received from a third-party partner. Public Data may be claimed, edited, or discarded from their systems and is subject to their privacy policy.

No special categories of personal data: We do not require or collect any personal data that is your sensitive personal data or any special category of personal data under domestic regulations or EU GDPR unless you decide to provide this information to us.

Cookies

What are cookies and why we use them

The Site may use electronic “cookies” from time to time. Cookies are small text files that are stored by your browser on your computer and are normally used to gather statistical information and to analyze trends of use or access to a website. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies may be used to save your personal preferences, so you do not have to re-enter them each time you access the Site.

What we do with your information

We will only use your personal information when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract, we are about to enter or have entered into with you.

  • Where it is necessary for our legitimate interest (or those of a third party) and your interests and fundamental rights do not override those interests.

  • Where we need to comply with a legal or regulatory obligation.

  • We have set out below, in a table format, a description of the ways we plan to use your personal data and the legal basis we rely only on to do so. We have also identified our legitimate interests where appropriate:

Purpose/Activity Type of data Legal basis for processing
To respond to your queries and to provide you with the information you request from us in relation to our products or Services. Identity Data Technical Data Usage Data Public Data Necessary for our legitimate interests (to respond to new or existing customer queries and grow our business) Performance of a contract with you
To set up and administer your account for the Services. Identity Data Performance of a contract with you
To provide the Services and perform our obligations arising from any contracts entered between you and us. Identity Data Financial Data Technical Data Usage Data Performance of a contract with you
To manage payments, fees, and charges and to collect and recover money owed to us. Identity Data Financial Data Performance of a contract with you Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you, including notifying you about changes to the Services, our Terms of Services or Privacy Policy. Identity Data Technical Data Usage Data Public Data Performance of a contract Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how customers use our products and services).
To provide you with information about goods and services we offer that are like those that you have already purchased or enquired about. Identity Data Technical Data Usage Data Public Data Necessary for our legitimate interests (to develop our products or Services and grow our business)
Where you have given us your consent to do so, to provide you with information about other goods or services we feel may interest you. Identity Data Technical Data Usage Data Consent
To ensure that content is presented in the most effective manner for you and for your computer or device. Identity Data Technical Data Usage Data Necessary for our legitimate interests (to keep the Site and the Services updated and relevant and to develop and grow our business).
To administer and protect our business, the Site, the Services, and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes. Identity Data Technical Data Usage Data Public Data Necessary for our legitimate interests (for running our business and as part of our efforts to keep the Site and the Services safe and secure)
To use data analytics to improve or optimize the Site, Services, marketing, customer relationships, and experiences Technical Data Usage Data Necessary for our legitimate interests (to define types of customers for our products and services, to keep the Site and the Services updated and relevant, to develop and grow our business and inform our marketing strategy).
To allow you to participate in interactive features of the Services (including surveys), when you choose to do so. Identity Data Technical Data Usage Data Performance of a contract with you necessary for our legitimate interests (to study how customers use our products or Services, to develop them and grow our business
To measure or understand the effectiveness of advertising we serve to you and others, and, where applicable, to deliver relevant advertising to you. Identity Data Technical Data Usage Data Necessary for our legitimate interests (to study how customers use our products or Services, to develop them, to grow our business, and to inform our marketing strategy).

Change of purpose

We will only use your personal data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at [email protected] If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with this Policy, where this is required or permitted by law.

How long we keep your information

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. This means that the period for which we store your personal data may depend on the type of data we hold. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data, and whether we can achieve those purposes through other means, and the applicable legal requirements. For more information about our data retention policies please contact us at [email protected].

Disclosure of your information

We do not sell your personal information to third parties. We may disclose information to third parties if you consent to us doing so as well as in the following circumstances:

You agree that we have the right to share your personal information with the following recipients or categories of recipients.

Any department or authorized person within our company or any member company within our group, which means any subsidiary, affiliated, or holding company.

Selected third parties including business partners, suppliers, and sub-contractors for the performance of any contract we enter with them or you in relation to the Services.

Where we have your consent to do so, email marketing service providers to send information to you from time to time by email about promotions, competitions, updates, and new products or services that may be of interest to you.

Analytics and search engine providers that assist us in the improvement and optimization of the Site.

Credit reference agencies for the purpose of assessing your credit score to the extent this is a condition of us entering a contract with you.

We will disclose your personal information to third-party recipients.

If we are under a duty to disclose or share your personal data in order to comply with any law, legal obligation, or court order, or in order to enforce rights under domestic regulations or the GDPR or to apply our Terms of Service and other agreements.

To protect our rights, property or safety, our customers, or others. This includes exchanging information with other companies and organizations for the maintenance and security of the Site and Services.

Google API Services

Additional Limits on Use of Your Google User Data

To avail of certain features, Gannett Fleming requests users’ access to their data via Google API services. Notwithstanding anything else in this Privacy Policy, if you provide Gannett Fleming access to the following types of your Google data, Gannett Fleming’s use of that data will adhere to the Google API Services User Data Policy including the Limited Use requirements.

International Transfers

Personal Data may be transferred to our trusted partners and service providers who maintain their servers outside of the domestic U.S. States, North America, and the European Economic Area (“EEA”), where the privacy and data protection laws may not be as protective as those in your jurisdiction. This is only for the purposes of providing, and to the extent necessary to provide, the Services to you. There are special requirements set out under Chapter V of the GDPR (with which we would comply) to regulate such data transfers and ensure that adequate security measures are in place to safeguard and maintain the integrity of your personal data on transfer. For more information about this and the safeguards in place relating to the transfer, please contact us by email at [email protected].

Security Measures

Acknowledgment and Disclaimer

We take our security responsibilities seriously, using the most appropriate physical and technical measures, and require our hosting partner to use the same standard of care. Unfortunately, the transmission of information via the internet is not completely secure. Although we will employ measures to protect your personal data, we cannot guarantee the security of your data transmitted to the Site; any transmission is at your own risk. Once we have received your information, we will use procedures and security features to try to prevent unauthorized access. These are described in more detail below.

Location of Servers and Accessibility

The Services are a SaaS-based CRM (Customer Relationship Management) system and, as such, your personal data is not stored locally but on a secure cloud-based server. No installs are required on your PC or laptop. Our web application is only accessible via HTTPS, which helps ensure your interactions with our app are secure and private.

Data Storage

Your personal data is stored on secure servers hosted on Amazon Web Services, a service provided by Amazon.com. These servers are located in the USA. Amazon Web Services comply with Standard Contractual Clauses as a valid mechanism for transferring data outside the European Union. You can read more about Amazon’s security policy on AWS Cloud Security.

Data Encryption

Data is encrypted using SSL Certification when transmitted from our servers to your browser. The connection from us to the server is secured using a 256 BIT ENCRYPTION key.

Restricted Access

Our servers in Amazon’s data center are run in an isolated private network (Amazon Virtual Private Cloud Service). Access to the production environment where your personal data is stored is limited and is held by us. Only our authorized staff have access to our servers, and this is on a ‘need to access’ basis. Access to personal data is limited to a specific IP address.

Development and Operations

New features and updates are developed and released on development servers prior to being pushed live to the main production environment. Extensive testing is undertaken by our Team to ensure all new features are working correctly and the performance of the Site and Services is maintained.

Passwords and Authentication

Connection to the Services environment is via TLS cryptographic protocols, using global step-up certificates, ensuring that our users have a secure connection from their browsers to our service. Individual user sessions are identified verified using a unique token created at login. Email address is the unique identifier in the Services.

Your Personal Data and Your Rights

Accessing your Personal Data

You may request access at any time to a copy of the personal data we hold about you. Any such request should be submitted to us in writing and sent to [email protected]. We will need to verify your identity in such circumstances and may request more information or clarifications from you if needed to help us locate and provide you with the personal data requested. There is usually no charge applied to access your personal data (or to exercise any of the other rights). However, if your request is clearly unfounded, repetitive, or excessive, we may charge a reasonable fee. Alternatively, we may refuse to comply with your request in these circumstances.

Right of Restriction

You may restrict us from processing your personal data in any of the following circumstances:

You have contested the accuracy of the personal data we hold on record in relation to you or for a period of time to enable us to verify the accuracy of the personal data.

The processing of your personal data is unlawful, and you request the restriction of the use of personal data instead of its erasure.

We no longer require your personal data for the purpose of processing, but you require this data for the establishment, exercise, or defense of legal claims.

Where you have contested the processing pending the verification of our legitimate grounds.

Corrections or Erasure (Right to Rectification and Right to Be Forgotten)

If we hold personal data concerning you which are no longer necessary for the purposes for which they were collected or if you withdraw consent for us to process your personal data, you can request the deletion of this personal data. This right, however, will not apply where we are required to process personal data in order to comply with a legal obligation or where the processing of this information is carried out for reasons of public interest in the area of public health. If the personal information we hold about you is inaccurate, you may request to have your personal information updated and corrected. To do so at any time, please contact us by email at [email protected].

Your Right to Object

You have the right to object to the processing of your personal data at any time:

For direct marketing purposes.

For profiling, to the extent, it relates to direct marketing.

Where we process your personal data for the purposes of legitimate interests pursued by us, except where we can demonstrate compelling legitimate grounds for this processing which would override your interests, rights, and freedoms or in connection with the enforcement or defense of a legal claim.

To exercise your right to object at any time, please email [email protected]. Should this occur, we will no longer process your personal data for these purposes unless doing so is justified by a compelling legitimate ground as described above. For more information about our marketing practices, please see the Marketing Communications section below.

Data Portability

Where we process your personal data by automated means (i.e., not on paper) and this processing is based on your consent or required for the performance of a contract between us, you have the right to request from us a copy of your personal data in a structured, commonly used machine-readable format and, where technically feasible, to request that we transmit your personal data in this format to another controller.

Profiling

Profiling is an automated form of processing of personal data often used to analyze or predict the personal aspects of an individual person. This could relate to a person’s performance at work, economic situation, health, personal preferences, reliability, behavior, location, or movements. An example of this would be where a bank uses an automated credit scoring system to assess and reject a loan application.

You have the right to be informed if your personal data will be subject to automated decision making, including profiling. You also have the right not to be subject to a decision based solely on the automated process, including profiling, where that decision impacts on your legal rights. There are some exceptions to this rule, where, for example, the decision is necessary for connection with the performance of a contract between us, is authorized by law, or where you have given your explicit consent to this automated processing. In this case, however, we do not engage in profiling or automated processing for profiling purposes.

Personal Rights

The rights described in this section are personal rights and are exercisable only by the individual person (or data subject) concerned. If we receive any such request or communication directly from your customers and/or in relation to your end-customer-data, we will refer the matter to you and cooperate in providing such reasonable assistance as may be required to enable you, as a data Controller, to respond to the matter. This may be described in more detail in the Terms of Service or the other relevant contract between us.

Marketing Communications

We will not use your data to send marketing communications to you about promotions, competitions, updates, and new products or services that may be of interest to you unless we have your permission to do so.

Your Right to Object

You have the right to object to the processing of your personal data for our marketing purposes. To object or if you change your mind at any later time, you can withdraw your consent to the processing of your personal data for such marketing purposes by contacting us at [email protected]. You may also opt-out of receiving marketing communications at any time by selecting the unsubscribe option when you receive electronic marketing communication from us. The withdrawal of your consent will not impact upon the lawfulness of processing based on your consent prior to the withdrawal.

We use MailChimp and other email marketing service providers

Some of our communications may be sent by email using MailChimp. Mailchimp’s servers and offices are located in the USA so if you choose to receive marketing communications from us by email, this means that your personal data may be transferred to, stored, or processed in the USA and you consent to the transfer, storing, and processing of your personal data in this way. MailChimp complies with Standard Contractual Clauses as a valid mechanism for transferring data outside the European Union. A copy of Mailchimp’s privacy policy is published at MailChimp’s Legal Policies.

We use ON24 for our INSIGHTS Webcast series.

Our ON24 Engagement Hub is hosted by ON24. Contact ON24 for their current privacy and cookie policies.

Third-Party Material

We always endeavor to deal with vendors and other third parties who are compliant with domestic regulations or the GDPR or, in the case of the third parties located outside of the EEA, who are compliant with Standard Contractual Clauses, or who have adequate security measures in place to safeguard the security of personal data. That said, we, our employees, agents, a holding company, and subsidiaries, accepts no liability howsoever arising for the content or reliability of any third-party materials or websites referenced by hyperlink or other means on the Site or for the data collection and use practices or security measures used by such third parties. If you submit personal data to any of those sites, your personal data is governed by their privacy policy. We encourage you to carefully read their privacy policies.

Changes to this policy

Any changes made to this Policy from time to time will be published at the Site.

Any material or other change to the data processing operations described in this Policy which is relevant to or impacts on you or your personal data will be notified to you in advance by email. In this way, you will have an opportunity to consider the nature and impact of the change and exercise your rights under the domestic regulations or the GDPR in relation to that change (e.g., to withdraw consent or to object to the processing) as you see fit.

Questions or Complaints

Should you have any queries or complaints relating to this Privacy Policy, please contact us at: [email protected].

Last update: 11th of September 2021