CHEIL USA
WEBSITE PRIVACY POLICY

Last updated: October 16, 2023

Cheil (“we”, “our”, or “us”) understands that privacy is important to our users. This Privacy Policy describes our practices regarding the collection, use, sharing, and protection of your personal information for the website located at https://us.cheil.com/ (the “Website”). This Privacy Policy also tells you about the rights and choices you have with respect to your personal information, how you can assert those rights, and how you can contact us to get answers to your questions.

With respect to the personal information that our clients and their vendors collect from you outside of our Website and provide to us via use of our agency services, where permitted by law, we process such information only as a “service provider” or “data processor” (as those terms are defined under applicable data protection laws). Our clients are the parties that control the use of this data and determine the purposes for which we process such information. To learn more about such clients’ use of your information and your rights that you may have over such information, please consult the privacy policy of the applicable company or publisher.

Please note that our privacy practices are subject to the applicable laws of the regions in which we operate. Accordingly, some additional region-specific terms will only apply to individuals in those locations, or as required by applicable laws.

For more information about how users with disabilities can access this Privacy Policy in an alternative format, please email a request for support to americas.it@cheil.com.

BY USING OR ACCESSING THE WEBSITE, YOU AGREE TO THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH OUR POLICIES OR PRACTICES, YOU SHOULD NOT USE OR ACCESS THE WEBSITE OR PROVIDE US WITH ANY PERSONAL INFORMATION.

The following links will take you directly to the corresponding sections of this Privacy Policy:

WHAT OUR PRIVACY POLICY COVERS

This privacy policy applies to the personal information that we obtain in various contexts, including when you:

We may provide different or additional privacy notices in connection with certain activities, programs, and offerings. Additionally, we may provide additional “just-in-time” notices or notices at collection that may supplement or clarify our privacy practices or provide you with additional choices regarding your personal information.

PERSONAL INFORMATION WE COLLECT FROM YOU

We use the term “personal information” – also called “personal data” or “personally identifiable information” in the laws of some jurisdictions – to refer to information that reasonably identifies, relates to, describes, or can be associated with you. Data that has been deidentified or that otherwise cannot reasonably be related back to a specific person is not considered personal information. The precise definition of personal information may vary depending on your place of residence, but we take the same general approach to protecting your privacy, subject to any additional measures that may be required by applicable laws.

The following are the categories and types of personal information that we may collect from or about you, depending on how you interact with the Website:

When you submit a job application to us via our website, we use third-party vendor Paycor to process your personal information. Please visit the Paycor Privacy Policy for additional information about Paycor’s privacy practices.

HOW WE COLLECT YOUR PERSONAL INFORMATION

Personal Information You Provide

We collect personal information that you provide to us directly. This may include, but is not limited to:

Personal Information We Collect Automatically

When you visit our Website, we or third parties we work with may automatically collect certain information using technologies such as cookies and other tracking technologies described below.

"Cookies" are pieces of information that may be placed on your computer by a website for the purpose of collecting data to facilitate and enhance your communication and interaction with that website. Such data may include, for example, the address of the websites you visited before and after you visited our Website, the type of browser you are using, your Internet Protocol (IP) address, what pages in the Website you visited and what links you clicked on, the region where your device is located, and geographic information based on your IP data. We may store some information on your device or device hard drive as a cookie or similar type of file (such as clear gifs, web beacons, tags, and similar technologies that work on mobile devices) to collect data related to usage of the Website. We may also use cookies to customize your visit to the Website and for other purposes to make your visit more convenient or to enable us to enhance the Website.

As you use the Internet, a trail of electronic information is left at each website you visit. This information, which is sometimes referred to as "clickstream data," can be collected and stored by a website's server. Clickstream data can tell us the type of computer and browsing software you use and the address of the website from which you linked to the Website. We may collect and use clickstream data as a form of aggregate information to anonymously determine how much time visitors spend on each page of our Website, how visitors navigate throughout the Website, and how we may tailor our web pages to better meet the needs of visitors. This information will be used to improve our Website.

We may work with third-party vendors who use the technologies described in this section to conduct website analytics to help us track and understand how visitors use our Website and other Services. One such provider is Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help analyze how users use the Website. The information generated by these cookies about your use (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the Website, compiling reports on activity for its staff, and providing other services relating to web page activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. You may refuse the use of cookies by selecting the appropriate settings in your browser. By using the Website and accepting cookies, you consent to the processing of data about you by Google in the manner and for the purposes set out above. Please refer to the currently available opt-outs for Google Analytics by visiting https://tools.google.com/dlpage/gaoptout/.

If you interact with us on social media or use features, such as plugins, widgets, or other tools made available by social media platforms or networks (such as Instagram) in connection with our Website, we may collect information that you share with us on social media or that such platforms share with us. Please review the privacy policies and settings of the social media platforms and networks that you use for more information about their privacy practices.

We may obtain information about you from other sources, such as data analytics providers, marketing or advertising vendors, fraud prevention vendors, vendors that provide other services on our behalf, or publicly available sources.

HOW WE USE YOUR PERSONAL INFORMATION

We collect and use personal information for the following purposes:

We reserve the right to supplement your personal information with information we gather from other sources which may include online and offline sources. We may collect information that is not personal information (“non-personal information”), including anonymous or aggregate data, or information lawfully made available from federal, state, or local government records. Because non-personal information does not personally identify you, we may collect, use, and disclose such information for any purpose permitted by law. In some instances, we may combine non-personal Information with personal information. If we combine any non-personal information with personal information, the combined information will be treated by us as personal information to the extent that it is capable of personally identifying you.

HOW WE DISCLOSE OR SHARE YOUR INFORMATION

In addition to using your personal information ourselves for the reasons stated above (and as otherwise mentioned in this Privacy Policy), we may disclose your personal information to other affiliates and entities in the following instances:

We may share your personal information with third-party service providers who may use your information to provide us with services including, but not limited to: website hosting, data analysis, infrastructure provision, information technology services, customer service, email delivery services, payment processing, auditing, and anti-fraud monitoring. These service providers may have access to personal information that is necessary to perform their functions, but they are only permitted to do so in connection with performing services for us. They are not authorized by us to use the information for their own benefit.

We may share personal information with our corporate affiliates and subsidiaries, who process personal information on our behalf, where necessary to provide a product or service that you have requested, or in other circumstances with your consent or as permitted or required by law.

We may disclose personal information and other information as we believe necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our Terms of Service; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

We may share your personal information and other information with third parties in connection with a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which the assets transferred may include information about the users of our Website.

We may share non-personal information with unaffiliated third parties, such as business partners, manufacturers, distributors, and retailers, to improve and enhance your experience using the Website, and for our own market research activities. We publicly commit to maintain and use the information in de-identified or aggregate form, and not to attempt to re-identify the information.

Please note that if you specifically consent to additional uses of your personal information, we may use your personal information in a manner consistent with that consent.

LINKS TO OTHER SITES AND SOCIAL MEDIA SERVICES

We may create links to other websites that we think may be of interest to you, such as providers of various products and services. We do not endorse any other websites, providers, or services by providing such links, and this Privacy Policy applies only to your use of our Website. We are not responsible for the privacy policies of any websites and services we link to on our Website, and you should read the privacy policies of each site you visit to determine what data that site may collect about you.

The Website may also integrate with social media services. We do not control such services and are not liable for the manner in which they operate. While we may provide you with the ability to use such services in connection with our Website, we are doing so merely as an accommodation and, like you, are relying upon those third-party services to operate properly and fairly.

You should be aware that any personal information which you voluntarily include and transmit online in a publicly accessible blog, forum, social network, or otherwise may be viewed and used by others. By using such features, you assume the risk that the personal information provided by you may be viewed and used by third parties.

HOW WE PROTECT YOUR PERSONAL INFORMATION

Personal information is maintained on our servers or those of our vendors, and is accessible by authorized employees, independent contractors, representatives, and agents as necessary for the purposes described in this privacy policy. We use reasonable and appropriate physical, technical, and organizational safeguards designed to promote the security of our systems and protect the confidentiality, integrity, availability, and resilience of personal information. However, no method of safeguarding information is completely secure, and we cannot guarantee that our safeguards will be effective or sufficient. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us of the problem by using the information provided in the section below titled Contacting Us.

YOUR CHOICES

Consistent with applicable law, you may exercise the choices described in this section regarding your personal information and communications from us. You may also have certain additional rights available depending on laws in your state or country of residence, as described further below in the Privacy Policy.

We may send you marketing messages via email. If you receive a marketing message from us, you may unsubscribe from future messages in accordance with our standard unsubscribe process (such as by using the unsubscribe link included in an email), or by sending an unsubscribe request to us at americas.it@cheil.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 our services may no longer be available to you.

If you would like to stop or restrict the placement of cookies or flush any cookies that may already be on your computer or device, please refer to and adjust your web browser preferences. Further information on cookies is available at www.allaboutcookies.org. By deleting our cookies or disabling future cookies, you may not be able to access certain areas or features of our Website or some of its functionality may be affected.

Note that cookie-based opt-outs must be performed on each device and browser that you wish to have opted out. For example, if you have opted out on your device browser, that opt-out will not be effective on your mobile device. Additionally, if you opt out on one of your devices, that opt out may not be effective on all of your devices. However, please be advised that cookie-based opt-outs are not effective on some mobile services.

Some browsers have a Do Not Track (“DNT”) feature that lets users signal to websites that they do not want to have their online activities tracked. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

CROSS-BORDER DATA TRANSFERS

If you submit personal information to us, that information may be processed in a jurisdiction where privacy laws may be less stringent than those in your country of residence. By submitting your personal information to us, you agree to the transfer, storage, and processing of such information in foreign jurisdictions including, but not limited to, the United States. Please note that personal information transferred to the United States is subject to access by law enforcement. Where applicable, we may use model clauses approved by the laws of your jurisdiction (such as Standard Contractual Clauses approved by the European Commission) for cross-border data transfers.

CHILDREN'S PRIVACY

Our Website are intended for users ages 18 and over, and we do not knowingly collect personal information from children under the age of 16. When we become aware that personal information (or other information that is protected under applicable law) from a child under 16 has been collected, we will use all reasonable efforts to delete such information from our databases. If you believe we might have any personal information from or about a child under 16, please contact us by using the information the section below titled Contacting Us.

CHANGES TO THIS POLICY

We reserve the right, at our discretion, to change, modify, add, or remove portions from this Privacy Policy at any time, provided that any such modifications will only be applied prospectively. We encourage you to periodically review the Website for the latest information on our privacy practices. Your continued use of the Website following the posting of any changes to this Privacy Policy means you accept such changes.

CONTACTING US

If you have any questions about our privacy or security practices, you can contact at americas.it@cheil.com, or via the following:

Cheil USA
6600 Chase Oaks Blvd
Suite 170
Plano, TX 75023

CALIFORNIA PRIVACY RIGHTS

The California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act of 2020, provides you with specific rights regarding your personal information. This section describes the rights that California consumers have and explains how to exercise those rights. For the purposes of this section, personal information does not include: (i) information that is lawfully made available from federal, state, or local government records; (ii) de-identified or aggregated data; or (iii) information excluded from the scope of the CCPA. To be clear, these rights are granted only to the extent that you are a California consumer and we are acting as a “business” under the CCPA with respect to your personal information. The rights in this section are not intended to grant you additional rights, but only your rights under the CCPA.

Information We Collect; How We Collect It; How We Use It

You can find a list of the categories of personal information that we collect in the Personal Information We Collect From You section of the Privacy Policy above. For details regarding the sources from which we obtain personal information, please see the How We Collect Your Personal Information section above. We collect and use personal information for the business or commercial purposes described in the How We Use Your Personal Information section above.

For more information on how your information is disclosed, please see the How We Disclose or Share Your Personal Information section above, which provides more detail on the service providers and affiliates who receive your personal information or collect it on our behalf. We do not sell your personal information or share it with third parties for cross-context behavioral advertising.

Rights to Your Information

As a California consumer, you have the right to request that we disclose certain information to you about our collection, use, or disclosure of your personal information. Once we receive and confirm your verifiable consumer request (see Exercising Your Rights, below), and subject to certain limitations that we describe below, we will disclose such information. You have the right to request any or all of the following:

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Your Rights, below), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. However, we may retain personal information that has been de-identified or aggregated. Furthermore, we may deny your deletion request if retaining the information is necessary for us or our service provider(s) in order to perform certain actions set forth under the CCPA, such as detecting security incidents and protecting against fraudulent or illegal activity.

You have the right to request a copy of personal information we have collected and maintained about you. The CCPA allows you to request your information from us up to twice during a 12-month period. We will provide our response in a readily usable (and usually electronic) format.

You have the right to request the correction of any personal information we maintain about you.

Although the CCPA provides you with the right to opt out of the sale of your personal information or sharing of it for cross-context behavioral advertising, we have not sold or shared your personal information within the past 12 months and, as of the date of this Privacy Policy, have no plans to do so.

Although the CCPA provides you with the right to limit the use or disclosure of your sensitive personal information (“SPI”), we have not collected SPI within the past 12 months and, as of the date of this Privacy Policy, have no plans to do so.

We will not discriminate against you for exercising any of your CCPA rights, including but not limited to, by:

To exercise the rights described above, please contact us by emailing us at americas.it@cheil.com.

After submitting a request, we will take steps to verify your identity in order for us to properly respond and confirm that it is not a fraudulent request. In order to verify your identity, we will ask, at a minimum, that you provide your name and email address so that we can seek to match this information with the information existing in our systems. When providing us this information, you represent and affirm that all information provided is true and accurate. If we are unable to verify that the consumer submitting the request is the same individual about whom we have collected personal information, we may contact you for more information, or we may not be able to meet your request.

Only you, or an agent legally authorized to act on your behalf, may make a verifiable request related to your personal information. If you are making a request as the authorized agent of a California consumer, we will ask you also submit reliable proof that you have been authorized in writing by the consumer to act on such consumer’s behalf.

We will make every effort to respond to your request within 45 days from when you contacted us. If you have a complex request, the CCPA allows us up to 90 days to respond. We will still contact you within 45 days from when you contacted us to let you know we need more time to respond.