Welcome to Innovation Advertising Limited’s privacy policy.
Innovation Advertising Limited respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we use and look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your rights regarding the personal information you provide to us.
Innovation Advertising Limited is a limited liability company registered with the department of the Registrar of Companies of Cyprus under registration number HE29825, having its registered office at 21 Akadimias street, KEMA BUILDING, Aglantzia 2107, Nicosia, Cyprus, operating under the business name INNOVATION/LEO BURNETT with registration number EE20583.
Innovation Advertising Limited, as well as other subsidiaries or affiliated companies of ours that may act as a service provider following a contractual agreement with us, is the controller and responsible for your personal data (collectively referred to as ‘‘Innovation Advertising Limited’’, ‘‘Innovation/Leo Burnett’’, ‘‘we’’, ‘‘us’’, or ‘‘our’’ in this privacy policy).

THE DATA WE COLLECT ABOUT YOU

Generally, we may gather the following information when you use this website:
Identity Data (including first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender).
Contact Data (including billing address, delivery address, email address and telephone numbers).
Technical Data (including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website).
Usage Data (including information about how you use our website, products and services).
Marketing and Communications Data (including your preferences in receiving marketing from us and our third parties and your communication preferences).
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

COLLECTION OF PERSONAL DATA WITH REGARD TO CAREER APPLICANTS

At times we may collect, use, store and transfer different kinds of personal data when you voluntarily supply us or you choose to provide us with your personal information by contacting us or emailing us via the ‘‘Contact’’ section of our website. The types of personal data processed by us in relation to career applicants generally include any personal data voluntarily provided to us by the applicant by way of the applicant’s curriculum vitae and through any professional references attached or accompanying such applicants curriculum vitae or provided during interviews and assessments.
In general, the data processed include contact details of the applicant (name, surname, email and telephone number), experience, education and professional qualifications, information provided as part of interviews and assessments, social mobility data, assessment and interview results and feedback, offer details.

• Purpose of processing
  The collection of personal data from us shall be restricted to the collection of personal data necessary or deemed necessary for the purpose of considering your career application with us.
• Legal Basis for Processing Personal Data of Career Applicants
  We process personal data of career applicants for our legitimate interests, for securing the best applicants to work for us and help us in running our business more efficiently.
• Data Retention
  We retain the personal data processed by us for as long as is considered necessary for the purpose for which it was collected (including as required by applicable law or regulation). In the absence of specific legal, regulatory or contractual requirements, our baseline retention period for records of unsuccessful career applicants is approximately 6 months from the date when of submission of such personal data to us. Personal data of successful career applicants will be retained as part of such person’s employee data.

COLLECTION OF PERSONAL DATA WITH REGARD TO PERSONS WHO GET IN TOUCH WITH US

Types of personal data processed in relation to individuals who get in touch with us with a question, complaint, comment or feedback, including prospective clients, may include, subject to the particulars of the relevant correspondence, all or any of the following:
– Full name and surname of the individual contacting us, name and surname of other individuals associated with the data subject, whether on a business or private nature and provided that such individuals are relevant to our correspondence with the data subject, contact details (including phone, fax, email), residential address, description of the business activities or of the specifics and nature of the data subject’s inquiry.

• Purpose of processing
  The collection of personal data by us shall be restricted to the collection of personal data necessary or deemed necessary for the purpose of responding to the inquiry of the data subject.
• Legal basis for processing data
  The processing is necessary in order to take steps at the request of the data subject prior to entering into a contract for the provision of services requested of us.
• Data retention
  We retain the personal data processed by us for as long as is considered necessary for the purpose for which it was collected (including as required by applicable law or regulation). In the absence of specific legal, regulatory or contractual requirements, our baseline retention period for records and other documentary evidence created in the provision of services is 8 years. In relation to the data of persons who get in touch with us with whom we do not eventually enter into a business relationship, will be retained for 6 months. Personal data may also be held for longer periods where clients expressly require us to retain / store their records for extended periods of time.

COLLECTION OF PERSONAL DATA WITH REGARD TO VISITORS TO OUR WEBSITE

Personal data of visitors to our webpage are automatically collected via the use of cookies and analytics tools on our website. Please refer to the Cookies section within our policy for further information on what data we collect automatically when you visit our page.
Any further personal data collected by us is collected via its voluntary submission by you. Such may include name, title, company address, email address, and telephone and fax numbers from website visitors; for example, when an individual registers to our newsletters and updates.
Visitors are also able to send an email to us through the website. Their messages will contain the user’s screen name and email address, as well as any additional information the user may wish to include in the message.
We ask that you do not provide Special Categories of Personal Data to us when using our website.

• Purpose of processing
  When you provide personal data to us, we may use it for any of the purposes described in this privacy statement or as stated at the point of collection (or as obvious from the context of collection), including the provision of newsletters and updates on our business (where such was the purpose at the point of collection); to administer and manage our website; to sort and analyse user data; to develop our businesses and services; to understand how people use the features and functions of our websites in order to improve the user experience; and any other purposes for which you provided the information to us (such as to subscribe you to our updates and newsletters).
• Data retention
  Personal data collected via our website will be retained by us for as long as it is necessary (e.g. for as long as we have a relationship with the relevant individual).

WHEN AND HOW WE SHARE PERSONAL DATA TO THIRD PARTIES

Personal data collected and processed by us will not be sold, leased or rented to any person. We may however share your personal data with others, provided that we are legally permitted to do so. Personal data held by us may be transferred to the following categories of recipients:

• Internal third parties: We may send your personal information to other Innovation/Leo Burnett group companies, affiliates and third parties to help us process your personal information for the purposes set out in this policy.
• External third parties: Your personal data may be transferred to (a) third parties providing functionality services to us and help us provide, run and manage our internal IT systems, including providers of information technology, cloud-based software, hosting and management providers, data analysis, data back-up, security and storage services and payment providers; (b) professional advisers including lawyers, bankers, auditors and insurers; (c) other third parties including market researchers, fraud prevention agencies and law enforcement agencies.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

Service providers and professional advisers are all set within the European Union.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. Appropriate contractual arrangements and security measures shall be applied in cases where your data is shared so as to protect your data and to maintain compliance with our data protection policy, confidentiality and security standards.

DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

YOUR RIGHTS REGARDING PERSONAL DATA SUBMITTED TO US

Your rights in relation to the personal information we hold about you, are detailed below.
• Right of access: You have the right to know whether we process personal information about you, and if we do, to access information we hold about you and certain information about how we use it and who we share it with.
• Request rectification: The accuracy of the information we hold about you is important to us. Under the law you have the right to access the information we hold about you and have any inaccuracies corrected. Where you request correction, please explain in detail why you believe the personal data we hold about you to be inaccurate or incomplete so that we can assess whether a correction is required.
• Request erasure: You may request that we erase the personal data we hold about you or for our use of it to be restricted. Your right can be exercised when you believe that it is no longer necessary for us to hold your personal data, when you wish to withdraw the consent you have already provided, when you object to such processing on the basis of our legitimate interest. Please provide as much detail as possible on your reasons for the request to assist us in determining whether you have a valid basis for erasure. Please note, however, that we may retain the personal data if there are valid grounds under law for us to do so but we will let you know if that is the case.
• Request transfer of your personal data: You have the right to receive a copy of the personal data we collect from you in a structured, commonly used and machine-readable format and a right to request that we transfer such personal data to another party. If you wish for us to transfer the personal data to another party, please ensure you detail that party and note that we can only do so where it is technically feasible. We are not responsible for the security of the personal data or its processing once received by the third party. Please be advised that we may not provide you with certain data if providing it would interfere with another’s rights (e.g. where providing the personal data we hold about you would reveal information about another person or our trade secrets or intellectual property).
• Right to withdraw consent: Where personal data based is processed on the basis of consent, individuals have a right to withdraw consent at any time. If you are on our mailing list for the purpose of receiving newsletters and updates then please be advised that by clicking on the unsubscribe link in the relevant email your consent with regard to this type of processing will automatically be considered to have been withdraw and no further email shall be required to be sent.
• Request restriction of processing or object to processing of your personal data: You have a right to require us to stop processing the personal data we hold about you other than for storage purposes in certain circumstances. You also have the right to object to our processing of data about you. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

HOW TO CONTACT US

In the event that you wish to be provided with further information on any of the particulars of this privacy policy or where you wish to make a complaint about how we process your personal data, please contact us via the ‘‘Contact’’ section of this website and we will endeavour to deal with your request as soon as possible.
This does not interfere with your right to raise a complaint with the data protection supervisory authority:
Data Protection Commissioner
1 Iasonos street, 1082 Nicosia
P.O. Box 23378, 1682 Nicosia
Tel:+35722919456
Fax:+35722304565
Email: commissioner@dataprotection.gov.cy

CHANGES TO THIS PRIVACY POLICY

Any changes we make to our privacy policy in the future will be posted on our website and we will notify our clients accordingly. Please check back frequently to see any updates or changes to our privacy notice. Any changes to this privacy policy will become effective when we post the revised privacy policy on our website, save as otherwise expressly agreed between us. This privacy notice was last updated in September 2019.