WEBSITE PRIVACY NOTICE AND COOKIE POLICY

WEBSITE PRIVACY NOTICE AND COOKIE POLICY

Date Posted: December 2018

Octagon Worldwide Limited (“FRUKT” or we) understand concerns about privacy and work hard to comply with relevant data protection laws.Welcome to our website, www.wearefrukt.com (the “Website”). The Website is provided by FRUKT in respect of its global operations headquartered out of London, England. FRUKT in the UK is a trading division of Octagon Worldwide Limited and is registered under number 2704128 in England with its principal place of business at 2 Waterhouse Square, 140 Holborn, London, EC1N 2AE and its registered office at 3 Grosvenor Gardens, London, SW1W 0BD (“us”, “we” or “our”). FRUKT is an agency of The Interpublic Group of Companies, Inc. (NYSE:IPG)

This website privacy notice is provided to explain:

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

Information We Obtain

We may collect and store personal information that you provide to us through your use of our website, including the following types of information:-

Automated Collection of Data

When you use our website, certain personal information may be obtained by automated means, such as browser cookies, web beacons, device identifiers, server logs, and other technologies.

What are cookies and web beacons?

“Cookies” are computer text files that websites send to a visitor’s computer or other device to:

“Web beacons” -also known as internet tags, pixel tags or clear GIFs - link web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server.

What kind of personal data is collected using “cookies”?

The information we collect using cookies 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 our website (such as the web pages you visit, links you click, videos you watch and features you use), the pages that led or referred you to our website, dates and times of access to our website, geolocation information, and other information about your use of our website.

Why do we use cookies and web beacons, and what do they do?

We may use cookies and web beacons to help us with any of the following:

Cookies – Your Choices

To the extent required by applicable law, we will obtain your consent before placing cookies or similar technologies on your computer. You may adjust your cookie settings at any time by clicking here. Additionally, 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 http://www.allaboutcookies.org.

Our website may not be 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 our website.

For more details on the cookies we use please see the Cookie Notice below.

Third-Party Web Analytics Services

We may obtain personal information about your online activities over time and across third-party websites, devices and other online services. In addition, our website may use third-party online analytics services, such as those of Google Analytics and Hubspot. The service providers that administer these analytics services use automated technologies to collect data (such as email address, IP addresses, cookies and other device identifiers) to evaluate, for example, use of our website and to diagnose technical issues. To learn more about Google Analytics, please visit http://www.google.com/analytics/learn/privacy.html. You may opt out of Google Analytics by visitinghttps://tools.google.com/dlpage/gaoptout?hl+en=GB.To learn more about Hubspot, please visit http://www.legal.hubspot.com/privacy-policy.

Online Tracking and Interest-Based Advertising

Through our website, both we and certain third parties may collect information about your online activities to provide you with advertising about products and services tailored to your individual interests. Where required by applicable law, we will obtain your consent for the processing of your personal information for such direct marketing purposes.Occasionally, you may see advertisements for our agency on other websites or mobile apps – this would be when we participate in advertising networks. Advertising networks allow us to broadcast advertising to internet user groups that are selected 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, web beacons and other similar technologies. The advertising networks use this information to show advertisements 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 advertising networks may collect includes data about users’ visits to websites and apps that participate in the relevant advertising networks, such as the pages or advertisements viewed and the actions taken on the websites or apps. This data collection takes place on third-party websites and apps that participate in the advertising networks.

To learn how to opt out of advertising network interest-based advertising in the European Union, please visit www.youronlinechoices.eu.

How We Use Personal Information

We may use the personal information we obtain through our website to:

If your personal information is used in any other ways we will provide you with specific notice of this at the time of collection or ensure that we have your consent.

We may combine information we obtain about you – from our website or third parties - for the purposes described above.

As our website may provide access to material published by online publishers that are independent to us, you should also refer to the section Other Online Services and Third-Party Features which gives information on how your personal information may be acquired and used by these publishers.

Information Sharing

We do not disclose personal information we obtain about you, except as described in this website privacy notice.

We may share your personal information with other agencies in our network, our affiliates and service providers who perform services on our behalf - such as hosting our website, relationship management or data analytics. This is only done for the purposes described in this website privacy notice. We do not authorize our service providers to use or disclose the information that we collect except as necessary to perform services on our behalf or comply with legal requirements. But as stated above, as our website may provide access to material published by online publishers that are independent to us, you should also refer to the section Other Online Services and Third-Party Features which gives information on how your personal information may be acquired and used by these publishers.

We also may disclose information about you:

Data Transfers

We will only share or transfer personal data to entities located outside of the country in which the information was originally collected in accordance with the law to ensure your rights are appropriately protected.

Your Rights and Choices

We offer you certain choices in connection with the personal information we obtain about you. To update your preferences, update or correct your information, limit the communications you receive from us, or submit a request, please contact us directly – see the How to Contact Us section. You can also unsubscribe from our marketing mailing lists by following the “Unsubscribe” link in our emails.

Under EU law, all data subjects to whom the EU General Data Protection Regulation (GDPR) applies have certain rights including to:

You can exercise any of your rights as a data subject under the GDPR by contacting us directly –see How to Contact Us.

Other Online Services and Third-Party Features

Our website 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 (eg., Facebook, Instagram, LinkedIn, Twitter and Vimeo buttons). These services, websites, and third-party features 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 the privacy statements of these parties, which we strongly suggest you review. To the extent any linked online services or third-party features are not owned or controlled by us, we are not responsible for these third parties’ personal information practices.

Retention of Personal Information

To the extent permitted by applicable law, we retain personal information as long as:

Our aim is always to comply with the GDPR which necessarily means that we only hold the personal data that we need and for so long as we either need or can reasonably justify holding it.

How We Protect Personal Information

We maintain administrative, technical and physical safeguards designed to protect the personal information we obtain through our website against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.

Children’s Personal Information

Our website is designed for a general audience – and primarily a business audience. It is not directed to children. We do not knowingly collect or solicit personal information from children – i.e. individuals under the age of 16 - through our website. If we learn that we have collected personal information from a child, we will promptly delete that information from our records. If you believe that a child may have provided us with personal information, please contact us as specified in the How to Contact Us section of this website privacy notice.

Updates to This 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.

E-Recruitment through our website

E-Recruitment - How we use data supplied by job applicants - If you apply for a position with us through our website, we may ask you to provide cover letters, CVs and references that contain a range of personal information relating to you including your name and contact information, your education and employment history, your work skills, your desired work location and work authorisation status. In addition, to assist us with diversity and equality monitoring, at your discretion, you may supply us with gender, race, ethnicity or disability details.

This privacy notice and cookie policy, applies in full to our e-recruiting activities. In addition, we may use personal information obtained from job applicants’ to:

E-Recruitment - Sharing personal data of job applicants - We may share job applicants’ personal information with other agencies in the Interpublic group around the world for the purpose of evaluating your experience and qualifications as they relate to specific requirements for the position and possibly to determine whether you would be suitable for other positions within the Interpublic group. In addition, we may use your personal information for reporting purposes as may be required by law.

We may also supply your personal information to third parties who perform services on our behalf. For example, we may share the information you provide to us with service providers such as recruitment agencies and salary evaluators helping us to evaluate candidates for employment opportunities, and online recruitment service providers. We will always require such third parties to adequately safeguard your personal information and not use it for any unauthorized purpose.

In addition, if you supply references to support your employment application, we may contact referees to help us evaluate you for employment opportunities with us. Doing so will necessarily involve a limited disclosure of your personal information to those individuals, such as your name, the fact that you have submitted an application to us for employment and that you are interested in a certain type of position with us.

We will not provide your personal information to third parties for those third parties’ own purposes without your prior consent.

E-Recruitment - Links to other recruitment-related websites – our website may provide links to other websites for your convenience and information. These websites may operate independently from us. Linked sites may have their own privacy notices or policies, which we strongly encourage you to review to better understand their procedures for collecting, using and disclosing personal information. We are not responsible for the content of linked websites, any uses of these sites, or the privacy practices of these sites.

E-Recruitment - How long we retain job applicants’ personal information - We will store the personal information that you send us via this website for as long as is reasonably necessary for your employment application, taking into consideration our need to answer queries or resolve problems and comply with legal requirements under applicable laws. We may also retain your personal information for a reasonable period to be able to contact you should a suitable job opening occur in the future. If you do not wish to be considered for future employment opportunities, we will delete your personal information at your request. Applicants who receive employment positions with us will have their information stored for longer periods, consistent with employment need and local law.

How to Contact Us

You can contact us in relation to any privacy matter including our use of your personal data or to exercise your rights by using the following contact details and providing details of your request:

Please contact by Email: london@wearefrukt.com

Our postal address for correspondence is 2 Waterhouse Square, 140 Holborn, London, EC1N 2AE. Correspondence should be marked for the attention of George Coleman, President

Alternatively, our Data Protection Officer for the purposes of the General Data Protection Regulation is:

NAME: Dr Deborah Prince

ADDRESS: 66 Prescot Street, London E1 8 HG

EMAIL: gdpr.dpo@interpublic.com