Privacy Policy

Effective as of February 8, 2018
Updated as of December 17, 2021

Introduction

Thank you for visiting our website. This site is owned and operated by Populous.  Populous Holdings, Inc. is the group parent company, with its head office located at 4800 Main Street, Kansas City, Missouri 64112 USA. Wholly-owned subsidiaries, affiliates, and branches operate throughout the world including Populous Group, LLC (Address: 4800 Main Street, Kansas City, Missouri 64112 USA), Populous Limited (14 Blades Court, Deodar Road, London SW15 2NU, England), and Populous Design Pty Ltd (469 Adelaide Street, Brisbane, Queensland 4000 Australia) (collectively “Populous,” “we,” “our,” or “us”). Unless otherwise stated, Populous is the data controller of personal data collected pursuant to this Privacy Policy.

We value the privacy of your information. This Privacy Policy is designed to assist you in understanding how we collect, use, and protect the information you provide to us in using our website and our subsidiaries’ websites (the “Sites”), and the services provided through our Sites (“Services”). If there is something you do not understand about our privacy practices, please feel free to contact us at [email protected].

From time to time, we may change this Privacy Policy. If we do, we will post an amended version on this webpage. If we make material changes to our Privacy Policy, we may also notify you by other means, such as sending an email or posting a notice on our home page. If required by applicable data protection laws, we will obtain your consent to any material changes. Please review this Privacy Policy periodically.

Our collection of your personal data may be subject to other privacy policies such as our Recruitment Privacy Statement. We encourage you to review those documents in addition to this Privacy Policy.

This Privacy Policy covers the following topics:

1. Information We Collect and Use
2. Cookies
3. Third Party Processors
4. Legal Bases for Processing Your Personal Data
5. International Data Transfers
6. Data Retention
7. Do Not Track Signals
8. Advertising and Marketing Choices
9. Third Party Links
10. Security Measures
11. Children’s Privacy
12. Your Rights – EEA and the United Kingdom
13. Your Rights—United States Only (Including California)
14. Your Choices and Rights – The Rest of the World
15. Accessibility
16. How to Contact Us

 

1. Information We Collect and Use

Personal Data We Collect Directly From You

Through your use of the Sites and Services, we will collect personal data from you. For purposes of this Privacy Policy, “Personal Data” refers to any information relating to an identified or identifiable natural person that we maintain in an accessible form.

Information You Provide

When you contact us through the Sites to request additional information about our products or services, or when you request to speak to a Populous representative, we will collect your name, email address, the subject of your inquiry, along with your inquiry so that we may address your question. We will keep this information for as long as reasonably necessary to fulfill the purpose for which your personal data is processed.

If you seek or inquire about our products or services on our Sites, we may collect your Personal Data to facilitate the transaction where we will keep this information for as long as is reasonably necessary to fulfill this purpose and if you become a direct customer, process, retain and store in accordance with this Privacy Policy and the contract we enter into.

If you subscribe to our Populous Magazine, we will collect your name, email address, and physical address.

If you post comments on our news articles and perspective pages, we will collect your name and email address.

Lastly, to apply for an open job position through our Sites, you may need to provide your name, email address, phone number, physical address, gender, ethnicity/race, whether you are a veteran, your employment history, your education/training, and references, among other things. Please see our Recruitment Privacy Statement  for further information. We use Paycor to process applications. Paycor’s privacy policy is available here.

Information as You Navigate Our Sites and Services

In addition to collecting information directly from you as described in the previous section, we also automatically gather information when you browse or view our Sites. This information may include your browser type and language, Internet service provider (ISP), referring and exit websites and applications, operating system, date/time stamp, clickstream data, whether you are a first-time or a returning user, links you clicked on while on the Sites, and your flow and navigation path through the Sites. We use this information to verify your identity and help prevent fraud, that the Sites, and its associated parts, are functioning properly, that the Sites are displayed properly for your equipment and software, and that we can provide you with information useful to you and your location.

Third Party Information

In some cases, we may receive Personal Data from you about a third party. For example, when you contact us, you may provide the name and email address of a third party. If you submit any Personal Data about another individual to us, you are responsible for making sure that you have the authority to do so and to allow us to use their Personal Data in accordance with this Privacy Policy.

Event Credentialing

One of the Services that Populous provides is event credentialing for our clients. We do not control what Personal Data our clients collect, with whom they share it, how they protect it, or what access they may provide you to it.

In general, our clients will use your Personal Data to decide whether Populous should issue you credentials to an event. We do not control our clients’ uses of your Personal Data.

Our clients may ask you for your name and postal address, email address, and telephone number, Social Security Number, drivers’ license number or other identifiers to determine your eligibility for credentials. The Personal Data requested will vary from client to client and event to event.

You are not required to provide the Personal Data that our client requests, but if you decline, you may not be eligible for the services or credentials sought.

You should review the Privacy Policy and Terms and Conditions of each client from whom you seek credentials to understand its collection, use, sharing or protection of your Personal Data, and inquire directly of the Client as you see fit.

How We Use Your Personal Data

We use your Personal Data to further our legitimate business interests, such as to transact business, to provide information about our company and products, and to communicate with Site visitors. As described above, we may use your Personal Data to send you requested information, to compile, analyze, and better understand user data, demographics and behavior, and to detect, investigate, and prevent activities that may violate our policies or be illegal. We may use the Personal Data we collect to provide you with our Populous Magazine if you subscribe. We also use anonymous information automatically collected during your use of the Sites, as described above, to improve the effectiveness of our websites, operations, mobile experience, or marketing efforts or as described elsewhere in this Privacy Policy, to prevent against fraud and theft, and otherwise to protect our Sites’ visitors and our business. Our employees and agents may view your Personal Data to perform their jobs and service your needs and the Site operations. We authorize their access to your Personal Data on a need-to-know basis to provide you with our products or services, or for one of the other reasons listed in this section, and always in connection with a contractual obligation to protect the privacy of that information.

How We Share Your Personal Data

We will not disclose your Personal Data except when we have your permission or under special circumstances, such as when we believe in good faith that the law requires it or under circumstances described in this Privacy Policy. We may provide your Personal Data to our partners, as outlined above, to assist us in operating the Sites and transacting business and communicating with you. When we do so, we will exercise reasonable care to ensure that such partners are prohibited from using that information for any other reason and that it is maintained securely and privately. We may disclose your Personal Data if we determine that disclosure is reasonably necessary to enforce our Terms of Use, this Privacy Policy or to otherwise protect our operations, clients, or users. We may release your Personal Data to others (including law enforcement) if we believe such release is reasonably necessary to comply with the law or legal process; enforce or apply the terms of applicable terms of use; detect, prevent, or otherwise address fraud, security or technical issues; or otherwise protect the rights, property or safety of others. We may sell, transfer and/or disclose your Personal Data as part of a business divestiture, sale, merger, or acquisition of all or a part of our business. If another company acquires our company, business, or assets, that company will possess the Personal Data collected by us and will assume the rights and obligations regarding your Personal Data as described in this Privacy Policy. In the event of an insolvency, bankruptcy, or receivership, your Personal Data may also be transferred as a business asset. In addition, we may share aggregate, non-individual information, incapable of identifying a particular person, with third parties for lawful purposes.

 

2. Cookies

Like many other companies, we use cookies and other tracking technologies (such as pixels and web beacons). To learn more about how we use cookies and to change your cookie settings, please see our Cookie Policy.

Google Analytics

We use Google Analytics, a web analytics service provided by Google, Inc. Google Analytics uses Cookies or other tracking technologies to help us analyze how users interact with the Sites and Services, compile reports on their activity, and provide other services related to their activity and usage. The technologies used by Google may collect information such as your time of visit, whether you are a returning visitor, and any referring website. The technologies used by Google Analytics do not gather information that personally identifies you. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies. To learn more about Google’s partner services and to learn how to opt-out of tracking of analytics by Google, click here.

 

3. Third Party Processors

To ensure that your Personal Data receives an adequate level of protection, we have put in place appropriate procedures with the service providers we share your Personal Data with to ensure that your Personal Data is treated by those service providers in a way that is consistent with and which respects the applicable laws on data security and privacy. For example, we use cloud data storage providers, payroll processors, accounting software providers, payment processors, and marketing service providers.

 

4. Legal Bases for Processing Your Personal Data

Depending on the jurisdiction in which you are located, you may be entitled to an explanation of the legal bases we rely on to process your Personal Data. The legal basis for collecting and using the Personal Data described above will depend on the Personal Data concerned and the specific context in which we collect it.

Consent

We may process your Personal Data based on your consent such as when you ask us to send certain kinds of marketing communications. You have the right to withdraw your consent at any time without affecting the lawfulness of the processing based on consent before its withdrawal. However, if you withdraw your consent, we may not be able to provide you with the requested services.

Our Legitimate Interests

We may process your Personal Data if doing so is necessary for our legitimate interests and your rights as an individual do not override those legitimate interests. For example, when we process your Personal Data to carry out fraud prevention activities and activities to increase network and information security, to market directly to you, to expand our business activities and to improve our services and the content and functionality of our Sites.

To Perform a Contract

We may process your Personal Data to administer and fulfill contractual obligations to you. If you do not provide us with your Personal Data, we may not be able to enter into the contract with you.

To Enable Us to Comply with a Legal Obligation

We may process your Personal Data to comply with legal obligations to which we are subject. This may include any requirement to produce audited accounts and to comply with legal process.

Necessary for the Exercise or Defense of Legal Claims

If you bring a claim against us or we bring a claim against you, we may process your Personal Data in relation to that claim.

If you have any questions about or need further information concerning the legal basis on which we collect and use your Personal Data for any specific processing activity, please contact us using the “How to Contact Us” section below.

 

5. International Data Transfers

We operate internationally and may transfer information to the United States or other countries in which we operate for the purposes described in this Privacy Policy. The United States and the other countries in which we operate may have privacy and data protection laws that differ from, and are potentially less protective than, the laws of your country. Your Personal Data can be subject to access requests from governments, courts, or law enforcement according to the laws of those countries.

By using our Services, you explicitly consent to this risk and to the transfer, processing and storage of your information in the United States, irrespective of which country you live in. This includes when you contact us, subscribe to our Populous Magazine, or post comments on our news articles or perspective pages. If necessary, we will enter into appropriate contractual arrangements for the transfer of your Personal Data abroad. To the extent that you agree to our Terms of Service and enter into a contract with us, you acknowledge that the transfer is necessary for performance of that contract.

For any transfers of Personal Data from the European Economic Area (EEA), Switzerland or the United Kingdom that we make to other entities as described in this Privacy Policy, we use appropriate safeguards to ensure for the lawful processing and transfer of the Personal Data, including, when appropriate, the use of standard contractual clauses approved by the European Commission. To obtain a copy of the safeguards, contact us at [email protected].

 

6. Data Retention

We will retain your Personal Data for as long as necessary to fulfill the purposes for which we collect it and as set out in this Privacy Policy and for the purpose of satisfying any legal, accounting, or reporting requirements that apply to us.

 

7. Do Not Track Signals

Some internet browsers incorporate a “Do Not Track” feature that signals to websites you visit that you do not want to have your online activity tracked. Given that there is not a uniform way that browsers communicate the “Do Not Track” signal, the Sites do not currently interpret, respond to, or alter its practices when it receives “Do Not Track” signals.

 

8. Advertising and Marketing Choices

Depending on your location (and reflecting applicable law), you may have been asked to indicate your preferences, provide us with your consent regarding the receipt of such information from us, and indicate how you would like to receive it.

Wherever you are located, we will send you marketing communications based on any direct communication preference you may have expressed.

We only want to send you information in which you are interested. If you do not want to receive these communications or would like to understand more about other unsubscribe options, please contact us as set out in the “How to Contact Us” section below.

For email communications, you can opt-out and/or manage your preferences by clicking on the unsubscribe link provided at the bottom of any email you receive from us. You also may submit a request to us at [email protected]. If we call you with information you do not want to receive, you can advise us of this during the telephone call.

 

9. Third Party Links

The Sites and Services may contain links that will let you leave the Sites and Services and access another website. For example, you may be able to post content to third party Social Networking Sites (such as Facebook, LinkedIn, and Twitter). Linked websites are not under our control. You acknowledge and agree that you are solely responsible for your use of those websites and that it is your responsibility to review the applicable terms of use and privacy policies. We are not responsible for the availability, accuracy, content, products or services of third-party Social Networking Sites.

Except as stated below, this Privacy Policy applies solely to Personal Data that is acquired on these Sites and Services. We accept no responsibility or liability for these other websites.

 

10. Security Measures

We maintain commercially reasonable security measures to protect the Personal Data we collect and store from loss, misuse, destruction, or unauthorized access. However, no security measure or modality of data transmission over the Internet is 100% secure. Although we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee absolute security.

 

11. Children’s Privacy

The Sites and Services are not intended for children under 16 years of age. We do not knowingly collect, use, or disclose personal information from children under 16.

 

12. Your Rights – EEA and the United Kingdom

If you are in a country in the EEA or in the United Kingdom, you have the following privacy rights.

Access Your Personal Data

You have the right to obtain from us confirmation as to whether or not we are processing Personal Data about you and, if so, the right to be provided with the information contained in this Privacy Policy. You also have the right to receive a copy of the Personal Data undergoing processing.

Rectify Your Personal Data

You have the right to ask us to rectify any inaccurate Personal Data about you and to have incomplete Personal Data completed.

Restrict Our Use of Your Personal Data

You have the right to ask us to place a restriction on our use of your Personal Data if one of the following applies to you:

• You contest the accuracy of the information that we hold about you, while we verify its accuracy;
• We have used your information unlawfully, but you request us to restrict its use instead of erasing it;
• We no longer need the information for the purpose for which we collected it, but you need it to deal with a legal claim; or
• You have objected to us using your information, while we check whether our legitimate grounds override your right to object.

Object to Our Use of Your Personal Data

You have the right to object to our use of your Personal Data where our reason for using it is based on our legitimate interests or your consent (rather than when the reason for using it is to perform an obligation due to you under a contract with us).

Delete Your Personal Data

You can ask us to delete your Personal Data if:

• We no longer need it for the purposes for which we collected it;
• We have been using it with no valid legal basis;
• We are obligated to erase it to comply with a legal obligation to which we are subject;
• We need your consent to use the information and you withdraw consent;
• You object to us processing your Personal Data where our legal basis for doing so is our legitimate interests and there are no overriding legitimate grounds for the processing.

However, this right is not absolute. Even if you make a request for deletion, we may need to retain certain information for legal or administrative purposes, such as record keeping, maintenance of opt-out requirements, defending or making legal claims, or detecting fraudulent activities. We will retain information in accordance with the “Data Retention” section above.

If you do exercise a valid right to have your Personal Data deleted, please keep in mind that deletion by third parties to whom the information has been provided might not be immediate and that the deleted information may persist in backup copies for a reasonable period (but will not be available to others).

Transfer Your Personal Data to Another Service Provider

You may request that we transfer some of the Personal Data you have provided to you or another service provider in electronic copy. This applies to Personal Data we are processing to service a contract with you and to Personal Data we are processing based on your consent.

To exercise any of these rights, please contact us as described in the “How to Contact Us” section below.

Make a Complaint

If you have any concerns or complaints regarding our processing of your Personal Data, please contact us as described in the “How to Contact Us” section below and we will do our best to answer any question and resolve any complaint to your satisfaction.

If, for whatever reason, you feel we do not meet the standards you expect of us, you are also entitled to make a complaint to your local supervisory authority:

EU Data Protection Authorities (DPAs)

Swiss Federal Data Protection and Information Commissioner (FDPIC)

Information Commissioner’s Office (United Kingdom)

 

13. Your Rights—United States Only (Including California)

Notice to Nevada Residents

Nevada law allows Nevada residents to opt-out of the sale of certain types of personal information. Subject to a number of exceptions, Nevada law defines “sale” to mean the exchange of certain types of personal information for monetary consideration or other valuable consideration to a third party. We do not currently sell personal information as defined in the Nevada law. However, if you are a Nevada resident, you still may submit a verified request to opt-out of sales and we will record your instructions and incorporate them in the future if our policy changes. Opt-out requests may be sent to [email protected].

Notice to California Residents

The California Consumer Privacy Act (CCPA) requires that we provide California residents with a privacy policy that contains a comprehensive description of our online and offline practices regarding the collection, use, disclosure, and sale of personal information and of the rights of California residents regarding their personal information. This section of the Privacy Policy is intended solely for, and is applicable only as to, California residents. If you are not a California resident, this does not apply to you and you should not rely on it.

The CCPA defines “personal information” to mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Personal information does not include publicly available, deidentified or aggregated information.  For purposes of this “Notice to California Residents” section we will refer to this information as “Personal Information.”

The CCPA contains an exception that is relevant to us. Some of the CCPA’s privacy rights explained below do not apply to personal information collected in a business-to-business context. That is information reflecting a written or verbal communication or a transaction between us and a consumer, where the consumer is acting as an employee, owner, director, officer, or contractor of another entity and when the communication or transaction occur solely within the context of us conducting due diligence regarding, or providing or receiving a product or service to or from such entity.

Right to Know About Personal Information Collected, Disclosed, or Sold

If you are a California resident, you have the right to request that we disclose what Personal Information we have collected about you in the 12-month period preceding your request. This right includes the right to request any or all of the following:

• Specific pieces of Personal Information that we have collected about you;
• Categories of Personal Information that we have collected about you;
• Categories of sources from which the Personal Information was collected;
• Categories of Personal Information that we sold (if applicable) or disclosed for a business purpose about you;
• Categories of third parties to whom the Personal Information was sold (if applicable) or disclosed for a business purpose; and
• The business or commercial purpose for collecting or, if applicable, selling Personal Information.

The CCPA defines “sell” to mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a California resident’s Personal Information to another business or a third party for monetary or other valuable consideration.

Collection of Personal Information

We currently collect and, in the 12 months prior to the Last Updated date of this Privacy Policy, have collected the following categories of Personal Information:

• Identifiers (name, online identifier, email address)
• Unique personal identifiers (device identifier; cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology; customer number, unique pseudonym or user alias; other forms of persistent or probabilistic identifiers that can be used to identify a particular consumer or device)
• Internet or other electronic network activity information (information regarding consumer’s interaction with website)
• Geolocation data

The Personal Information is collected from California residents directly and from internet service providers, data analytics providers, and operating systems and platforms. Not all categories of Personal Information are collected from each source.

In addition to the purposes stated above we currently collect and have collected the above categories of Personal Information for the following business or commercial purposes:

• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
• Debugging to identify and repair errors that impair existing intended functionality
• Performing services on behalf of the business or service provider, including providing customer service
• Undertaking internal research for technological development and demonstration.
• Advancing a person’s commercial or economic interests

Disclosure of Personal Information

The following table identifies the categories of Personal Information that we disclosed for a business purpose in the 12 months preceding the Updated Date of this Privacy Policy and, for each category, the category of third parties to whom the Personal Information was disclosed. We did not sell Personal Information to third parties in the 12 months preceding the Last Updated date of this Privacy Policy.

Category of Personal Information

Category of Third Parties to Whom Information was Disclosed

Identifiers (name, online identifier, email address); Unique personal identifiers (device identifier; cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology; customer number, unique pseudonym or user alias; other forms of persistent or probabilistic identifiers that can be used to identify a particular consumer or device); Internet or other electronic network activity information (information regarding consumer’s interaction with website); geolocation data

Data analytics providers

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

Right to Request Deletion of Personal Information

If you are a California resident, you have the right to request that we delete the Personal Information about you that we have collected. However, per the CCPA, we are not required to comply with a request to delete if it is necessary for us to maintain the Personal Information in order to, for example, complete a transaction, detect security incidents, comply with a legal obligation, or otherwise use the Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information.

How to Submit a Request to Know or Delete

You may submit a request to know or delete by telephone at 855-458-1519 or by email at [email protected].

If you submit a request to delete online, you may be asked to confirm separately that you want your Personal Information deleted.

Our Process for Verifying a Request to Know or Delete

If we determine that your request is subject to an exemption or exception, we will notify you of our determination. If we determine that your request is not subject to an exemption or exception, we will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request.

We will verify your identity either to a “reasonable degree of certainty” or a “reasonably high degree of certainty” depending on the sensitivity of the Personal Information and the risk of harm to you by unauthorized disclosure or deletion as applicable.

For requests to access categories of Personal Information and for requests to delete Personal Information that is not sensitive and does not pose a risk of harm by unauthorized deletion, we will verify your identity to a “reasonable degree of certainty” by verifying at least two data points that you previously provided to us and which we have determined to be reliable for the purpose of verifying identities.

For requests to access specific pieces of Personal Information or for requests to delete Personal Information that is sensitive and poses a risk of harm by unauthorized deletion, we will verify your identity to a “reasonably high degree of certainty” by verifying at least three pieces of Personal Information previously provided to us and which we have determined to be reliable for the purpose of verifying identities. In addition, you will be required to submit a signed declaration under penalty of perjury stating that you are the individual whose Personal Information is being requested.

Right to Opt-Out of Sale of Personal Information

If you are a California resident, you have the right to direct businesses to stop selling your Personal Information. We do not sell Personal Information as it is defined in the CCPA.

Right to Non-Discrimination for the Exercise of a California Resident’s Privacy Rights

We will not discriminate against California residents if they exercise any of the rights provided in the CCPA as described in this section “Notice to California Residents.”

Authorized Agents

If you are submitting a request on behalf of a California resident, please submit the request through one of the designated methods discussed above. After submitting the request, and if the request is not subject to an exemption or exception, we will require additional information to verify your authority to act on behalf of the California resident.

Shine the Light Law     

We do not disclose personal information obtained through our Sites or Services to third parties for their direct marketing purposes. Accordingly, we have no obligations under California Civil Code § 1798.83.

 

14. Your Choices and Rights – The Rest of the World

Depending on the jurisdiction in which you are located, you may have certain rights with respect to your Personal Data. We discuss some of those jurisdictions and rights in the following sections. For example, you may have the following rights:

• Right to access your Personal Data;
• Right to receive a copy of your Personal Data, including in a machine readable format;
• Right to delete your Personal Data;
• Right to update your Personal Data;
• Right to correct inaccurate, out-of-date, or irrelevant Personal Data;
• Right to anonymization, blocking or deletion of unnecessary or excessive Personal Data or Personal Data processed in noncompliance with applicable law;
• Right to receive information about public and private entities with which we have shared your Personal Data;
• Right to information about the possibility of denying consent and the consequences of such denial;
• Right to revoke consent;
• Right to confirm that we are processing your Personal Data;
• Right to restrict our processing of your Personal Data; and
• Right to object to or opt out of direct marketing from us.

If you would like to exercise your legal rights, please contact us at [email protected]. We will process your request in accordance with any applicable legal requirements.

 

15. Accessibility

We are committed to ensuring this Privacy Policy is accessible to individuals with disabilities. If you wish to access this Privacy Policy in an alternative format, please contact us as described below.

 

16. How to Contact Us

For questions, concerns or to make a complaint about our Privacy Policy or practices, please contact us at:

4800 Main Street, Suite 300
Kansas City, Missouri 64112
[email protected]
855-458-1519

We will respond to your inquiry as soon as possible and in accordance with applicable law.