Gordon & Frost (“Gordon & Frost,” “G&F,” or “we,” “us,” or “our”) respects your privacy. This Privacy Policy (the “Privacy Policy”) is intended to describe how Gordon & Frost collects, uses, and shares information that you submit to us, that we collect through our website (gordonandfrost.com (the “Website”)), and that is provided by and to our business partners. When we reference “Services”, we mean the provision and operation of our media agency business for our advertising clients and related activities. 

Please note that certain requirements and disclosures in this Privacy Policy may be subject to exemption according to applicable law or regulations. 

INFORMATION WE COLLECT 

As described in this Privacy Policy, we may collect certain Personal Information from or about you in connection with our provision of the Services which you provide voluntarily through use of our website. “Personal Information,” for purposes of this Privacy Policy, generally includes information that we collect to provide the Services that may be used to identify you specifically. 

We provide Services to our clients, including to allow our clients to offer their consumers specialized marketing, advertising, offers, campaigns, or rewards. Our use of information on behalf of our clients is governed by our contract with that client and the client’s own privacy policies and disclosures. 

HOW WE USE THE INFORMATION WE COLLECT 

G&F uses the data we collect as follows: 

• For the purposes for which You provided it; 

• To initiate or to provide the features, services and products available through the Website or our services; 

• To send You information about Your relationship or transactions with us, account alerts, or other communications, such as newsletters to which You have subscribed; 

• For internal research and reporting; 

• To enforce the legal terms that govern Your use of the Website or our services; and 

HOW WE MAY SHARE AND/OR DISCLOSE THE INFORMATION WE COLLECT 

• To third parties who perform services on our behalf, including without limitation marketing, market research, customer support, data storage, analysis and processing, and legal services.  

• Where required to do so by law or in a good faith belief that such access, preservation, or disclosure is permitted by this Privacy Statement or reasonably necessary or appropriate for any of the following reasons:  

• To comply with legal process, including law enforcement or government agencies;  

• To enforce this Privacy Statement or other contracts with You, including investigation of potential violations thereof 

• To respond to claims that any content violates the rights of third parties; 

• To respond to Your requests for customer service 

USE OF COOKIES, WEB BEACONS, AND SIMILAR TECHNOLOGIES 

A “cookie” is a small text file that a web server stores in browser software. A browser sends cookies to a server when the browser makes a connection to the server (for example, when requesting a web page from the same domain that created the cookie). The purpose of cookies is to remember the browser over time and distinguish one browser instance (or user) from all others. Some cookies and other technologies may serve to track personal information previously entered by a web user on the Website. Most browsers allow you to control cookies, including whether or not to accept them and how to remove them. Cookies can remember login information, preferences, and similar information. 

Cookies, as well as other tracking technologies, such as HTML5 local storage, and Local Shared Objects (such as “Flash” cookies), and similar mechanisms, may record information such as a unique identifier, information you enter in a form, IP address, and other categories of data. 

If you want to block the use and saving of cookies from the Website on to the computer’s hard drive, you should take the necessary steps within your web browser’s settings to block all cookies from the Services and external serving vendors. 

PROTECTING CHILDREN’S PRIVACY 

Our website is intended for general audiences, and not for children under the age of 13. We do not knowingly collect information from individuals under the age of 13 years without parental consent. If you become aware that an individual under 13 years of age has provided us with Personal Information without parental consent, please contact us at info@gordonandfrost.com 

REGION SPECIFIC DISCLOSURES 

CALIFORNIA 

Under Section 1798.83 of the California Civil Code, residents of California have the right to request from a business, with whom the California resident has an established business relationship, certain information with respect to the types of personal information (as defined by California law) the business shares with third parties for those third parties' direct marketing purposes, and the identities of the third parties with whom the business has shared such information during the immediately preceding calendar year. To exercise your rights, you may make one request each year by emailing us at info@gordonandfrost.com with "Request for California Privacy Information" in the subject line and in the body of your message. Please be sure to provide in the request sufficient information to properly identify you and/or the members of your family. 

Rights of California Residents 

If you are a California resident, subject to applicable law, you have the following rights under California law with respect to your Personal Information: 

• Right to Know. You have the right to request what Personal Information we collect, use, disclose, and/or sell, as applicable. 

• Right to Delete. You have the right to request the deletion of your Personal Information that is collected or maintained by us. 

• Right to Non-Discrimination. You have the right not to receive discriminatory treatment by us for the exercise of the privacy rights described above. 

You have the right to opt-out of the sale of your Personal Information where applicable; however, we do not sell Personal Information. 

You may also authorize someone to exercise the above rights on your behalf, provided that you provide that person with written signed permission to do so, verify the authorized person’s identity with us, and directly confirm with us that the authorized person provided the written signed permission to submit your request. If we have collected information on your minor child, you may exercise the above rights on behalf of your minor child. 

The above rights are subject to our being able to reasonably verify your identity and authority to make these requests. These rights are also subject to various exclusions and exceptions under applicable laws. We may ask you to verify your identity by answering certain questions. 

Please note that, where we have received your information through our clients, or where we are otherwise operating as a processor or service provider, we may refer you to the client or entity with whom you have a direct relationship in order to implement your request, pursuant to applicable law. 

EUROPE / GDPR 

The EU General Data Protection Regulation (or the “GDPR”) requires Gordon & Frost and those using our services to provide users with certain information about the processing of their “Personal Data.” “Personal Data” is a term used in Europe that means, generally, data that identifies or can identify a particular unique user or device – for instance, names, addresses, Cookie identifiers, mobile device identifiers, precise location data and biometric data. 

To comply with the GDPR, we provide the below representations and information, which are specific to persons located in EEA countries or Switzerland (so please don’t rely on the below, if You’re not): 

Legal Grounds for Processing Your Personal Data 

When we act as a “data controller”, the GDPR requires us to tell You about the legal basis we’re relying on to process any Personal Data about You. The legal basis for us processing Your Personal Data for the purposes set out in the “Types of Information We Collect and How We Use It” section above and will typically be because: 

• Legitimate Interests. In some cases, we use legitimate interest as a legal basis for processing Personal Data. We rely on legitimate interest when we use Personal Data to maintain the security of our services, and when we communicate with or otherwise manage our client data. 

• You provided Your consent. 

• Contractual Relationships. Sometimes, we process certain data as necessary under a contractual relationship we have (such as our client records and contact information); 

• Legal Obligations. Finally, some processing of data may be necessary for us to comply with our legal or regulatory obligations. 

Personal Data Retention

As a general matter, we retain Your Personal Data for as long as necessary to provide our Website and services, or for other important purposes such as complying with legal obligations, resolving disputes, and enforcing our agreements, as well as for auditing, corporate record-keeping, compliance accounting or security and bug-prevention purposes. 

Your Rights as a Data Subject 

The GDPR provides You with certain rights in respect of Personal Data that data controllers hold about You, including certain rights to access Personal Data, to request correction of the Personal Data, to withdraw Your consent where we process Your Personal Data pursuant to Your consent, to request to restrict or delete Personal Data, and to object to our processing of Your Personal Data (including profiling for online ad targeting). To exercise those rights, You may contact us as described above, in Section 12. 

However, where we process Personal Data on behalf of a client (which is often the case), we may refer the request to the relevant client and cooperate with their handling of the request, subject to any special contractual arrangement with that client. Many of the rights described here are subject to significant limitations and exceptions under applicable law. For example, objections to the processing of Personal Data, and withdrawals of consent, typically will not have retroactive effect. You also have the right to lodge a complaint with a supervisory authority. However, we hope that You will first consult with us, so that we may work with You to resolve any complaint or concern You might have. 

If You reside in the EU, following is a more detailed overview of Your rights under GDPR, if it applies to You. 

You have the right to request: 

• Access to the personal data we hold about You 

• The correction of Your personal data when incorrect, out of date or incomplete. 

• That we stop using Your personal data for direct marketing (either through specific channels, or all channels). 

• That we stop any consent-based processing of Your personal data after You withdraw that consent. 

• You can contact us to request to exercise these rights at any time by emailing our legal contacts listed above. 

Your right to withdraw consent 

Whenever You have given us Your consent to use Your personal data, You have the right to change Your mind at any time and withdraw that consent. 

Where we rely on our legitimate interest 

In cases where we are processing Your personal data on the basis of our legitimate interest, You can ask us to stop for reasons connected to Your individual situation.  

We must then do so unless we believe we have a legitimate overriding reason to continue processing Your personal data. 

Direct marketing 

You have the right to stop the use of Your personal data for direct marketing activity through all channels, or selected channels. We must always comply with Your request. 

Checking Your identity 

To protect the confidentiality of Your information, we will ask You to verify Your identity before proceeding with any request You make under this Privacy Policy.  

If You have authorized a third party to submit a request on Your behalf, we will ask them to prove they have Your permission to act. 

MISCELLANEOUS  

• Our Website may contain links to other websites. It is important that You know that our Privacy Statement does not extend to those third-party Websites, as their policy(ies) may differ from ours. 

CHANGES TO OUR PRIVACY POLICY 

We reserve the right to make changes to this Privacy Policy at any time. By using our Website You consent to our collection and use of Your information as described in this Privacy Policy. 

CONTACT US 

For more information or if you have questions or concerns about our privacy practices, please contact us at info@gordonandfrost.com