Date This Privacy Policy Was Last Revised: December 31, 2019

PRIVACY POLICY

  1. Introduction
    This website is owned or managed by Headway (also referred to as, the “Company”, “us”, “our”, or “we”). This Privacy Policy describes the types of information that we may collect from you or that you may provide when you visit and/or use services related to our website located at https://headwaydigital.com and any website owned or operated by us that links to this Privacy Policy (collectively, the “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This Privacy Policy applies to the services offered by Headway (collectively, the “Services”).

Headway is committed to protecting your privacy. We provide this Privacy Policy to explain the type of information we collect and also to inform you of the specific practices and guidelines that protect the security and confidentiality of your personal data. Please read this Privacy Policy carefully. Please note that this Privacy Policy is incorporated into our Cookie Policy, which also applies when you visit or use Services related to our Website. If any term in this Privacy Policy is unacceptable to you, please do not use the Website or provide any personal data. By accessing or using this Website or the Services, you signify your acknowledgment of this Privacy Policy and consent to our practices as described herein.

This Privacy Policy may change from time to time. Visiting this Website or using our Services after we make any changes to this Privacy Policy will be considered to be an acceptance of and consent to those changes. Please check this Privacy Policy periodically for updates. If Headway materially changes its practices regarding collection or use of your personal data, your personal data will continue to be governed by the Privacy Policy under which it was collected unless you have been provided notice of, and have not objected to, the change.

  1. Information we collect about you and how we collect it
    We collect several types of information from and about users of our Website, which may include information defined as personal data or personally identifiable information under an applicable law (“Personal Data”). For example, we may collect information such as your name, e-mail address, telephone number, address, job title, your Foreigner ID Number (“NIE”), your company/organization name, current supplier status, and information related to inquiries and requests. We also may collect information about the internet connection and equipment you use to access our Website. As you navigate through the Website, we may automatically collect information such as your usage details, IP addresses, and information collected through cookies.

Information You Give to Us. The information we collect on or through our Website may include:

  • Information that you provide by filling in forms and applications on our Website, including your username, password, company, job position, skype username, country and e-mail.
  • When you apply for career opportunities through the Website. This information includes your date of birth, your name, marital status, study level, educational level, address, and your Spanish social security number or your NIE.
  • Information you provide when signing up for newsletters and other types of informational material when you inquire about products, technical support, and customer service; and when you provide feedback about our Website.
  • Records and copies of your correspondence with us (including e-mail addresses).
  • Your country and age.

If you give us the Personal Data of a third party, you represent that you have provided notice to, and received authorization to provide such information from, that third party.

Information We Collect About You. As with many other websites, as you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  • Information about your computer and internet connection, including your IP address, operating system, host domain, device ID, longitude and latitude, and browser type.
  • Details of your visits to our Website, including the resources that you access and use on our Website, traffic data, location data, logs, language, date and time of access, frequency, and other communication data.
  • Details of referring websites (URL).

The information we collect automatically is statistical data that helps us improve our Website and deliver a better and more personalized service, including by enabling us to:

  • Determine Website traffic patterns.
  • Count web visits.
  • Determine traffic sources so we can measure and improve the performance of our Website.
  • Help us to know which pages and content are the most and least popular.
  • Observe Website search patterns to provide more intuitive navigation cues.
  • Determine the frequency of user visits and last date of visit.

III. How we use your information
Below, please find information regarding the purposes for which we process information collected about you (including Personal Data) as well as the corresponding legal basis (collectively below, “Purposes”). We may process your information where the processing is:

Necessary to personalize your experience, contact you by e-mail or through retargeting campaigns.
Necessary for us to comply with a legal obligation.
Necessary for entering into or the performance of a contract with you. For example:
To carry out our obligations arising from any contract entered into between you and us.
To provide you with the information, products, and services that you request from us.
To process your supplier application and registration form, and to create online accounts for your organization and its authorized agents.
To communicate with you about our contracts or your account.
Necessary for the purposes of the legitimate interests pursued by a third party or us (to the extent it does not infringe on any data subject’s fundamental rights and freedoms). For example:
To make sure that content from our Website is presented in the most effective manner for you and for your computer.
To allow you to participate in interactive features of our Website and services (when you so choose).
To keep our Website safe and secure (for example, security protection and fraud prevention).
To provide you with technical support and to improve our Website and services.
To provide you with information that you have requested and respond to your inquiries.
To notify you about changes to our service or our Website.
Subject to applicable law and regulations, in the event of a sale, merger, consolidation, change in control, transfer of substantial assets, reorganization, or liquidation, to transfer, sell, or assign to third parties information concerning your relationship with us, including, without limitation, Personal Data that you provide and other information concerning your relationship with us.
To manage our everyday business needs, such as auditing, administration of our services, analytics, and the enforcement of any corporate reporting obligations, or other policies.

Pursuant to valid consent provided by you, in order to provide you with information about goods or services we feel may interest you. If you do not want us to use your data in this way, simply do not opt-in when we ask for your consent on the relevant forms where we collect your data.
Allowed for any other purpose where you have provided valid consent where it is legally required.

  1. Disclosure of your information
    We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. Subject to applicable law and regulations, we may disclose Personal Data that we collect or you provide as described in this Privacy Policy:

To third parties who assist us in operating our Website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential.
To comply with the law, enforce our Website policies, or protect our or others’ rights, property, or safety.
For any other purpose disclosed by us when you provide your information or with your consent when required by applicable law and regulations.
To enforce or apply our Website policies and/or other agreements, including for billing and payment collection purposes, or to protect the rights, property, or safety of Headway or our customers, or others. This may include an exchange of information, including your Personal Data, to other companies and organizations for the purposes of fraud protection and credit risk reduction.
However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.

  1. Cross-border transfers of personal data
    The data that we collect from you will be transferred to, and stored and processed in, the United States or in a destination outside the European Economic Area (“EEA”). It also may be processed by staff operating outside the EEA who work for us or by other entities acting as data processors processing data on our behalf. This includes staff engaged in, among other things, the fulfillment of your request or order and the provision of support services. Please note that the data protection and privacy laws of the United States or other jurisdictions outside the EEA may not be as protective as the laws in your country.

Headway has implemented international data transfer agreements on the basis of EU Standard Contractual Clauses in order to provide appropriate and suitable safeguards for Personal Data being transferred to countries outside the EEA where an adequate level of protection is not already guaranteed. A copy can be obtained by contacting privacy@headway.com. We will take all steps reasonably necessary to ensure that your data is treated securely and subject to appropriate safeguards in accordance with this Privacy Policy and applicable legislation.

  1. Data retention
    Headway retains your data so long as necessary to fulfill the Purposes for which it was collected, unless a shorter retention period is otherwise agreed to by contract. Scroller Ads further retains all job applications and other information related to an employee’s employment at Scroller Ads for five (5) years after his or her last date of employment at Scroller Ads.

VII. Choices about how we use and disclose your information
Headway strives to provide you with choices regarding the Personal Data you provide us. We have created mechanisms to provide you with the following control over your information:

Do Not Track Signals: We do not currently respond to “do not track” signals.

Communications from Headway: Headway provides you with the opportunity to opt-out of receiving email communications from us and our business partners. To opt-out of receiving email communications, you may send an email to privacy@headway.com.

VIII. Your Rights with Regard to Your Personal Data
Under applicable data protection law, you have certain rights with respect to your Personal Data, including the following:

The right to request access to your Personal Data, which includes the right to obtain confirmation from us as to whether or not Personal Data concerning you is being processed, and where that is the case, access to the Personal Data and information related to how it is processed.
The right to rectification or erasure of your Personal Data, which includes the right to have incomplete Personal Data completed.
The right to restrict or object to the processing concerning your Personal Data, which includes restricting us from continuing to process your Personal Data under certain circumstances.
The right to data portability, which includes certain rights to have your Personal Data transmitted from us to another controller.
Where data processing is based on your consent, the right to withdraw consent at any time.
In certain jurisdictions, you also have the right to lodge a complaint with a supervisory authority.
Any requests related to the above rights may be made by sending an e-mail to privacy@headway.com.

  1. Your California Privacy Rights
  • Shine the Light: This privacy policy describes how we may share your information, including for marketing purposes. California residents are entitled to request and obtain from Headway once per calendar year information about any of your personal information shared with third parties for their own direct marketing purposes, including the categories of information and the names and addresses of those businesses with which we have shared such information. To request this information and for any other questions about our privacy practices and compliance with California law, please contact us at headway-privacy@entravision.com.

 

  • Erasure Rights for Minors: If you are a California resident under the age of 18 and a registered user of any Headway services, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted. To make such a request, please send an email with a detailed description of the specific content or information to headway-privacy@entravision.com. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.

 

  • California Individual Privacy Rights: California residents can exercise the following privacy rights with respect to their Personal Information 2-times a year free of charge. If we cannot complete the request within 45-days of receipt, we will reach out and let you know when you can expect the request to be completed, and will not take more than an additional 45-day period to do so.

 

  • The right to know. You have the right to know (i) the specific pieces of Personal Information we have about you; (ii) the categories of Personal Information we have collected about you in the last 12 months; (iii) the categories of sources from which that Personal Information was collected; (iv) the categories of your Personal Information that we sold or disclosed in the last 12 months; (v) the categories of third parties to whom your Personal Information was sold or disclosed in the last 12 months; and (vi) the purpose for collecting and selling your Personal Information. Generally:
    • Within the preceding 12 months, Headway has collected the categories of Personal Information detailed in Section II “Information we collect about you and how we collect it” above.
    • Within the preceding 12 months, Headway has sold the categories of Personal Information detailed in Section II “Information we collect about you and how we collect it” above. We do not sell the Personal Information of minors under 16 years old without consent from either the minor or the parent/guardian.
    • Within the preceding 12 months, Headway has disclosed the categories of Personal Information detailed in Section II “Information we collect about you and how we collect it” above.

 

  • The right to deletion. You have the right to request that we delete the Personal Information that we have collected or maintain about you. There may be circumstances under which we will be unable to delete your Personal Information, such as if we need to comply with our legal obligations or complete a transaction for which your Personal Information was collected. If we are unable to comply with your request for deletion, we will let you know the reason why.

 

  • The right to opt out of the sale of your Personal Information. You have the right to opt out of the sale of your Personal Information. If you do not affirmatively opt out, and you are not a minor, your Personal Information may be sold as disclosed in this Privacy Policy. You can submit your request to opt out of the sale of your Personal Information by completing our “Do not Sell my Personal Information” request form available at: https://privacyportal-cdn.cookiepro.com/dsarwebform/cce882d4-72ca-4ce7-9ece-b97c9a3da5d7/69faee56-6fad-445c-9e2e-a935e0632033.html

 

  • The right to equal service. If you choose to exercise any of these rights, Headway will not discriminate against you in anyway. If you exercise certain rights, understand that you may be unable to use or access certain features of Headway’s Sites or services.

To exercise any of these rights, contact us at +1-888-382-6755 or complete our “California Consumer Request” form available at: https://privacyportal-cdn.cookiepro.com/dsarwebform/cce882d4-72ca-4ce7-9ece-b97c9a3da5d7/69faee56-6fad-445c-9e2e-a935e0632033.html

We will take steps to verify your identity before processing your request, which may include requesting information from you to match with information we already have about you.

You may use an authorized agent to submit a request to know or a request to delete. When we verify your agent’s request, we may verify both your and your agent’s identity and request a signed document from you that authorizes your agent to make the request on your behalf. To protect your Personal Information, we reserve the right to deny a request from an agent that does not submit proof that they have been authorized by you to act on their behalf.

 

X. Data security

We have implemented measures to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and/or disclosure.

Unfortunately, the transmission of information over the Internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your data transmitted to us through our Website and shall not be liable for breaches of security or integrity, third-party interception in transit, or any damage caused to you or your company, your computer(s), or other property by accessing or using our Website or services. Any transmission of your Personal Data is at your own risk.

XI. Third party links

Occasionally, at our discretion, we may include on our Website links to other websites containing third party products or services. Please note that this Privacy Policy does not apply to those websites or services. We encourage you to read the privacy statements and terms and conditions of any linked or referenced websites you enter. These third party websites may use their own cookies and tracking devices, log your IP address, and otherwise collect data or solicit your Personal Data. Scroller Ads claims no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our Website and welcome any feedback about these sites.

XII. Children under the age of 16
Our Website is not intended for children under 16 years of age, and Headway does not knowingly collect or use any Personal Data from children under the age of 16. No one under the age of 16 may provide any information to or on the Website. If we learn we have collected or received Personal Data from a child under the age of 16, we will delete that information. If you believe we might have any information from or about a child under the age of 16, please contact us at privacy@headway.com.

XIII. Revisions to our privacy policy
We reserve the right to change this Privacy Policy at any time. Any changes we make will be posted on this page. If we make material changes to how we treat your Personal Data, we will notify you by e-mail to the e-mail address provided by you or through a notice on the Website home page. The date of this Privacy Policy was last revised is identified at the top of the page. You are responsible for periodically monitoring and reviewing any updates to this policy. Your continued use of our Website after such amendments will be deemed your acknowledgement and consent of these changes to this Privacy Policy.

XIV. Contact information
The data controller is Headway.

Should you have any questions or concerns about this Privacy Policy and our privacy practices, you may contact us at:

General Counsel
c/o Legal Department
Entravision Communications Corporation
2425 Olympic Boulevard
Suite 6000 West
Santa Monica, CA 90404