October 5, 2021
Last Updated: 10/1/2021
- through Our Website;
- through social media properties (“Social Media”);
- through email messages that We send to You or receive from You (“Emails”);
- through services We provide to Our clients and customers (“Client Services”); and
- through offline information provided directly to employees and recorded and stored as electronic data (“Direct Data”).
Collectively, We refer to the Website, Social Media, Emails, Client Services, and Direct Data as the “Services.”
If You have any questions, please contact Us by email or regular mail as set forth below in the “Contacting Us” section.
COLLECTION OF PERSONAL INFORMATION
“Personal Information” is any information that, either alone or in combination with other information, identifies You as an individual or relates to an identifiable individual. This includes:
- Postal address (including personal, business, billing, and shipping addresses);
- Telephone number; and
- Email address (personal and business).
We collect, and Our authorized service providers collect, Personal Information in a number of ways, including:
- Through Neff’s Services: We may collect Personal Information through Neff’s Services. This includes in the course of operating Our business generally, as well as personal information that You voluntarily provide, including when You visit Our Website, sign up for an email list or fill out a contact sheet.
- Offline: We may collect Personal Information from You offline. This includes when You provide information in conjunction with Our Services, when You interact with Us as or on behalf of a client, or when You provide data directly to Us.
- From Other Sources: We may receive Your Personal Information from other sources, for example:
- publicly available databases and websites;
- individuals and entities to whom We provide Client Services, which may include Your employer; and
- social media platforms.
USE OF PERSONAL INFORMATION
We and Our authorized service providers may use Your Personal Information in the following circumstances:
- when We need to perform a contract We are about to or have entered into with You;
- when We need to do so in order to comply with a legal obligation;
- when it is necessary for Our legitimate interests (or those of a third party) and Your interests and fundamental rights do not override those legitimate interests;
- when it is necessary to establish, exercise, or defend legal claims;
- if You have already made the information public; or
- if You have given Your consent.
Specifically, We use Your Personal Information for Our legitimate business purposes, including the following:
- To provide Client Services, including:
- using contact data, data concerning Your business activities, and any other data relevant to the marketing and public relations matters upon which We are advising;
- conducting media relations, public relations and market research;
- contacting individuals (including members of the media to conduct media relations activities) in connection with providing Client Services; and
- responding to communications or inquiries and fulfilling requests from Our clients, administering client work, providing marketing, public relations and advertising services, and managing Our client relationships.
- To provide the Services to You and fulfill Your requests, including:
- providing You with Client Services;
- responding to Your inquiries and fulfilling Your requests when You contact Us through one of Our online contact forms, via Emails, or otherwise;
- sending administrative information to You, such as information regarding the Services, changes to Our terms, conditions and policies, and notices as may be required by law or regulation; and
- allowing You to send Services-related content to another person through the Services if You choose to do so.
- To provide You with Our marketing materials and facilitate social sharing, including:
- sending You Our newsletters, blogs, publications, marketing insights, Emails, and mailings related to content or events that We think may be of interest to You;
- sending You information about Our Services and other information or news about Our company;
- if You respond to invitations to events, if You download content offers or other marketing content, or if You comment on Our blog or social networks; and
- enabling Your ability to share content from Our Website on various social media platforms, including Twitter, Facebook, and LinkedIn.
- To aggregate or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for Our use, which We may use and disclose for any purpose, because that other data We have generated is not Personal Information.
- To accomplish Our business purposes, including:
- data analysis, which includes improving the efficiency of Our Services;
- potential employment (see below for additional information);
- audits, to verify that Our internal processes function as intended and are compliant with legal, regulatory, and contractual requirements;
- fraud and security monitoring, which includes activities to detect and prevent cyberattacks or attempts to commit identity theft;
- enhancing, improving, or modifying Our current products and services;
- identifying usage trends, which includes understanding which parts of Our Services are of most interest to users;
- determining the effectiveness of Our marketing and promotions, so that We can adapt to the needs and interests of Our users;
- operating and expanding Our business activities, which includes understanding which parts of Our Services are of most interest to Our users so We can focus Our energies on meeting users’ interests; and
- business intake procedures, which includes using and/or obtaining information for the purposes of carrying out conflict and other business intake searches, and completing retention agreements and other client-related documents.
We also use the Personal Information of Our clients and customers and the Personal Information of third-parties that Our clients and customers provide Us to fulfill Our contractual obligations with Our clients and customers. We disclose this information in accordance with Our client and customer contracts and for the purposes discussed above.
ONLINE APPLICATIONS FOR POTENTIAL EMPLOYMENT
The additional provisions set forth in this section apply solely to individuals seeking potential employment with the Company and the personal information We may collect or process to identify and communicate with actual and potential candidates for employment with the Company.
We are an Equal Employment Opportunity/Affirmative Action Employer. We adhere to a policy of making all employment decisions without regard to race, color, religion, national origin, age, disability, veteran status, citizenship or any other protected classification that may be applicable under the law of the particular state or locality in which You are applying for employment with the Company.
If You are unable or limited in Your ability to make or process an employment application as a result of a physical or mental impairment, You can request reasonable assistance (an “Accommodation”). We will be happy to assist You, and please send an email to Careers@neffknows.com or call our Corporate HR department at 215-627-4747 to request an Accommodation. We will respond to Your request within a reasonable period. Please note that only requests for an employment application Accommodation will receive a response.
By submitting an employment application, CV or resume, or responding to Our outreach, You consent to and authorize the Company, and its applicable third party service providers, to collect, process, maintain (in both paper and electronic format) and use personal information about You as allowable by applicable law, including without limitation Your name, personal contact and demographic details, employment history, employment application or resume submission, contact requests, surveys, and other activities or information You may provide as part of the application process, or others may provide about You in connection with You application for potential employment.
We will use Your Personal Information for business and human resources management purposes related to Your application for employment, including without limitation requesting and processing any employment applications and/or resumes, and considering, verifying, and evaluating Your employment history and Your qualifications for employment opportunities within Company.
Your Personal Information may be accessed by authorized personnel of the Company as necessary for purposes related to potential or actual employment, human resource requirements, and to comply with legal requirements or enforce or defend legal rights.
If You have any further questions regarding the collection and use of personal information in connection with an application for employment and potential employment, please contact Your recruiter or email the Company at Careers@neffknows.com.
THIRD PARTIES WORKING WITH US
Neff does not sell Your personal information to any third parties.
DISCLOSURE OF PERSONAL INFORMATION
We disclose Personal Information as necessary or appropriate, especially in connection with Our contractual relationship with You, or when We have a legal obligation or legitimate interest to do so. This may include disclosure outside Your country of residence. This includes the following:
- To Our authorized third party service providers, to facilitate services they provide to Us. This includes providers of services for website hosting, search engine optimization, cloud services, customer relationship management, information technology consulting, email delivery, software management, time management, human resource services, legal services, and other services related to meeting Our clients’ public relations, marketing, and advertising needs or conducting business operations. Our disclosure to these service providers is limited to processing Personal Information based upon Our instructions and as authorized by Neff, and Personal Information is given to these service providers only to the extent it is necessary to do so.
Note that by using certain Services to which You are able to post information and content (e.g., social media), or through which You are able to send messages, any information You post or disclose through these Services will become public and may be available to other users and the general public.
- To comply with applicable law and regulations.
- To cooperate with law enforcement, or public and government authorities. This includes responding to law enforcement requests and orders, or to provide information We believe is important.
- In connection with a sale or business transaction. We have a legitimate interest in disclosing or transferring Your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of Our business, assets or stock (including in connection with any bankruptcy or similar proceedings). Such third parties may include, for example, an acquiring entity and its advisors.
- To companies and people purchasing or receiving Our Client Services. For Us to conduct media relations and marketing campaigns and provide Our company’s services, We often must disclose the Personal Information of Our clients, including their names and contact information.
“Other Information” is any information that does not reveal Your specific identity or does not directly relate to an identifiable individual. This includes:
- Browser and device information;
- Information collected through cookies, pixel tags, and other technologies;
- Demographic information and other information provided by You that does not reveal Your specific identity; and
- Information that has been aggregated in a manner such that it does not reveal Your specific identity.
If We are required to treat Other Information as Personal Information under applicable law, then We may use and disclose it for the purposes for which We use and disclose Personal Information as detailed in this Policy.
Neff and Our authorized service providers may collect Other Information in a variety of ways, including:
- Through Your browser or device: Certain information is collected by most browsers or automatically through Your device, such as Your mobile phone number, mobile network information, physical location, Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version, and the name and version of the Services You are using.
- Using cookies. Cookies are small files that a site or its service provider transfers to Your computer’s hard drive through Your internet browser (if You allow) that enables the sites’ or service providers’ systems to recognize Your browser and capture and remember certain information. This helps Us to improve Your access to Our Website, identify repeat visitors, help ensure the authenticity of registered users, target advertising and enable website traffic monitoring.
At this time, Neff does not respond to browser “do not track” signals or other similar mechanisms. Go to http://www.networkadvertising.org. or http://www.aboutads.info if You wish to learn more about Your options to not accept tracking cookies for the purpose of receiving targeted interest-based advertisements. Please note that the opt-out is cookie-based and will only affect the specific computer and browser on which the opt-out is applied.
- Using pixel tags and other similar technologies. Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of users of the Services (including email recipients), measure the success of Our marketing campaigns, and compile statistics about usage of the Services and response rates.
- IP Address. Your IP address is automatically assigned to Your computer by Your Internet Service Provider. An IP address may be identified and logged automatically in Our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications, and other services.
We may use and disclose Other Information for any purpose, except where We are required to do otherwise under applicable law. In some instances, We may combine Other Information with Personal Information. If We do, We will treat the combined information as Personal Information as detailed in this Policy for as long as it is combined.
We seek to use reasonable organizational, technical, and administrative measures to protect Personal Information within Our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If You have reason to believe that Your interaction with Us is no longer secure, please immediately notify Us in accordance with the “Contacting Us” section below.
OPTION TO DISCONTINUE MARKETING-RELATED EMAILS
If You no longer want to receive marketing-related emails, direct mail and other content from Us on a going-forward basis, You may opt-out by following the unsubscribe instructions in any such message or by contacting Us by email at firstname.lastname@example.org. We will undertake efforts to comply with Your request as soon as reasonably practicable. Please note that if You choose to discontinue receiving marketing-related emails from Us, We may still send You important administrative messages, which You cannot elect to discontinue.
DATA PRIVACY INQUIRIES AND ACCESS TO PERSONAL INFORMATION
If You believe the Personal Information We have for You is inaccurate, incomplete, or no longer current, please contact Us at email@example.com so that We can update, remove or correct the information as appropriate.
If You would like to request to review, correct, update, or delete Personal Information that You have previously provided to Us, or if You would like to request to receive an electronic copy of Your Personal Information for purposes of transmitting it to another company (to the extent any of these rights are provided to You by applicable law), You may contact Us by email at firstname.lastname@example.org. We will respond to Your request consistent with applicable law.
In Your request, please provide a specific detailed description of the Personal Information You would like to have changed, whether You would like to have Your Personal Information suppressed from Our database, or otherwise let Us know what limitations You would like to put on Our use of Your Personal Information. For Your protection, We may only implement requests with respect to the Personal Information associated with the particular email address that You use to send Us Your request, and We may need to verify Your identity and obtain other relevant information before implementing Your request. We will undertake Our best efforts to comply with Your request as soon as reasonably practicable and as required by law.
The Website contains links to other websites that are not owned or controlled by Neff. Neff is not responsible for the privacy policies or information privacy and security practices of any other websites and encourages You to review the privacy policies of those websites. Neff is not responsible for the content of linked sites, Your use of any linked sites, or any information (including Your personal information) collected, posted, used, or displayed by operators of any linked sites. This includes, but is not limited to, social media sites (e.g., Facebook, Pinterest, Twitter, etc.) or any other application developer, application provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, which are not affiliated with Neff.
INTENDED SITE AUDIENCE AND NOTICE REGARDING CHILDREN’S PRIVACY
The Website is a general audience site for use by adults age 18 or over, and is intended for use solely by individuals in the United States. The Website is not designed or intended for use by persons under the age of 18.
We do not knowingly collect or store any personal information from children under the age of 18. We encourage parents and guardians to spend time with their children online and to be fully familiar with the online services used by their children. If a parent or guardian becomes aware that his or her child under 18 has provided Us with information without his or her consent, he or she should contact Us at email@example.com.
California minors under 18 years old may request the removal of any information that they posted to this Website by contacting firstname.lastname@example.org. Upon such request, Neff will anonymize or remove from public view any content posted by a minor to Our Website, unless required by law to retain such content or information.
CALIFORNIA PRIVACY RIGHTS
This Section applies only to consumers who are California residents, and to the personal information of those consumers that is collected by Neff. For California residents, personal information is defined by the California Consumer Privacy Act (“CCPA”) as any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
The CCPA requires certain disclosures about the categories of personal information that We collect and how We use it, the categories of sources from whom We collect personal information, and the third parties with whom We share it. This information is explained in the “Collection of Personal Information”, “Use of Personal Information, “Other Information”, “Third Parties Working With Us”, and “Disclosure of Personal Information” sections above.
California customers have the right to request: (1) that Neff disclose what personal information about them that We collect, use, and disclose, including the specific pieces of the personal information about them collected by Neff in the preceding 12 months (known as a “request to know”); and (2) that Neff delete the personal information about them collected or maintained by Neff (known as a “request to delete”). Note that there are certain exceptions under the CCPA that, if applicable, may not require Neff to delete personal information in response to a request to delete.
If You are a California resident and would like to submit a request to know or a request to delete, You may submit Your request in one of the following methods:
- Submit a Data Access Request Form;
- Email: email@example.com. You will be asked to complete the Data Access Request Form from line 1; or
- Send a completed printed Data Access Request Form (found in the link from line 1) to the following address:
CCPA Rights Requests
13 South 3rd Street
Philadelphia, PA 19106
Requests will be responded to, free of charge, within 45 days of receiving the request. Consistent with California law, You may only make two such requests in a 12-month period, and the information provided will only cover the information collected in the preceding 12 months.
In order to process a request, We will need to verify Your identity. We may request two or more data points of personal information and other proof of identification depending on the nature of the request and the personal information requested to verify Your identity.
As a California resident, You also have the right to designate an agent to exercise these rights on Your behalf. We may require proof that You have designated the authorized agent to act on Your behalf and to verify Your identity directly with Us.
Your exercise of these rights will have no adverse effect on the price and quality of Our goods or services.
VISITORS FROM OUTSIDE THe UNITED STATES—CROSS-BORDER TRANSFER
Except when specifically requested in connection with the Client Services We provide You, We request that You not send Us, and You not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religious, philosophical, or other beliefs, information related to sex life or sexual orientation, health data, biometric or genetic characteristics, criminal convictions and offenses, or trade union membership) on or through the Services or otherwise to Us.
You can reach Us at firstname.lastname@example.org or at:
13 south 3rd Street
Philadelphia. PA 19106
Because email communications are not always secure, please do not include any sensitive information in Your emails to Us.
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