Advantage Communications Group

Privacy Policy

1.      Introduction

Advantage respects and values the privacy of its customers, partners, visitors, employees, and end users, thereby recognizing the need to protect and manage the personal information it receives on a daily basis. Advantage stands by the principles in this privacy policy (“Policy”) and is committed to the protection of all personal information in its possession. This Policy explains how Advantage processes and protects personal identifiable information (“Personal Data”), which will either be disclosed by you (“You” or “Your” as applicable) or obtained by Advantage on Your behalf.

The core of Advantage’s services involve the processing of confidential and sensitive information, and/or Personal Data. Such processing requires Advantage to comply with applicable privacy and data protection laws. In particular, when Advantage processes Personal Data of EU citizens, Advantage has a duty to comply with the General Data Protection Regulation (GDPR) established by the EU. The GDPR requires companies to ensure that when Personal Data of EU citizens is transferred out of the EU, it is transferred to a recipient that will adequately protect the Personal Data. In furtherance of this obligation, Advantage volunteered to adhere to the EU-U.S. and Swiss-U.S. Privacy Shield frameworks (“Privacy Shield”) because any company that is certified under these frameworks is deemed to have  the requisite ‘adequate protection’. These frameworks will be referred to collectively as the “Principles”.

For the purposes of this Policy, Advantage distinguishes between the following categories of individuals that may have their information processed by Advantage:

  • “Customer” means an entity which engages Advantage for technology and telecommunication advisory services;

  • “End User” means any individual who provides data to Customer and is included as an employee or representative with respect to Customer’s account with Advantage;

  • “Partner” means either (i) an individual who has facilitated the relationship between Advantage and Customer, and who may from time to time, with Customer’s consent, access Advantage’s systems to review Customer data or (ii) a provider of telecommunications and technology services; and

  • “Visitor” means an individual that visits www.advantagecg.com.

Advantage provides technology and telecommunication advisory services (“Services”) to its customers and utilizes an on-line portal to provide reports from such Services to its customers. All information stored on Advantage’s platform is treated as confidential, is stored securely, and is only accessed by authorized personnel.  As a requirement of Privacy Shield, Advantage maintains appropriate technical, security, and organizational measures to protect Personal Data against unauthorized or unlawful processing and use, and against accidental loss, destruction, damage, theft or disclosure.

2.      Privacy Shield

2.1 Notice. The U.S. Department of Commerce and the European Commission and the U.S. Department of Commerce and the Swiss Federal Data Protection and Information Commissioner have each agreed on a framework of data protection principles and supplemental principles to enable U.S. companies to provide an adequate level of protection for when Personal Data is transferred from the EEA[1] to the U.S., and from Switzerland to the U.S, respectively. Advantage complies with the Principles regarding the collection, use, and retention of Personal Data from European Union member countries, and from Switzerland, respectively. Advantage has certified that it adheres to the Principles of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access, recourse, enforcement and liability as well as the supplemental principles of both frameworks.

Advantage complies with Privacy Shield as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Data transferred from the (European Union and/or Switzerland, as applicable) to the United States in reliance on Privacy Shield. Advantage has certified to the Department of Commerce that it adheres to the Privacy Shield Principles with respect to such information. To learn more about the Privacy Shield program, and to view Advantage’s certification, please visit https://www.privacyshield.gov/ or the U.S. Department of Commerce website. A current list of organizations certified under the Privacy Shield framework (“Privacy Shield List”) is available at https://www.privacyshield.gov/list. Should there be any conflict between the Principles and this Policy, the Principles shall prevail. This Policy outlines the general practices for implementing the requirements of the Principles in connection with Personal Data that is transferred from the EEA to the U.S and from Switzerland to the U.S., including the types of information that is collected and transferred; how it is used; and, the choices individuals located in the EEA or Switzerland, have regarding the use of, and their ability to correct, that information.

Whether Advantage collects Personal Data of individuals directly or indirectly, this Policy informs such individuals of the purposes for which Advantage collects and uses Personal Data, including any transfer to Advantage in the U.S., the identity of third parties acting as processors to which Advantage discloses such information, the purposes for which it does so, the means in which Advantage limits the use and disclosure of their Personal Data, and about the right of individuals to access their Personal Data. Notice will be provided to Customers or individuals as appropriate before Advantage uses the information for a purpose other than that for which it was originally collected or discloses it for the first time to a third party.

2.2   Choice.   Advantage will offer Partners and Customers, the opportunity to opt-out as to whether Personal Data of their End Users is (a) disclosed to a third party acting as a sub-processor, or (b) used for a purpose that is materially different from the purpose for which it was originally collected or subsequently authorized by the individual. Advantage will provide Controller and individuals, as applicable, with reasonable mechanisms to exercise their choices.

Advantage respects Your privacy and has no desire to contact You if You do not wish to hear from us. If, for any reason, You wish to cease receiving messages from Advantage please send an email to advantgaecg.com with a subject line of “Unsubscribe”, including any other details that will help Advantage fulfill Your request.

2.3   Accountability for Onward Transfer.  Advantage will obtain assurances from authorized third parties that they will safeguard Personal Data consistent with this Policy and will transfer Personal Data only for limited and specific purposes. Advantage recognizes its responsibility and potential liability for onward transfers to unauthorized third parties. Where Advantage has knowledge that a third party is using or disclosing Personal Data in a manner contrary to this Policy and/or the level of protection as required by the Principles, Advantage will take reasonable and appropriate steps to prevent, remediate or stop the use or disclosure. The sub-processors that Advantage engages for support services will be posted on the Advantage website.

2.4   Access. Upon request, Advantage will take reasonable steps to permit individuals, whether directly or through the Controller of the Personal Data, to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete or has been processed in violation of the Principles. Advantage may limit an individual’s access to Personal Data where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy or where the legitimate rights of persons other than the individual would be violated.

2.5   Security.  Advantage will take reasonable and appropriate precautions to protect Personal Data in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the Personal Data.

2.6   Data Integrity and Purpose Limitation. Advantage will use Personal Data only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Advantage will take reasonable steps to ensure that Personal Data is relevant to its intended use, accurate, complete, and current. Advantage will adhere to the Principles as long as it retains Personal Data received under the Principles.

2.7   Recourse, Enforcement and Liability. Advantage utilizes the self-assessment approach to assure its compliance with this Policy. Advantage periodically verifies that this Policy is accurate, appropriate for the information intended to be covered, prominently displayed, completely implemented, and in conformity with the Principles. Advantage encourages interested persons to raise any concerns with it using the contact information below. Advantage and its dispute resolution provider, will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Data in accordance with the Principles.

2.8   Limitations. Advantage's adherence to the Principles may be limited (a) to the extent necessary to meet applicable national security, public interest, or law enforcement requirements (i.e. in the course of lawful requests by public authorities) (b) by statute, government regulation, or case law that creates conflicting obligations or explicit authorizations, provided that, in exercising any such authorization, an organization can demonstrate that its non-compliance with the Principles is limited to the extent necessary to meet the overriding legitimate interests furthered by such authorization; or (c) if the effect of a Directive or Member State law is to allow exceptions or derogations, provided such exceptions or derogations are applied in comparable contexts.

3.      Collection and use

3.1   General. This section addresses how data is collected for Visitors, Partners, End Users and Customers.

3.2   Visitors. If You are a Visitor to Advantage’s website only, and not an End User or a user of Advantage’s platform, then this section applies to You.

By visiting Advantage’s website, You consent to the collection and use of the Personal Data You provide as described herein. If You do not agree with the terms set out herein, please do not visit this website or otherwise provide Advantage’s Your Personal Data. If required by applicable law, Advantage will seek Your explicit consent to process Personal Data collected on this website or volunteered by You. Any consent You provide will be entirely voluntary. However, in the event You do not grant Advantage consent to process Your Personal Data, the use of this website may not be possible.

By using the website and volunteering Your Personal Data, You authorize Advantage to collect, record, and analyze information that You disclose. We may also record Your IP address and use cookies and add information collected by way of pageview activity. Advantage may also collect and process any Personal Data You volunteer to Advantage in our website’s forms for sales and marketing purposes. If You submit Your resumé in response to a job positing, when Advantage evaluates Your candidacy Advantage will not disclose such information to third parties that do not have a need to know. However, Advantage may use Your Personal Data for purposes of furthering Your candidacy. If You provide Advantage with Your social media details, Advantage may retrieve publicly available information about You from social media. In this context, Personal Data may comprise Your IP address, first and last name, postal and email address, telephone number, job title, data for social networks, interest in Advantage products, and certain information about the company You are working for (company name and address), as well as the type of relationship that exists between Advantage and Yourself.

Advantage gathers data about visits to the website, including number of Visitors, geo-location data, length of time spent on the site, pages clicked, or where Visitors have come, etc. Advantage uses the collected data to communicate with Visitors and to improve its website by analyzing how Visitors navigate its website, so it may also share such information with service vendors or contractors in order to provide a better Visitor experience

3.3   Partners.  Partners should be aware that by utilizing the Advantage platform, they could be disclosing information that could make their Personal Data available to Advantage. Advantage will collect Partner’s data for the purpose of enhancing its customer relationships, improving its Services and website experience, making payment to Partner when applicable, and to inform Partners of any updates regarding Advantage, via newsletters or other means of communication.  Partners should be aware that they themselves are responsible for the content they disclose to Advantage. For more detailed information, Partners may contact Advantage at the address below.   

3.4   End Users.   End Users should be aware that by being employed by Customer, they have or could be disclosing Personal Data. The security and privacy protection implemented on Advantage’s platform covers this type of transfer or disclosure of Personal Data. Nonetheless, End Users providing any Personal Data to its employers should be aware that they are responsible for the uses of such Personal Data and have rights to withdraw their consent for Advantage to process their Personal Data. End Users have a right to contact their employer or the Customer that is providing End User’s Personal Data. It is the Customer’s responsibility to ensure that collection and processing of data is done in accordance with applicable law. Therefore, Advantage will not process Personal Data of End Users for purposes or by means other than instructed by its Customers. If You wish to inquire about Your Personal Data that may have been collected while Advantage provides Services to Your employer or to Advantage’s Customer, Advantage recommend that You contact Customer that created or sent Your Personal Data. For clarity, Advantage is a Processor with respect to End User Personal Data, so it does not control the Personal Data used or stored in its possession, but rather processes it on behalf of Customer.

3.5   Customers. In order to provide Services to Customers, Advantage needs to collect certain types of data. Most of this data may be deemed Personal Data that Customer collected from its End Users during its ordinary course of business. To be clear, data transferred to Advantage by Customers through direct or indirect means, remains the property of the Customer and will not be shared with a third party by Advantage without express consent from Customer.

3.5.1    Collection of Customer data.    Upon Customer’s onboarding process and all throughout the engagement with Advantage, Customers provide data relating to Customer and its End Users, which may include names of employees, company name, email, business address, corporate provided mobile numbers, business telephone numbers, business e-mail, and other relevant data. This information is used by Advantage to identify the Customer and provide them with Services, support, surveys, mailings, sales and marketing actions, billing and to meet contractual obligations. Advantage does not sell, rent, or lease customer lists to third parties.

Advantage Customers may at any time access, create, edit, update or delete their contact details by logging in with their username and password to Advantage’s platform, provided employees of Customer have such permissions. Advantage Customers may create more user accounts with different privilege levels within their account. It is Customer’s responsibility to choose the level of access each user accessing Customer accounts should have. Advantage will not retain Customer data longer than is necessary to fulfill the purposes for which it was collected or as required by applicable laws or regulations. Notwithstanding, Advantage will expunge such data in accordance with its normal operating procedures with respect to data deletion

3.5.2    Collection of End User data. For purposes of the Services, End User Personal Data used is provided by Customers, so it is the Customer’s responsibility to ensure that collection and processing of data is done in accordance with applicable law. Advantage will not process Personal Data for other purposes or by other means than instructed by its Customers.

The purpose of collecting or processing End User Personal Data would be ancillary to the core Services, but may necessary for Advantage to provide the Services. For these purposes, Personal Data may include, personal contact information such as name, business address, mobile number, email address, business contact details, country of where End User may access Advantage portal, and other sensitive Personal Data

3.5.2.1    Collection of End User data in EEA or Switzerland.   For Customers in the EEA or Switzerland, or for Customers providing Personal Data of End Users who are citizens of the EEA, or Switzerland, the Customer will be the “Controller”, as defined in the Directive and the GDPR. The purpose of processing will consequently be defined by Advantage’s Customer. If You or Your organization are required under GDPR to enter into a contract, or other binding legal act under EU or Member State law, with Your data processors, then You must review and accept Advantage’s Data Processing Agreement which governs the transfer of data from the E.U. to U.S and from Switzerland to the U.S.

3.6   Security. Advantage secures Personal Data from unauthorized access, use or disclosure. When Personal Data is transmitted to other websites, it is protected through the use of encryption, such as the Secure Sockets Layer (SSL) protocol.

3.7   Geographical location. Advantage’s data center that stores all collected information, whether Visitor, Partner, End User, Customer, is stored in secure hosting facilitates provided by Amazon Web Services located in the United States. No Personal Data is transmitted outside of the U.S, without the proper legal authorization documented by Data Processing Agreements. Advantage has a data processing agreement in place with Amazon Web Services, ensuring compliance with applicable law. All hosting is performed in accordance with the highest security regulations.

3.8   Processing in the EEA and Switzerland. The GDPR (the Regulations (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data) is the prevailing EU law.

3.9   Cookies

3.9.1     What are Cookies? Modern websites collect certain basic information about users in order to work according to user’s expectations. To do this, sites create small text files that are placed on user’s devices, known as “Cookies”. Cookies are uniquely assigned to each user and can only be read by a web server in the domain that issued the Cookie to the user. Cookies cannot be used to run programs or deliver viruses to a user’s device. Cookies do various jobs which make the user’s experience of the internet much smoother and more interactive by remembering a user’s preferences, which supports navigation between pages. Much of the data collected is anonymous, though some of it is designed to detect browsing patterns and approximate geographical location to improve user experience.

3.9.2      How Advantage uses Cookies. Advantage places Cookies to store and then retrieve small bits of information on Your computer when You visit the Advantage website or portal to ensure that Advantage’s content is tailored to Your specifications, thereby improving the user experience. Amongst other things, the Cookies Advantage use allow Advantage to calculate anonymously website traffic. We may collect the country of origin of users, the screen resolution and what browser is being used to access the web-site.

3.9.3      We believe that the user experience of the website would be adversely affected if any users opt-out of the Cookies Advantage uses. Nonetheless, Visitors may, at any time, opt-out and prevent the setting of Cookies through Advantage’s website by means of a corresponding setting of the Internet browser used, and may thus permanently deny the setting of Cookies. Furthermore, already set Cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If You deactivate the setting of Cookies in the Internet browser used, not all functions of Advantage’s website may be entirely usable.

3.9.4      Please be aware that while visiting Advantage’s site, users can follow links to other sites that are beyond Advantage’s sphere of influence. Advantage has no control over software, content, promotions, materials, information, goods or services available on these sites. We provide them for Your convenience only and You follow them at Your own risk because Advantage is not responsible for the content of these other sites. Further, You should be aware that any Personal Data You provide to these sites is no longer governed by this Policy.

3.10 Controller. If a Visitor submits Personal Data in conjunction with a resumé or inquiry through the Advantage website, Advantage acts as a Controller in these limited circumstances. Therefore, Advantage will determine how and when to use such data for legitimate business purposes including, but not limited to research, marketing, and billing purposes. 

With respect to End User Personal Data, Customer will be the Controller in accordance with the GDPR because Customer determines the purpose and means of processing End User Personal Data (i.e. provides the Processor instructions as to how and to what extent it can process).

3.11 Processor. With respect to End User Personal Data, Advantage is the Processor and adheres to the GDPR. Advantage only processes data in accordance with Controller’s instructions and applicable law. Advantage adopted reasonable physical, technical and organizational safeguards that substantially mirror the EU safeguards against accidental, unauthorized, or unlawful destruction, loss, alteration, disclosure, access, use or processing of the Customer’s data in Advantage’s possession. Advantage will promptly notify the Customer in the event of any known unauthorized access to, or use of, the Customer’s data.

4.      Retention and Deletion

Advantage will retain data only as long as reasonably necessary to fulfill the purposes for which it was collected or as required by applicable law or regulation.  

For End User Personal Data, Advantage’s Customers have control of the purpose for collecting data, and the duration for which the Personal Data may be kept. Customers will therefore have the responsibility to request the deletion of data when required. When a Customer’s account is terminated, all Personal Data collected through the platform that remains active will be deleted, however such information may remain on back-up data for archival purposes. Upon Your request to delete Personal Data, Advantage will honor this request unless deleting such information prevents Advantage from carrying out necessary business functions, including, but not limited to billing for the Services, calculating taxes, or conducting required internal audits, in which case Advantage will delete the requested information in accordance with its data retention policy.

5.      Acceptance of these Conditions

Advantage assumes all Visitors, Partners, End Users, and Customers have carefully read this Policy and agree to its contents. If You do not agree with this Policy, You should refrain from using Advantage’s website and platform. Advantage reserves the right to change its Policy as necessary. Continued use of Advantage’s website and platform after having been informed of any such changes to these conditions implies acceptance of the revised Policy. This Policy is an integral part of Advantage’s terms of use.

6.      Our Legal Obligation to Disclose Personal Information

Advantage will reveal an End User’s Personal Data without his/her prior permission only when there is reason to believe disclosure of this information is required to establish the identity of, to contact or to initiate legal proceedings against a person or persons who are suspected of infringing rights or property belonging to Advantage or to others who could be harmed by the user’s activities or of persons who could (deliberately or otherwise) transgress upon these rights and property. Advantage is permitted to disclose Personal Data when it has good reason to believe that this is legally required.

7.      Advantage’s Data Protection Officer

Advantage has a Data Protection Officer who can be contacted if You have questions or concerns about processing Your Personal Data.  Advantage and its dispute resolution provider will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Data in accordance with the Principles.

If You have an unresolved privacy or data use concern that Advantage have not addressed satisfactorily, please contact Advantage’s U.S. based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

With respect to unresolved disputed concerning Swiss-U.S Privacy Shield, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel. In the event Advantage or such authorities determine Advantage did not comply with this Policy, Advantage will take appropriate steps to address any adverse effects and to promote future compliance and if necessary, take disciplinary action against an employee who violated this Policy. Advantage is also subject to the investigatory and enforcement powers of the Federal Trade Commission, which is the competent supervisory body of Privacy Shield

8.      Further Information

If You have further questions regarding data collection, or how Advantage uses it, contact:

Advantage Communications Group, LLC

25 Mineola Avenue, Suite 306

Roslyn Heights, NY 11577

Attn: Chief Privacy Officer

privacy@advantagecg.com

 

[1] The European Economic Area (EEA) currently includes the following countries: Austria, Belgium, Bulgaria, Croatia, Republic of Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, Netherlands, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden and the UK

Last updated: September 2019