Privacy Policy Statement

1. Havas commits to protect your personal data

Havas Worldwide Hong Kong Limited (“us”, “we”, “our”, “Havas”) is committed to protecting your personal data and your privacy.  We comply with the requirements of the Personal Data (Privacy) Ordinance (Cap. 486 of the Laws of Hong Kong) (the “Ordinance”) to collect, hold, use and process your personal data.  We encourage you to carefully read this Privacy Policy Statement (the “Policy”).

The meaning of “personal data” in this Policy shall have the same meaning as defined in the Ordinance. Generally, personal data means information which relates to a living individual and can be used to identify that individual. This Policy informs you of our data protection and privacy practices and the way your personal data is collected, held, used and processed by Havas. This Policy will be readily available on our home page and at the bottom of each page of this website.

2. Collection of Personal Data Statement

i. How do we collect, hold, process and use your personal data?

Havas respects the rights of each individual to have their privacy and personal data protected.  We will keep your personal data confidential. We take appropriate steps to protect personal data we hold against loss, unauthorised access, use, modification or disclosure. 

Havas will observe the following principles when we collect, hold, process and use  your personal data:

  1. We collect your personal data in a lawful and fair way, for specified and lawful purposes. The personal data collected is relevant to and not excessive for the purposes for which it is collected and used.
  2. We seek to maintain your personal data accurate, and where necessary, up-to-date. We will take practicable steps to correct inaccurate or incomplete data. We keep your personal data only for the duration as it is necessary for the purposes for which it is collected and used and as permitted or required by the applicable law.
  3. We only use your personal data for the purpose for which it is collected or for a directly related purpose.
  4. We take appropriate technical and organisational security measures to keep your data safe and prevent unauthorised access, processing, loss or use.
  5. We are open about our personal data policies and practices.
  6. We give you access to your personal data and allow you to make corrections where the data is inaccurate.
ii. Why we collect and for what purposes we use your personal data?

Havas may collect personal data from you for the following purposes:

  • provision and administration of Havas’s services (including organising or co-organising events);
  • identity verification;
  • enquiry and/or complaint;
  • promotion;
  • advertisement;
  • subscriptions to newsletters and sending those letters;
  • job applications and recruitment;
  • website analytics (including improving web user experience) – see also our Cookies Policy for our use of cookies;
  • prevention and detection of crime and disclosure or assistance in accordance with legal (such as court order) or regulatory authority requirement; and
  • all other matters in relation to the daily operation of Havas.
iii. What data is collected?

Havas collects and uses your personal data with appropriate notice and consent when it is required, and after having informed you in a proper way. The types of personal data we collect from you may include:

  • your name, surname, age, company, email address, phone number;
  • educational and employment background, and job interest data (for candidates);
  • your Havas user ID and password (where applicable);
  • online identifiers (cookie id, pixels, IP address); and
  • website navigation behaviour.

You have the right to decide whether you provide your personal data to us and are not obliged to do so.  If you do not provide us with the requested personal data or if the personal data provided by you is inadequate or inaccurate, we may not be able to provide you with the services of Havas.

iv. Disclosure/transfer of personal data

Havas use external providers which may have access to your personal data.  Where disclosure of personal data is necessary to satisfy the purpose of using your personal data, we may provide such personal data to:

  • agents, contractors, suppliers and any third-party service provider who provides administrative, marketing and research, distribution, data processing, telemarketing, telecommunications, computer, payment or other services to Havas in connection with our operations;
  • business partners for such purposes in relation to promotion or direct marketing; and
  • government and regulatory authorities and other organisations, as required by law, by court order or in response to any legally valid inquiry, or otherwise necessary to the establishment of the legal claims or defences, to obtain legal advice or to exercise and defence Havas’s legal rights.
v. Links to third-party websites

Havas websites or services may provide links to third-party applications, products, services, or websites for your convenience and information. If you access those links, you will leave the Havas website. Havas does not control those third-party websites or their privacy practices, which may differ from our practices. We do not endorse or make any representations about third-party websites. The personal data you choose to provide to or that is collected by these third parties are not covered by this Policy. We encourage you to review the privacy policy of any website you interact with before allowing the collection and use of your personal data. We may also provide social media links that enable you to share data with your social networks and to interact with Havas on various social media sites. Your use of these links may result in the collection or sharing of data about you, depending on the feature. We encourage you to review the privacy policies and settings on the social media sites with which you interact to make sure you understand the data that may be collected, used, and shared by those sites. If you post, comment, indicate interest, or share personal data, including photographs, to any public forum, social network, blog, or other such forum, please be aware that any personal data you submit can be read, viewed, collected, or used by other users of these forums, and could be used to contact you, send you unsolicited messages, or for purposes that neither you nor Havas have control over. Havas is not responsible for the personal data you choose to submit in these forums.

vi. Direct marketing

Subject to your consent, we may use the personal data you provide for direct marketing carried out by us, and such personal data held by us may be provided to other entities for their use for direct marketing.  We will not use your personal data for direct marketing unless and until you consent (or indicate that you have no objection).

If you do not wish us to use your personal data for direct marketing, you may send request in writing to the Havas Data Protection Officer at [email protected]

vii. Your data protection rights
  • Right of access

You may inquire as to the nature of the personal data Havas owned about you in accordance with the provisions of the Ordinance. Your right of access includes the right to request a copy of your personal data provided to us.  Havas has the right to charge a reasonable fee for processing any data access request.

  • Right to correction

If your personal data is inaccurate or incomplete, you may request that the data be amended in accordance with the provisions of the Ordinance.

  • Enquires

Any enquiries regarding your personal data provided or access to and request for correction of your personal data shall be made in writing to the Havas Data Protection Officer at Data.protectionhk@annabellali

3. Changes to the Policy

Havas reserves the right to modify the Policy as needed, for example, to comply with changes in laws, regulations, Havas’s practices and procedures, or requirements imposed by data protection authorities.

Last update: September 2022