MAX DEF PRODUCTIONS, INC.
Last Modified and Effective as of August 16, 2016
“Agent” means any third party that processes, collects or uses Personal Data under the instructions of, and solely for, us or to which we disclose Personal Data for use on our behalf.
“Personal Data” means any information or set of information that (1) identifies or could be used by us or on our behalf to identify any individual (such as name, email address, telephone number, photograph, etc.), (2) is recorded in any form and (3) is received by us in the U.S. from the E.E.A. and Switzerland, either directly from individuals or from our affiliates. Personal Data does not include anonymized information, aggregated information or publicly available information that has not been combined with non-public personal information. Personal Data includes all Sensitive Personal Data (as defined below).
“Sensitive Personal Data” means Personal Data that: (a) reveals race; ethnic origin; political opinions, religious, ideological or philosophical beliefs; or trade union membership, views or activities; (b) concerns health or sex life, information about social security benefits, or information on criminal or administrative proceedings and sanctions other than in the context of pending proceedings or (c) is received from a third party where that third party reasonably identifies and treats the information as sensitive personal data pursuant to the European Union Data Protection Directive 95/46/EC (the “Data Protection Directive”).
Purposes for which we will collect and use your Personal Data
Purposes for which we may collect and use Personal Data from our employees and job applicants include:
- Carrying out human resources functions such as employee record-keeping, corporate administration, training, operations and management, implementing career and succession planning, administering employee contracts, evaluating employees, implementing employment-related actions and obligations and providing employment benefits and related information.
- Enabling us and our employees to contact one another using an employee’s work telephone and fax numbers, e-mail address or mailing address or use our systems (e.g., authentication).
- Administering compensation, bonus and benefits plans and other employment
- Arranging, booking and implementing employees’ travel plans and arrangements for business related
- Enabling us to maintain building security and employee security, health and
- Transferring Personal Data in connection with our legal, regulatory compliance and auditing
- Facilitating our internal administration operations and analytics, such as project staffing, headcount, statistics initiatives and internal
- Complying with our legal obligations, policies and
- As otherwise stated when you provide your
Purposes for which we may collect and use Personal Data from our customers, consumers and other non-employees include:
- Responding to individual inquiries, including in connection with prospective employment with us, and administering and processing an individual’s employment application to our company.
- Communicating to individuals about our or third party products, services and related issues (e.g., e-mail marketing and advertising).
- Notifying individuals of, and administering, contests, sweepstakes, promotions and other offers.
- Evaluating the quality of and supporting our products and
- Allowing individuals to register for our Web sites, online communities and other social networking services, and administering and processing these
- Enhancing or customizing your experience on our Web sites (e.g., online behavioral advertising).
- Transferring Personal Data in connection with our legal, regulatory compliance and auditing
- Facilitating our internal administration operations and analytics, maintaining and administering and operating our Web sites and complying with our legal obligations, policies and
- As otherwise described in the privacy policies of any of our consumer Web sites, apps or online services.
Where we receive Personal Data from our affiliates or other entities in the E.E.A. or Switzerland, we will use and disclose such Personal Data in accordance with the notices provided by such entities and the choices made by the individuals to whom such Personal Data relates.
We may share Personal Data with our affiliated entities. We may also disclose Personal Data to our Agents in the United States and other third parties when required to do so under law or by legal process. We do not use Personal Data for purposes incompatible with the purposes for which the information was originally collected without notifying the relevant individuals of such uses and offering an opportunity to opt out. We will also take reasonable steps to ensure that Personal Data is relevant to its intended use, accurate, complete and current.
Your choices with respect to disclosure and use of your Personal Data
We will allow individuals whose Personal Data is collected in the E.E.A. or Switzerland and transferred to the U.S. to decide, by either opt-in or opt-out, as may be required by relevant local laws, rules or regulations, whether your Personal Data may be (1) disclosed to a third party that is not an Agent or (2) used for a purpose other than the purpose for which it was originally collected or subsequently authorized by that individual, as may be identified by us from time to time.
For Sensitive Personal Data, we will give you the opportunity to affirmatively and explicitly consent (opt in) to permit us to (1) disclose Sensitive Personal Data to a third party that is not an Agent or (2) use Sensitive Personal Data for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.
Steps we take when transferring Personal Data to Agents
We will obtain assurances from our Agents that they will safeguard Personal Data that they receive from us in a manner consistent with this Policy. Examples of appropriate assurances that may be provided by Agents include: (1) entering into Standard Contractual Clauses (as approved by the European Commission or Swiss Federal Data Protection Commissioner) with us, or (2)
entering into other contractual obligations with us, by which the Agents agree to comply with the Data Protection Directive or the Swiss Federal Act on Data Protection (as appropriate). Where we have knowledge that an Agent is using or disclosing Personal Data in a manner contrary to this Policy, we will take reasonable steps to prevent or stop the use or disclosure.
How we secure your Personal Data
We will take reasonable precautions to protect Personal Data from loss, misuse and unauthorized access, disclosure, alteration or destruction. As necessary, we will take additional precautions regarding the security of Sensitive Personal Data. While we strive to secure Personal Data, even reasonable security measures do not guarantee the security of any information, and we cannot guarantee that the Personal Data it seeks to protect will be protected in all circumstances, including those beyond its reasonable control. Records containing Personal Data are considered our property and should be afforded confidential treatment at all times, regardless of whether these records are in electronic or paper form.
How you can access your Personal Data
If you request it, we will grant you with reasonable access to your Personal Data that is held by us. In addition, we will take reasonable steps to permit you to correct, amend or delete Personal Data that you tell us is inaccurate or incomplete. However, to the extent permitted by applicable local laws, we may limit your access to your Personal Data where the burden or expense of providing access would be disproportionate to the risks to your privacy or where the legitimate rights of other persons would be violated.
With respect to Personal Data of employees and job applicants, we will provide such access either directly or through the employer located in the E.E.A. or Switzerland.
How to contact us
Any questions or concerns regarding the use or disclosure of Personal Data should be directed to us at the e-mail address listed below.
We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Data using our internal procedures. For complaints that cannot be resolved through our internal procedures, you may contact your national Data Protection Authority in the E.E.A. or Switzerland. As far as reasonably practicable, we will cooperate with any dispute resolution procedures established by the Data Protection Authority.
Please submit questions or comments regarding this Policy or our practices concerning Personal Data to:
For all questions or comments, please include your name, street address, city, state, zip code and email address (your street address is optional if you wish to receive a response to your request via email), indicate your preference on how our response to your request should be sent (email or postal mail) and include “E.E.A./Swiss Data” in the subject of the email.
Our adherence to this Policy may be limited by any applicable legal, regulatory, ethical or public interest consideration and as expressly permitted or required by any applicable law, rule or regulation. For example, we may disclose Personal Data to law enforcement or judicial authorities when this is requested of us as part of civil or criminal law enforcement or legal proceedings to comply with our legal obligations. We will use our reasonable efforts to ensure the security and confidentiality of Personal Data in such cases.
We may also sell, transfer or otherwise disclose Personal Data reasonably related to the sale, assignment, transfer or other disposition of all or part of our business, subject to and in accordance with applicable law.
Changes to this Policy
This Policy may be amended from time to time. Subject to any local law requirements, we will post or display notices of material changes at the top of this Policy, on the homepage or otherwise on the websites that link to this Policy, and/or via e-mail; the form of such notice is at our discretion.