Data Protection Policy

Havas is committed to protecting your privacy and personal data.

Havas (“we”, “our”) is committed to protecting your personal data and your privacy. We encourage you to carefully read this Data Protection Policy (“Policy”). This Policy informs you of our data protection and privacy practices and the way your personal data is collected and used by Havas. This Policy will be readily available on our home page and at the bottom of each page of this Website. Havas strongly supports the fundamental rights to privacy and data protection as well as compliance with national and international privacy laws. This Policy is applicable to all Havas UK entities which collect, process, use, transfer and store personal data.

How we process your personal data

Havas respects the rights of each individual to have their privacy and personal data protected. Havas will observe the following principles when processing your personal data:

  1. Processing your personal data fairly, lawfully and in a transparent manner;
  2. Collecting your personal data for specified, legitimate purposes and not processing further in ways incompatible with those purposes;
  3. Collecting your personal data which is relevant to and not excessive for the purposes for which it is collected and used.  We may render personal data anonymous when feasible and appropriate, depending on the nature of the data and the risks associated with the intended uses;
  4. Maintaining your personal data accurate, and where necessary, kept up-to-date. We will take reasonable steps to rectify or delete data that is inaccurate or incomplete;
  5. Keeping your personal data only as long as it is necessary for the purposes for which it was collected and processed;
  6. Processing your personal data in accordance with the individual’s legal rights;
  7. Taking appropriate technical and organisational security measures to keep your data safe and prevent unauthorised access, unlawful processing, and unauthorised or accidental loss, destruction, or damage to personal data;
  8. Processing your personal data only if it is lawful in accordance with a legal basis including if you have unambiguously given your consent to such process

What data is collected 

In its capacity as data controller, Havas collects and processes your personal data after informing you accordingly. Personal data is any information relating to an identified or identifiable natural person. An identifiable person is a person who can be identified, directly or indirectly, in particular by reference to an identifier or to one or more factors specific to their physical, physiological, mental, economic, cultural or social identity. This Policy does not cover data rendered anonymous, i.e. when individuals are no longer identifiable or are identifiable only with a disproportionately large expense in time, cost and labour. If anonymous data becomes identifiable, or if pseudonyms are used and allow individuals to be identified, then this Policy will apply. It is up to you whether or not to disclose personal data to us. However, if you choose not to do so, we reserve the right not to register you as a user or not to provide you with the requested service.

In general, your personal data is collected directly from you, but it may also be collected from third parties.

The types of personal data we process include:

Except for specific legal obligations, we do not collect so-called “sensitive” personal data or special categories of personal data.

In general, and with some exceptions, the use of Havas websites and Havas pages on social networks is reserved for adults.

Purpose, Legal Basis and Data Retention Period

The processing operations carried out by Havas have the following purposes, legal bases and retention periods:

PurposeLegal basisRetention period
Customer relationship managementPerformance of the contract
Legal obligation (accounting/tax
Term of the contract plus applicable limitation periods
Partner and supplier relationship managementPerformance of the contract
Legal obligation (accounting/tax
Term of the contract plus applicable limitation periods
Application managementLegitimate interest of Havas2 years
Product and institutional communication management (website and social networks)Legitimate interest of HavasDuration of the communication plus applicable limitation periods
Administrative and legal formalities and the fight against fraudLegal and regulatory obligationDuration of applicable legal requirements
Subscription to newslettersConsentDuration of subscription to the newsletter
Management of cookies and other website trackersConsent
Legitimate interest of Havas (technical cookies)
Periods specified in the website cookies policy
Management and follow-up of contact requestsLegitimate interest of HavasTime required to process the request
Reporting and securing access to websitesLegitimate interest of Havas6 months to 1 year maximum
Exercising your personal data rightsLegal and regulatory obligation1 year or 6 years from the request to exercise the right, according to the right exercised

In the event of litigation/proceedings, particularly legal proceedings, initiated before the end of the above periods and which require the retention of personal data, particularly with a view to the establishment, exercise or defence of rights, such personal data shall be retained for the duration of said proceedings and until the exhaustion of the legal remedies. 

Who is the recipients of your data

Your personal data may be disclosed to staff in the following departments, according to their powers and authorizations and only if necessary for their activity, according to the purposes strictly pursued:

Internal recipients: General Secretariat, Communication, Legal, Finance and Accounting, Purchasing, Business Development, Digital, IT, General Services and Human Resources departments.

External recipients: The hosting providers of our websites, our auditors and statutory auditors, our legal advisers, our insurers, our duly authorized partners, service providers and subcontractors which we may use to carry out our activities, tax and social security bodies, public authorities, court officers and ministerial officers where applicable.

Data Transfer 

Your personal data collected and processed for the purposes described above may in certain cases be transmitted to companies outside of the UK.

Some of these companies maybe be based in countries that have an adequate level of data protection. In other cases, the transfers of your personal data are governed by the implementation of appropriate safeguards to ensure the confidentiality and security of the transferred data.

Havas may conclude contractual clauses with the recipients of such data in accordance with the recommendations of the ICO.  In addition, and where the legislation of the third country does not provide protection equivalent to that offered in the UK, we shall ensure that additional measures are implemented to guarantee a level of protection of your personal data essentially equivalent to that provided in the UK.

You are also advised that transfers of personal data outside the UK are lawful if in particular (i) the transfer is necessary for the performance of a contract between the data subject and the data controller or for the implementation of pre-contractual measures taken at the request of the data subject, if (ii) the transfer is necessary for the conclusion or performance of a contract concluded in the interest of the data subject between the data controller and another natural or legal person, or if (iii) the data subject has given explicit consent to the proposed transfer, after having been informed of the risks that the transfer could entail for him or her due to the absence of an adequacy decision and appropriate safeguards.

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.

Your data protection rights

Right of access: As data subjects you may inquire as to the nature of the personal data Havas holds about you. You will be provided access to your personal data regardless of the location of the data processing and storage.

Right to rectification: If your personal data is inaccurate or incomplete, you may request that the data is amended.

Right to object: You have the right to object at any time to the processing of your personal by Havas.

Right to erasure: You can ask for the deletion of your personal data when it is allowed by applicable laws and regulations.

Right to restriction of processing: You have the right to request the processing of your personal data to be restricted when it is permitted by applicable laws and regulations.

Right to data portability: If you meet the conditions settled by the applicable laws and regulations, you have the right to receive a subset of your personal data and to transmit it from Havas to another data controller.

Right to lodge a complaint: You have the right to lodge a complaint with the competent supervisory authority. All requests for aforementioned rights, and any questions regarding this Data Protection Policy, may be sent to: Havas Data Protection Officer

Changes to this policy

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

Last update: August 2023