GHC-SRV - Privacy Notice
Going Home Creative also known as GHC-SRV (“we,” “us,” or “our”), located at 42 Broadway, Fl. 12-200, New York, NY, 10004, offers performance marketing solutions that help individuals, clients and businesses improve their marketing performance including: Paid Social, Programmatic advertising, Affiliate Marketing, SEO, Advanced Analytics and Conversion Rate Optimization. This Privacy Notice sets out how we collect, use, share, and protect any information we collect through our website. This Privacy Notice also explains the measures we take to safeguard your information and describes how you may contact us regarding our privacy practices.
Please note, this Privacy Notice does not apply to the services provided by us on behalf of clients or to data that the Agency processes on behalf of our clients.
Any data collected through this Website, including personal data (as defined under applicable data protection laws, referred to collectively as “Personal Data”), will only be used for the purposes set out in this Privacy Notice. Notwithstanding, we may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law. When data is collected on this Website, Performics is acting as a data controller.
Please read this Privacy Notice thoroughly. If you disagree with the way personal information will be used, please do not use www.ghc-srv.online
We may include links to other websites, including social media platforms. This Privacy Notice only covers this Website and does not apply to the data practices of other websites. We encourage you to read the privacy notices available on other websites you visit.
What Personal Data and Sensitive Personal Information do we collect and process through the Website?
The following table describes the categories of Personal Data and Sensitive Personal Information we collect.
Category of Personal Data and Contact Information and Identifiers
First name, last name, e-mail address, telephone number, mailing address, online identifiers; IP address; mobile ad identifiers
Internet or other electronic network activity information (Technical data)
Browsing history; online interests, such as information about categories of consumer interests derived from online usage; and information on a consumer's interaction with a website or advertisement
Geolocation data
Location information from your device or IP address
Your verbatim communications to us or shared on the public areas of our site
Information that you directly send us by using the comment functionality on this Website . Categories of the sources of Personal Data and Sensitive Personal Information we may collect: We may collect the Personal Data outlined above from the following categories of sources:
- Directly from you, for example, when you send us your questions or comments using the query form or make usage of your privacy rights.
- From data brokers, partners (e.g., that offer co-branded services, sell or distribute our products, or engage in joint marketing activities), advertising networks, data analytics providers, operating systems and social networks.
- Indirectly from you by using automated technologies, such as cookies, pixels, third party tags, scripts, log files and other means to automatically collect information about the use of our Website Further information about our use of cookies can be found in our “Cookies Notice”
III. Purpose of data collection and legal basis
The following table provides information about our purposes and legal basis for collecting your Personal Data:
Our Purposes for collecting and using your Personal Data
Basis for processing: To read and respond to your queries to us, sent using our online forms.
Depending on your request, we will rely on our legitimate interest or the performance of pre-contractual measures to respond to individuals’ queries. When you contact us through the data access request form. We rely on our legal obligation to provide you a process to exercise your rights
To contact you where you have indicated you wish to receive news from us. For visitors from the European Union, we rely on your consent, where you indicate that you want to receive marketing material from us. This concerns operating, analyzing, improving, and securing our website.
For visitors from the European Union, we rely on your consent to obtain your Personal Data through cookies
For visitors from other geographies, we rely on our legitimate interest to improve our services and develop new products.
Marketing services, for example:
Analyzing and optimizing our (or our service providers’) proprietary databases or helping us identify and mitigate potential fraud
For visitors from the European Union, we rely on your consent to use your Personal Data for marketing services
Other internal purposes, such as: internal research, internal operations, auditing, detecting security incidents, debugging, short-term and transient use, quality control, and legal compliance
Our legitimate interest to support our internal operations and conduct research
For our Canadian users, your use of the Website constitutes your implied consent for us to process your
Personal Data for the above-noted purposes.
- Interest-based Advertising.
We work with agencies, advertisers, ad networks, and other technology services to place ads about our products and services on other websites and services. For example, we place ads through Facebook that you may view on their platforms as well as on other websites.
- How We Engage in Target Advertising or Cross-Context Behavioral Advertising
As part of this process, we may incorporate tracking technologies into our own website as well as into our ads displayed on other websites and services. Some of these tracking technologies may track your activities across time and services for purposes of associating the different devices you use and delivering relevant ads and/or other content to you (“Interest-based Advertising”).
- Interest-based Advertising is also called Targeted Advertising or Cross-Context Behavioral Advertising. As indicated below, vendors and other parties may in certain contexts independently decide how to process your information. We encourage you to familiarize yourself with and consult their privacy policies and terms of use. With whom do we Share or Sell Personal Data or Sensitive Personal Data? We may disclose your Personal Data collected and processed through this Website for various purposes related to our business. The disclosure may be to our clients, partners, or vendors.
Sharing Personal Data under the California Privacy Rights Act means to disclose your Personal Data to a third party for Interest-based Advertising.
Selling Personal Data means to disclose your Personal Data to a third party for an exchanged value and a purpose other than one of the listed business purposes below in section IV of this Privacy Notice.
The table below shows with whom we may Share or Sell your Personal Data, and whether we believe we have “sold” or “shared” a particular category of information in the prior 12 months.
Category of Personal Data: The data that you submit becomes the shared property of GHC-SRV Services
Categories of Parties with Whom We Sold or Shared Your Data “Sold” in the Last 12 Months
“Shared” in the Last 12 Months
Contact Information and Identifiers
Affiliates, Service providers, advertising partners, analytics partners, promotional partners
Yes
Internet or other electronic network activity information.
Service providers, analytics partners
Yes
Geolocation data
Service providers, analytics partners
Yes
Your verbatim communications to us or shared on the public areas of our site
Affiliates
No
- Whom do we disclose Personal Data or Sensitive Personal Data?
We may disclose your Personal Data or Sensitive Personal Data to our service providers that assist us with our business purposes. Our service providers are to only process your Personal Data in accordance with our instructions and only for the purpose listed below.
The table below shows with whom we disclose your Personal Data for the specific business purpose(s).
Category of Personal Data
Categories of Parties With Whom We Disclosed Your Data for a Business Purpose
Business Purpose for the Disclosure
All submitted data is shared in compliance with the United States Federal Government, we have no control over this rule.
Contact Information and Identifiers
Affiliates, Service providers, advertising partners, analytics partners, promotional partners
Analytics, Operating Website, Marketing
Internet or other electronic network activity information.
Service providers, analytics partners. Analytics, Operating Website, Marketing.
Geolocation data
Service providers, analytics partners, Analytics, Operating Website, Marketing.
Your verbatim communications to us or shared on the public areas of our site
Affiliates: Responding to your communication
- Automated Decision Making and Profiling
To the extent that we use processes that involve automated decision making or profiling when processing your Personal Data, we take steps to ensure that any automated decision making or profiling practices are fair and not discriminatory.
- How long do we keep your information?
We keep Personal Data for as long as is necessary for the purposes described in this Privacy Notice, complying with legal and regulatory obligations, protecting our or other’s interests, and as otherwise permitted or required by law. When Personal Data is no longer necessary for or compatible with these purposes, it is removed from our systems in accordance with our internal retention policies. The criteria used to determine our retention periods include: The length of time we have an ongoing relationship with you and provide the Website or our services to you;
Whether our processing of the Personal Data is consistent with what an average consumer would expect when the Personal Data was collected;
Whether the Personal Data is processed for any other disclosed purpose(s) compatible with what is reasonably expected by the average consumer;
Whether the Personal Data is relevant and useful to the provision of our services and our further processing is permitted by law; Whether the Personal Data has been de-identified, anonymized, and/or aggregated; and
Whether there is a legal obligation to which we are subject.
- Your rights and choices regarding your Personal Data
Please email support@ghc-srv.online or complete this form if you want to make use of any of your legal rights.
- Where you are resident of the EU
1.1 General
Subject to certain exceptions and the jurisdiction in which you live, if you are a resident of the EU, the GDPR provides you with specific rights regarding your Personal Data. This subsection describes your rights and explains how to exercise those rights regarding Personal Data that we hold about you. These rights include:
The right of access:
You can access all Personal Data we hold about you, know the origin of this Personal Data and obtain a copy in an understandable format. You may also use your right to access your Personal Data to control the exactness of the data and have them rectified or deleted. You have no justification to provide to exercise your right to access;
The right to rectification:
To avoid that inaccurate or incomplete Personal Data relating to you is process or shared, you can ask us to rectify them;
The right to erasure:
You may request the erasure or deletion of the Personal Data we hold on you. This is not an absolute right since we may have to keep your Personal Data for legal or legitimate reasons. You may, for example, exercise your right to deletion in the following cases:
- if you have withdrawn your consent to the processing (see below);
- if you legitimately objected to the processing of your data (see below);
- when data is not or is no longer necessary for the purposes for which it was initially collected or processed;
- the data is processed unlawfully (e.g., publishing hacked data);
The right to object to the processing of your Personal Data:
When we process your Personal Data based on our legitimate interest (to determine to which processing this applies, please refer to Section II of this Privacy Notice), you may at any time object to the processing of your Personal Data for reasons relating to your personal situation. We may nevertheless, on a case-by-case basis, reject such a request by pointing out the legitimate and imperious reasons justifying the processing of this data which prevail on your interests, rights and freedoms, or when this data is necessary to establish, exercise or defend a right before a Court.
The right to restrict processing:
The right to limit the processing completes your other rights. This right means that the data processing relating to you and that we are performing is limited, so that we may keep this data, but we cannot use it or process it in any other manner.
This right applies in specific circumstances, i.e.:
- if you challenge the exactness of your Personal Data. The processing is then limited for a period so that the agency may verify the exactness of the Personal Data;
- if the processing is unlawful and you object to the erasure of your Personal Data and request instead that its use be limited;
- if we do not need the Personal Data for the purposes mentioned above in Section I anymore, but you still need it to establish, exercise or defend rights before a Court; and
- in the cases where you objected to the processing which is based on the legitimate interests of the agency, you may ask to limit the processing for the time necessary for us to verify if we can accept your objection request (i.e., the time necessary to verify whether the legitimate reasons of the agency prevail over yours).
- Right to object to data processing for direct marketing purpose
You may unsubscribe or object, at any time and without any justification, to the reception of direct marketing communications. Simply either (i) click on the link in the footer of the communications you receive from us; or (ii) use the hyperlink above; or (iii) send us an email at the email address set out in the “Further Information” section below with the word unsubscribe in the subject field of the email.
The right to data portability:
You may request to retrieve the Personal Data you provided us with, in a structured, commonly used, and machine-readable format, for personal use or to share them with a third party of your choice. This right only applies to Personal Data you provided us with, directly or indirectly, and which was processed through automated means, if this processing is based on your consent or the performance of a contract. Please check the list of our Personal Data processing activities’ legal grounds (in Section II of this Privacy Notice) to know whether our processing is based on the performance of a contract or on consent.
The right to withdraw your consent to the processing of your Personal Data at any time:
You may read Section II of this Privacy Notice to identify the purposes for which the processing of your Personal Data is based on your consent. If you are unsatisfied with the way we process your Personal Data or if your request has been rejected, you may also lodge a formal complaint with your local competent data protection authority. Personal Data will be stored in accordance with our applicable data retention requirements and corporate policies. The retention period for Personal Data varies depending on the type of Personal Data and the purposes of processing it.
We will respond without undue delay and in any event within one month from the data we receive your request. This timeframe can be extended by two months to take the complexity of the request, or the number of requests received into account. In this case, we will inform you within one month from receiving your request, specifying the reasons for extending the response timeframe.
- Your Rights and Choices
Residents of certain US states, such as California, Virginia, Colorado, Connecticut, and Utah, have specific rights regarding their Personal Data. This section describes how to exercise those rights and our process for handling those requests. (To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.)
2.1 Right to request access to your Personal Data
California residents have the right to request that we disclose what categories of Personal Data that we collect, use, disclose, or sell about them. U.S residents may request:
- the specific pieces of Personal Data that we have collected about you;
- the categories of Personal Data we have collected about you;
- the categories of sources from which the Personal Data was collected;
- the categories of Personal Data about you we disclosed for a business purpose or sold;
- the categories of third parties to whom the Personal Data was disclosed for a business purpose or sold; and
- the business or commercial purpose for collecting or selling the Personal Data.
When exercising the right to access Personal Data, you have the right to obtain materials in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.
When we receive and verify your request to access your Personal Data, we will make best efforts to fulfill your request unless an exception applies. We will not disclose your government identification numbers, financial account numbers, health insurance or medical identification numbers, account passwords, security questions and answer, or unique biometric data; however, to the extent we have this information, we will inform you that we have collected this information. You are permitted 2 access reports every 12 months.
2.2 Right to request deletion of your Personal Data
You may also request that we delete any Personal Data that we obtained about you. However, we may retain Personal Data for certain important purposes, as set out by applicable law.
When we receive and verify your request to delete your Personal Data, we will proceed to delete the data unless an exception applies. We will retain a record of your deletion request to keep your Personal Data deleted, unless and until you provide consent for the processing of your Personal Data post your deletion request.
2.3 Right to correct your Personal Data
If you believe we hold inaccurate personal information about you, you may request that we correct that information. We may ask for documentation showing that the information you submit is accurate and the Personal Data we hold is inaccurate. Once we receive your request, we will verify your identity and considering the type of personal information and the purposes of our holding that personal information we will make best efforts to complete your request. We may deny your request if we determine that the contested Personal Data is more likely than not accurate. Additionally, we may choose to delete your Personal Data in response to your request to correct your Personal Data if the deletion of your Personal Data would not negatively impact you.
2.4 Right to limit use of Sensitive Personal Data
You may request that we limit the use and disclosure of your Sensitive Personal Data. However, we may deny your request in part of in full under uses authorized by applicable law.
2.5 Right to nondiscrimination.
We will not deny, charge different prices for, or provide a different level of quality of goods or services if you choose to exercise your privacy rights.
2.6 Right to Opt-out of the sale of your Personal Data.
Depending what information, we have about you, and whether we have disclosed any of it to a third party in exchange for valuable consideration, we may have sold (as defined by US state laws) certain Personal Data about you, as described in the above table in Section II of this Privacy Notice. If you would like to opt out, you may do so as outlined on the following page in the “Do Not Sell My Personal Information” link in the footer of the page.
2.7 Right to Opt-Out of Share/Cross Contextual Behavioral Advertising and Targeted Advertising
You may opt-out of the processing or sharing of your Personal Data for cross-contextual behavioral advertising or targeted advertising (what we refer to above as Interest-based Advertising) by emailing support@ghc-srv.online
Additionally, you may choose not to receive targeted advertising from ad networks, data exchanges, and other digital advertising providers by opting out of targeted advertising via YourAdChoices powered by the Digital Advertising Alliance.
2.8 Right to opt-out of Automated Decision Making and Profiling
It’s your right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect. You may opt-out of the processing of your Personal Data for profiling and other automated decision making by emailing or by completing this form.
2.9 Shine the Light
Customers who are residents of California may request (i) a list of the categories of Personal Data disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To exercise a request, please write us at the email or postal address set out in the “Further Information” section below and specify that you are making a “California Shine the Light Request.”
2.10 How to exercise your US state privacy rights
US residents may exercise their applicable privacy rights by sending an email to support@ghc-srv.online or by contacting “Performics".
For security purposes (and as required under US state laws), we will verify your identity in part by requesting certain information from you—when you make a request to access, correct, or delete, your Personal Data. The verification process will utilize an email verification process, a telephone number verification process, and, if applicable, a request for any assigned ID number previously communicated to you. If we are unable to complete your request fully for any reason, we will provide you additional information about the reasons why we could not comply with your request. You may also designate an agent to make requests to exercise your rights under certain US state laws. We will take steps both to verify your identity and to verify that your agent has been authorized to make a request on your behalf by requesting your agent to provide us with a signed written authorization or a copy of a power of attorney executed by you.
- Appeal
It is your right to appeal a decision made concerning the exercise of your data privacy rights. You may appeal this decision within 60 days of receiving your response from us. To submit your appeal, contact support@ghc-srv.online or call 516-945-9157.
- Where you are a Nevada Resident
Nevada law (NRS 603A.340) requires each business to establish a designated request address where Nevada consumers may submit requests directing the business not to sell certain kinds of Personal Data that the business has collected or will collect about the consumer. A sale under Nevada law is the exchange of Personal Data for monetary consideration by the business to a third party for the third party to license or sell the Personal Data to other third parties. If you are a Nevada consumer and wish to submit a request relating to our compliance with Nevada law, please contact us as at privacyofficer@publicisgroupe.com.
- Where you are a resident of Canada
5.1 Right to request access to your Personal Data
You have a right to access your Personal Data in our control. We will also provide you with a description of what uses we have made of your Personal Data and which third parties we have shared it with. In some cases, we may not be able to provide you with access to your Personal Data, such as where:
- Personal data about another person might be revealed and the other person’s personal information cannot be separated from yours;
- Commercially confidential information might be revealed, and the confidential information cannot be separated from yours;
- The requested data is subject to solicitor and client privilege;
- Someone's life or security might be threatened because of giving you access and the personal data about the other person cannot be separated from yours;
- The information was collected for purposes related to an investigation of a breach of an agreement or contravention of the law.
We will respond to your request within 30 days, unless we require more time to do so, in which case we will advise you of the date by which we will respond to your request within 30 days of receiving it.
5.2 Right to request correction to your Personal Data
If you note any inaccuracies or wish to update any of your Personal Data, we will make those changes upon your request.
5.3 Right to withdraw your consent
At any time, you may withdraw your consent for us to process your Personal Data for the purposes described at Section II of this Privacy Notice. However, this may affect our ability to offer you some of the services. For example, we may not be able to respond to your queries.
- Your general rights regarding to data collection
6.1 Do Not Track:
Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals.
6.2 Analytics:
We may use our own technology or third-party technology to track and analyze usage information to provide enhanced interactions and more relevant communications, and to track the performance of our advertisements.
6.3 Interest-Based Advertising:
The companies we work with to provide you with targeted ads are required by us to give you the choice to opt out of receiving targeted ads. Most of these companies are participants of the Digital Advertising Alliance (“DAA”) and/or the Network Advertising Initiative (“NAI”). To learn more about the targeted ads provided by these companies, and how to opt out of receiving certain targeted ads from them but does not mean you will no longer receive any targeted content and/or ads (e.g., in connection with the participants’ other customers or from other technology services).
Please note that if you opt out using any of these methods, the opt out will only apply to the specific browser or device from which you opt out. We are not responsible for the effectiveness of, or compliance with any opt out options or programs, or the accuracy of any other entities’ statements regarding them opt out options or programs.
6.4 E-mails:
You can opt-out of receiving promotional emails from us at any time by following the instructions as provided in emails to click on the unsubscribe link or emailing us at the email address set out in the “Further Information” section below with the word unsubscribe in the subject field of the email. Please note that you cannot opt-out of non-promotional emails, such as those about transactions, servicing, or our ongoing business relations.
XII. Children
The Website is intended for general audiences and is not directed at children or for children. to use. We do not knowingly collect Personal Data (as defined by the U.S. Children’s Privacy Protection Act, or “COPPA”) from children. If you are a parent or guardian and believe we have collected Personal Data in violation of COPPA, contact us at support@ghc-srv.online We will remove the Personal Data in accordance with COPPA. We do not knowingly “sell,” as that term is defined under the US state privacy laws, like CCPA or VCDPA, the Personal Data of minors under 16 years old without legally required affirmative authorization.
XIII. Data Security
We use a variety of methods, such as firewalls, intrusion detection software and manual security procedures, designed to secure your data against loss or damage and to help protect the accuracy and security of information and to prevent unauthorized access or improper use. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about you. If you think that your Personal Data is not secure or that there has been unauthorized access to your Personal Data, please contact support@ghc-srv.online immediately.
XIV. Data Transfers
Due to the international nature of our business, your Personal Data may be transferred outside the European Union. If you are an EU resident, your Personal Data may be transferred to the US or any country which is not considered to have the same level of data protection as in the EU. While in those jurisdictions, your Personal Data may be accessible to regulatory authorities in accordance with the laws of those jurisdictions. However, we ensure all data transfers from the EU comply with applicable legal requirements by executing standard contractual clauses. Should you wish to know more about how your Personal Data is protected or wish to request a copy please contact support@ghc-srv.online
- Use of cookies, other tracking technology, social media and social media plug-ins
Cookies are small pieces of text or code sent to your device when you visit the Website. Cookies are used to optimize the viewing experience, count visitors to a webpage, troubleshoot any problems, keep websites secure, and better serve content. The following cookies are used on the Website: Strictly Necessary cookies are required to provide the basic functions of the website and cannot be turned off. They are essential for accessing certain features of the website and could include signing in, adding items to a cart, or e-billing. Performance cookies are used to identify the pages used and to measure and track the performance of our website. This helps us to analyze web page traffic data and improve our website to fit your needs. We only use the information for statistical analysis purposes. Functional cookies are used to provide services you request. These cookies can remember your preferences to boost the user experience on a website. Targeting cookies may be set by us or by our advertising partners. They may be used to build a profile of your interests and show you relevant advertisements on this website or others. They do not store personal information but are based on uniquely identifying your browser. If you do not allow these cookies, you will experience less relevant advertising. Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the Website. Currently GHC-SRVdoes not have a fan page or a company page. We collect Personal Data about you to understand our followers better and understand their public response to our products and services. We may use this information to contact you. Any information you provide to us when you engage with our content (such as through our brand page or via DM, SM and email is treated in accordance with this Privacy Notice. Also, if you publicly reference us or our website on social media (such as by using a hashtag associated with us in a tweet or post), we may use your reference without approval from you.
You can read more regarding our joint controllership with the platforms at the following links:
YouTube: https://business.safety.google/controllerterms/
LinkedIn: https://legal.linkedin.com/pages-joint-controller-addendum
Facebook: https://www.facebook.com/legal/controller_addendum
Twitter: https://gdpr.twitter.com/en/controller-to-controller-transfers.html
Instagram: https://www.facebook.com/legal/controller_addendum
We provide social media plug-ins on the Website to allow you to easily share content from our website through social media, and in doing so, we may receive your Personal Data from the social media platform that you have authorized to share with us. When you share content using these buttons, a new page will pop up from the relevant social media platform. If you’re already logged into your account on that social media platform, then you will probably be automatically logged into this pop-up page, so that you don’t have to log in again. If, however, you are not logged in (or if you are not registered with the social media platform), the page will ask you for your information. Performics is joint data controllers with the social media platforms for the collection of your personal data that is collected by the platforms when you visit our website.
We have no control over how social media platforms use your Personal Data and they may independently collect information about you when you leave our website. The information collected and stored by those parties remains subject to their own policies and practices, including what information they share with us, your rights and choices on their services and devices, and whether they store information in the U.S. or elsewhere. We encourage you to read the privacy notices on the various social media platforms you use.
Find out more about how these social media platforms use your Personal Data:
- YouTube (Google’s general privacy policy)
XVI. Financial Incentive
We do not offer any financial incentives related to our collection of your Personal Data
XVII. Notification of changes
Any changes to this Privacy Notice will be promptly communicated on this page and you should check back to see whether there are any changes.
XVIII. Further Information
This Privacy Notice has been designed to be accessible to people with disabilities.
If you experience any difficulties accessing the information here, please contact us at Support@ghc-srv.online