Privacy Policy

Introduction

Any data collected through this Website, including personal data (as defined under applicable data protection laws, referred to 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, we are 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 this Website. 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.

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 Information we collect. 

Categories of the sources of Personal Data we may collect:

We may collect the Personal Data outlined above from the following categories of sources:

• Directly from you, for example, when you make usage of your privacy rights.

• 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 this Privacy Notice.

Purpose of data collection and legal basis

The following table provides information about our purposes and legal basis for collecting your Personal Data:

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 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.

With whom do we disclose Personal Data or Sensitive Personal Data for a Business Purpose?

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). 

Automated Decision Making and Profiling

When processing your Personal Data, we do not use processes that involve automated decision making or profiling.

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 use this link if you want to make use of any of your below-mentioned legal rights.

1. Where you are a resident of the EU

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:

1.1 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;

1.2 The right to rectification:

In order to avoid inaccurate or incomplete Personal Data relating to you is processed or shared, you can ask us to rectify them;

1.3 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:

a) if you have withdrawn your consent to the processing (see below);

b) if you legitimately objected to the processing of your data (see below);

c) when data is not or is no longer necessary for the purposes for which it was initially collected or processed;

d) the data is processed unlawfully (e.g., publishing hacked data);

1.4 The right to object to the processing of your Personal Data:

We process your Personal Data based on our legitimate interest (to determine to which processing this applies, please refer to 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.

1.5 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.:

a) if you challenge the exactness of your Personal Data. The processing is then limited for a period of time so that the agency may verify the exactness of the Personal Data;

b) if the processing is unlawful and you object to the erasure of your Personal Data and request instead that its use be limited;

c) if we do not need the Personal Data for the purposes mentioned above anymore, but you still need it to establish, exercise or defend rights before a Court; and

d) 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).

1.6 Right to object to data processing for direct marketing purposes

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.

1.7 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 this Privacy Notice) to know whether our processing is based on the performance of a contract or on consent.

1.8 The right to withdraw your consent to the processing of your Personal Data at any time:

(a) You may read Privacy Notice in order to identify the purposes for which the processing of your Personal Data is based on your consent.

(b) 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.

(c) 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.

(d) 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.

2. Where you are a US resident

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

You may request access to your Personal Data that we collect, use, disclose, or sell. In particular, you may request:

• the specific pieces of Personal Data that we process 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 or shared;

• the categories of third parties to whom the Personal Data was disclosed for a business purpose or sold or shared; and 

• the business or commercial purpose for processing 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 in order 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 taking into account 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 the use of Sensitive Personal Data

We do not collect Sensitive Personal Data as that term is defined in US state privacy laws like the California Consumer Privacy Act and the Virginia Consumer Privacy Act.

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.

We do not sell any Personal Data as the term ‘sell’ is used in US state privacy laws like the California Consumer Privacy Act and the Virginia Consumer Data Protection Act.

2.7 Right to Opt-Out of Share/Cross-Contextual Behavioral Advertising and Targeted Advertising

We do not share your Personal Data for cross-contextual behavioral advertising or otherwise engage in targeted advertising.

2.8 Right to opt-out of Automated Decision-Making and Profiling

When processing your Personal Data, we do not use processes that involve automated decision-making or profiling.

2.9 Universal Opt-Out Mechanisms

Our Website recognizes certain global opt-out of sale and share preference signals like the Global Privacy Control and the IAB CCPA privacy string/MSPA privacy string. This means that if you enact your choice to opt-out or opt-in through these signals, we will honor your choice upon receiving the signal related to your visit on our Website. We will apply your preference to the Personal Data we collected from our Website. If you have previously provided affirmative consent for the sale or share of your Personal Data, and your opt-out choice via the signal conflicts with such consent, we will ignore the opt-out choice via the signal.

2.10 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.”

2.11 How to exercise your US state privacy rights

US residents may exercise their applicable privacy rights by sending an email to privacyofficer@publicisgroupe.com, submitting your request here, or by contacting us at 1-833-983-0087. 

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.

2.12 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 privacyofficer@publicisgroupe.com or visit our portal. 

2.13 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 at privacyofficer@publicisgroupe.com.

3. Where you are a resident of Canada

3.1 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 as a result 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.

3.2 Right to request a 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. 

3.3 Right to withdraw your consent

At any time, you may withdraw your consent for us to process your Personal Data for the purposes described in 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.  

4 Your general rights regarding data collection

4.1 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. For more information on “Do Not Track,” visit https://www.allaboutdnt.com.

4.2 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.

For example, we use Google Analytics (“Google Analytics”), a web analytics service provided by Google, Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. You can learn about Google’s privacy practices by going to www.google.com/policies/privacy/‌partners/.

Google Analytics uses cookies to help us analyze how our websites are used, including the number of visitors, the websites from which visitors have navigated to our websites, and the pages on our websites to which visitors navigate. This information is used by us to improve our websites. We use Google Analytics with restrictions on how Google can process our data enabled. For information on Google’s Restricted Data Processing go to https://privacy.google.com/businesses/rdp/.

4.3 E-mails: 

You can opt-out of receiving promotional emails from us at any time by clicking on the unsubscribe link in the footer of the email or by 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.

Children

The Website is intended for general audiences and is not directed at children. 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 privacyofficer@publicisgroupe.com. 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. 

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 the Website or any Personal Data is not secure or that there has been unauthorized access to the Website or your Personal Data, please contact privacyofficer@publicisgroupe.com immediately. 

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 of the contractual protections please contact privacyofficer@publicisgroupe.com.  

Use of cookies and other tracking technology

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.

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 all cookies except for those that are strictly necessary for Website functionality. 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.

For more information about the cookies dropped on your device, please review the Cookie Notice.

Use of social media and social media plug-ins

We have a fan page or a company page on Twitter, Facebook, Instagram, YouTube, and LinkedIn that you can use or visit. We act as a joint data controller with the social media platform for the collection of your personal data when you visit our company page on the social media platform. We will collect Personal Data about you in order to understand our followers better and understand the public response to our products and services. We may use this information to respond to your messages when you contact us and engage in social listening to identify and assess what is being said about us publicly to understand industry trends and market sentiment. Any information you provide to us when you engage with our content (such as through our brand page or via Facebook Messenger or Twitter) 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 on or in connection with our Website.

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 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:

• Facebook
• Twitter
• YouTube (Google’s general privacy policy)
• Instagram
• LinkedIn

Financial Incentive

We do not offer any financial incentives related to our collection of your Personal Data.

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. Continued use of the Website after a change in the Privacy Notice indicates your acknowledgment and acceptance of the use of Personal Data in accordance with the amended Privacy Notice.

If you wish to save this text please click here to download a PDF. 

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 privacyofficer@publicisgroupe.com.  

If you consider that we are not complying with this Privacy Notice, if you have any questions in relation to this Privacy Notice, or have questions about your rights and choices, please contact privacyofficer@publicisgroupe.com. Data subjects in Europe may also lodge a formal complaint with their competent data protection authority. 

If you have any questions about our data practices or you wish to exercise your rights or know about the contractual protections in place, please contact the Publicis Chief Data Privacy Officer at privacyofficer@publicisgroupe.com.