Mediabrands Worldwide, Inc.

EU/Swiss-U.S. Privacy Shield Privacy Policy

Last Updated: July 9, 2018

Mediabrands Worldwide, Inc. (“Mediabrands”) respects your concerns about privacy. Mediabrands participates in the EU-U.S. and Swiss-U.S. Privacy Shield frameworks (collectively, the “Privacy Shield”) issued by the U.S. Department of Commerce. Mediabrands commits to comply with the Privacy Shield Principles with respect to Consumer Personal Data the company receives from the EU and Switzerland in reliance on the Privacy Shield in connection with (1) the Mediabrands website (www.ipgmediabrands.com), (2) Personal Data Mediabrands’ business unit known as Mediabrands Data & Technology (“MBD&T”) receives in connection with its relationships with its Clients, vendors and service providers, and (3) the services offered by MBD&T. This Policy describes how Mediabrands implements the Privacy Shield Principles for this Consumer Personal Data.

For purpose of this policy:

“Client” means any entity for which Mediabrands provides its affiliated agencies with technologies that help make online advertising more relevant and for ad delivery and reporting services, such as audience discovery, measurement and activation abilities, campaign performance analytics and the creation and review of digital audience data, social media insights and audience insights.

“Consumer” means any natural person who is located in the EU or Switzerland, but excludes any individual acting in his or her capacity as an Employee.

“Controller” means a person or organization which, alone or jointly with others, determines the purposes and means of the processing of Personal Data.

“Employee” means any current, former or prospective employee, contractor, intern or temporary worker of Mediabrands or any of its EU or Swiss affiliates, or any related individual whose Personal Data Mediabrands processes in connection with an employment relationship, who is located in the EU or Switzerland.

“EU” means the European Union and Iceland, Liechtenstein and Norway.

“Personal Data” means any information, including Sensitive Data, that is (i) about an identified or identifiable individual, (ii) received by Mediabrands in the U.S. from the EU or Switzerland in connection with (a) the Mediabrands website (www.ipgmediabrands.com), (b) MBD&T’s relationships with its Clients, vendors and service providers, and (c) the services offered by MBD&T, and (iii) recorded in any form.

“Privacy Shield Principles” means the Principles and Supplemental Principles of the Privacy Shield.

“Processor” means any natural or legal person, public authority, agency or other body that processes Personal Data on behalf of a Controller.

“Sensitive Data” means Personal Data specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership (including trade union-related views or activities), sex life (including personal sexuality), information on social security measures, the commission or alleged commission of any offense, any proceedings for any offense committed or alleged to have been committed by the individual or the disposition of such proceedings, or the sentence of any court in such proceedings (including administrative proceedings and criminal sanctions).

Mediabrands’ Privacy Shield certification, along with additional information about the Privacy Shield, can be found at https://www.privacyshield.gov/. For more information about Mediabrands’ processing of Consumer Personal Data, please visit Mediabrands’ Privacy Notice.

Types of Personal Data Mediabrands Collects

Mediabrands obtains Personal Data about Consumers in various ways that are relevant to the company’s Privacy Shield certification, as described below.

Through its website

As a Controller, Mediabrands collects Personal Data from Consumers when they visit Mediabrands’ website. The company may use this information for the purposes indicated in Mediabrands’ Privacy Notice. The types of Personal Data Mediabrands collects in this manner include:

• Personal Data in content Consumers submit, such as when Consumers email Mediabrands by clicking on Mediabrands email address hyperlinks on the website; and
• other data collected automatically through the website (such as IP addresses, device ID, browser characteristics, device characteristics, operating system, language preferences, referring URLs, information on actions taken on our website, and dates and times of website visits).

Through MBD&T’s relationships with its Clients, vendors and service providers

With respect to MBD&T, Mediabrands serves as both a Controller and a Processor for the Consumer Personal Data it obtains and maintains.

As a Controller, MBD&T obtains from Client representatives Personal Data such as contact information. This information is used to manage the relationships with its Clients and carry out MBD&T’s obligations under contracts with Clients. MBD&T also obtains as a Controller Personal Data of its vendors’ and service providers’ representatives. The information obtained may include contact information and payment data. MBD&T uses this information to manage its relationships its vendors and service providers, process payments, and carry out MBD&T’s obligations under contracts with these parties.

Through the services offered by MBD&T

MBD&T provides specialized analytics services and tools that help make online advertising more relevant and for ad delivery and reporting services, such as audience discovery, measurement and activation abilities, campaign performance analytics and the creation and review of digital audience data, social media insights and audience insights.

The types of Personal Data MBD&T may collect include:

• age;
• gender;
• marital status;
• employment information (such as job title and location);
• educational history;
• religion and philosophical beliefs;
• social media preferences;
• behavioral data (such as purchasing habits); and
• geolocation information.

In providing its services, MBD&T receives pseudonymized Personal Data of Consumers. Pseudonymized data is information from which identifying characteristics have been replaced with a pseudonym (i.e., a value that does not identify the individual directly).
As a Controller, MBD&T obtains Personal Data about Consumers in various ways. For example, MBD&T licenses pseudonymized demographic and behavioral data relating to Consumers from third parties to assist its Clients in serving online advertisements to Consumers who are existing customers of Clients or who have particular demographic or behavioral characteristics similar to existing customers (“lookalikes”). This demographic and behavioral data is sent directly to MBD&T or to a third party service provider who hosts the data on MBD&T’s behalf. Clients send Personal Data about their Consumers to the third party host who matches the data with the demographic and behavioral data stored with such third party host (“Matched Data’). The third party host sends randomly generated unique identifiers corresponding to matched Consumers to MBD&T (“MBD&T IDs”) together with some contextual information. For example, grouping the MBD&T IDs into existing owners of a Client product and those who are not.
MBD&T uses the MBD&T ID as a Controller to match against pseudonymized demographic and behavioral data to evaluate and build audience segments and create a refined set of MBD&T IDs. These audience segments will be used to deliver relevant advertising tailored to Consumers’ interests, making recommendations and analyzing users. MBD&T then sends the refined MBD&T IDs to the third party host who converts the refined MBD&Ts to identifiers that it sends to technology partners (such as advertisement distributors, media companies, advertising agencies and advertising sponsors) to serve online advertisements.
As a Processor, MBD&T receives pseudonymized Consumer Personal Data relating to Consumers from business partners (e.g., ad servers and demand side platforms) to enable MBD&T to understand Consumers’ engagement with an online advertisement (if they viewed it or clicked on it) or other relevant interactions (e.g., products purchased), to help measure and report on the digital campaigns run by clients.

MBD&T also receives pseudonymized Consumer Personal Data as a Processor from its ad tech partners to facilitate the creation and review of digital audience data, tracking and conversion data for audience campaigns.

Mediabrands’ privacy practices regarding the processing of Consumer Personal Data comply with the Privacy Shield Principles of Notice; Choice; Accountability for Onward Transfer; Security; Data Integrity and Purpose Limitation; Access; and Recourse, Enforcement and Liability.

Notice

Mediabrands provides information in this Policy and Mediabrands’ Privacy Notice. about its Consumer Personal Data practices, including the types of Personal Data Mediabrands collects, the types of third parties to which Mediabrands discloses the Personal Data and the purposes for doing so, the rights and choices Consumers have for limiting the use and disclosure of their Personal Data, and how to contact Mediabrands about its practices concerning Personal Data.

When Mediabrands acts as a Processor and Consumer Personal Data is transferred to Mediabrands in the U.S. on behalf of a Client, the Client is responsible for providing appropriate notice to its Consumers and obtaining the requisite consent.

Relevant information also may be found in notices pertaining to specific data processing activities.

Choice

When Mediabrands collects Consumer Personal Data in its role as a Controller, the company generally offers the relevant Consumers the opportunity to choose whether their Personal Data may be (i) disclosed to third-party Controllers or (ii) used for a purpose that is materially different from the purposes for which the information was originally collected or subsequently authorized by the relevant Consumer. These Consumers may contact Mediabrands as indicated below regarding the company’s use or disclosure of their Personal Data. Unless Mediabrands offers these Consumers an appropriate choice, the company uses Personal Data only for purposes that are materially the same as those indicated in this Policy.

When Mediabrands obtains Consumer Personal Data in its role as a Processor for its Clients, its Clients are responsible for providing the relevant Consumers with certain choices with respect to the Clients’ use or disclosure of the Consumers’ Personal Data.

Mediabrands shares certain Consumer Personal Data with its affiliates and subsidiaries. Mediabrands may disclose Consumer Personal Data without offering an opportunity to opt out, and may be required to disclose the Personal Data, (i) to third-party Processors the company has retained to perform services on its behalf and pursuant to its instructions, (ii) if it is required to do so by law or legal process, or (iii) in response to lawful requests from public authorities, including to meet national security, public interest or law enforcement requirements. Mediabrands also reserves the right to transfer Consumer Personal Data in the event of an audit or if the company sells or transfers all or a portion of its business or assets (including in the event of a merger, acquisition, joint venture, reorganization, dissolution or liquidation).

Accountability for Onward Transfer of Personal Data

This Policy and Mediabrands’ Privacy Notice. describe Mediabrands’ sharing of Consumer Personal Data.

To the extent Mediabrands acts as a Controller, except as permitted or required by applicable law, Mediabrands provides Consumers with an opportunity to opt out of sharing their Personal Data with third-party Controllers. Mediabrands requires third-party Controllers to whom it discloses such Consumer Personal Data to contractually agree to (i) only process the Personal Data for limited and specified purposes consistent with the consent provided by the relevant Consumer, (ii) provide the same level of protection for Personal Data as is required by the Privacy Shield Principles, and (iii) notify Mediabrands and cease processing Personal Data (or take other reasonable and appropriate remedial steps) if the third-party Controller determines that it cannot meet its obligation to provide the same level of protection for Personal Data as is required by the Privacy Shield Principles.

With respect to transfers of Consumer Personal Data to third-party Processors, Mediabrands (i) enters into a contract with each relevant Processor, (ii) transfers Personal Data to each such Processor only for limited and specified purposes, (iii) ascertains that the Processor is obligated to provide the Personal Data with at least the same level of privacy protection as is required by the Privacy Shield Principles, (iv) takes reasonable and appropriate steps to ensure that the Processor effectively processes the Personal Data in a manner consistent with Mediabrands’ obligations under the Privacy Shield Principles, (v) requires the Processor to notify Mediabrands if the Processor determines that it can no longer meet its obligation to provide the same level of protection as is required by the Privacy Shield Principles, (vi) upon notice, including under (v) above, takes reasonable and appropriate steps to stop and remediate unauthorized processing of the Personal Data by the Processor, and (vii) provides a summary or representative copy of the relevant privacy provisions of the Processor contract to the Department of Commerce, upon request. Mediabrands remains liable under the Privacy Shield Principles if the company’s third-party Processor onward transfer recipients process relevant Personal Data in a manner inconsistent with the Privacy Shield Principles, unless Mediabrands proves that it is not responsible for the event giving rise to the damage.

Security

Mediabrands takes reasonable and appropriate measures to protect Consumer Personal Data from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the Personal Data.

Data Integrity and Purpose Limitation

Mediabrands limits the Consumer Personal Data it processes to that which is relevant for the purposes of the particular processing. Mediabrands does not process Consumer Personal Data in ways that are incompatible with the purposes for which the information was collected or subsequently authorized by the relevant Consumer. In addition, to the extent necessary for these purposes and consistent with its role as a Controller or Processor, Mediabrands takes reasonable steps to ensure that the Personal Data the company processes is (i) reliable for its intended use, and (ii) accurate, complete and current. In this regard, Mediabrands relies on its Consumers and Clients (with respect to Personal Data of Consumers with whom Mediabrands does not have a direct relationship) to update and correct the relevant Personal Data to the extent necessary for the purposes for which the information was collected or subsequently authorized. Consumers (and Clients, as appropriate) may contact Mediabrands as indicated below to request that Mediabrands update or correct relevant Personal Data.

Subject to applicable law, Mediabrands retains Consumer Personal Data in a form that identifies or renders identifiable the relevant Consumer only for as long as it serves a purpose that is compatible with the purposes for which the Personal Data was collected or subsequently authorized by the Consumer.

Access

Consumers generally have the right to access their Personal Data. Accordingly, to the extent
Mediabrands acts as a Controller, where appropriate, Mediabrands provides Consumers with reasonable access to the Personal Data Mediabrands maintains about them. Mediabrands also provides a reasonable opportunity for those Consumers to correct, amend or delete the information where it is inaccurate or has been processed in violation of the Privacy Shield Principles, as appropriate. Mediabrands may limit or deny access to Personal Data where the burden or expense of providing access would be disproportionate to the risks to the Consumer’s privacy in the case in question, or where the rights of persons other than the Consumer would be violated. Consumers may request access to their Personal Data by contacting Mediabrands as indicated below.

When Mediabrands obtains Consumer Personal Data in its role as a Processor for its affiliates’ Clients, the Clients are responsible for providing Consumers with access to the Personal Data and the right to correct, amend or delete the information where it is inaccurate or has been processed in violation of the Privacy Shield Principles, as appropriate. In such circumstances, Consumers should direct their questions to the appropriate Client. When a Consumer is unable to contact the appropriate Client, or does not obtain a response from the Client, Mediabrands will provide reasonable assistance in forwarding the Consumer’s request to the Client.

Recourse, Enforcement and Liability

Mediabrands has mechanisms in place designed to help assure compliance with the Privacy Shield Principles. Mediabrands conducts an annual self-assessment of its Consumer Personal Data practices to verify that the attestations and assertions Mediabrands makes about its Privacy Shield privacy practices are true and that Mediabrands’ privacy practices have been implemented as represented and in accordance with the Privacy Shield Principles.

Consumers may file a complaint concerning Mediabrands’ processing of their Personal Data. Mediabrands will take steps to remedy issues arising out of its alleged failure to comply with the Privacy Shield Principles. Consumers may contact Mediabrands as specified below about complaints regarding Mediabrands’ Consumer Personal Data practices.

If a Consumer’s complaint cannot be resolved through Mediabrands’ internal processes, Mediabrands will cooperate with JAMS pursuant to the JAMS Privacy Shield Program, which is described on the JAMS website at https://www.jamsadr.com/eu-us-privacy-shield. JAMS mediation may be commenced as provided for in the JAMS rules. Following the dispute resolution process, the mediator or the Consumer may refer the matter to the U.S. Federal Trade Commission, which has Privacy Shield investigatory and enforcement powers over Mediabrands. Under certain circumstances, Consumers also may be able to invoke binding arbitration to address complaints about Mediabrands’ compliance with the Privacy Shield Principles.

When Mediabrands obtains Consumer Personal Data in its role as a Processor for its Clients, Consumers may submit complaints concerning the processing of their Personal Data to the relevant Client, in accordance with the Client’s dispute resolution process. Mediabrands will participate in this process at the request of the Client or the Consumer.

How to Contact Mediabrands

To contact Mediabrands with questions or concerns about this Policy or Mediabrands’ Consumer Personal Data practices:

Write to:

IPG Mediabrands
100 W. 33rd Street, 9th Floor
New York, NY 10001
Attn: Chief Data Strategist

or

Mediabrands UK
42 St. John’s Square
London, EC1M 4EA
Attn: Head of Ad Operations

E-mail: [email protected]