Last update: June 11, 2024 

This policy is made in both English and Bahasa Indonesia. Click here for the Bahasa Indonesia version


Dentsu is a global media, creative and customer experience management group made up of several brands. We help our clients to improve how they advertise and market, whether by print, post, email or in the digital world. We believe that the responsible use of data supports business growth and builds strong relationships between brand and consumer. As a business, we are committed to respecting and protecting the privacy of all individuals we interact with. We are committed to being always transparent in our handling and processing of Personal Data in accordance with applicable privacy and data protection laws.   


Who is responsible for processing your Personal Data? 

Dentsu does business through its subsidiaries and affiliates worldwide. The privacy laws in some countries require a Controller (the legal entity who defines the purposes for which the processing of personal information takes place and how that information is processed) to be selected.  

Where this is relevant for the privacy laws in your country, the Dentsu group company who acts as the Controller of your Personal Data, and who is responsible for processing your Personal Data will be the Dentsu group company operating in your country or region unless Dentsu International or another Dentsu company identifies itself as the Controller for a specific interaction with you. The relevant Dentsu group company is referred to as “our”, “us” and “we” in this notice.    

If you have any questions or are unsure about who your Controller is, please contact us DPO@dentsu.com and we will ensure your details reach the correct entity.  


What this privacy notice covers  

This privacy notice explains in detail the types of Personal Data we may collect about you when you interact with us through our websites, digital experiences, business relationship management, events, B2B marketing activities or where you visit our offices. By using our website or services and providing your Personal Data to us, you are allowing our collection, use and disclosure of your Personal Data for the purposes set forth in this privacy notice based on the lawful basis set out in this privacy notice. 

  • If you are a Dentsu employee or job applicant, please find our Employee Privacy Notice here; 
  • If you are using one of our products, please consult our product specific privacy notices. These are likely to be different market to market. 
  • If you are looking for information on cookies, please consult our Cookie Notice here. 

"Personal Data" means any information about the personal or material circumstances of an identified or identifiable individual. Your Personal Data therefore includes all data related to you that enables identification, such as your name, your address, your telephone number or your e-mail address.  


What's not included 

This Privacy Notice does not cover:   

  • the advertising activities we carry out for our clients;  
  • information about our employees, contractors or potential employees; 
  • Information about the cookies we use and the data they capture;  
  • Information collected through products we provide as part of our marketing, advertising or media activities (i.e. information we process as a data processor when undertaking any of our marketing, advertising or media activities on behalf of our clients).  

These are all covered in separate privacy notices, or cookie notices which can be found through the relevant site of the market they operate in.    

1. Personal Data we may collect 

We may process Personal Data you provide directly to us, Personal Data we collect through automated means, or Personal Data we obtain through other sources. You are not required to provide any Personal Data, however, if you choose not to do so, we may not be able to provide you with our products or services or respond to your requests. Generally speaking, we will collect Personal Data relating to you and/or your use of our services in the following ways: 

(A)  Personal Data you provide to us: 

  • Contact data 

We collect contact details when you sign-up to receive email alerts, attend one of our events, visit our offices, work with us, download our content, subscribe to our newsletters or where you ask us to respond to a query you have. The Personal Data we collect may include your name, email address, phone number, job title, and workplace location.    

  • Marketing and communications data   

We collect Personal Data relating to your preferences regarding receiving marketing information from us and your communication preferences (where permitted under applicable privacy laws).   

  • Location Data 

We may ask you where you are located as part of our marketing activities, or when you sign up to events or ask to attend meetings. This will not be tracked through your device at all and will only ever include what you have shared with us. 


(B)  Personal Data we collect through automated means: 

  • Personal Data relating to your use of our website(s) 

We collect Personal Data about how you use our website(s). This includes Personal Data relating to the pages you visit on our website(s), the services or information you search for and the links and content you choose to access.    

  • Profiling data 

We may use the Personal Data you provide through your use of our website(s) to provide you with relevant content and to inform our marketing strategy. This type of activity is sometimes known as “profiling” – using automated means to process your Personal Data to analyse or predict your personal preferences, interests or behaviours. You can object to profiling (where entitled under applicable privacy laws). 

  • Technical Personal Data  

We collect Personal Data about the device(s) you use to access our website(s) as well as other related information. You may find more information on the cookies we use and the purposes for which we use them on our separate Cookie Notice.  


(C)  Data we collect from other sources: 

  • Data we collect from third parties 

We may collect Personal Data about you from third parties. Such third parties may include analytics providers, affiliate partners and third-party platforms such as LinkedIn. We may also collect Personal Data where you register and/or attend an event which we host or are a named affiliate partner of. We do not buy Personal Data lists. 

Note that we do not actively seek to collect information about children or minors, or anyone’s sensitive Personal Data. Please see more details below. 

  • Children 

We do not actively seek to collect the Personal Data of children or minors (as defined under the applicable law in your jurisdiction). However, if required, we will collect the Personal Data of children or minors based on consent from their parents and/or guardians.  

If you have any concerns about your child’s privacy in relation to our services, or if you believe that your child may have entered Personal Data onto our website(s), please contact us at dpo@dentsu.com. We will delete such Personal Data from our records within a reasonable time. 

  • Sensitive Personal Data  

We do not intentionally collect sensitive Personal Data as part of the processing activities carried out under this privacy notice. 

2. How we use this Personal Data 

Except where required by law, we use and process the Personal Data we collect about you for the following purposes:   

  • to generate leads; 
  • to send you newsletters and information relating to our brands and services; 
  • to manage our relationship with you; 
  • to arrange and manage visits to our offices;  
  • to ensure our website(s) is kept relevant and useful; 
  • to ensure our website(s) remain secure; 
  • to respond to your enquiries and feedback;  
  • to respond to, and manage, data subject rights requests;  
  • to analyse and/or improve our services; 
  • to verify your identity and Personal Data; 
  • to maintain and update our records; 
  • to protect and defend our legal rights / respond to complaints; and 
  • to facilitate acquisitions and potential acquisitions of or by our business, including any related transitional and business integration activities.   

Under various data protection laws we are required to advise you on the legal basis for processing your Personal Data. In the table below we set out further information about the purposes for which we use your personal data and the legal basis we rely on for its use (where required under applicable privacy laws). Note that we may process your Personal Data for more than one lawful basis depending on the specific purpose for which we are using your data. 

In APAC we usually rely on Consent as our lawful basis in accordance with local laws. Where this is the case, we will have explicitly asked you to consent, and you will have the ability to withdraw your consent at any time. Where we rely on a lawful basis other than consent, it will be as listed below.  


Processing Activity Types of data used Lawful basis (where applicable) 

To arrange and run events:

The process by which invitations are sent to, acceptances are received from and attendance at Dentsu events, are managed. 

Contact data, data we collect from other parties, location data. Legitimate Interests  

To generate leads:

We may use Personal Data collected from visitors to and users of our website(s), attendees of events, or client contacts to locate potential leads.  

Contact data, data we collect from other parties, Personal Data relating to your use of our website(s). Legitimate interests or consent (where you have expressly provided it) 

To send you our newsletters and information relating to our brands and services:

The distribution of Dentsu's own commercial content to potential customers, leads and prospects, and anyone else who has subscribed to receiving such collateral. 

Contact data, data we collect from third parties, location data, marketing and communications data. Consent 

To manage our relationship with you:

The processing of basic contact details of clients and suppliers for the purpose of relationship, account and/or project management. 

Contact data, location data, marketing and communications data, technical Personal Data Contractual Necessity 

To arrange and manage visits to our offices:

The process of ensuring we keep an appropriate record of all visitors to the office, as well as possible accidents or incidents that may have occurred. 

Contact data, location data. Legitimate Interests 

To ensure our website(s) are kept relevant and useful:

We conduct statistical analysis on your usage of our website(s) e.g. to enable us to improve our website(s), offer new features and material. 

Personal Data relating to your use of our website(s), Personal Data processed through automated means, technical Personal Data. Legitimate interests (to study how clients use our service and engage with our content. To develop our service, to grow our business and to inform our marketing strategy) where permitted under applicable privacy laws. 

To ensure our website(s) remain secure:

This process protects against malicious web activity and blocks access to our website(s) that violate enterprise policy. Cloud and endpoint web filtering service. 


Personal Data relating to your use of our website(s), technical Personal Data. Legitimate interests  

To respond to any enquiries or feedback that you send us:

To update you with any changes to our terms and conditions/other policies 


All Personal Data we collect may be relevant. Legitimate Interests or Contractual Necessity  

To respond to, and manage, data subject rights requests:

The process of responding to data subject rights requests such as data subject access requests, data erasure requests, requests to opt out from specific type of processing and other, as legally required under relevant data protection laws.  

All Personal Data we collect may be relevant. Legal Obligation  

To analyse and improve our services:

This processing enables us to utilise our interactions with you to ensure we continue to provide the best service possible. 


Personal Data relating to your use of our website(s), email, name, phone, company name, job title. Legitimate Interests or consent where cookies are used 

To maintain and update our records:

We are required to keep up to date records to ensure we can operate efficiently and effectively as a business. 


Contact data, location data, marketing and communications data. Legitimate Interests or Legal Obligation  

To protect and defend our legal rights / respond to complaints:

This process involves complaints submitted to Dentsu by regulators and/or individuals whistleblowing regarding Dentsu Personal Data protection and management practices.  


All Personal Data we collect may be relevant. Legal Obligation or Legitimate Interests 
To facilitate acquisitions and potential acquisitions of or by our business, including any related transitional and business integration activities.  All Personal Data we collect may be relevant. Legitimate Interests 


3. How long will we keep your Personal Data  

We will keep your Personal Data for as long as is necessary for the relevant service, in accordance with our legal obligations. After this time, your Personal Data will either be securely deleted or anonymised so that it can be used for analytical purposes. You may request further information about our retention periods via the contact details given in this privacy notice or request that we delete your data in accordance with your rights as set out below. 

4. How we secure your Personal Data  

We maintain appropriate organisational and technological safeguards to help protect against unauthorised use, access to or accidental loss, alteration or destruction of Personal Data whether in physical or electronic form. We also seek to ensure our service providers and/or any approved external Third-parties who store or process Personal Data on our behalf do the same. The safeguards we use, depending on the circumstances, may include firewalls, penetration testing, vulnerability scans, encryption and restricted access to our IT systems. 

5. Information Sharing and Disclosure 

Whenever we share Personal Data, access is controlled on a need-to-know basis, and is only provided where it is necessary to provide you with requested services or to allow us to perform any necessary or legitimate functions.  

We will only transfer your Personal Data outside the market in which you are located where we are satisfied that adequate levels of protection are in place to protect the integrity and security of any Personal Data being processed and in compliance with applicable privacy and data protection laws. This may be through a contract we have in place with the importing company, or because we know that where the importing company is based has even stricter data protection laws than the one you are based in/ it was received in. 

We take internal data protection very seriously. Our employees and the service companies commissioned by us have been contractually bound to treat Personal Data with appropriate confidentiality and to act in compliance with data protection regulations.  

Information shared with our third-party service providers 

We use a number of third parties to perform business functions on our behalf, such as sending our newsletters and hosting our online services and customer relationship management. We will only disclose the information necessary to enable these third parties to perform their services. Our service providers are contracted to comply with our instructions.  

We might share information with third parties who help us with our marketing efforts, including social media platforms, advertising networks, and ad tech companies. For example, we may share email addresses or other contact information with social media platforms so they can serve our advertising to you on their platform. Personal data received by our partners may also be subject to their privacy policies and the tools they provide for you to manage how your Personal Data is used for advertising purposes. 

Group company transfers  

Dentsu International is a globally operating media group consisting of multiple companies. Therefore, we may from time to time disclose your Personal Data within our group of companies.  

Where we transfer Personal Data between our group companies, we have covered these transfers by entering into an Intra-Group Data Transfer Agreement. This provides us with a mechanism to transfer Personal Data around the globe where necessary. 

We may also disclose personal information with any successor to all or part of our business. For example, if part of our business is sold, we may give our customer list as part of that transaction.   

Information shared with other parties  

Where required or permitted by law, Personal Data may be provided to others, such as regulators and law enforcement agencies, for example in response to a court order or a subpoena, or in response to a law enforcement agency request, or where we believe it is necessary to investigate, prevent or act regarding illegal activities, and as otherwise required by law.  

We may also collect Personal Data from the parties described in this section. 

You may request further information on the measures used for such transfers via the contact details given in this Privacy Notice. 

6. Your Rights 

Depending on the applicable privacy law of the market you are in, you may have several rights in relation to your Personal Data, including: 

  • Objecting to our processing of your Personal Data. Where we rely on legitimate interest (or those of a third-party) and if you feel it impacts on your fundamental rights and freedoms, you can object to our processing. You also have a right to object where your Personal Data is used for direct marketing, profiling, or automated decisions that result in legal consequences or have a significant impact on you. You can object at any time, and we shall stop processing the data you have objected to, unless we can show legitimate grounds to continue.  
  • Accessing your Personal Data. We may be required to provide you with information we hold about you upon your request, including a description and copy of the Personal Data and why we are processing it, unless a lawful exception applies. We will require you to prove your identity before providing your Personal Data.  
  • Requesting the provision of your Personal Data to a third party. You may ask us to provide you or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. This right only applies to Personal Data you have provided to us; and if you have consented to our use or where we used the Personal Data to perform a contract with you.  
  • Requesting erasure (deletion) of your Personal Data.  You may ask us to delete your data where you think we no longer require it. Note, we may be required to retain certain Personal Data by law and/or for our own legitimate business purpose. But when we do so, we will inform you. 
  • Requesting correction or updating of your Personal Data. This enables you to have any incomplete or inaccurate Personal Data we hold about you corrected.  
  • Requesting the restriction of our processing of your Personal Data. In some situations and only in some jurisdictions you can request a restriction to our processing. If you request this, we can continue to store your Personal Data but are restricted from processing it while the restriction is in place. 
  • Withdrawing your consent. Where you have consented to our processing of your Personal Data, you can withdraw your consent at any time. Withdrawal of consent will not affect the lawfulness of what we have done with your Personal Data before you withdrew consent or affect our right to continue with our collection, use or disclosure of your Personal Data where such collection, use or disclosure of Personal Data is permitted under applicable laws without consent. If you receive marketing communications from us, you can withdraw your consent to marketing by hitting the unsubscribe button contained within the email. 
  • Making a Complaint. We will do our best to resolve any complaint. However, if you feel we have not resolved your complaint, or if you wish to reach out to them directly, you can complain to your local data protection authority. For example, in the UK, the local data protection authority is the UK Information Commissioner's Office. If you have any questions about who your local authority is, please contact us and we can provide the relevant information. 
  • Opting out of marketing. You may choose not to receive marketing communications from us. You can ask us to stop such messages at any time by clicking on the “unsubscribe” link at the bottom of the message.  Please note that even if you choose not to receive marketing communications from us, you still may receive non-marketing communications, such as responses to your inquiries or notices regarding your account or our relationship with you. 

If you exercise the rights above, the request should include your contact information and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. In addition, you should provide adequate information that we can reasonably verify that you are the person about whom we collected the personal information (including information that enables us to verify the identifying information we possibly maintain about you).  

We will respond to requests within the required timeframes. If we need extra time to respond, we will let you know why, and how long we require, in writing. To protect your Personal Data, we will only honour requests if we have been able to verify your identity or authority to make the request and confirm the Personal Data relates to you. The method used to verify your identity will depend on the type, sensitivity and value of the information, including the risk of harm to you posed by any access or deletion. Verification will usually be performed by matching the identifying information provided by you to the personal information that we already have.  

Note that if you are in a market where these rights do not exist, we reserve the right to deny your request. 

7. Our responsibility for Personal Data collected through website links 

This privacy notice is limited to the Personal Data collected by us. We do provide links within our website(s) to other websites, including social media websites such as Facebook, Twitter and LinkedIn, or links to the sites of other Dentsu entities. If you follow these links, your use of these websites will be governed by their applicable user and privacy notices since their data practices fall outside the scope of this privacy notice. Further, we can have no responsibility for or control over the Personal Data collected by any third-party website and we cannot be responsible for the protection and privacy of any information which you may provide on such websites. 

8. Updates 

This privacy notice may be updated from time to time to reflect changes in law, best practice, changes in what we do, or changes in the way we treat Personal Data. The date of the most recent revision will appear at the top of this page. If you do not agree to the changes, please stop using our services and refrain from sharing your Personal Data with us. You should check this notice frequently for updates. 

9. Contact Us 

If you have any questions about this privacy notice, our approach to privacy or you would like to exercise any of the rights mentioned in this privacy notice you can contact our Data Protection Officer in any of the following ways: 

1.     Address: Data Protection Officer, Dentsu international, Regent’s Place, 10 Triton Street, Regent’s Place, London, NW1 3BF  

2.     Email: DPO@dentsu.com    

 

Additional note 

As a supplement to the policy above, the processing of your Personal Data will be in accordance with Law No. 27 of 2022 concerning Personal Data Protection as may be amended from time to time and other implementing regulations that may be issued by the relevant government authorities from time to time. 

Language 

This policy is made in the English and the Indonesian languages. In the event of any inconsistency between the English and the Indonesian language versions, then the English language version shall prevail and take precedence.