Dentsu International

Privacy Notice

Last updated: 24.09.20

Dentsu International (referred to as “our”, “us” and “we” in this notice) is a global media group. We help our clients to improve how they advertise and market, whether by print, post, email or on websites. 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 with whom we interact. We are committed to being transparent in our handling and processing of personal data at all times in accordance with applicable privacy and data protection laws. 

This Privacy Notice explains in detail the types of personal data we may collect about you when you interact with us. Dentsu International is the data controller of any personal data you provide to us, including in relation to this website. 

This Privacy Notice explains the following:

• Information we may collect
• How we use this information
• How we store your personal data
• How we secure your personal data
• Information sharing and disclosure
• International and group company transfers 
• Your rights
• Our responsibility for website links
• Updates
• How to contact us

In the Supplementary Information section of this Privacy Notice, we explain what is meant by “personal data” and other terms used in this notice. 

The California Consumer Privacy Act of 2018 (“CCPA”) provides California residents with rights with respect to their personal information. Those rights are explained below in the Supplemental Information section below (Your California Rights). 

1. Information we may collect 

The type of information we collect will depend on the circumstances and the service you are using. Generally speaking, we will collect information relating to you and/or your use of our services in the following ways: 

• Information relating to your use of the website

We collect information about how you use our website. This includes information relating to the pages you visit on our website, the services or information your search for and the links and content you choose to access. We may also use the personal information you provide through your use of our website to provide you with relevant content and to inform our marketing strategy. This type of activity is known as “profiling” – using automated means to process your personal data to analyse or predict your personal preferences, interest or behaviours. You can object to profiling (see below).

•  Technical data 

We collect information about the device(s) you use to access our site. This includes collecting unique mobile device ID or the internet protocol (IP) address online identifiers, which are numbers that can uniquely identify a specific computer or other network device on the internet. This information is linked to a cookie ID, which we receive and process. You may find more information on the cookies we use and the purposes for which we use them on our separate Cookie Notice (available here: https://www.dentsu.com/policies/cookies-notice).

• Contact data

We collect contact details when you sign-up to receive email alerts, attend one of our events, download our content, subscribe to our newsletters or where you ask us to respond to a query you have. The personal data we collect includes your name, email address, job title, and location. 

• Marketing and communications data 

We collect information about your preferences in receiving marketing information from us and your communication preferences. 

Children

We do not actively seek to collect information about children aged 16 or under. 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, please contact us at dpo@dentsu.com. We will delete such information from our records within a reasonable time. 

2. How we use this information

Except where required by law, we use the personal data you provide for the following purposes: 

• to deliver the specific information or services you have requested;
• to enable the download of our content;
• send you newsletters and information relating to our brands and services;
• respond to your requests and feedback; and 
• analyse and/or improve our services. 

Under data protection law we are required to advise you on the legal basis for processing your personal data. For the most part, the processing of your personal information is based either on a) our legitimate interests related to us providing you services you have requested or otherwise your customer relationship with us, or b) your consent, where requested. 

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. 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.

Purpose/Activity	Types of personal data that may be processed	Lawful basis for processing including basis of legitimate interest
To send you information about our services: To send you information which you have requested e.g. newsletters or publications in accordance with your specified preferences	- Name - Email address - Telephone number - Company - Location - Job title and role - Any interests that you express in our services - Your attendance at events (online or offline)	Where you have requested information from us, such as newsletters, publications or event invitations, we send such communications based on your consent. You can ask us to stop such communications at any time by clicking on the unsubscribe link at the bottom of the message.
To improve and develop our website: We conduct statistical analysis on your usage of the website e.g. to enable us to improve our website, offer new features and material	- Technical information - Usage	Necessary for our legitimate interest (to define types of clients for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).
To deliver relevant content to you and measure or understand the effectiveness of the content we serve to you.	- Name - Email address - Telephone number - Company - Location - Job title and role - Usage - Marketing and communications preferences - Technical information - Your attendance at events (online or offline)	Necessary for our 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).
To respond to any enquiries or feedback that you send us To update you with any changes to our terms and conditions/other policies	- Name - Email address - Telephone number - Company - Location - Job title and role - Your attendance at events (online or offline) - Marketing/communications preferences - Any other information you volunteer in your enquiry or feedback	It is in our legitimate interest to respond to communications that you send to us, inform you of relevant information in relation to the services that we provide and utilise your information to improve our business.
To reach out with information on our products and services relevant to your needs	- Name - Email address - Telephone number - Location - Usage - Job title and role	It is our legitimate interests to work out which of our products or services may interest you and tell you about them.
To share information with our service providers.	- Name - Email address - Telephone number - Usage - Marketing and communications - Technical information	It is our legitimate business interest to share your data with trusted third parties who provide us with services relevant to the provision of our website.
To share information within the dentsu international group.	- Name - Email address - Telephone number - Job title and role - Company - Location - Usage	As dentsu international Limited operates as a global operating media company, it is our legitimate business interest to share your data within the dentsu international group in order to manage our business effectively and provide our products and services.
To share information with other third parties, such as regulator and law enforcement agencies	- Name - Email address - Telephone number - Job title and role - Company - Location - Usage - Technical information	We share your data as necessary for compliance with any legal obligation to which we are subject or in order to satisfy our legitimate business interests.

The categories of personal data we collect under CCPA are: personal information; geolocation data, professional or employment related information; and internet or other similar network activity. For more information about the CCPA categories of personal information, see Your California Rights. 

3. How long we will keep your information 

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 via the contact details given in this Privacy Notice.

4. How we secure your information 

We maintain appropriate organisational and technological safeguards to help protect against unauthorised use, access to or accidental loss, alteration or destruction of personal data. We also seek to ensure our service providers do the same. 

5. Information Sharing and Disclosure

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 and we require that they do not use your personal data for their own business purpose. 

Information shared with other parties 

Where required or permitted by law, personal data may be provided to others, such as regulator and law enforcement agencies, for example in response to a court order or a subpoena, or in response to a law enforcement agency’s request, or where we believe it is necessary to investigate, prevent or take action regarding illegal activities, and as otherwise required by law. 

We do not sell or rent any personal data about you to any third party.

All of the categories of personal information under CCPA may be shared within our group of companies. We do not sell or rent any personal data about you to any third party, and have not done so within the past 12 months. 

6. International and 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. Access will always be controlled on a need-to-know basis, and only provided where it is necessary to provide you with requested services or to allow us to perform any necessary or legitimate functions. Some of our group companies are located outside the European Union, but we always ensure the security of such disclosures and transfers in accordance with the applicable privacy and data protection laws.

We will only transfer your personal data outside the EU, where we are satisfied that adequate levels of protection are in place to protect the integrity and security of any information being processed and compliance with applicable privacy and data protection laws. These measures may include the use of standard contractual/data protection clauses adopted by the European Commission, or appropriate data sharing mechanisms that may be in force from time to time. Where we transfer personal data between our group companies we have covered these transfers by entering into standard contractual clauses adopted by the European Commission.  

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

7. Your rights 

• Object to our processing of your personal data where we are relying on legitimate interest (or those of a third-party), and you want to object to processing on this ground, as you feel it impacts on your fundamental rights and freedoms. You also have a right to object where we are processing your personal data for the purposes of direct marketing or profiling. You can object at any time and we shall stop processing the information you have objected to, unless we can show compelling legitimate grounds to continue that processing. 
• Access your personal data. If you make this kind of request and we hold personal data about you. We are required to provide you with information on it, including a description and copy of the personal data and why we are processing it. We will require you to prove your identity before granting access to your personal data. We will process your request within the timeframe required under the relevant law. 
• Request the transfer of your personal data. We will provide to you or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Please note, this right applies to the personal data you have provided to us; and if we use your personal data on the basis of consent or where we used the information to perform a contract with you. 
• Request erasure (deletion) of your personal data.  You have a right to ask us to delete or remove your data where you have successfully exercised your right to object (see above), or where we are required to erase your personal data to comply with local law. Please note, we may be required to retain certain information by law and/or for our own legitimate business purpose. But when we do so, we will inform you
• Request correction or updating of your personal data. This enables you to have any incomplete or inaccurate data we hold about you corrected. 
• Request the restriction of our processing of your personal data in some situations. If you request this, we can continue to store your personal data but are restricted from processing it while the restriction is in place.
• Withdraw your consent. Where you have provided your consent to our processing of your personal data you can withdraw your consent at any time. If you do withdraw consent, that will not affect the lawfulness of what we have done with your personal data before you withdrew consent.
• Make a Complaint. We will do our best to resolve any complaint. However, if you feel we have not resolved your complaint, you have a right to make a complaint 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 exercise the rights above and there is any question about who you are, we may require you to provide information from which we can satisfy ourselves as to your identity. 

8. Our responsibility for website links

This Privacy Notice is limited to the personal data collected by dentsu international. We do provide links within this site to other websites, including social media sites such as Facebook, Twitter and LinkedIn. If you follow these links, you should use these sites in conjunction with their applicable user and privacy notices as their data practices fall outside the scope of this Privacy Notice. Further, we can have no responsibility for or control over the information 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.

9. Updates

This Privacy Notice may be updated from time to time to reflect changes in law, best practice or a change in our practices regarding the treatment of 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 do not continue to use our services and please refrain from sharing your personal data with us. You should check this notice frequently for updates. 

10. 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:

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

Telephone: (+44) (0) 207 070 7700

Email: dpo@dentsu.com

SUPPLEMENTARY INFORMATION

In this Supplementary Information section, we explain some of terminology used in this Privacy Notice. 

“data controller” – the person or company that controls the purposes and means of processing personal data. 

"personal data" – any information that relates to you (or from which you can be identified). 

 “processing” – means doing anything with data. For example, it includes collecting it, holding it, disclosing it and deleting it. 

“profiling” - using automated means to process personal data in order to work out certain things about people, like analysing or predicting their performance at work, reliability, economic situation, personal preferences, interests, behaviour, location or movements.

"transfer" – sending personal information outside the European Economic Area (e.g. by storing it on equipment located outside the European Economic Area), or allowing someone from outside the European Economic Area to access the personal information.

Your California Rights 

This section describes the rights that residents of California have and in other jurisdictions as provided by local law, and how to exercise such rights.  

Right to Know about Personal Information Collected, Disclosed or Sold 

You have the right to request that we disclose certain information to you about our collection, use, disclosure or sale of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access and Deletion Rights), and subject to certain limitations that we describe below, we will disclose such information. You have the right to request any or all of the following: 

• The categories of personal information we collected about you. 
• The categories of sources from which the personal information is collected. 
• Our business or commercial purpose for collecting or selling that personal information. 
• The categories of third parties with whom we share that personal information. 
• The specific pieces of personal information we collected about you (also called a data portability request).  

Right to Request Deletion 

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records.  However, we may retain personal information that has been de-identified or aggregated. Furthermore, we may deny your deletion request if retaining the information is necessary for us or our service provider(s) in order to perform certain actions set forth under CCPA, such as detecting security incidents and protecting against fraudulent or illegal activity.  

Exercising Access and Deletion Rights 

To exercise the access and deletion rights described above, please submit a request to us by emailing us at contact.privacyus@amnetgroup.com or via the following toll-free number: (877) 570-1441. 

Only you, or a person or business entity registered with the California Secretary of State that you authorize to act on your behalf (an “authorized agent”), may make the requests set forth above. You may also make a request on behalf of your minor child.   

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 consumer requests in a reasonably timely manner. If we require extra time to respond, we will inform you of the reason and extension period in writing. In order to protect the security of your personal information, we will not honor a request if we cannot verify your identity or authority to make the request and confirm the personal information 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 authorized access or deletion. Generally speaking, verification will be performed by matching the identifying information provided by you to the personal information that we already have.  

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request (and will not be made more than twice in a 12-month period). If we cannot comply with a request, or cannot fully comply with a request, the response we provide will also explain the reasons we cannot comply.  

Non-Discrimination 

We will not discriminate against you for exercising any of your CCPA rights, including, but not limited to, by: 

• Denying you goods or services. 
• Charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties. 
• Providing you a different level or quality of goods or services. 
• Suggesting that you may receive a different price or rate for goods or services or a different level or quality of goods or services.