Privacy Notice 

This U.S. Privacy Notice is effective as of August 8th, 2025.

This U.S. Privacy Notice includes certain disclosures required under applicable U.S. privacy laws.  Please note that the rules implementing some of these laws are subject to change.  We are committed to continual compliance with these laws and will update our processes and this notice as the rules are updated and the law requires.

Data collected by us within the scope of this Privacy Notice is not incorporated into our data products. You can find privacy information for our products here.

U.S. state privacy laws, including The California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act, provides residents of their respective states with additional rights with respect to their Personal Data. Those rights are explained below in the “Your Privacy Rights” section.

In this U.S. Privacy Notice, the term “Personal Data” has the meaning ascribed to it under applicable U.S. privacy laws, and includes the term “Personal Information” as defined by the California Consumer Privacy Act of 2018, as amended.

Personal Data does not include de-identified or aggregate data or publicly available data.

1. Information We May Collect

In addition to the information that we disclose in the “Personal Data that we may collect” section of our Privacy Notice, we also collect the following additional information in the U.S. as explained herein.  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:

Contact data

We collect information when you enter into an agreement, contact us, or sign up for our marketing communications and newsletters. We also collect any Personal Data you provide if you post a comment, make a request, or complete a survey.

Commercial and Preference Information

We may collect information about our contact history with you and your other transactions and preferences. We may collect information about your job and title, details of your attendance at our events, and your interest in our services.

Location Information

We may infer a location based on your IP address. We may automatically collect your precise GPS location when you access the mobile version of our websites. We may also collect information about your general location, using your zip code or postcode and IP address.

Online Advertising

Our partners may also place cookies, pixel tags and similar technologies on many online services, including ours. They use these technologies to collect information about your activities on these services in order to allow us to deliver you more relevant advertising. For example, they may use the information they collect from their cookies on our services to identify which of our products and services you might be interested in and to recognize your device so they can show you relevant advertisements about our products while you are using our services and other online services. Additionally, we sometimes provide information we collect (such as email addresses) to service providers, who may “match” this information to cookies, mobile ad identifiers, and other proprietary IDs, in order to provide you with more relevant ads when you visit other online services.

You can learn about how to opt out of receiving personalized online advertisements from our advertising partners by following the instructions in the “Your Choices” and “Your Privacy Rights” sections below, and through our Cookies Notice.

Inferences

Using the other pieces of Personal Data collected about you, we may draw inferences about you, reflecting what we believe to be your preferences, characteristics, predispositions, and attitudes as well as attributes connected to your IP address.

Combining Information

We may combine information collected offline with information we collect online. Or we may combine information we get from another party with information we already have. We may also aggregate your information with other consumers’ information to understand preferences and trends over time. We also may combine information collected across devices, such as computers and mobile devices.

    2. How We Use This Information

Except where prohibited by law or court order we use your Personal Data to generate leads and for the following business purposes in the U.S.:

• 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;
• to facilitate acquisitions and potential acquisitions of or by our business, including any related transitional and business integration activities;
• to enable the download of our content;
• to send you newsletters and information relating to our brands and services;
• to recognize you across multiple touchpoints by creating a single record for you; 
• other purposes for which we seek your consent; and
• to protect us, our websites, customers, employees, and business partners from fraud or other malicious activity.

As noted above, in this U.S. Privacy Notice, the term “Personal Data” has the meaning ascribed to it under applicable U.S. laws, and includes the term “Personal Information” as defined by the California Consumer Privacy Act of 2018, as amended.

In the table below we set out further information about the purposes for which we use your Personal Data and the categories of third parties that we disclose, “sell,” or share the Personal Data.  The term “share” has the meanings ascribed to it under applicable U.S. privacy laws, including for “cross-context behavioral advertising” or “targeted advertising.”  The term “sell” has the meanings ascribed to it under applicable U.S. laws, meaning the sale of your Personal Data to an outside party for monetary or other valuable consideration, subject to certain exceptions.  In the second column, we also specify how such Personal Data is categorized under applicable U.S. privacy laws. For more information about the categories of Personal Data under applicable U.S. privacy laws, see the “Your Privacy Rights” section.

Purpose/Activity	Types of Personal Data that may be processed	Categories of third parties to which we may disclose this Personal Data for a business purpose	Categories of third parties to which this Personal Data may be ”shared” or “sold” for advertising/analytical purposes
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.	(a) Name (b) Email address (c) Phone number (c) Social media account handles (d) Mailing address (e) General location (Identifiers: Personal Data; professional or employment related information)  (f) Commercial and Preference Information (responses to surveys, details of your attendance at our events, interest in our services, information about our contact history with you and your other transactions and preferences) (g) Technical and usage (identifiers: Personal Data, such as IP address, device identifiers, internet or other similar network activity) (h) Location information (identifiers: precise geolocation, general location using zip code or postal code and IP address) (i) Inferences (using other pieces of Personal Data collected about you and attributes connected to your IP address)	Third-party service providers; Entities due to corporate mergers or restructuring; Other parties as required by law or to prevent or investigate illegal activities	Business partners and marketing companies.
To arrange and run events: The process by which invitations are sent to, acceptances are received from and attendance at dentsu events, are managed.	(a) Name (b) Email address (c) Phone number (c) Social media account handles (d) Mailing address (e) General location (Identifiers: Personal Data; professional or employment related information)  (f) Commercial and Preference Information (responses to surveys, details of your attendance at our events, interest in our services, information about our contact history with you and your other transactions and preferences)	Third-party service providers; Entities due to corporate mergers or restructuring; Other parties as required by law or to prevent or investigate illegal activities	We do not sell/share.
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	(a) Name (b) Email address (c) Phone number (c) Social media account handles (d) Mailing address (e) General location (Identifiers: Personal Data; professional or employment related information)  (f) Commercial and Preference Information (responses to surveys, details of your attendance at our events, interest in our services, information about our contact history with you and your other transactions and preferences) (g) Technical and usage (identifiers: Personal Data, such as IP address, device identifiers, internet or other similar network activity) (h) Location information (identifiers: precise geolocation, general location using zip code or postal code and IP address) (i) Inferences (using other pieces of Personal Data collected about you and attributes connected to your IP address)	Third-party service providers; Entities due to corporate mergers or restructuring; Other parties as required by law or to prevent or investigate illegal activities;	We do not sell/share
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 etc.	(a) Technical and usage (identifiers: Personal Data, such as IP address, device identifiers, internet or other similar network activity)	Third-party service providers; Entities due to corporate mergers or restructuring; Other parties as required by law or to prevent or investigate illegal activities	We do not sell/share
To respond to any inquiries or feedback that you send us To update you with any changes to our terms and conditions/other policies	(a) Name (b) Email address (c) Phone number (c) Social media account handles (d) Mailing address (e) General location (Identifiers: Personal Data; professional or employment related information)  (f) Commercial and Preference Information (responses to surveys, details of your attendance at our events, interest in our services, information about our contact history with you and your other transactions and preferences) (g) Technical and usage (identifiers: Personal Data, such as IP address, device identifiers, internet or other similar network activity) (h) Location information (identifiers: precise geolocation, general location using zip code or postal code and IP address) (i) Inferences (using other pieces of Personal Data collected about you and attributes connected to your IP address)	Third-party service providers; Entities due to corporate mergers or restructuring; Other parties as required by law or to prevent or investigate illegal activities	We do not sell/share
To manage our relationship with you: To provide you with services and for the purpose of relationship, account, and/or project management.	(a) Name (b) Email address (c) Phone number (c) Social media account handles (d) Mailing address (e) General location (Identifiers: Personal Data; professional or employment related information)  (f) Commercial and Preference Information (responses to surveys, details of your attendance at our events, interest in our services, information about our contact history with you and your other transactions and preferences) (g) Technical and usage (identifiers: Personal Data, such as IP address, device identifiers, internet or other similar network activity) (h) Location information (identifiers: precise geolocation, general location using zip code or postal code and IP address) (i) Inferences (using other pieces of Personal Data collected about you and attributes connected to your IP address)	Third-party service providers; Entities due to corporate mergers or restructuring; Other parties as required by law or to prevent or investigate illegal activities	We do not sell/share
To protect this website, our company, our employees, and our users from malicious attacks, hacking, fraud, or other illegal or unauthorized activity	(a) Name (b) Email address (c) Phone number (c) Social media account handles (d) Mailing address (e) General location (Identifiers: Personal Data; professional or employment related information)  (f) Commercial and Preference Information (responses to surveys, details of your attendance at our events, interest in our services, information about our contact history with you and your other transactions and preferences) (g) Technical and usage (identifiers: Personal Data, such as IP address, device identifiers, internet or other similar network activity) (h) Location information (identifiers: precise geolocation, general location using zip code or postal code and IP address) (i) Inferences (using other pieces of Personal Data collected about you and attributes connected to your IP address)	Third-party service providers; Entities due to corporate mergers or restructuring; Other parties as required by law or to prevent or investigate illegal activities	We do not sell/share
To analyze and improve our services:  To deliver relevant content to you, and measure or understand the effectiveness of the content we serve to you.	(a) Name (b) Email address (c) Phone number (c) Social media account handles (d) Mailing address (e) General location (Identifiers: Personal Data; professional or employment related information)  (f) Commercial and Preference Information (responses to surveys, details of your attendance at our events, interest in our services, information about our contact history with you and your other transactions and preferences) (g) technical and usage (identifiers: Personal Data, such as IP address, device identifiers, internet or other similar network activity) (h) Location information (identifiers: precise geolocation, general location using zip code or postal code and IP address) (i) Inferences (using other pieces of Personal Data collected about you and attributes connected to your IP address)	Third-party service providers; Entities due to corporate mergers or restructuring; Other parties as required by law or to prevent or investigate illegal activities	Business partners and marketing companies.
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.	(a) Name (b) Email address (c) Phone number (c) Social media account handles (d) Mailing address (e) General location (Identifiers: Personal Data; professional or employment related information)  (f) Commercial and Preference Information (responses to surveys, details of your attendance at our events, interest in our services, information about our contact history with you and your other transactions and preferences) (g) technical and usage (identifiers: Personal Data, such as IP address, device identifiers, internet or other similar network activity) (h) Location information (identifiers: precise geolocation, general location using zip code or postal code and IP address) (i) Inferences (using other pieces of Personal Data collected about you and attributes connected to your IP address)	Third-party service providers; Entities due to corporate mergers or restructuring; Other parties as required by law or to prevent or investigate illegal activities	We do not sell/share
To protect and defend our legal rights/respond to complaints:  This process allows us to share information with other third parties, such as regulator and law enforcement agencies	(a) Name (b) Email address (c) Phone number (c) Social media account handles (d) Mailing address (e) General location (Identifiers: Personal Data; professional or employment related information)  (f) Commercial and Preference Information (responses to surveys, details of your attendance at our events, interest in our services, information about our contact history with you and your other transactions and preferences) (g) technical and usage (identifiers: Personal Data, such as IP address, device identifiers, internet or other similar network activity) (h) Location information (identifiers: precise geolocation, general location using zip code or postal code and IP address) (i) Inferences (using other pieces of Personal Data collected about you and attributes connected to your IP address)	Third-party service providers; Entities due to corporate mergers or restructuring; Other parties as required by law or to prevent or investigate illegal activities	We do not sell/share
To facilitate acquisitions and potential acquisitions of or by our business, including any related transitional and business integration activities.	(a) Name (b) Email address (c) Phone number (c) Social media account handles (d) Mailing address (e) General location (Identifiers: Personal Data; professional or employment related information)  (f) Commercial and Preference Information (responses to surveys, details of your attendance at our events, interest in our services, information about our contact history with you and your other transactions and preferences) (g) technical and usage (identifiers: Personal Data, such as IP address, device identifiers, internet or other similar network activity) (h) Location information (identifiers: precise geolocation, general location using zip code or postal code and IP address) (i) Inferences (using other pieces of Personal Data collected about you and attributes connected to your IP address)	Entities due to corporate mergers or restructuring	We do not sell/share

We may use Personal Data to create deidentified or aggregated data which does not identify you or any other individual. We may use and disclose this anonymous or aggregated data as we choose.

3. Information Sharing and Disclosing

Information shared with our business partners and marketing companies

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.

Information shared with other parties as required by law or to prevent or investigate illegal activities

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 or to protect us, our websites, customers, employees, and business partners from fraud or other malicious activity, and as otherwise required by law. We might share your Personal Data in order to enforce our agreements and to protect our rights and/or the rights of others. We might share your Personal Data when we are investigating potential fraud. This might include fraud we think has happened during a promotion. Where we have a legal requirement to do so, if you are the winner of a sweepstakes or contest, we may also share your certain Contact Information with anyone entitled to request a winner’s list.

We may use and share Personal Data as otherwise disclosed to you from time to time when collecting your Personal Data or as otherwise permitted by law. 

Your Choices

You have certain choices about how we use your information. 

You can control cookies and tracking tools. To learn more about your choices related to cookies, please see our Cookie Notice. 

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.

5. Your Privacy Rights

U.S. state privacy laws, including the California Consumer Privacy Act (“CCPA”), as amended, provides residents of their respective states with additional rights with respect to their Personal Data.

Depending on where you live and what you are asking us to do, we may or may not be obligated to comply with your request, and/or the time required to complete a request may vary.  Based on how we collect and utilize your Personal Data, you may have the following rights:

• Right to Access – You have the right to request that we provide you with a copy of the specific pieces of Personal Data we collected about you.
• Right to Delete – You have the right to request that we delete your Personal Data that we maintain about you, subject to certain exceptions.
  • If you were known by another name or lived at another address, we may not be able to locate all information which relates to you if you do not include it in the form below. Please provide as much information as possible so that we can try to identify all records which relate to you.  We may keep certain Personal Data in accordance with our legal obligations and rights, such as keeping sufficient information about you to recognize that you have made a Personal Data request and to keep a record of that request.
  • However, if we lawfully receive your Personal Data after fulfilling your deletion request, that new information may be included in future data products unless/until you submit a new deletion request. However, if one of our clients separately has your Personal Data and they provide it to us, along with specific instructions on how we are to use it on their behalf, you may still receive their advertising. (We do not add our clients’ data to our own data products unless allowed to by our clients)
• Right to Opt-Out of Targeted Advertising – You have the right to request that we not include your data for any targeted advertising we conduct.
  • Your choices do NOT affect marketing that is not based on your Personal Data. For example, you may still receive advertising based on the content and predicted audience of the website you are browsing. This is known as “contextual advertising” and will not stop in response to your requests.
• Right to Correct – You have the right to request that we correct inaccurate Personal Data that we maintain about you, subject to certain exceptions.
• Right to Limit Use of Sensitive Personal Data – You have the right to request that we do not process or share your sensitive Personal Data.
• Right to Opt-Out of Profiling – You have the right to request that we not process your information for profiling.
• Right to Non-Discrimination – You have the right to not receive discriminatory treatment for the exercise of your privacy rights.
• Do Not Sell/Share My Info – You can request that Merkle does not sell or share your Personal Data that we have in our products by clicking Your Privacy Choices. For purposes of our Product Privacy Notice, “sell” means the sale of your Personal Data in our products to an outside party for monetary or other valuable consideration, subject to certain exceptions set forth in applicable U.S. privacy laws. For purposes of our Product Privacy notice Notice, “share” means the targeting of advertising to you based on that your Personal Data obtained from your activity across websites in our products, subject to certain exceptions set forth in applicable U.S. privacy laws. Any opt-out of cookie-based tracking for advertising purposes is specific to the device, website, and browser you are using, and is deleted whenever you clear your browser’s cache.
  • If you request an opt-out of the sale or share of your Personal Data, we will stop including your information in the data products we give to our clients.

For non-product related requests or any business to business (B2B) data subject requests, please call us at (+1) (833) 570-5939 (toll-free in the US) or e-mail us at Americas.DPO@dentsu.com. For any employment related requests, you can make these requests online by reviewing the respective Employee, Job Candidates and Job Leavers Privacy Notice for your region. 

We may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations. For example, we may retain Personal Data as permitted by law, such as for tax or other record keeping purposes, to maintain an active account, and to process transactions and facilitate customer requests. Note that for purposes of these requests under this Privacy Notice, Personal Data does not include information we have collected as a service provider to our clients. Finally, please note that we are required by California Civil Code section 1798.105(d) to keep a record of your request. Only you, or a person or business entity 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.  For California residents, Authorized Agents may be an entity that is registered with the California Secretary of State or a person.

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 sufficient information (including information that reasonably enables us verify the identifying information we currently maintain about you) that allows us to reasonably verify that you are the person about whom we collected the Personal Data or an authorized representative.

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 Data, we will not honor a request if we cannot 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 authorized access or deletion. Generally speaking, verification will be performed by matching the identifying information provided by you to the Personal Data that we already have. 

Any disclosures we provide for California residents 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. If we deny your request in whole or in part, you may have the right to appeal the decision. In such circumstances, we will provide you with information regarding the appeals process.

Merkle Specific Privacy Choices

You may have the following additional choices related to how Merkle uses your information.

Opting Out of Merkle Interest Based Advertising

We enable users to opt-out from certain uses of information in a digital environment. If you want to opt-out from our Merkle solutions from the browser you are currently using, click here and our systems will attempt to place an opt-out cookie on your computer. 

We and other third party companies collect and receive information from across a variety of websites and mobile applications you visit or use over time in order to infer your interests and deliver relevant advertising to the browsers and devices you may use, including across associated devices. This type of advertising is known as interest-based advertising. You may visit http://www.aboutads.info/choices/ to learn more about this activity and opt out of our and many of our partners collection and use of data for that purpose.

You may also visit http://www.aboutads.info/choices/ to have the option of opting out of many of our partners. Please note that if you clear cookies from your browser, you may need to renew your opt-out choice. The mobile operating systems (e.g., Android and iOS) have their own opt-out mechanisms that apply IBA in mobile app environments. To exercise this opt-out, please visit the privacy settings of your Android or iOS device and select “limit ad tracking” (Apple iOS) or “opt-out of interest based ads” (Android).

Please note that if you clear cookies from your browser or reset your device identifier, you may need to renew your opt-out choice. You will also continue to receive advertising after an opt-out, but those advertisements may be less relevant to your interests. If you use multiple browsers or devices you will need to exercise your choices on those browsers or devices as well.

Opting Out of Direct Mail and Telemarketing

Responsible marketing companies respect your choice to not receive direct mail advertising. We use Direct Marketing Association (DMA) resources to suppress the names and addresses of individuals who have notified the DMA that they do not want to receive advertising by mail.

If you would like to opt out of direct mail advertising, send your complete name and address to: DMA Mail Preference Service P.O. Box 643 Carmel, NY 10512

Responsible marketing companies respect your choice to not receive telemarketing calls. We use DMA resources to suppress the phone numbers of individuals who have notified the DMA that they do not want to receive telemarketing calls.

If you would like to opt out of telemarketing calls, send your complete name, address and telephone number to: DMA Telephone Preference Service P.O. Box 1559 Carmel.

Email Marketing Preferences

If you wish to update your email marketing preferences or unsubscribe, from Merkle communications, you can also do so by visiting this page.

Data Subject Rights Requests Merkle Metrics - California Consumer Privacy Act

• Click here to view our most recent reporting metrics for Merkle.

If you reside in California, you have the right to ask us one time each year if we have shared Personal Data with third parties for their direct marketing purposes. To make a request, please send us an email, or write to us at the address listed below. Indicate in your letter that you are a California resident making a “Shine the Light” inquiry.

1. Children

This website is not intended for children. We do not actively seek to collect Personal Data about children. 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 Americas.DPO@dentsu.com. We will delete such Personal Data from our records or seek verifiable parental or legal guardian consent to retain such information within a reasonable time.

2. Data Broker

Merkle is a registered data broker under California, Oregon, Texas, and Vermont.  To conduct business in Texas, a data broker must register with the Texas Secretary of State (Texas SOS).  Information about data broker registrants is available on the Texas SOS website.

Merkle Incorporated is registered with the Oregon Secretary of State.

3. Contact Us

If you have any questions about this Privacy Notice or our approach to privacy, you can contact our Data Protection Officer in any of the following ways:

Address: 

Americas Privacy Office
Dentsu International
150 E 42nd Street

New York, NY 10017

Telephone:

(+1) (877) 570-5939 (U.S. toll-free)

Or by email at: Americas.DPO@dentsu.com