Publicis Health Media Privacy Notice

Publicis Health Media (“we,” “us,” or “our”) offers media planning and buying services. This Privacy Notice sets out how we collect, use, share, and protect any information we collect through this website (“Website”). This Privacy Notice also explains the measures we take to safeguard your information and describes how you may contact us regarding our privacy practices.

Introduction

Any data collected through this Website, including personal data or personal information (as defined under applicable data protection laws, referred to collectively as “Personal Data”), will only be used for the purposes set out in this Privacy Notice. Notwithstanding, we may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law.

When data is collected on this Website, Publicis Health Media is acting as a data controller. However, in some instances, Publicis Health Media acts as a processor on behalf of a client, which is the controller. Where this is the case, we will process your Personal Data in line with our legal obligations and contractually commitments to our clients.

Please read this Privacy Notice thoroughly. If you disagree with the way personal data will be used, please do not use this Website.

We may include links to other websites, including social media platforms. This Privacy Notice only covers this Website and does not apply to the data practices of other websites. We encourage you to read the privacy notices available on other websites you visit.

I. What personal data do we collect and process through the Website?

The following table describes the categories of personal data we collect.

Category of Personal data	Examples
Contact Information and Identifiers	First name, last name, e-mail address, telephone number any other contact details provided, online identifiers; IP address; mobile ad identifiers
Internet or other electronic network activity information (Technical data)	Online interests, such as information about categories of consumer interests derived from online usage; and information on a consumer’s interaction with a website, application, or advertisement.
Geolocation data	Location information from your device or IP address
Your verbatim communications to us or shared on the public areas of our site	Information that you directly send us by using the comment functionality on this Website

Categories of the sources of personal data we may collect:

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

• Directly from you, for example, when you send us your questions or comments using the query form or make usage of your privacy rights.
• From publicly available sources, data brokers, partners (e.g., that offer co-branded services, sell or distribute our products, or engage in joint marketing activities), advertising networks, data analytics providers, and social networks.
• Indirectly from you by using automated technologies, such as cookies, pixels, third party tags, scripts, log files and other means to automatically collect information about the use of our Website Further information about our use of cookies can be found in our Cookie section below.

II. Purpose of data collection and legal basis

The following table provides information about our purposes and legal basis for collecting your personal data:

Our Purposes for collecting and using your personal data	Basis for processing
To read and respond to your queries to us, sent using our online query form.	Legitimate interest to respond to individuals’ queries.
When you contact us for a  data access request.	We rely on your consent to process your personal data to respond to your queries.
To contact you where you have indicated you wish to receive news from us.	For visitors from the European Union, we rely on your consent, where you indicate that you want to receive marketing material from us.
Operating our Website, for example, operating, analyzing, improving, and securing our Website.	For visitors from the European Union, we rely on your consent to obtain your personal data through cookies. For visitors from other geographies, we rely on our legitimate interest to improve our services and develop new products.
Online targeting, for example: – Creating or helping to create defined audience segments based on common demographics and/or shared (actual or inferred) interests or preferences (e.g., households with prospective students). When we do this, we work with a data partner that “matches” our or other information through de-identification techniques (such as through coded data “hashing”) with online cookies and other identifiers, in order to target and measure ad campaigns online across various display, mobile and other media channels.  – Creating “identity” graphs, to help locate users across various channels, such as connecting identities based on common personal, device-based, or network-based identifiers (e.g., IP address, email address).	For visitors from the European Union, we rely on your consent for online targeting.
Marketing services, for example: – Assisting in targeting and optimizing of direct mail and email campaigns, display, mobile and social media marketing. – Measuring the effectiveness of online or offline ad campaigns by determining which messages are most likely to be seen or opened by which types of clients and potential clients, or which types of ads are most likely to lead to purchases. – Analyzing and optimizing our (or our service providers’) proprietary databases, or helping us identify and mitigate potential fraud. – Providing “verification” or data “hygiene” services, which is how companies update and/or “clean” their databases by either verifying or removing or correcting old, incorrect or outdated information.	For visitors from the European Union, we rely on your consent to use your personal data for marketing services.
– Other internal purposes, such as: internal research, internal operations, auditing, detecting security incidents, debugging, short-term and transient use, quality control, and legal compliance.	Our legitimate interest to support our internal operations and conduct research.

In addition, we use analytics services, such as Google Analytics, to help us understand how users access and use the Website. We also we work with agencies, advertisers, ad networks, and other technology services to place ads about our products and services on other websites and services. For example, we place ads through Google and Facebook that you may view on their platforms as well as on other websites.

As part of this process, we may incorporate tracking technologies into our own Website as well as into our ads displayed on other websites and services. Some of these tracking technologies may track your activities across time and services for purposes of associating the different devices you use, and delivering relevant ads and/or other content to you (“Interest-based Advertising”).

We also use audience matching services to reach people (or people similar to people) who have visited our Website or are identified in one or more of our databases (“Matched Ads”). This is done by us uploading a customer list to another party or incorporating a pixel from another party into our own Website, and the other party matching common factors between our data and their data or other datasets. For instance, we incorporate the Facebook pixel on our Website and may share your email address with Facebook as part of our use of Facebook Custom Audiences.

As indicated below, vendors and other parties may act as our service providers, or in certain contexts, independently decide how to process your information. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.

III. With whom do we share personal data?

We will share your personal data for various business purposes, with service providers.

The table below shows how and with whom we may share or disclose your personal data, and whether (based on the California Consumer Privacy Act’s definition of “sell”) we believe we have “sold” a particular category of information in the prior 12 months.

Category	Categories of Parties With Whom We Share Your Data	Whether We “Sold” This Category of Personal data in the Last 12 Months
Identifiers	Affiliates, service providers, advertising partners.	Yes – online identifiers with regard to interest based advertising cookies.
Internet or other electronic network activity information	Affiliates, service providers, advertising partners.	Yes – online identifiers with regard to interest based advertising cookies.
Geolocation data	Affiliates, service providers, advertising partners.	Yes – online identifiers with regard to interest based advertising cookies.
Your verbatim communications to us or shared on the public areas of our site	Affiliates	No

We also may share any of the personal data we collect with the following

Sharing for Legal Purposes: In addition, we may share personal data with other parties in order to: (a) comply with legal process or a regulatory investigation (e.g. regulatory authorities’ investigation, subpoena, or court order); (b) enforce our Terms of Service, this Privacy Notice, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of other parties; and/or (d) protect the rights, property or personal safety of us, our platform, our customers, our agents and affiliates, its users and/or the public. We likewise may provide information to other companies and organizations (including law enforcement) for fraud protection, and spam/malware prevention, and similar purposes.

Sharing In Event of a Corporate Transaction: We may also share personal data in the event of a major corporate transaction, including for example a merger, investment, acquisition, reorganization, consolidation, bankruptcy, liquidation, or sale of some or all of our assets, or for purposes of due diligence connected with any such transaction.

Aggregate, Deidentified, or Anonymized Information: We may aggregate, de-identify and/or anonymize any information collected so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”). We may use Aggregate/De-Identified Information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any other party, including advertisers, promotional partners, and sponsors, in our discretion, unless otherwise prohibited by applicable law.

IV. Your rights and choices regarding your personal data

1. Where you are resident of the EU

1.1. General

Subject to certain exceptions and the jurisdiction in which you live, if you are a resident of the EU, the GDPR provides you with specific rights regarding your personal data. This subsection describes your rights and explains how to exercise those rights regarding personal data that we hold about you. These rights include:

• The right of access
• The right to rectification
• The right to erasure
• The right to object
• The right to restrict processing
• The right to data portability
• The right to withdraw your consent to the processing of your personal data at any time

If you are unsatisfied with the way we process your Personal Data or if your request has been rejected, you may also lodge a formal complaint with your local competent data protection authority.

Personal data will be stored in accordance with our applicable data retention requirements and corporate policies. The retention period for personal data varies depending on the type of personal data and the purposes of processing it.

You can exercise your rights by contacting us at info@publicishealthmedia.com. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information. We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way. If we cannot fully address your request, we will contact you to let you know and explain the reason why your request was denied.

1.2. Information from our clients

If personal data about you has been processed by us as a processor on behalf of a client and you wish to exercise any rights you have with such personal data, please inquire with our client directly. If you wish to make your request directly to us, please provide the name of our client on whose behalf we processed your personal data. We will refer your request to that client, and will support them to the extent required by applicable law in responding to your request.

2. Where you are a California resident

Your California Rights and Choices

California residents, under the California Consumer Privacy Act of 2018 (“CCPA”), have specific rights with regard to their personal data. This section describes how to exercise those rights and our process for handling those requests. (To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.)

Our website is intended to provide information and services to job applicants and business clients. You understand and agree that information collected about you is solely within the context of (i) your role as an employee, job applicant, owner, director, officer, or contractor or (ii) Publicis Health Media’s conducting due diligence regarding, or providing or receiving a product or service to or from your employer.

2.1. Information from our clients

We also acknowledge that you may have rights under the CCPA in connection with the personal data we process on behalf of our clients. If personal data about you has been processed by us as a service provider on behalf of a client and you wish to exercise any of the rights described below, please provide the name of our client on whose behalf we processed your personal data. We will refer your request to that client, and will support them to the extent required by applicable law in responding to your request.

2.2. Right to request access to your personal data

California residents have the right to request that we disclose what categories of personal data that we collect, use, disclose, or sell about them. In particular, California residents may request:

• the specific pieces of personal data that we have collected about you;
• the categories of personal data we have collected about you;
• the categories of sources from which the personal data was collected;
• the categories of personal data about you we disclosed for a business purpose or sold;
• the categories of third parties to whom the personal data was disclosed for a business purpose or sold; and
• the business or commercial purpose for collecting or selling the personal data.

2.3. Right to request deletion of your personal data

You may also request that we delete any personal data that we collected from you, such as if you have been a customer of ours. However, we may retain personal data for certain important purposes, as set out by law. When we receive and verify your request to delete your personal data we will proceed to delete the data unless an exception applies.

2.4. Right to nondiscrimination

We will not deny, charge different prices for, or provide a different level of quality of goods or services if you choose to exercise these CCPA rights.

2.5. Right to Opt-out of the sale of your personal data

The CCPA broadly defines what constitutes a “sale” – including in the definition making available a wide variety of information in exchange for “valuable consideration.” To the extent we engage in the “sale” of your personal data as defined by the CCPA, California residents may opt out of the “sale” of their personal data.

Depending what information we have about you, and whether we have included any of it in our marketing products and services, we may have sold (as defined by California law) certain categories of information about you in the last 12 months, as described in the above table in Section III of this Privacy Notice, titled “With whom do we share your personal data.” If you would like to opt out, you may do so by contacting us here: Do Not Sell My Personal data.

2.6. Shine the Light

Customers who are residents of California may request (i) a list of the categories of personal data disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To exercise a request, please write us at the email or postal address set out in the “Further Information” section below and specify that you are making a “California Shine the Light Request.”

2.7. How to exercise your CCPA privacy rights

California residents may exercise their CCPA privacy rights by sending an email to info@publicishealthmedia.com or by submitting your request to the “Let’s Talk!” form found on several pages of the website.

For security purposes (and as required under California law), we will verify your identity – in part by requesting certain information from you – when you request to exercise your California privacy rights. For instance, if you request categories or specific pieces of personal data we have collected about you, you may need to confirm your possession of an identifier (such as an email address) or to provide a piece of identification that confirms you are the person you claim to be.

If we are unable to complete your request fully for any reason, we will provide you additional information about the reasons why we could not comply with your request.

You may also designate an agent to make requests to exercise your rights under CCPA as described above. We will take steps both to verify the identity of the person seeking to exercise their rights as listed above, and to verify that your agent has been authorized to make a request on your behalf through providing us with a signed written authorization or a copy of a power of attorney.

3. Where you are a Nevada Resident

Nevada law (NRS 603A.340) requires each business to establish a designated request address where Nevada consumers may submit requests directing the business not to sell certain kinds of personal data that the business has collected or will collect about the consumer. A sale under Nevada law is the exchange of personal data for monetary consideration by the business to a third party for the third party to license or sell the personal data to other third parties. If you are a Nevada consumer and wish to submit a request relating to our compliance with Nevada law, please contact us as at info@publicishealthmedia.com

4. Your general rights regarding to data collection

4.1. Do Not Track:

Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals. For more information on “Do Not Track,” visit http://www.allaboutdnt.com

4.2. Analytics:

Google provides tools to allow you to opt out of the use of certain information collected by Google Analytics at https://tools.google.com/dlpage/gaoptout and by Google Analytics for Display Advertising or the Google Display Network at https://www.google.com/settings/ads/onweb/.

4.3. Interest-Based Advertising:

The companies we work with to provide you with targeted ads are required by us to give you the choice to opt out of receiving targeted ads. Most of these companies are participants of the Digital Advertising Alliance (“DAA”) and/or the Network Advertising Initiative (“NAI”). To learn more about the targeted ads provided by these companies, and how to opt out of receiving certain targeted ads from them, please visit: (i) for website targeted ads from DAA participants, https://www.aboutads.info/choices; (ii) for app targeted ads from DAA participants, https://www.aboutads.info/appchoices; and (iii) for targeted ads from NAI participants, https://www.networkadvertising.org/choices/. Opting out only means that the selected participants should no longer deliver certain targeted ads to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., in connection with the participants’ other customers or from other technology services).

To opt out of us using your data for Matched Ads, please contact us as set forth in the “Contact Us” section below and specify that you wish to opt out of matched ads. We will request that the applicable party not serve you matched ads based on information we provide to it. Alternatively, you may directly contact the applicable party to opt out.

Please note that if you opt out using any of these methods, the opt out will only apply to the specific browser or device from which you opt out. We are not responsible for the effectiveness of, or compliance with, any opt out options or programs, or the accuracy of any other entities’ statements regarding their opt out options or programs.

4.4. E-mails:

You can opt-out of receiving promotional emails from us at any time by following the instructions as provided in emails to click on the unsubscribe link, or emailing us at the email address set out in the “Further Information” section below with the word unsubscribe in the subject field of the email. Please note that you cannot opt-out of non-promotional emails, such as those about transactions, servicing, or our ongoing business relations.

V. Children

The Website is intended for general audiences and is not directed at children. We do not knowingly collect personal data (as defined by the U.S. Children’s Privacy Protection Act, or “COPPA”) from children. If you are a parent or guardian and believe we have collected personal data in violation of COPPA, contacts us at info@publicishealthmedia.com. We will remove the personal data in accordance with COPPA. We do not knowingly “sell,” as that term is defined under the CCPA, the personal data of minors under 16 years old who are California residents.

VI. Data Security

We use a variety of methods, such as firewalls, intrusion detection software and manual security procedures, designed to secure your data against loss or damage and to help protect the accuracy and security of information and to prevent unauthorized access or improper use. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about you. If you think that the Website or any personal data is not secure or that there has been unauthorized access to the Website or your personal data, please contact info@publicishealthmedia.com immediately.

VII. Data Transfers

Due to the international nature of our business, your Personal Data may be transferred outside the European Union.

Your Personal Data may be transferred to the US or any country which is not considered to have the same level of data protection as in the EU. However, we ensure all data transfers comply with applicable legal requirements (for example under intercompany agreements with appropriate contractual protections). Should you wish to know more about how your Personal Data is protected or wish to request a copy of the contractual protections please contact privacyofficer@publicisgroupe.com.

VIII. Use of cookies, other tracking technology, social media and social media plug-ins

Cookies are small pieces of text or code sent to your device when you visit the Website. Cookies are used to optimize the viewing experience, count visitors to a webpage, troubleshoot any problems, keep websites secure, and better serve content. The following cookies are used on the Website:

• Functional and required cookies are always used to allow our hosting platform, to securely serve this Website to you.
• Analytics and performance cookies are used on the Website to view site traffic, activity, and other analytics data.

Overall, cookies help us provide you with a better Website, by enabling us to monitor which pages you find useful and which you do not. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the Website.

If you follow us on social media (for example, through our accounts on LinkedIn, Facebook, Twitter or Instagram), we will also collect personal data about you in order to understand our followers better and understand the public response to our products and services. We may use this information to contact you, send you marketing information which we think may be of interest to you, and/or engage in social listening to identify and assess what is being said about us publicly to understand industry trends and market sentiment. Any information you provide to us when you engage with our content (such as through our brand page or via Facebook Messenger) is treated in accordance with this Privacy Notice. Also, if you publicly reference us or our Website on social media (such as by using a hashtag associated with us in a tweet or post), we may use your reference on or in connection with our Website.

We provide social media plug-ins on the Website to allow you to easily share content from our Website through social media, and in doing so, we may receive your personal data from the social media platform that you have authorized to share with us. When you share content using these buttons, a new page will pop up from the relevant social media platform. If you’re already logged into your account on that social media platform, then you will probably be automatically logged into this pop-up page, so that you don’t have to log in again. If, however, you are not logged in (or if you are not registered with the social media platform), the page will ask you for your information.

We have no control over how social media platforms use your personal data and they may independently collect information about you when you leave our Website. The information collected and stored by those parties remains subject to their own policies and practices, including what information they share with us, your rights and choices on their services and devices, and whether they store information in the U.S. or elsewhere. We encourage you to read the privacy notices on the various social media platforms you use.

Find out more about how these social media platforms use your personal data:

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

IX. Notification of changes

Any changes to this Privacy Notice will be promptly communicated on this page and you should check back to see whether there are any changes. Continued use of the Website after a change in the Privacy Notice indicates your acknowledgement and acceptance of the use of Personal Data in accordance with the amended Privacy Notice.

If you wish to save this text, please mark the entire statement (e.g. with your mouse) and copy-paste by pushing ctrl-c.

X. Further Information

This Privacy Notice has been designed to be accessible to people with disabilities. If you experience any difficulties accessing the information here, please contact us at info@publicishealthmedia.com.

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

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

Updated: 6/22/2021