VI. Automated Decision Making and Profiling
To the extent that we use processes that involve automated decision making or profiling when processing your Personal Data, we take steps to ensure that any automated decision making or profiling practices are fair and not discriminatory. Situations where we may use profiling in connection with your Personal Data include personalizing the Website and advertising campaigns to market service(s) that may be of the most importance to you.
VII. How Long We Keep Your Information
- The length of time we have an ongoing relationship with you and provide the Website or our services to you;
- Whether our processing of the Personal Data is consistent with what an average consumer would expect when the Personal Data was collected;
- Whether the Personal Data is processed for any other disclosed purpose(s) compatible with what is reasonably expected by the average consumer;
- Whether the Personal Data is relevant and useful to the provision of our services and our further processing is permitted by law;
- Whether the Personal Data has been de-identified, anonymized, and/or aggregated; and
- Whether there is a legal obligation to which we are subject.
VIII. Your Rights and choices regarding Personal Data
Please access the Publicis Sapient Subject Access Request form if you want to make use of any of your below mentioned legal rights. If you wish to exercise your access rights, the service is provided by our vendor OneTrust as processor on our behalf.
1. Where You Are a Resident of the EU/UK
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:
1.1. Right of access:
You can access all Personal Data we hold about you, know the origin of this Personal Data and obtain a copy in an understandable format.
You may also use your right to access your Personal Data to control the exactness of the data and have them rectified or deleted. You have no justification to provide to exercise your right to access;
1.2. Right to rectification:
In order to avoid that inaccurate or incomplete Personal Data relating to you is processed or shared, you can ask us to rectify them;
1.3. Right to erasure:
You may request the erasure or deletion of the Personal Data we hold on you. This is not an absolute right since we may have to keep your Personal Data for legal or legitimate reasons. You may, for example, exercise your right to deletion in the following cases:
(a) if you have withdrawn your consent to the processing (see below);
(b) if you legitimately objected to the processing of your data (see below);
(c) when data is not or is no longer necessary for the purposes for which it was initially collected or processed;
(d) the data is processed unlawfully (e.g., publishing hacked data);
1.4. Right to object to the processing of your Personal Data:
1.5. Right to restrict processing:
The right to limit the processing completes your other rights. This right means that the data processing relating to you and that we are performing is limited, so that we may keep this data, but we cannot use it or process it in any other manner. This right applies in specific circumstances, i.e.:
(a) if you challenge the exactness of your Personal Data. The processing is then limited for a period of time so that the agency may verify the exactness of the Personal Data;
(b) if the processing is unlawful and you object to the erasure of your Personal Data and request instead that its use be limited;
(c) if we do not need the Personal Data for the purposes mentioned above in Section III anymore, but you still need it to establish, exercise or defend rights before a Court; and
(d) in the cases where you objected to the processing which is based on the legitimate interests of the agency, you may ask to limit the processing for the time necessary for us to verify if we can accept your objection request (i.e., the time necessary to verify whether the legitimate reasons of the agency prevail over yours).
1.6. Right to object to data processing for direct marketing purpose
You may unsubscribe or object, at any time and without any justification, to the reception of direct marketing communications. Simply either (i) click on the link in the footer of the communications you receive from us; or (ii) use the hyperlink above; or (iii) send us an email at the email address set out in the “Further Information” section below with the word unsubscribe in the subject field of the email.
1.7. Right to data portability:
(a) You may request to retrieve the Personal Data you provided us with, in a structured, commonly used, and machine-readable format, for personal use or to share them with a third party of your choice.
1.8. Right to withdraw your consent to the processing of your Personal Data at any time:
(b) 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.
(c) 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.
(d) We will respond without undue delay and in any event within one month from the date we receive your request. This timeframe can be extended by two months to take the complexity of the request, or the number of requests received into account. In this case, we will inform you within one month from receiving your request, specifying the reasons for extending the response timeframe.
2. Where You are a non-EU Resident
You may have privacy rights based on the laws of your jurisdiction of residence, such as the states of California or Virginia or the provinces and country of Canada. 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.)
2.1. Right to request access to Your Personal Data
If the state/province/country in which you reside provides you with the right of access or know the Personal Data which Sapient processes about you, you may request, up to two times per year, access to the categories and specific pieces of Personal Data about you that we collect.
When exercising the right to access Personal Data, you have the right to obtain materials in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.
When we receive and verify your request to access your Personal Data, we will make best efforts to fulfill your request unless an exception applies. We will not disclose your government identification numbers, financial account numbers, health insurance or medical identification numbers, account passwords, security questions and answer, or unique biometric data; however, to the extent we have this information, we will inform you that we have collected this information. You are permitted 2 access reports every 12 months.
2.2. Right to request deletion of Your Personal Data
You may also request that we delete any Personal Data that we obtained about you. However, we may retain Personal Data for certain important purposes, as set out by applicable law.
When we receive and verify your request to delete your Personal Data, we will proceed to delete the data unless an exception applies. We will retain a record of your deletion request in order to keep your Personal Data deleted, unless and until you provide consent for the processing of your Personal Data post your deletion request.
2.3. Right to correct your Personal Data
If you believe we hold inaccurate personal information about you, you may request that we correct that information. We may ask for documentation showing that the information you submit is accurate and the Personal Data we hold is inaccurate. Once we receive your request, we will verify your identity and taking into account the type of personal information and the purposes of our holding that personal information we will make best efforts to complete your request. We may deny your request if we determine that the contested Personal Data is more likely than not accurate. Additionally, we may choose to delete your Personal Data in response to your request to correct your Personal Data if the deletion of your Personal Data would not negatively impact you.
2.4. Right to limit use of Sensitive Personal Data
You may request that we limit the use and disclosure of your Sensitive Personal Data. However, we may deny your request in part of in full under uses authorized by applicable law or if we do not collect your Sensitive Personal Data.
2.5. 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 your privacy rights.
2.6. Right to opt-out of the sale of your Personal Data
2.7. Right to opt-out of share/cross contextual behavioral advertising and targeted advertising
You may opt-out of the processing or sharing of your Personal Data for cross-contextual behavioral advertising or targeted advertising (what we refer to above as Interest-based advertising) by indicating on our Publicis Sapient Subject Access Request form.
Additionally, you may choose not to receive targeted advertising from ad networks, data exchanges, and other digital advertising providers by opting out of targeted advertising via YourAdChoices powered by the Digital Advertising Alliance.
2.8. Right to opt-out of automated decision making and profiling
It’s your right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect. You may opt-out of the processing of your Personal Data for profiling and other automated decision making by submitting your request on our Publicis Sapient Subject Access Request form.
2.9. Universal Opt-Out Mechanisms
Our Website recognizes certain global opt-out of sale and share preference signals like the Global Privacy Control and the IAB CCPA privacy string. This means that if you enact your choice to opt-out or opt-in through these signals, we will honor your choice upon receiving the signal related to your visit on our Website. We will apply your preference to the Personal Data we collected from our Website. If you have previously provided affirmative consent for the sale or share of your Personal Data, and your opt-out choice via the signal conflicts with such consent, we will ignore the opt-out choice via the signal.
2.10. 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.”
2.11. How to Exercise Your Privacy Rights in the U.S.
US residents may exercise their applicable privacy rights by sending an email to email@example.com, submitting your request to our online Publicis Sapient Subject Access Request form, or by contacting us at 1-833-983-0087.
For security purposes (and as required under US state laws), we will verify your identity—in part by requesting certain information from you—when you make a request to access, correct, or delete, your Personal Data. The verification process will utilize an email verification process, a telephone number verification process, and, if applicable, a request for any assigned ID number previously communicated to you.
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 certain US state laws. We will take steps both to verify your identity and to verify that your agent has been authorized to make a request on your behalf by requesting your agent to provide us with a signed written authorization or a copy of a power of attorney executed by you.
It is your right to appeal a decision made concerning the exercise of your data privacy rights. You may appeal this decision within 60 days of receiving your response from us. To submit your appeal, contact firstname.lastname@example.org or visit our Publicis Sapient Subject Access Request form.
2.13. Where you are a Resident of Nevada
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 email@example.com.
3. Where you are a resident of Canada
3.1. Right to request access to your Personal Data
You have a right to access your Personal Data in our control. We will also provide you with a description of what uses we have made of your Personal Data and which third parties we have shared it with. In some cases, we may not be able to provide you with access to your Personal Data, such as where:
- Personal data about another person might be revealed and the other person’s personal information cannot be separated from yours;
- Commercially confidential information might be revealed and the confidential information cannot be separated from yours;
- The requested data is subject to solicitor and client privilege;
- Someone's life or security might be threatened as a result of giving you access and the personal data about the other person cannot be separated from yours;
- The information was collected for purposes related to an investigation of a breach of an agreement or contravention of the law.
We will respond to your request within 30 days, unless we require more time to do so, in which case we will advise you of the date by which we will respond to your request within 30 days of receiving it.
3.2. Right to request correction to your Personal Data
If you note any inaccuracies or wish to update any of your Personal Data, we will make those changes upon your request.
3.3. Right to withdraw your consent
4. Your General Rights Regarding 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.
We may use our own technology or third-party technology to track and analyze usage information to provide enhanced interactions and more relevant communications, and to track the performance of our advertisements.
For example, we use Google Analytics (“Google Analytics”), a web analytics service provided by Google, Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. You can learn about Google’s privacy practices by going to www.google.com/policies/privacy/partners/.
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 on the Publicis Sapient Subject Access Request form 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. 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.
Depending on the choices you made when providing us with your Personal Data and in compliance with applicable data protection laws, we may send you direct marketing communications. 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.
IX. No Data of 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 firstname.lastname@example.org. We will remove the Personal Data we inadvertently collect in accordance with COPPA. We do not knowingly “sell,” as that term is defined under US state privacy laws, like CCPA or VCDPA, the Personal Data of minors under 16 years without legally required affirmative consent.
X. Data Security
We use a variety of methods, such as firewalls, intrusion detection software and manual security procedures for the purpose of securing your data against loss or damage, protecting the accuracy and security of Personal Data, and preventing unauthorized access or improper use. 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 email@example.com immediately.
XI. Data Transfers
Due to the international nature of our business, your Personal Data may be transferred outside of your country of residence.
If you are an EU/UK resident, 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. While in those jurisdictions, your Personal Data may be accessible to regulatory authorities in accordance with the laws of those jurisdictions. However, we ensure all data transfers from the EU comply with applicable legal requirements by executing standard contractual clauses. 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 firstname.lastname@example.org.
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