California Consumer Privacy Statement

Effective: January 2020

This California Consumer Privacy Statement supplements the Omnicom Media Group Holdings Inc. (“OMG”) Online Privacy Notice and applies solely to California consumers. This section provides information about our online and offline privacy practices. This Statement does not apply to Omnicom personnel.

This California Consumer Privacy Statement uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 and its implementing regulations (the “CCPA”).

1. Notice of Collection and Use of Personal Information

We may collect the following categories of personal information about you:

  • Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, account name, and other similar identifiers
  • Protected Classifications: characteristics of protected classifications under California or federal law, such as race, color, national origin, age, sex, gender, marital status, and military and veteran status
  • Commercial Information: commercial information, including records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies
  • Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements
  • Geolocation Data
  • Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, predispositions, behavior, and attitudes.

We may use the categories of personal information listed above for the purposes described in our Online Privacy Notice. In addition, we may use these categories of personal information for certain business purposes specified in the CCPA, as described in this table:

We may use the categories of personal information listed above for the purposes described in our Online Privacy Notice [insert jump link]. In addition, we may use these categories of personal information for certain business purposes specified in the CCPA, as described in this table:

Purposes Categories of Personal Information
Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services Identifiers; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; and Inferences
Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance Identifiers; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; and Inferences
Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity Identifiers; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; and Inferences
Debugging to identify and repair errors that impair existing intended functionality Identifiers; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; and Inferences
Undertaking internal research for technological development and demonstration Identifiers; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; and Inferences
Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us Identifiers; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; and Inferences

2. Our Prior Collection, Use and Disclosure of Personal Information

We may have collected and used your personal information, as described in section 1 above, during the 12-month period prior to the effective date of this California Consumer Privacy Statement. For the personal information collected during that timeframe, we describe below: (a) the categories of sources from which we may have obtained the personal information, (b) the categories of third parties with whom we may have shared the information, (c) the categories of personal information we may have sold, and (d) the categories of personal information we may have disclosed for a business purpose.

a. Sources of Personal Information

We may have obtained personal information about you from various sources, as described below.

Categories of Sources of Data Collection Categories of Personal Information
Directly from you, such as when you contact us Identifiers; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; and Inferences
From your devices, such as when you visit our Site Identifiers; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; and Inferences
Our affiliates and subsidiaries Identifiers; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; and Inferences
Vendors who provide services on our behalf Identifiers; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; and Inferences
Social networks Identifiers; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; and Inferences
Online advertising companies Identifiers; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; and Inferences
Government entities Identifiers; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; and Inferences
Consumer data resellers Identifiers; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; and Inferences

b. Sharing of Personal Information

We may have shared your personal information with certain categories of third parties, as described below.

Categories of Third Parties Categories of Personal Information
Our affiliates and subsidiaries Identifiers; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; and Inferences
Vendors who provide services on our behalf Identifiers; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; and Inferences
Professional services organizations, such as auditors and law firms Identifiers; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; and Inferences
Our joint marketing partners Identifiers; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; and Inferences
Our business partners Identifiers; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; and Inferences
Advertising networks Identifiers; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; and Inferences
Internet service providers Identifiers; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; and Inferences
Data analytics providers Identifiers; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; and Inferences
Government entities Identifiers; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; and Inferences
Operating systems and platforms Identifiers; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; and Inferences
Social networks Identifiers; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; and Inferences
Consumer data resellers Identifiers; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; and Inferences

c. Sale of Personal Information

During the 12-month period prior to the effective date of this California Consumer Privacy Statement, we may have sold the following categories of personal information:

  • Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, account name, and other similar identifiers.
  • Commercial information: such as records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies.
  • Geolocation Data
  • Internet and other electronic network activity information: including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements
  • Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, predispositions, behavior, and attitudes.

We do not knowingly sell the personal information of minors under 16 years of age.

d. Disclosure of Personal Information for a Business Purpose

We may have disclosed to third parties the following categories of personal information for a business purpose:

  • Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, account name, and other similar identifiers.
  • Commercial information: such as records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies
  • Geolocation Data
  • Internet and other electronic network activity information: including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements
  • Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, predispositions, behavior, and attitudes.

3. California Consumer Privacy Rights

You have certain choices regarding our use and disclosure of your personal information, as described below:

  • Access: You may have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed and sold about you during the past 12 months.
  • Deletion: You have the right to request that we delete certain personal information we have collected from you.
  • Opt-Out of Sale: You have the right to opt-out of the sale of your personal information.
  • How to Submit a Request: To submit an access or deletion request, click here or call us at 1-800-306-7508. To opt-out of the sale of your personal information, click here or contact our Privacy Officer.
  • Verifying Requests: To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request If you request access to or deletion of your personal information, we may require you to provide additional information so that we can verify your request based on the information we maintain.
  • Additional Information: If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request. This Statement is available in alternative formats upon request. Please contact our Privacy Officer or 1-800-306-7508 to request this Statement in an alternative format.
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