Privacy Policy

Publicis Canada Inc. (“we,” “us,” or “our”) is a communications agency offering advertising services including creative, strategy, production, data, sponsorship, and CRM. 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.

Please note, this Privacy Notice does not apply to the services provided by us on behalf of clients or to data that the Agency processes on behalf of our clients.

Introduction

Any data collected through this Website, including personal data (as defined under applicable data protection laws, referred to 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 Canada is acting as a data controller.

Please read this Privacy Notice thoroughly. If you disagree with the way personal information will be used, please do not use this Website. For our Canadian users, your use of the Website constitutes your implied consent for us to process your Personal Data for the above-noted purposes.

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.

This Privacy Notice does not cover employee data or data collected during the application process. For more information, please visit Publicis Groupe Staff HR Privacy Notice.

I. What Personal Data and Sensitive Personal Information do we collect and process through the Website?

The following table describes the categories of Personal Data and Sensitive Information we collect.

Category of Personal DataExamplesContact Information and Identifiers
First name, last name, personal e-mail address, telephone number, IP address
Professional or Employment Information (may be B2B Contact Information)
Professional email address, business address, telephone number
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
InferencesInformation drawn from any of the information identified in this section to create an attribute about your preferences, characteristics, or behaviour

II. 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 use of your privacy rights.

• 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 section XIV of this Privacy Notice.

III. 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 DataBasis for processingTo read and respond to your queries to us, sent using our online query formDepending on your request, we will rely on our legitimate interest or the performance of pre-contractual measures to respond to individuals’ queriesWhen you contact us through the data access request formWe rely on our legal obligation to provide you a process to exercise your rightsTo contact you where you have indicated you wish to receive news from usFor visitors from the European Union, we rely on your consent, where you indicate that you want to receive marketing material from usOperating 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

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 researchLegal purposes, such as: (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. Such disclosure may be for a business purpose but may also be considered a “sale” under certain state privacy laws.We rely on our legal obligation or the performance of contract to support such legal purposes.In the event of a 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.Our legitimate interest or performance of contract to support our corporate transactionsWe 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 lawOur legitimate interest to support our internal operationsWe use analytics services, such as Google Analytics, to help us understand how users access and use the Website.Our legitimate interest to support our internal operations

IV. With whom do we disclose Personal Data or Sensitive Personal Data for a Business Purpose?

Category of Personal DataCategories of Parties With Whom We Disclosed Your Data for a Business PurposeBusiness Purpose for the Disclosure Contact Information and IdentifiersAffiliates, Service ProvidersHelping to ensure security and integrity to the extent the use of the consumer's personal information is reasonably necessary and proportionate for these purposes.Professional or Employment Information (may be B2B contact information)Affiliates, Service ProvidersHelping to ensure security and integrity to the extent the use of the consumer's personal information is reasonably necessary and proportionate for these purposes.Your verbatim communications to us or shared on the public areas of our siteAffiliates, Service ProvidersHelping to ensure security and integrity to the extent the use of the consumer's personal information is reasonably necessary and proportionate for these purposes.InferencesService Providers, Analytics ServicesHelping to ensure security and integrity to the extent the use of the consumer's personal information is reasonably necessary and proportionate for these purposes.

V. Automated Decision Making and Profiling

When processing your Personal Data, we do not use processes that involve automated decision making or profiling.

VI. How long do we keep your information?

We keep Personal Data for as long as is necessary for the purposes described in this Privacy Notice, complying with legal and regulatory obligations, protecting our or other’s interests, and as otherwise permitted or required by law. When Personal Data is no longer necessary for or compatible with these purposes, it is removed from our systems in accordance with our internal retention policies. The criteria used to determine our retention periods include:

• 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.

VII. Your rights and choices regarding your Personal Data

Please use this LINK if you want to make use of any of your below mentioned legal rights.

1. Where you are resident of the EU

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. The 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. The right to rectification:

In order to avoid that inaccurate or incomplete Personal Data relating to you is process or shared, you can ask us to rectify them;

1.3. The 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);

(d) the data is processed unlawfully (e.g., publishing hacked data);

1.4. The right to object to the processing of your Personal Data:

We process your Personal Data based on our legitimate interest (to determine to which processing this applies, please refer to Section II of this Privacy Notice), you may at any time object to the processing of your Personal Data for reasons relating to your personal situation. We may nevertheless, on a case-by-case basis, reject such a request by pointing out the legitimate and imperious reasons justifying the processing of this data which prevail on your interests, rights and freedoms, or when this data is necessary to establish, exercise or defend a right before a Court.

1.5. The 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 I 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. The 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.

(b) This right only applies to Personal Data you provided us with, directly or indirectly, and which was processed through automated means, if this processing is based on your consent or the performance of a contract. Please check the list of our Personal Data processing activities’ legal grounds (in Section II of this Privacy Notice) to know whether our processing is based on the performance of a contract or on consent.

1.8. The right to withdraw your consent to the processing of your Personal Data at any time:

(a) You may read Section II of this Privacy Notice in order to identify the purposes for which the processing of your Personal Data is based on your consent.

(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 data 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 US resident

Residents of certain US states, such as California, Virginia, Colorado, Connecticut, and Utah, have specific rights regarding 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.)

2.1. Right to request access to your Personal Data

You may request access to your Personal Data that we collect, use, disclose, or sell. In particular, you may request:

• the specific pieces of Personal Data that we process 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 or shared;

• the categories of third parties to whom the Personal Data was disclosed for a business purpose or sold or shared; and

• the business or commercial purpose for processing the Personal Data.

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

We do not collect 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.

We do not sell any Personal Data as the term ‘sell’ is used in US state privacy laws like the California Consumer Privacy Act and the Virginia Consumer Data Protection Act.

2.7. Right to Opt-Out of Share/Cross Contextual Behavioral Advertising and Targeted Advertising

We do not process or share your Personal Data for cross-contextual behavioral advertising or targeted advertising.

2.8. Right to opt-out of Automated Decision Making and Profiling

We do not utilize automated decision-making and profiling processes.

2.9. 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.”

2.10. How to exercise your US state privacy rights

US residents may exercise their applicable privacy rights by sending an email to privacyofficer@publicisgroupe.com, submitting your request to our online web 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.

2.11. Appeal

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 privacyofficer@publicisgroupe.com or visit our portal.

2.12. 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 at privacyofficer@publicisgroupe.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

At any time, you may withdraw your consent for us to process your Personal Data for the purposes described at Section II of this Privacy Notice. However, this may affect our ability to offer you some of the services. For example, we may not be able to respond to your queries.

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 https://www.allaboutdnt.com.

4.2. Analytics:

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/.

Google Analytics uses cookies to help us analyze how our websites are used, including the number of visitors, the websites from which visitors have navigated to our websites, and the pages on our websites to which visitors navigate. This information is used by us to improve our websites. We use Google Analytics with restrictions on how Google can process our data enabled. For information on Google’s Restricted Data Processing go to https://privacy.google.com/businesses/rdp/.

4.3. 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.

VIII. 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, contact us at 1. We will remove the Personal Data in accordance with COPPA. We do not knowingly “sell,” as that term is defined under the US state privacy laws, like CCPA or VCDPA, the Personal Data of minors under 16 years old without legally required affirmative authorization.

IX. 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 privacyofficer@publicisgroupe.com immediately.

X. Data Transfers

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

If you are an EU 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 privacyofficer@publicisgroupe.com.

XI. 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:

•Strictly Necessary

These cookies are necessary for the website to function and cannot be switched off in our systems. Some of these cookies are only set in response to requests made by you, such as setting your preferences, logging in or filling out forms. They may also be set for certain security purposes and network management. You can manage these types of cookies using your browser settings, but it may affect your ability to use our website.

•Functional

These cookies enable the website to provide enhanced functionality and improve your experience. They may be set by us or by third party providers whose services have been added to our website. If you do not allow these cookies, you may not receive the best experience when visiting our website and parts of our website may not function properly.

•Performance

These cookies allow us to engage in certain activities, such as counting visits and identifying traffic sources that assist us in measuring the performance of our website. They help us to know which pages are the most and least popular and see how visitors move around the website. If you do not allow these cookies we will not know when you have visited our website and will not be able to monitor our website’s performance.

•Targeting

These cookies are used to collect information about your browser, device and website visit and use such formation to provide you with personalised experiences and advertising on this website and others across the internet. If these cookies are disabled, your data will not be shared with third parties for this purpose.

If you are located in the United States, local law may provide you with the right to opt-out of the sale or sharing of your personal information to third parties. You may exercise your right to opt out of this activity by disabling targeting cookies using this toggle switch. Additionally, you may find further information about exercising your consumer rights under local law by visiting our privacy notice.

XII. Use of social media and social media plug-ins

Publicis Canada has a fan page or a company page on YouTube, Facebook, Twitter, Instagram and LinkedIn that you can use or visit. Publicis Canada acts as a joint data controller with the social media platform for the collection of your personal data when you visit our company page on the social media platform. We will 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 social media followers, to send marketing information, to engage in social listening, and agency information-sharing. 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.

You can read more regarding our joint controllership with the platforms at the following links:

YouTube: https://business.safety.google/controllerterms/

LinkedIn: https://legal.linkedin.com/pages-joint-controller-addendum

Facebook: https://www.facebook.com/legal/controller_addendum

Twitter: https://gdpr.twitter.com/en/controller-to-controller-transfers.html

Instagram: https://www.facebook.com/legal/controller_addendum

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. Publicis Canada is joint data controllers with the social media platforms for the collection of your personal data that is collected by the platforms when you visit our website.

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

• X (formally Twitter)

• YouTube (Google’s general privacy policy)

• Instagram

• LinkedIn

XIII. Financial Incentive

We do not offer any financial incentives related to our collection of your Personal Data.

XIV. 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.

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XV. 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 privacyofficer@publicisgroupe.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 privacyofficer@publicisgroupe.com. Data subjects in Europe may also lodge a formal complaint with their competent data protection authority.

If you have any questions about our 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 at privacyofficer@publicisgroupe.com.