[m]PLATFORM Privacy Notice - EU

Cookie	is a small alphanumeric text file that is stored in a browser by a web site or by a third-party ad server or other third party which allows that web site or third party to recognize that browser and remember User Information and other information. Our targeting cookies, which are named “Mookie” and operate on the mookie1.com domain, are persistent cookies that contain unique randomly-generated values that enable our Services to distinguish browsers and devices and are associated with User Information and other information. Mookie cookies, together with this associated information, are used in the performance of our Services, and in particular Interest-Based Advertising activities. More information about our Mookie cookies is set forth in the table immediately below this explanation of terms.
Advertising ID	is an alphanumeric identifier made available by a platform or operating system (such as Apple iOS or Google Android) that allows application developers and third parties to recognize a particular device in an application environment. It is associated with User Information and other information and, together with this associated information, is used in the performance of our Services, and in particular Interest-Based Advertising activities.
Pixel	is a line of code that is used by a Site or third party to assign online activities to a device or browser, or more specifically to the applicable cookie or advertising ID. The use of a pixel allows us to record, for example, that a device or browser has visited a particular Site or page.

[m]PLATFORM processes the information it collects and receives for the purposes of providing the Services to clients which we have explained above, as well as for administrative, security and compliance purposes. Specifically, we carry out the following activities:

How do we use this information?

Ad Selection, Delivery, Reporting

We analyze the information collected when client advertising is delivered through [m]PLATFORM and information received from our partners. We organize this information into collections of IDs (which we call segments), based on various components of the User Information we explained above.  For example, we may have segments of IDs that visit sport websites. GroupM agencies then use these segments within our platform to deliver Interest-Based Advertising for their clients, using our partners and service providers. This advertising may be delivered across computers, phones, and other mobile devices.

We may also integrate (and use for the same purposes) User Information obtained from other carefully selected companies (including Site owners, data providers and data aggregators).

We also maintain our own internal identifier, which we call “[mP]ID”. We use the [mP]ID to associate information relating to browsers, environments, and/or devices that we reasonably believe belong to the same user. This helps us to provide more useful and relevant advertising to a specific user, regardless of the browser, device, or environment.

Personalization

In order to provide our client-specific personalization Services, we:

• collect information on each client’s Sites (this includes websites, apps, and other digital properties) – as described above in “How we collect information”;
• access or store this information on devices (via cookie IDs and advertising IDs, as applicable); and
• analyze the information collected, sometimes with other information received from the client and organize it into segments of IDs, based on the various User Information we have

Our clients can then use these segments to deliver, on their own behalf or on behalf of their clients, Interest-Based Advertising to users on their computers, phones, and other mobile devices (this is through a variety of means).

Where we are providing this client-specific personalization, the segments that we build for one client are logically segregated from the segments and data of other clients. Data collected in this way, and the segments produced, can only be used on behalf of that specific client.

Measurement

We process User Information to deliver advertisements and measure the delivery of these advertisements, to learn about what factors make advertising successful or unsuccessful for advertisers and generate reports to understand and improve Service usage and advertising effectiveness.

Storage and Access of Information

In order to provide our Services, we store our Mookie cookies on the browser(s) of individuals to whom we have delivered advertising and then recognize the Mookie cookies, when your browser is used to access websites of our clients and publishers we work with.  Sites on which we are dropping and/or reading, or seek to drop and/or read, Mookie cookies should tell you about the use of third-party cookies, and in particular Mookie cookies where required by law, on those Sites. In the data feed we receive from our partners in connection with the delivery of digital advertising in mobile application environments we also receive Advertising IDs associated with users’ mobile device platforms/operating systems and recognize these Advertising IDs.

We use the information collected and received for Interest-Based Advertising, such as:

• Matching Data to Offline Sources – as indicated above under “User Information received from third parties”:
  • We receive offline User Information, including demographic and interest information, from other companies, including our clients, partners and service providers, that is collected outside the Platform and is provided to us for use in our Services.  It is the responsibility of those companies collecting that data to do so in an appropriate and legal way, and to permit sharing that information with us for our purposes.
  • When we receive offline User Information, this information may be provided to us via a service provider in conjunction with a cookie ID, advertising ID, or similar user ID that identifies a customer or consumer to the client or service provider.
  • In addition, we may receive names, mailing addresses, phone numbers, email addresses or similar data connected with the IDs we receive.
• Linking Devices – we make use of our own [mP]ID identifier to associate information relating to browsers, environments, and/or devices that we reasonably believe belong to the same user, in order to help provide more useful and relevant advertising regardless of browser, environment, or device.
• Precise Geographic Location Data – when we have the necessary rights to do so we may receive and/or use a user’s precise geographic location data in connection with our Services.  Where we collect this type of data it is provided in the data feed we receive from our partners in connection with the delivery of digital advertising.

Whom do we share data with?

[m]PLATFORM shares data with GroupM agencies and Choreograph and their clients for purposes of delivering Interest-Based Advertising, analytics, and the other Services described above. We also share data with third-party service providers that perform services and functions on our behalf and/or on behalf of our clients, in the provision of the Services such as companies that are responsible for the actual delivery of Interest-Based Advertising – including demand-side platforms, advertising networks, advertising exchanges, and ad servers.

If we reasonably believe we are obliged by law or legal process to disclose information to a third party (including law enforcement), then we will do so. In addition, we may disclose information to a third party (including an auditor or other service provider) in order to investigate, prevent, or take action regarding suspected or actual prohibited activities and/or in order to review, evaluate, or address the integrity or security of our Platform and Services.

Memberships

We are a member of the Digital Advertising Alliance (DAA), the European Interactive Digital Advertising Alliance (EDAA), and the Digital Advertising Alliance of Canada (DAAC). In connection with these memberships, we adhere to the DAA’s self-regulatory framework, the IAB Europe EU Framework for Online Behavioural Advertising, and the DAAC’s Canadian Self-Regulatory Principles for Online Behavioural Advertising, respectively, in those markets where the applicable self-regulatory framework applies, and we support deployment of the Advertising Option icons (AdChoices and, where available, AppChoices). Advertisements that are provided by organizations that participate in these frameworks display the icon shown below when technologically feasible. Clicking on the icon provides you with information about Interest-Based Advertising.

When the IAB Europe’s Transparency & Consent Framework is finalized, we plan to participate in the framework as a “global vendor” (ID number 98).

Opt-out/Right to withdraw consent

You may opt out of [m]PLATFORM Interest-Based Advertising through several mechanisms.

You may choose not to receive customized third-party advertisements via [m]PLATFORM targeting cookies on the browser you are using by clicking below. If you do this the [m]PLATFORM targeting cookies will be replaced with an “opt-out” cookie. Any Interest-Based Advertising data linked to the replaced [m]PLATFORM targeting cookies will not be used for Interest-Based Advertising on any device or browser that we have reasonably linked to the browser where the information was collected. In addition, if we have actual knowledge that another device or browser is linked to your opted-out browser, that other device or browser will also be opted out from receiving Interest-Based Advertising via [m]PLATFORM.

To opt out of data collection via cookies from [m]PLATFORM please click here.

Our opt-out cookies are programmed to expire ten years after they are initially issued. If you buy a new device, upgrade or change web browsers or delete this opt-out cookie, you will need to perform the opt-out process again. In order for the opt-out process to work, your browser must be set to accept third-party cookies.

In browser environments, you may also refuse or remove cookies from both [m]PLATFORM and other service providers, via the following methods:

• Adjusting your browser settings to refuse or remove cookies, which would result in the cessation of Interest-Based Advertising via cookies from [m]PLATFORM and from other providers. However, by doing so, you may not be able to use certain features on certain web sites or take full advantage of all web site offerings and Interest-Based Advertising. You may refuse or remove cookies by following the directions provided in your browser settings. Further information about cookies is available at www.aboutcookies.org, www.youronlinechoices.com, and www.aboutads.info/consumers#cookies.

• Adjusting the cookie settings at the level of the web site owner where you granted us consent to our cookie usage; cookie settings options may vary by web site owner.

• Opting out of Interest-Based Advertising via our targeting cookies, as well as the targeting cookies of other service providers, at the following web sites:

• www.aboutads.info/choices/
• www.youradchoices.ca/choices/
• www.youronlinechoices.com (by clicking the “Your ad choices” link after selecting the appropriate country)

In mobile app environments, you may opt out of Interest-Based Advertising from just [m]PLATFORMor from both [m]PLATFORM and other service providers, via the following methods:

• Going to the privacy setting on your device and selecting “Limit Ad Tracking” via your device settings, which will result in the elimination of Interest-Based Advertising via the applicable advertising ID from [m]PLATFORM and from other providers.
• Opting out of Interest-Based Advertising via the applicable advertising ID from [m]PLATFORM and/or other providers via the AppChoices app. Please note that, in order for the AppChoices app to function properly, the “Limit Ad Tracking” device setting must not be selected. Interest-Based Advertising data previously collected or received in association with the replaced advertising ID will not be used via [m]PLATFORM for Interest-Based Advertising on any other device or browser that we have reasonably linked to the mobile app environment where the information was collected. In addition, if we have actual knowledge that another device or browser is linked to the opted-out mobile app environment, that other device or browser will also be opted out from receiving Interest-Based Advertising via [m]PLATFORM. Additional information regarding the AppChoices app is available at http://www.aboutads.info/consumers and http://www.youradchoices.ca/choices/.

Children’s privacy

[m]PLATFORM’s Services are not directed at children (as defined by applicable law) or at Sites primarily directed to children. [m]PLATFORM does not knowingly collect information from children (determined in accordance with the age requirement for the applicable country). If you believe a child has provided us with personal data and would like to have the information removed, please contact us

Transfer of data in the event of acquisition

In the event that another company acquires all or substantially all of our assets, or all or substantially all of the assets of our Platform business, through a consolidation, merger, asset purchase, corporate reorganization, or other transaction, we reserve the right to transfer all information or all Platform information, as applicable, that is in our possession or under our control to the acquiring party.

Information security and global data transfers

We follow generally accepted online advertising industry standards to protect against unauthorized access to, unlawful processing of, unauthorized retention of, and unauthorized disclosure of data. These standards include undertaking necessary physical, electronic, and management activities required to protect data integrity, access, and use. Please keep in mind, however, that despite these efforts to protect data on our servers, no method of transmission over the Internet is guaranteed to be secure.

[m]PLATFORM Services and the Platform are used globally and therefore we may transfer data to countries around the world, including countries outside your country. We will, where necessary, put in place appropriate safeguards to ensure such data is protected. When we transfer personal data from the EEA or Switzerland or the UK either to an affiliate or an unaffiliated entity (e.g. a service provider performing services on our behalf) outside the EEA or Switzerland or the UK, we enter into standard (“model”) contractual clauses with the recipient in order to ensure an appropriate level of data protection.

 

Data retention

We maintain the information we collect through our Services in non-aggregated form for a period of not more than 13 months. This data includes Sites visited, content viewed, ad interactions, IP addresses, browser type and language settings.  We maintain this information for the 13-month period to enable our clients to perform year-over-year analyses. For example, a retailer may wish to compare the effectiveness of its online advertising activities at Christmas for the current year vs. the effectiveness in the prior year. A 13-month retention period enables that client to perform such a comparison.

We maintain information we collect through our Services in an aggregated form for a period longer than 13 months.

EEA and Switzerland

Legal bases for processing information

We collect, use, share, and/or transfer personal data of individuals in the EEA only when we have a lawful basis for doing so, which typically entails user consent or our legitimate interests.

Where required by applicable law we only drop our Mookie cookies in the browsers of individuals who have provided consent for such cookies and we only deliver Interest-Based Advertising to individuals who have provided consent for that activity.

To the extent we rely on your consent, which may be provided either directly to us or via a third party (such as a “consent management provider”) to use your information in certain ways, we will process your personal data within the scope of that consent.

Under the IAB Europe’s Transparency & Consent Framework mentioned above under “Memberships”, in our capacity as a data controller we intend to rely on consent as a lawful basis for all “Purposes” other than “Measurement” (which Purpose includes measurement, analysis, and reporting with respect to the applicable personal data).  In connection with such Purpose, when we process data for measuring the delivery of advertising or analyzing its effectiveness we have a legitimate interest in understanding that our suppliers have delivered the advertising that they have contracted to deliver. In addition, we believe that advertising clients have a legitimate interest in understanding whether or not their advertising is delivered and whether it is effective. We believe these activities are fundamental to online advertising but do not result in any decisions which affect individuals.

If you are in the European Union, you have the right to object to any of this processing. If you want to object, please click here.

Rights of People in the EEA and Switzerland

Individuals in the EEA and Switzerland have a number of rights with regard to their personal data, including the right to access their information. For these users, in many cases where we process your personal data, you may also have a right to restrict or limit the ways in which we use that personal data.

In certain circumstances – for example, where we process your personal data for directing marketing purposes or pursuant to our legitimate interests – you also have the right to object to the processing of your https://cpp.choreograph.com/personal data by us , and you can also request that we delete your personal data.  You also have a right to obtain a copy of your personal data in an easily accessible format, and in certain circumstances, you may also request us to transfer personal data about you to third parties .  We don’t retain and store your actual browsing activity history in association with a Mookie cookie ID, a mobile advertising ID, or an [mP]ID. Instead, we use an “aggregate scoring” methodology that categorizes the Sites you browse and then use combinations of these categorizations to create segments and deliver Interest-Based Advertising.  As a consequence, we are unable technically to offer the ability for you to change individual elements of data that lead to the segment allocation simply because we do not retain them.  If you believe that we hold or have used inaccurate personal data elements about you please note that you have the right to withdraw your consent to our processing of your personal data at any time .

If you have questions about any of these rights, please contact us at [email protected]. You should also contact us at that email alias if your personal data or preferences change, if you don’t want us to send you the information you previously requested, or if you have any queries about how we use your personal data.

Without limiting any other rights you may have, you also have the right to lodge a complaint against us with a supervisory authority in the EU Member State where you are based or in which we are based.  Click here to find your local supervisory authority.

Information received from market research companies in the Netherlands

If you have provided consent to market research companies in the Netherlands to disclose your panel data to [m]PLATFORM, then, based on the scope of such consent: we may receive User Information and other information, including panel IDs, from such companies; and we may use this information only for purposes of research and analysis, campaign optimization, advertising customization, and reporting on the effectiveness of online advertising campaigns.

Changes to this Privacy Notice

Please note that because of the changing nature of privacy laws and regulations, digital technologies, and our business, we may modify this Privacy Notice from time to time. Please review this Privacy Notice periodically to become aware of any changes that may have occurred (we will update the effective date at the top of the page to help you know when changes have been made).

About Us

Other than when acting at the direction of a client or other third party, [m]PLATFORM is a data controller responsible for your personal data (as this term or similar term is defined by applicable law) when you interact with our Services.

Contact Us

Europe (Choreograph Limited)

• By email to [email protected]
• By post to Choreograph Limited, c/o GroupM, Sea Containers, 18 Upper Ground, London, United Kingdom, SE1 9GL Attn: Privacy

 Worldwide (Choreograph LLC)

• By email to [email protected]
• By post to Choreograph , 175 Greenwich Street, 3 WTC, New York, NY 10007, USA, Attn: Privacy