Data Protection Policy
Section 1: HAVAS MEDIA COMMITS TO THE PROTECTION OF YOUR PERSONAL DATA
Havas Media (“we”, “our”, “Artemis Alliance”) is committed to protect your personal data and your privacy. We encourage you to carefully read this Data Protection Policy (“Policy”), which informs you of our data protection and privacy practices and the way your personal data are processed by Havas Media when acting as a data controller regarding our products and services considering the General Data Protection Regulation requirements. This Policy is available at all times at: https://havasmediagroup.com/data-protection-policy/.
Havas Media strongly supports the fundamental rights to privacy and data protection as well as compliance with national and international privacy laws. Havas commits to maintain confidential any personal data and to strictly limit any disclosure in accordance with applicable local laws and regulations.
Havas Media is member of the Interactive Advertising Bureau (IAB Europe). We are also a registered vendor under IAB’s Transparency and Consent Framework (TCF 2.0), a framework built to provide additional transparency and choice for the data subjects with regards to their personal data processed online, with ID 1031.
This Policy is only applicable to the processing activities carried out by Havas Media entities indicated in Schedule I as independent data controllers for the collection, processing, use, transmission, transfer and storage of personal data unless a national legislation imposes to some of them specific data protection rules. Havas has developed an internal platform and connected systems for the processing activities included in point 3 in this Policy for which Havas Media acts as data controller. The Havas Media entity processing your personal data will depend on the country you are located in – please consult Schedule I to understand which Havas Media Entity is the data controller of your personal data, and what are the means of contacting and exercising your rights recognised by applicable data protection laws.
This Policy shall apply following the General Data Protection Regulation territorial scope principle.
Section 2: HOW DO WE PROCESS YOUR PERSONAL DATA?
Havas Media respects the rights of each individual to have his or her privacy and personal data protected, following at all times the principles below when processing your personal data:
Processing your personal data fairly, lawfully and in a transparent manner;
Collecting your personal data for specified, legitimate purposes and not processing further in ways incompatible with those purposes;
Collecting your personal data which is relevant to and not excessive for the purposes for which it is collected and used. We may render personal data anonymous when feasible and appropriate, depending on the nature of the data and the risks associated with the intended uses;
Maintaining your personal data accurate, and where necessary, kept up-to-date. We will take reasonable steps to rectify or delete data that is inaccurate or incomplete;
Keeping your personal data only as long as it is necessary for the purposes for which it was collected and processed;
Processing your personal data in accordance with the individual’s legal rights;
Taking appropriate technical and organizational security measures to keep your data safe and prevent unauthorized access, unlawful processing, and unauthorized or accidental loss, destruction, or damage to personal data;
Processing your personal data only if it is lawful in accordance with a legal basis, including if you have unambiguously given your consent to such process.
Section 3: WHAT PURPOSES WILL WE PROCESS YOUR PERSONAL DATA FOR?
Havas Media will collect or may have access to your personal data to complete following operations. These purposes include the processing of personal data and the processing activities related to aggregated or anonymized information, such as analytical information, campaign impacts, aggregated audiences… :
Generation of insights and aggregated reports: On the basis of your personal data, we may extract some aggregated patterns. For example, that the age group between 25 and 35 years old is more likely to be interested in technology and travel.
Matching and combination of personal data: For the generation of insights, we may match the data collected from you on a website with data that a particular brand or make (our advertising client) holds about you as their customer.
Creation of user profile on the basis of its preferences and behaviour: We can create your profile on the basis of the data received and our insights as we understand it, taking into account your online behaviour: websites visited, articles of interest or products acquired.
Elaboration of audiences and segments including user profile: We can build an audience with similar interests to be able to impact it with products and services of our advertising clients.
Targeted advertising on the basis of user profile: We can show you specific, tailored ads of products and services we whing you may be interested in, bearing in mind your user profile and preferences.
Measurement of ad performance: We can access statistical information concerning ad performance, such as number of clicks or location thereof on a country level.
Addressing of data subject rights. Lastly, we shall use your personal data to honour your data subject rights requests, such as access, rectification or erasure rights, recognized by applicable data protection regulation.
Section 4: WHAT DATA IS COLLECTED?
Havas Media will only collect and process your personal data pursuant to prior appropriate notice and your validly-given consent, when it is required. Your consent -and, therefore, choice regarding the collection and usage of your personal data by Havas Media – shall always be freely given, specific, and informed by a positive act; you will be able to withdraw it at any time by means established in Section 9 of this Policy.
In a general way, Personal data means any information relating to an identified or identifiable natural person (‘Data subject’). An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
The types of personal data we collect from you may include:
Personal characteristics data and demographic information: marital status, gender, age range, nationality, income, language etc.
Behaviour data: data about user interests (app usage etc.); purchase data; lifestyle, memberships, licenses, authorisations.
Navigation behaviour: browsing history, user journey on the site; search queries; session time; site behaviour (contextual and thematic preferences to certain topics and pages, interactions such as downloads, transitions to other pages through clicking on advertisements and links); events (scrolling, clicking, highlights, media views).
Online and advertising identifiers: IP address; cookie ID, pixel, and all types of online identifiers enabling the use of Data Subjects´ data, internet browser o device type for the purpose of targeting advertising, audience segmentation, analytics or and similar purposes.
Technical information: user-agent string identifying the browser and device type; user’s location; user’s time zone; detected language of the user’s system; device type (desktop/mobile, brand, model, operating system).
Section 5: WHAT WE DO WITH YOUR PERSONAL DATA?
Regarding the platform and connected systems used by Havas Media as data controller, we will:
not sell or rent it to a third party without your permission;
implement appropriate technical and organisational measures to protect your personal data from loss, misuse and unauthorized access, disclosure, alteration and destruction;
not process the personal data except:
on the basis of your consent;
in an aggregated or otherwise anonymised format;
as required by law, for example, in response to a subpoena or search warrant;
to outside auditors who have agreed to keep the data confidential;
as necessary to protect the rights, safety or property of Havas Media, its users, or others. This may include (for example) exchanging information with outside auditors who are subject to duty of confidentiality, other organizations or public authorities for identification, fraud protection and/or risk reduction.
Havas Media makes reasonable commercial efforts to process only personal data belonging to individuals following the minimum age principles in the GDPR and specific local regulations.
Section 6: LAWFUL BASIS FOR THE PROCESSING OF YOUR PERSONAL DATA
For the purposes and the data indicated under sections 3 and 4 respectively, Havas Media relies on your informed consent for the processing of your personal data, which can be withdrawn at any time by means established in section 9 of this Policy. Therefore, the data shall be processed as long as you keep consenting to the processing activity.
If you provide us with personal data about another person, you confirm that they have appointed you to act for them, to consent to the processing of their personal data and that you have informed them of our identity and the purposes (as set out in this Policy) for which their personal data will be processed.
Section 7: THIRD PARTIES AND PROVIDERS
Havas Media uses external providers which could access to the information included in this policy. These third parties provide services such as hosting, technical connections in our applications or help us to process your personal data regarding the purposes declared in this policy. Havas Media has signed agreements with such providers in accordance with GDPR requirements (for example, article 28 requirements) and verify their security measures.
Section 8: INTERNATIONAL TRANSFERS
As a general rule, Havas Media does no transfer data outside of the European Economic Area. In this sense, Havas Media, contractually and making reasonable commercial efforts, verifies that the processing is performed inside of the European Economic Area.
In the scenario where an international data transfer is required to be made to a third party located in a country which does not offer the same guarantees that are required in the GDPR, this transfer will be covered under proper legal mechanism such as Standard Contractual Clauses or Binding Corporate Rules. In this scenario, Havas Media will require such provider the implementation of additional measures to protect the processing activities performed.
Section 9: YOUR DATA PROTECTION RIGHTS
Right of access: As data subject, you may inquire as to the nature of the personal data Havas Media owns about you. You will be provided access to your personal data regardless of the location of the data processing and storage.
Right to rectification: If your personal data is inaccurate or incomplete, you may request that the data be amended.
Right to object: You have the right to object at any time to the processing of your personal data by Havas Media, in case we process your data on the basis of our or third-party legitimate interests, or where the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority.
Right to erasure: You can ask for the deletion of your personal data when it is allowed by applicable data protection laws and regulations.
Right to restriction of processing: You have the right to require a restriction of the processing of your personal data when it is authorized by applicable data protection laws and regulations
Right to data portability: If you meet the conditions settled by the applicable data protection laws and regulation, you have the right to receive a subset of your personal data and to transmit them from Havas to another data controller. You can also require the direct transmission from Havas Media to another controller when it is technically feasible.
Right to lodge a complaint: You have the right to lodge complaint with the competent supervisory authority.
All requests for aforementioned rights, and any questions regarding this Data Protection Policy, may be sent to the general Data Protection Officer address:
Havas Media
29/30, Quai de Dion Bouton,
Puteaux Cedex
92800 France
Additionally, those requests may be addressed to the contact person of the local Havas Media controllers listed in Schedule I.
You can withdraw the consent granted through the cookie configurator or CMP at any moment accessing the vendor or partner list and changing the status of your consent given to Havas Media. Also, you can access https://www.youronlinechoices.eu/ to modify your preferences.
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Section 10: CHANGE IN THIS DATA PROTECTION POLICY
Havas Media reserves the right to modify this privacy policy as needed, for example, to comply with changes in laws, regulations, Havas Media practices and procedures, or requirements imposed by data protection authorities. In this case, Havas Media will inform data subjects of any material changes in this policy. Havas Media will post all changes on relevant Havas Media websites.
SCHEDULE I
Company details of Havas local entity:
Havas Media Ltd
The HKX Building
3 Pancras Square
LONDON, N1C 4AG