California Consumer Privacy Statement
Effective: December 1, 2022
This California Consumer Privacy Statement supplements the TBWA Privacy Policy and applies solely to California consumers. This section provides information about our online and offline privacy practices. This Statement does not apply to TBWA 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:
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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; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, account name, Social Security number, driver’s license number, passport number, and other similar identifiers
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Additional Data Subject to Cal. Civ. Code § 1798.80: signature, physical characteristics or description, state identification card number, insurance policy number, education, bank account number, credit card number, debit card number, and other financial information, medical information, and health insurance information
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Protected Classifications: characteristics of protected classifications under California or federal law, such as race, color, national origin, religion, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, medical condition, ancestry, genetic information, disability, citizenship status, and military and veteran status
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Commercial Information: commercial information, including records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies
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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
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Sensory Information: audio, electronic, visual, and similar information
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Employment Information: professional or employment-related information
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Education Information: education information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99)
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Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
We may use the categories of personal information listed above for the purposes described in our Privacy Policy. In addition, we may use these categories of personal information for certain business purposes specified in the CCPA, as described in this table:
In addition, we may also use the following categories of personal information for purposes of managing our career opportunities: Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Employment Information; Education 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, and (b) the categories of third parties with whom we may have shared the information, and (c) 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.
b.Sharing of Personal Information
We may have shared your personal information with certain categories of third parties, as described below.
c.Sale of Personal Information
We do not and will not sell your personal information.
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:
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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; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, account name, Social Security number, driver’s license number, passport number, and other similar identifiers
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Signature, physical characteristics or description, state identification card number, insurance policy number, education, bank account number, credit card number, debit card number, and other financial information, medical information, and health insurance information
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Characteristics of protected classifications under California or federal law, such as race, color, national origin, religion, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, medical condition, ancestry, genetic information, disability, citizenship status, and military and veteran status
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Commercial information, including records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies
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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
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Professional or employment-related information
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Education information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99)
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Inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
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, and disclosed 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: We do not sell your personal information in exchange for monetary compensation, nor have we done so in the preceding 12 months.
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 any of the following information: name, address, state-issued photo identification. In addition, if you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. If you designate an authorized agent to make an access, deletion or opt-out of sale request on your behalf (1) we may require you to provide the authorized agent written permission to do so, and (2) for access and deletion requests, we may require you to verify your own identity directly with us (as described above).
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.
CCPA Contact Information: Please contact privacy@tbwa.com or (833) 520-0506, Monday to Friday, 9 am – 5 pm EST, to request this Statement in an alternative format.
