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:

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:

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; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Employment Information; Education Information 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; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Employment Information; Education Information and Inferences
Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction
Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Employment Information; Education Information and Inferences
Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Employment Information; Education Information and Inferences
Debugging to identify and repair errors that impair existing intended functionality
Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Employment Information; Education Information and Inferences
Undertaking internal research for technological development and demonstration
Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Employment Information; Education Information 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; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Employment Information; Education Information and Inferences

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.

Categories of Sources of Data Collection
Categories of Personal Information
Directly from you, such as when you contact us with a question or comment
Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Employment Information; Education Information and Inferences
From your devices, such as when you visit the Site
Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Employment Information; Education Information and Inferences
Vendors who provide services on our behalf
Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Employment Information; Education Information and Inferences
Social networks
Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Employment Information; Education Information and Inferences
Government entities
Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Employment Information; Education Information and Inferences
Consumer data resellers
Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Employment Information; Education Information 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; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Employment Information; Education Information and Inferences
Vendors who provide services on our behalf
Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Employment Information; Education Information and Inferences
Professional services organizations, such as auditors and law firms
Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Employment Information; Education Information and Inferences
Our business partners
Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Employment Information; Education Information and Inferences
Advertising networks
Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Employment Information; Education Information and Inferences
Internet service providers
Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Employment Information; Education Information and Inferences
Data analytics providers
Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Employment Information; Education Information and Inferences
Government entities
Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Employment Information; Education Information and Inferences
Operating systems and platforms
Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Employment Information; Education Information and Inferences
Social networks
Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Employment Information; Education Information and Inferences

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:

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.

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