Privacy Notice for Epsilon.Com

This Privacy Notice sets out how Epsilon Data Management, LLC (“we”, “our”, “us”, “Epsilon”) collects, uses, discloses, and protects any Personal Data through epsilon.com and its subpages (“Website”). This Privacy Notice also explains the measures we take to safeguard your Personal Data and describes how you may contact us regarding our privacy practices.

Introduction

Our website is intended to provide information to business clients about our products and services, potential applicants who are interested in a career with Epsilon, and website visitors utilizing our privacy portal.

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 anything else in this Privacy Notice, 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.

Please read this Privacy Notice thoroughly. If you disagree with the way your Personal Data 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 BELOW-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. If you are an employee, please visit Publicis Groupe Maison or contact your local human resources office. If you are an applicant, please see our applicant Privacy Policy contained in the recruitment platform.

I. What Personal Data do we collect through the Website and how do we process it?

The following chart describes (i) the categories of Personal Data we collect, (ii) why we collect and use that Personal Data (called the purpose), and (iii) how we collect the Personal Data/ More information about the information found in each column can be found in the sections following this chart.

II. Who do we collect Personal Data from?

We may collect the Personal Data outlined above from the following categories of sources:

• Directly from you, for example, when you complete an intake form, send us your questions or comments, subscribe to receive marketing communication or news from us, manage your email subscriptions, or make usage 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 VII of this Privacy Notice.

III. With whom do we disclose your Personal Data?

We will disclose the Personal Data collected from and about you for the various purposes described above, both with service providers and with third parties including our clients. The tables below shows how and with whom we may disclosed Personal Data, and whether (based on the US state privacy laws’ definition of “sell” and “share”) we believe we have “sold” or “shared” a particular category of information in the prior 12 months. We may also disclose your Personal Data to any other party with your prior consent.

Your (i) contact information and other identifiers and (ii) internet or other electronic network activity information may have been shared or sold (based on the US state privacy laws’ definitions of “share” and “sell”) with the following categories of third parties in the past 12 months through our interest-based advertising services (see our services and product privacy notice):

We may disclose your Personal Data to our service providers that assist us with our business purposes. Our service providers are to only process your Personal Data in accordance with our instructions and only for the purpose listed below.

The table below shows with whom we disclose your Personal Data for the specific business purpose(s).

We may disclose your Personal Data for the following additional purposes:

• For legal purposes: we may disclose Personal Data with other parties in order to: (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. We likewise may provide information to other companies and organizations (including law enforcement) for fraud protection, and spam/malware prevention, and similar purposes.
• Sharing In Event of a Corporate Transaction: We may also disclose Personal Data in the event of a major 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.

IV. Automated Decision Making and Profiling

To the extent that we use processes that involve automated decision making or profiling when processing your Personal Data, we take steps to ensure that any automated decision making or profiling practices are fair and not discriminatory. We may use automated decision making and profiling in connection with your Personal Data in our Interest Based Advertising services described in our Services and Products Privacy Notice.

V. How long do we keep your Personal Data?

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;

• 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.

VI. Your rights and choices regarding your Personal Data

Your Privacy Rights and Choices

Residents of several U.S. states are granted specific rights regarding the collection, use, and disclosure of their personal information. As of the effective date of this privacy notice, these states include California, Colorado, Connecticut, Delaware, Florida, Iowa, Minnesota, Montana, Nebraska, Nevada, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, Virginia, and Washington. These rights are subject to applicable legal exceptions and may vary by state. Canadian residents are also granted specific rights regarding the collection, use, and disclosure of their personal information.

This section outlines the privacy rights available to consumers under these state/province/federal laws and explains how to exercise them.

You may also be permitted to designate an agent to make the following requests to exercise your rights where the law allows. We will take steps to verify that your agent has been authorized to make a request on your behalf by asking for a copy of your authorization to the agent. All requests submitted by an agent must be made by using our agent form or by calling us toll-free at (866) 267-3861. You may exercise any of the following rights by filling out and submitting our online request form or by calling toll-free (866) 267-3861.

Right to request access to and portability

If the state/province/country in which you reside provides you with the right to access or know the Personal Data which Epsilon processes about you, you may request, up to two times each year, access to categories and specific pieces of Personal Data about you that we collect. This may include a list of categories or specific third parties to whom we disclosed your or any personal data if required by your state’s law. To make an access request please visit https://legal.epsilon.com/dsr/ or by calling us toll-free at (866) 267-3861. Once we receive your form, our identity verification service provider will confirm your identity with a series of test questions to be verified against the service provider’s data. We will provide your report of categories and specific pieces of Personal Data in a portable format. When we receive and verify your request, we will make best efforts to fulfill your request unless an exception applies.

Right to request deletion

If the state/province/country in which you reside provides you with the right to delete your Personal Data, you may 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 law. When we receive and verify your request to delete your Personal Data, we will proceed to delete the data unless an exception applies. To make a deletion request please visit https://legal.epsilon.com/dsr/ or by calling us toll-free at (866) 267-3861. Once we receive your form, our identity verification service provider will confirm your identity with a series of test questions to be verified against the service provider’s data.

Right to request correction/rectification

If the state/province/country in which you reside provides you with the right to correct your Personal Data and if you believe we hold inaccurate Personal Data about you, you may request that we correct that Personal Data. We will delete your Personal Data upon receipt of your correction request. When we receive and verify your request, we will proceed to delete the data unless an exception applies. To make a correction or deletion request please visit https://legal.epsilon.com/dsr/ or by calling us toll-free at (866) 267-3861. Once we receive your form, our identity verification service provider will confirm your identity with a series of test questions to be verified against the service provider’s data.

Right to Opt-out.

We offer multiple ways for consumers to opt out of the use, sharing, or sale of their personal information, including for purposes such as targeted advertising, profiling, and automated decision-making. These options are available to all U.S. residents, regardless of whether their state has enacted specific privacy laws, and Canadian residents are entitled to all opt-out or revocation of consent options offered by the Canadian provinces.

How to Opt Out

Consumers may submit opt-out requests through our privacy portal at https://legal.epsilon.com/dsr/ or by calling us toll-free at (866) 267-3861. These channels support requests to:

• Opt out of the sale or sharing of personal information.
• Opt out of cross-context behavioral advertising and targeted advertising.
• Opt out of profiling and automated decision-making.
• Limit the use of sensitive personal information.
• Revoke previously given consent for data processing.

Universal Opt-Out Mechanisms

We recognize browser-based opt-out preference signals, such as Global Privacy Control (GPC), as valid requests to opt out of the sale or sharing of personal information. These signals are processed in accordance with applicable state laws, including, as of the effective date of this privacy notice, California, Colorado, Connecticut, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, and Texas. We will recognize GPC for visitors from Maryland, Delaware, and Oregon in accordance with the timing provided within their state privacy laws.

Sensitive Personal Information

Where required by law, we obtain opt-in consent before processing sensitive personal information. Consumers may revoke this consent using the same opt-out channels listed above.

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.

Right to non-discrimination

You have the right not to receive discriminatory treatment for the exercise of your privacy rights.

Appeal

Certain residents of the United States have the right to appeal our denial of your privacy rights request. Within 60 days of receiving our denial of your request, you may make an appeal by visiting https://legal.epsilon.com/dsr/ or by calling us toll-free at (866) 267-3861.

Notice of financial incentive

We offer no financial incentives for your Personal Data that is collected by this Website.

DAA AdChoices

Epsilon is a proud member of the Digital Advertising Alliance (DAA). The DAA is an organization that works with digital advertising companies to develop and enforce responsible and privacy-friendly online advertising practices, including the development of the AdChoices program. Epsilon’s IBA activities adhere to the DAA’s Self-Regulatory Principles for Online Behavioral Advertising.

Rather than opting out from Epsilon’s IBA activities directly, as indicated above, you may opt-out by using the DAA’s AdChoices tool. Canadian visitors may opt-out by using the DAAC’s AdChoices tool.

Please note that opting out of targeted advertising does not eliminate all advertising. You may still receive ads, but they will be less tailored to your interests.

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 browser-initiated “Do Not Track” signals. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.

VII. Minors

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 or individuals under the age of 18 years of age. Further, we do not knowingly sell or share Personal Data of individuals under the age of 18. If you are a parent or guardian and believe we have collected Personal Data in violation of COPPA or state privacy law, contact us at privacy@epsilon.com. We will remove the Personal Data in accordance with COPPA or other state privacy law.

VIII. 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 privacy@epsilon.com immediately.

IX. 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 cookies are required to provide the basic functions of the website and cannot be turned off. They are essential for accessing certain features of the website and could include signing in, adding items to a cart, or e-billing.
• Performance cookies are used to identify the pages used and to measure and track the performance of our website. This helps us to analyze web page traffic data and improve our website to fit your needs. We only use the information for statistical analysis purposes.
• Functional cookies are used to provide services you request. These cookies can remember your preferences to boost the user experience on a website.
• Targeting cookies may be set by us or by our advertising partners. They may be used to build a profile of your interests and show you relevant advertisements on this website or others. They do not store Personal Data but are based on uniquely identifying your browser. If you do not allow these cookies, you will experience less relevant advertising.

Overall, cookies help us provide you with a better Website, by enabling us to monitor which pages you find useful and which you do not. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the Website.

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.

We have no control over how social media or other advertising 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 disclose to 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.

X. Google’s Privacy Sandbox

Together with Epsilon’s affiliate, ReTargetly, we are testing the Google Privacy Sandbox, a set of technologies to facilitate online advertising by sharing a subset of website visitor personal information without the use of third-party cookies in Google Chrome. Through the Google Protected Audience API, we may store and access data on your device or browser related to your interests and ad measurement. For more information about the Google Privacy Sandbox, visit https://privacysandbox.com/.

XI. Privacy Rights Metrics

From January 1, 2024 to December 31, 2024, we facilitated requests from individuals in the United States that submitted a request through our online request form or by calling our toll-free number (866) 267-3861. The following metrics apply to all personal data processed by Epsilon in the United States, not solely personal data collected from this website.

XII. Notification of changes

From time to time, we may update this Privacy Notice. Any changes to it will become effective within 15 days from when it is posted to our website. 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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XIII. Data Broker

THE ENTITY MAINTAINING THIS WEBSITE IS A DATA BROKER UNDER TEXAS LAW. TO CONDUCT BUSINESS IN TEXAS, A DATA BROKER MUST REGISTER WITH THE TEXAS SECRETARY OF STATE (TEXAS SOS). INFORMATION ABOUT DATA BROKER REGISTRANTS IS AVAILABLE ON THE TEXAS SOS WEBSITE.

XIV. Contact Us

Epsilon has a designated privacy contact. To ask questions about Epsilon’s privacy policy or to request more information on Epsilon’s privacy practices, email us or send correspondence to:

North America
Epsilon
P.O. Box 1478
Broomfield, CO 80038
Attn: Privacy

Updated: September 17, 2025