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 and potential applicants who are interested in a career with Epsilon.
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, 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. If you are an applicant, please see our applicant Privacy Policy contained in the SmartRecruiters platform.
I. What Personal Data do we collect through the Website and how do we process and disclose the Personal Data?
The following chart describes (i) the categories of Personal Data we collect, (ii) why we collect and use that Personal Data (called the purpose), (iii) from whom we collect the Personal Data from, (iv) to whom we disclose the Personal Data for our Business Purposes, and (v) to whom we “sold” or “shared” (as defined by the US privacy laws) the Personal Data. More information about the information found in each column can be found in the sections following this chart.
Category of Personal Data | Purpose for Processing | Category of Source Personal Data Collected from |
Internet or other electronic network activity information: e.g. browsing history, search history, your interaction with a website or advertisement |
| Directly and Indirectly from you (see more information in Section II) |
Business to Business Contact Information: e.g. name of your employer or company, your title, department |
| Directly from you (see more information in Section II) |
Contact Information and Identifiers: e.g. first and last name, email address, telephone number, IP address. |
| Directly and Indirectly from you (see more information in Section II) |
Your verbatim communications to us or disclosed on the public areas of our site: e.g. information you directly send us by using the online forms on this Website |
| Directly from you (see more information in Section II) |
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):
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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).
Category of Personal Data | Categories of service providers | Business Purpose |
| Analytics service providers |
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| Online marketing and measurement providers |
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| Web or data hosting |
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| Technical or customer support |
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| Privacy request verification provider |
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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
You may have privacy rights based on the laws of your jurisdiction of residence, such as the states of California or Virginia or the provinces and country of Canada. This section describes how to exercise those rights and our process for handling those requests. 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 through providing us with a signed written authorization or a copy of a power of attorney. All requests submitted by an agent must be made through our agent request form or by calling us toll-free at (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. 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
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 of the Sale
If the state/province/country in which you reside provides you with the right to opt-out of the sale of your Personal Data and if you would like to opt out of our use of your information for such purposes that are considered a “sale” under privacy laws, you may do so by visiting https://legal.epsilon.com/dsr/ or by calling us toll-free at (866) 267-3861. Please note that we do not knowingly sell the Personal Data of minors under 16 years of age without legally-required affirmative authorization.
Nevada law (NRS 603A.340) requires each business to establish a designated request address where Nevada consumers may submit requests directing the business not to sell certain kinds of Personal Data that the business has collected or will collect about the consumer. A sale under Nevada law is the exchange of Personal Data for monetary consideration by the business to a third party for the third party to license or sell the Personal Data to other third parties. If you are a Nevada consumer and wish to submit a request relating to our compliance with Nevada law, you can make the opt-out request by visiting https://legal.epsilon.com/dsr/, calling us toll-free at (866) 267-386, or emailing us at privacy@epsilon.com.
Right to Opt-out of the Share/Cross Context Behavioral Advertising/Targeted Advertising
If the state/province/country in which you reside provides you with the right to opt-out of share/cross context behavioral advertising/targeted advertising and if you would like to opt out of our use of your information for such purposes that are considered a “share” under privacy laws or cross-context behavioral advertising/targeted advertising (what we refer to above as Interest-based Advertising), you may do so by visiting https://legal.epsilon.com/dsr/ or by calling us toll-free at (866) 267-3861.
Additionally, you may choose not to receive targeted advertising from ad networks, data exchanges, and other digital advertising providers by opting out of targeted advertising via YourAdChoices (US) or YourAdChoices (Canada) powered by the Digital Advertising Alliance
Right to Opt-out of Automated Decision Making and Profiling
If your state/province/country provides you with the right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on your or produce a similarly significant effect, you may opt-out of the processing of your Personal Data for profiling and other automated decision making by visiting https://legal.epsilon.com/dsr/ or by calling us toll-free at (866) 267-3861.
Right to limit the use of Sensitive Personal Data
Our Website does not collect Sensitive Personal Data, as defined by privacy laws. However, if your state/province/country provides you with the right to limit the use of your sensitive Personal Data, you may request that we limit the use and disclosure of your Sensitive Personal Data by visiting https://legal.epsilon.com/dsr/ or by calling us toll-free at (866) 267-3861, and such request will be applied to your Personal Data that we use as part of our services and products (see our services and products notice). Additionally, we may deny your request in part or in full under uses authorized by applicable law.
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.
Canadian residents – right to withdraw your consent
If you are a Canadian resident, you request to withdraw your consent to our processing of your Personal Data. To do so, you may select deletion request by visiting https://legal.epsilon.com/dsr/ or by calling us toll-free at (866) 267-3861. Please note this may affect our ability to communicate with you and we may retain certain data points if permitted by law.
Notice of financial incentive
We offer no financial incentives for your Personal Data that is collected by this Website.
VII. Your general rights regarding to data collection
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 “Do Not Track” signals. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.
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.
Interest-Based Advertising
Companies like us that provide Interest Based Advertising services are participants of the Digital Advertising Alliance (“DAA”) and/or the Network Advertising Initiative (“NAI”). To learn more about the targeted ads provided by us and similar companies, and how to opt out of receiving certain targeted ads from them, please visit: (i) for website targeted ads from DAA participants, https://www.aboutads.info/choices; (ii) for app targeted ads from DAA participants, https://www.aboutads.info/appchoices; and (iii) for targeted ads from NAI participants, https://www.networkadvertising.org/choices/. Opting out only means that the selected participants should no longer deliver certain targeted ads to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., in connection with the participants’ other customers or from other technology services).
Please note that if you opt out using any of these methods, the opt out will only apply to the specific browser or device from which you opt out. We are not responsible for the effectiveness of, or compliance with, any opt out options or programs, or the accuracy of any other entities’ statements regarding their opt out options or programs.
Analytics
We may use our own technology or third-party technology to track and analyze usage information to provide enhanced interactions and more relevant communications, and to track the performance of our advertisements.
For example, we use Google Analytics (“Google Analytics”), a web analytics service provided by Google, Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. You can learn about Google’s privacy practices by going to www.google.com/policies/privacy/partners/.
Google Analytics uses cookies to help us analyze how our websites are used, including the number of visitors, the websites from which visitors have navigated to our websites, and the pages on our websites to which visitors navigate. This information is used by us to improve our websites. We use Google Analytics with restrictions on how Google can process our data enabled. For information on Google’s Restricted Data Processing go to https://privacy.google.com/businesses/rdp/
VIII. 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. If you are a parent or guardian and believe we have collected Personal Data in violation of COPPA, contact us at privacy@epsilon.com. We will remove the Personal Data in accordance with COPPA.
IX. 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.
X. 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 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.
Find out more about how these social media platforms use your Personal Data:
XI. 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/.
XII. California Privacy Rights Metrics
From January 1, 2022 to December 31, 2022, we facilitated requests made pursuant to CCPA 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.
Delete | Correction | To Know/ Access | Opt-out of sale/ sharing | Limit Sensitive Data | |
Number of requests received | 11,565 | 16 | 2,823 | 39,687 | 162 |
Number of requests complied with in full | 5,389 | 10 | 1,327 | 39,687 | 162 |
Number of requests complied with in part | 0 | 0 | 0 | 0 | 0 |
Number of requests denied due to inability to verify consumer | 6,176 | 6 | 1,496 | 0 | 0 |
Mean number of days we took to substantively respond to requests | 2 Days | 2 Days | 20 Days | 2 Days | 2 Days |
XIII. Notification of changes
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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XIV. 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.
XV. 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
privacy@epsilon.com
Epsilon
P.O. Box 1478
Broomfield, CO 80038
Attn: Privacy
Updated: March 11, 2024