Commercial Services Privacy Notice
Effective Date: July 20, 2020
Kinesso, LLC (formerly known as Cadreon, LLC, and referred to herein as “Kinesso”), and Matterkind, a Kinesso company, respect your concerns about privacy and believes all data and technology should be ethical, accountable, safe and secure. This Kinesso Companies Commercial Services Privacy Notice (“Privacy Notice”) describes our services, how we process personal information for our clients, and how individuals can contact us about our privacy practices and exercise their rights in connection with Kinesso’s and Matterkind’s commercial services.
ABOUT KINESSO AND MATTERKIND
Kinesso and Matterkind provide advertising technology services that help our clients reach and connect with people in more beneficial, convenient, and respectful ways. Our technology services are enhanced by data and help our clients with audience discovery, measurement and activation abilities, campaign performance analytics, and the creation and review of digital audience data, social media insights and audience insights.
INFORMATION WE COLLECT AND HOW WE USE IT
Through Our Kinesso Services:
To perform our services, we use personal information about individuals to help our clients serve digital advertisements to their customers and other people who have particular demographics, attributes or interests and that might be interested in our clients’ messages, services or products. To perform our services, Kinesso uses affiliate partners and third-party partners. We receive ethically sourced demographic and attribute data about individuals from our affiliate data partner, and use a third party technology partner to help us match data together. We use this data and matching technology to help clients recognize and connect with audiences to deliver relevant digital advertisements across different channels of communication. Our affiliate data partner is responsible for determining the legal basis for their processing if required by applicable law.
How data matching works: our affiliate data partner sends identifying personal information such as name and address, and attribute data, such as demographics, likes and interests, to our third party technology partner, who replaces identifying personal information with a record key that is not directly identifiable by Kinesso. Our clients may send identifying personal information to our third-party technology partner, who removes the identifying information and replaces it with a record key. The third-party technology partner then sends Kinesso the matching record keys for use in performing advertising services for the client.
Additionally, Kinesso partners with select social media platforms and advertising technology (“ad tech”) partners.
From social media platforms or similar ad tech partners: Kinesso receives and analyzes data about user sentiment, engagement and other interactions and references about clients and their brands to help our clients understand the health of their brand and inform how they communicate with people.
From ad tech partners: Kinesso receives personal information or aggregate data relating to people from ad tech partners, such as ad servers, demand-side platforms, and sell-side platforms, to enable our services. Kinesso helps our clients understand engagement with an online advertisement (if they viewed or clicked an ad) or other relevant interactions (e.g., products purchased). We use our technology, data science, and analytic modeling capabilities to help our clients designate different audiences for their different brand messages, products and services, measure and report on their advertising campaigns, and optimize for efficiency and effectiveness.
The use of pixel tags, cookies, and other bits of code: as instructed by our clients, we place pixel tags on our clients’ websites, apps, and ads that allow ad tech partners to collect information to serve and measure ads, and to help clients reconnect with users in the future. The information types collected include IP address, mobile advertising ID, browser type, operating system, referral URLs, date/time stamps, pages viewed, and simple keyword tags.
Through Our Matterkind Services:
Kinesso’s data and technology services fuel Matterkind’s offering. Matterkind takes a people-first approach to help our clients engage audiences and drive brand growth regardless of channel. Powered by people, enhanced by technology, activated by Matterkind, our client services include addressable media buys, and blending technology, data, inventory and strategy to provide addressable advertising services to our clients. Using information about people, their attributes and interests, Matterkind is able to reach the audiences most likely to be interested in the products or services of Matterkind’s clients and activate the delivery of relevant, addressable advertising.
In providing our services to clients, Matterkind works with ad tech partners who collect demographic and other personal information from third party websites and mobile applications, and organizes that information into groups or audience segments we are trying to reach on behalf of our clients. Our technology partners are responsible for determining the legal basis for their processing of information if required under applicable law. Matterkind processes demographic and other personal information from our ad tech partners to analyze trends and identify browsers or devices that make up the audience most likely to have a positive experience with a client’s advertisement and help place advertisements onto the most appropriate, respectful and cost-effective sites and applications.
Matterkind does not collect directly identifiable personal information such as names, email addresses or phone numbers through our services.
We share information processed through the services offered by Kinesso and Matterkind with our clients for reporting or measurement purposes, to provide insights and analysis, to help clients understand how their brand is perceived by people and to advise clients on media planning. We also share such information with our affiliates and other service providers who to perform analytics or other services on our behalf, and ad tech partners to deliver relevant advertisements tailored to individuals’ interests, improve placement of advertisements and improve our services.
We also may disclose personal information (1) if we are required to do so by law or legal process (such as a court order or subpoena), including laws outside a country of residence; (2) in response to requests by, or cooperate with, government agencies, such as law enforcement authorities, including outside of a country of residence; (3) to establish, exercise, or defend our legal rights; (4) when we believe disclosure is necessary or appropriate to protect our rights, privacy, safety, or property and/or that of our affiliates, individuals, or others; (5) in connection with an investigation of suspected or actual illegal activity; (6) in connection with the sale or transfer of all or a portion of our business, assets, or stock (including in the event of a reorganization, dissolution, or liquidation); or (7) otherwise with individual consent.
The security of information is important to us, and we maintain reasonable administrative, technical and organizational measures designed to protect the personal information we in our systems. While we design security procedures adequate for the protection of our systems and the data within it, we cannot guarantee the security of the information stored or processed in our systems.
Personal information may be processed and stored in any country where we have facilities or in which we engage service providers, and you understand that personal information may be transferred to countries outside of a country of residence, including the United States, which may have data protection rules that are different from those of a country of origin. In certain circumstances, courts, law enforcement agencies, regulatory agencies, or security authorities in those other countries may be entitled to access personal information.
On July 16, 2020, the European Court of Justice invalidated Privacy Shield as a Transfer Mechanism between EU and US companies. Kinesso intends to utilize alternate transfer mechanisms going forward for transfers from the EU. Even though Privacy Shield was invalidated in the EU, Kinesso will continue to honor its commitments with respect to EU personal data transferred pursuant to Privacy Shield before July 16, 2020. Kinesso continues to honor the obligations for UK and Switzerland personal data as a valid mechanism until new guidance becomes available, as recommended by the ICO and FDPIC – UK and Switzerland data protection authorities, respectively.
YOUR RIGHTS AND CHOICES
We offer you certain choices in connection with the personal information we obtain about you. If you would like to request to review, correct, update, suppress, restrict, or delete personal information, to object to the processing of personal information, or to receive an electronic copy of your personal information for purposes of transmitting it to another company (to the extent these rights are provided to you by applicable law), please contact us as specified in the How to Contact Us section of this Commercial Services Privacy Notice. We will respond to your request consistent with applicable law. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to your information. To the extent permitted by applicable law, a charge may apply before we provide you with a copy of any of your personal information that we maintain.
We believe that data and technology should serve people, and are available to discuss concerns and answer questions related to advertising. To further explore our people-care program and learn how to exercise your choices please visit our People Care Center.
RETENTION OF PERSONAL INFORMATION
We retain personal information for as long as needed or permitted in light of the purposes for which we obtained it and consistent with applicable law. The criteria used to determine our retention periods include:
- The length of time it is needed for the purposes for which we obtained the personal information;
- Whether there is a legal obligation to which we are subject; and
- Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitation, litigation, or regulatory investigations).
HOW TO CONTACT US
Kinesso, LLC, located at 100 W 33rd Street, 3rd Floor, New York, NY 10001, is the company responsible for collection, use, and disclosure of your personal information under this Privacy Notice.
If you wish to exercise any of your privacy rights, or if you wish to contact us in relation to this Privacy Notice or any privacy matter, including our use of your personal information, please use the following contact details:
ATTN: Digital Responsibility
Or for any query or issue, our Data Protection Officer for the UK and the EU can be contacted via post or email using the following details:
UK DPO or EU DPO
Interpublic Group Limited
66 Prescot Street
London E1 8 HG
For the UK: UK.DPO@interpublic.com
For the EU: GDPR.DPO@interpublic.com
You have the right to lodge a complaint with a data protection authority for your country or region or where an alleged infringement of applicable data protection law occurs. A list of data protection authorities is available here.