Back

Kinesso US Products and Services Privacy Notice

California consumers click here for a summary of your state-specific rights

 

Effective Date: April 2, 2021

SCOPE

Kinesso, LLC and Matterkind, a Kinesso company, (collectively, “Kinesso”) respect the privacy of every individual about whom we either process information or maintain information in our products and services. This privacy notice describes our product and service offerings in the United States, the personal information we collect, how we use that information, 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 products and services. Please see our Privacy Center for privacy policies and notices that cover other aspects of Kinesso’s business and operations.

ABOUT KINESSO AND MATTERKIND

Kinesso and Matterkind provide marketing and advertising solutions and technology services that help our clients connect and engage with people in more respectful and beneficial ways.  We believe that marketing and advertising done consciously, ethically and fairly connects people to brand value, creates community, democratizes knowledge and access, and is a vital economic engine. This requires that marketing and advertising across connected digital channels be done in a transparent, accountable and trustworthy manner.  We call this Digital Responsibility and hope the information below gives you insight into our services, the data we process and the partners we work with. Our People Care Center also links to resources to express your preferences and exercise control over the use of your data in the advertising ecosystem.

Our products and services include three areas of capability; connection solutions which includes the ability to match data together and connect across digital channels; a suite of audience solutions which help our clients define audience groups; and a suite of addressable activation capabilities that help our clients prepare, deploy and measure advertising campaigns. These capabilities are enabled with data.

Our connection solutions help us reconcile disparate sets of data and connect our clients to their customers and prospective customers in connected channels, such as websites, mobile apps, and connected TV.  Our audience solutions enable the development of audience groups who are our clients’ customers or who may be interested in our clients’ products and services.  Our addressable activation services help our clients with advertising campaign preparation, deployment, monitoring, measurement, and performance analytics and reporting.

PERSONAL INFORMATION COLLECTION AND USE

Kinesso Products and Services

To enable our connection and audience solutions, we use personal information about individuals.  These two solution capabilities help our clients find their customers and other people that might be interested in their messages, products or services, and then connect with them using our Activation Services across connected digital channels such as websites, apps, and connected TV.

CONNECTION

How data connection works:  we receive and process permissible personal information from our affiliate and third-party partners.  We receive both identifying personal information, such as records with a name and address, and non-identifying personal information, such as records keyed with a provider-specific pseudonymous match key, also known as a connector key.  These two types of data are kept distinct and separate in a specialized clean-room environment for secure processing.  The identifying personal information, such as name and address, phone number and email address, is removed in a one-way process and each record is re-keyed with our Kinesso pseudonymous connector key, which we call Kinesso IDs.  The non-identifying personal information records are translated from the providers’ pseudonymous match key to our pseudonymous connector key, our Kinesso ID.

We then use our Kinesso IDs to help us match disparate data sets together for accuracy. We also use our Kinesso IDs to accurately match across connected channels where we have established relationships with digital platforms. This connection capability enables our clients to reach people in connected channels accurately, and in more responsible and efficient ways.

AUDIENCE SOLUTIONS

How audience solutions work:  our audience solutions include two aspects – (1) data enabled internal software tools, and (2) custom addressable audience advertising services for including activation, measurement, reporting, and analysis.

DATA ENABLED SOFTWARE

Data enabled audience software is a combination of attribute data about people and data processing capabilities.  The attribute data inside the software is pseudonymized and relates to people’s possible interests, demographics, and other characteristics that would help a brand group their own customers into interested audience groups and help find new audience groups that might be interested in their products or services.  To develop an audience, we receive ethically sourced demographic and interest attribute data related to individuals and households from our affiliate data partner.  We process this data in pseudonymized form with our Kinesso IDs.

ACTIVATION SERVICES

When our clients would like custom addressable advertising services, our Kinesso activation team handles this work, and activates our clients’ digital advertisements across different connected channels of communication and performs measurement, reporting and analysis on the advertising.

The use of tags, cookies, and other bits of code:  as instructed by our clients, we place 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 people 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.

Kinesso has established partnerships for advertising service capabilities and for the distribution of advertising with select media and technology providers in the online, app, email, and addressable TV ecosystem. With these partners, Kinesso enables our clients to display ads to audiences through websites, mobile apps, email, and addressable TVs.

From social media platforms or similar partners, we receive and analyze data about user sentiment, engagement and other interactions and references about our clients and their brands to help our clients understand the health of their brand and inform how they communicate with people.

From other advertising technology (adtech) partners, we receive engagement data related to how people engage with our clients’ advertising.  These partners include ad servers, demand-side platforms, and sell-side platforms. We help our clients understand engagement with an online advertisement (if an ad was viewed or clicked) 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.

We do not knowingly collect or disclose identifiable information on anyone younger than 18.  We do use information related to households or an adult that indicates presence of minors, solely for the purpose of creating insights into possible advertising interests. However, we do not disclose identifiable information about the minor as part of the insights created.

Matterkind Services

Matterkind takes a purposeful, people-first approach to help our clients engage audiences and drive brand growth across all connected channels. Matterkind uses Kinesso’s connections and audience solutions to enable Matterkind’s audience services. Matterkind client services include addressable media buys, and blending technology, data, inventory, and strategy to provide addressable advertising services to our clients. Using pseudonymized characteristics and interest information about audience groups, Matterkind is able to help our clients develop audiences most likely to be interested in their products or services.  Matterkind then activates the delivery of relevant, addressable advertising, monitors, measures, analyzes, and reports.

In providing our services to clients, Matterkind works with select 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 across connected channels.

Matterkind does not collect directly identifiable personal information such as names, email addresses or phone numbers through our services.

Additional Terms and Conditions: For a company to use Kinesso and Matterkind products and services, it is required to enter into a contract with us.  The terms of these contracts further govern the use of personal information we collect and maintain.

SHARING INFORMATION

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 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.

In addition to disclosures of information in the ordinary course of business, 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.

 

DATA TRANSFER

Personal information may be processed and stored in any country where we have facilities or in which we engage service providers.   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.

If an individual is located in the European Economic Area (“EEA”) the United Kingdom (“UK”) or Switzerland, we rely on Standard Contractual Clauses and Intercompany Agreements for the transfer of EEA, UK and Swiss data outside of those areas.  With respect to historical transfers of personal information to the U.S., transferred under EU/Swiss-US Privacy Shield, the data will continue to be processed pursuant to that agreement.  Kinesso remains certified under the EU/Swiss-U.S. Privacy Shield frameworks developed by the U.S. Department of Commerce, and the European Commission and Swiss Federal Data Protection and Information Commissioner, respectively, regarding the transfer of personal information from the EEA, UK and Switzerland to the U.S. Click here  to view our EU/Swiss-U.S. Privacy Shield Privacy Policy. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov.

YOUR RIGHTS AND CHOICES

We offer you certain choices in connection with the personal information we collect about you. If you would like to understand your rights related to the personal information we collect and process and to exercise your rights, including the right to object to the processing of personal information, to request deletion of personal information or to receive an electronic copy of your personal information please contact us as specified in the  section of this Kinesso Products and Services Privacy Notice. We will respond to your request as quickly as possible.  To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to your information. Importantly, to receive a copy of your pseudonymized personal information you will have to grant us affirmative consent to reverse the pseudonymity of your personal 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 our digitally responsible, data-driven and technology-enabled advertising products and services. 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:

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
Kinesso: peoplecare@kinesso.com 
Matterkind: peoplecare@wearematterkind.com

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.

CALIFORNIA CONSUMER PRIVACY RIGHTS ACT

The California Consumer Privacy Act (“CCPA” or the “Act”) confers privacy rights for California consumers and imposes corresponding obligations subject to the Act.  The rights conferred to consumers include:  the right to know what personal information covered businesses are collecting about them and how that information is being used and shared; the right to delete personal information held by covered businesses; the right to stop the sale of personal information by covered businesses; and the right to non-discrimination in service and price when exercising privacy rights.

The following is intended to explain California consumers’ rights and the obligations Kinesso has under the CCPA.  Kinesso employees in California should refer to the CCPA Employee Privacy Notice.

RIGHT TO KNOW/REQUEST FOR ACCESS TO PERSONAL INFORMATION

As a consumer under the CCPA, you have the right to request that Kinesso disclose what personal information we collect, use, disclose, and sell about you.  We call this your “right to know.”

To take advantage of your right to know, you must submit a request by filling out this form on our online People Care portal.

You can also submit your request by mail or telephone.  Our telephone number is 1-888-914-9661, Pin #894002.  Our mailing address is:

Kinesso, LLC
People Care
Attention:  CCPA Requests
100 W 33rd Street
3rd Floor
New York, NY 10001

To respond to your right to know request, the CCPA permits Kinesso to verify your identity.  We do this by using an identity verification service provided to us by LexisNexis. The LexisNexis service gives us a reasonably high degree of certainty you are the person you claim to be.  This will require that you satisfactorily answer a series of authentication questions based on data in the service. This may also require that you submit certain personal information for LexisNexis to compare and match to data in their verification system. For additional help, please email or call and a Kinesso employee will email you a link with information on how to request an access report and how to go through the automated identity validation process.

We do not retain the information you provide to LexisNexis for identity verification.  We receive an authentication indictor from LexisNexis into our systems.

If we are unable to verify your identity, we will be unable to fulfill your right to know request. In that case, please see the information below concerning Kinesso’s data collection, maintenance, and sale practices.

 

TYPES OF PERSONAL INFORMATION KINESSO COLLECTS

RIGHT TO KNOW ABOUT PERSONAL INFORMATION COLLECTED, DISCLOSED OR SOLD

 

Business and Commercial Purposes for which Personal Information is Collected:

We collect personal information for our own business purposes, including internal research, internal operations, auditing, detecting security incidents, improving our services, quality control, and legal compliance. We also collect personal information for commercial purposes. Kinesso licenses the categories of personal information described below from our affiliate and the third-party sources categorized below in developing Kinesso’s data matching and audience solutions for advertising purposes as previously described. Kinesso discloses personal data to the categories of third parties as described in the table below.

Categories of Personal Information Collected

Affiliate Companies and Data Brokers Origination Sources from these parties include Public Record and Publicly Available Information

Information from Other Data Brokers

Categories of Third Parties with Which Personal Information is Sold

Categories of Service Providers with Whom Personal Information is Disclosed for a Business Purpose

Kinesso does not collect data directly from consumers for use in our products and solutions. Please also note that Kinesso does not collect biometric information from consumers who are not Kinesso employees.  Lastly, Kinesso does not collect sensory information such as voice, visual, thermal, olfactory, or similar sensory information.

 

DISCLOSURE AND SALE OF PERSONAL INFORMATION

During the last year, Kinesso has not sold personal information it has collected to our third-party clients for their business and commercial purposes.  Kinesso does not sell personal information to individual consumers.

During the last year, Kinesso has disclosed personal information to service providers (e.g., cloud computing and storage vendors; security contractors, consultants and analysis providers), for Kinesso’s own operational business purposes.

Kinesso does not knowingly sell personal information about consumers younger than 18 for the purpose of marketing or advertising directly to the minor.  Kinesso does use personal information from minors younger than 18 to create insights about the possible advertising interests of households or adults.

 

RIGHT TO DELETE PERSONAL INFORMATION

Pursuant to the CCPA, California consumers have a right to request deletion of personal information about them that Kinesso has collected or maintained.

To take advantage of your right to delete, you need to submit a request by completing this form.

You can also submit your request by mail or telephone.  Our telephone number is 1-888-914-9661, Pin #894002. Our mailing address is:

Kinesso LLC
People Care
Attention:  CCPA Requests
100 W 33rd Street
3rd Floor
New York, NY 10001

To respond to your right to delete request, the CCPA permits Kinesso to verify your identity. We do this by using an identity verification service provided to us by Lexis-Nexis. The Lexis-Nexis service gives us a reasonably high degree of certainty you are the person you claim to be.  This will require that you satisfactorily answer a series of authentication questions based on data in the service. This may also require that you submit certain personal information for Lexis-Nexis to compare and match to data in their verification system. If you call or mail us and request a consumer access report, a Kinesso employee will email you a link directing you to how to request an access report and how to go through the automated identity validation process.

We do not retain the information you provide to LexisNexis for identity verification.  We receive an authentication indictor from LexisNexis into our systems.

If we are unable to verify your identity, we will either request additional information as permitted by the CCPA or provide a limited response (for example, by providing a report with categories of personal information rather than specific pieces of information).  Even assuming a verifiable request, Kinesso will retain certain personal information in our data-enabled products and solutions as necessary to comply with a legal obligation (including ensuring the deletion request is honored and CCPA record-keeping obligations), detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for the activity. In such cases, Kinesso will retain only the minimum amount of information that does not qualify for a statutory or regulatory exception, and only use the remaining data for the purposes provided by the statutory or regulatory exception.

 

RIGHT TO OPT OUT

California consumers have a right to opt out from Kinesso selling their personal information for marketing and adverting purposes.

To take advantage of your right to opt out, you need to submit a request completing this form.

You can also submit your request by mail or telephone.  Our telephone number is 1-888-914-9661, Pin #894002.  Our mailing address is:

Kinesso LLC
People Care
Attention:  CCPA Requests
100 W 33rd Street
3rd Floor
New York, NY 10001

 

RIGHT TO NON-DISCRIMINATION

The CCPA protects California consumers who exercise their rights from discrimination.  Kinesso will not discriminate against consumers who request access to personal information about them, request deletion, or request that Kinesso opt them out of future sells.

 

RIGHT TO USE AUTHORIZED AGENTS TO EXERCISE RIGHTS

The CCPA allows California consumers to use authorized agents to submit requests to Kinesso on their behalf.  Kinesso requires that the authorized agent verify its identity and provide written authorization from the consumer to act on the consumer’s behalf.  If the agent is a business, it must also be registered with the secretary of state of the authorized agent’s state of incorporation and provide proof of such registration.

In the case of an authorized agent’s request for access to personal information, the resulting report will be delivered to the consumer directly.  Prior to any release of the report to the consumer, Kinesso will require the consumer to complete the identity verification process described above to minimize the risk of unauthorized access to personal information and potential resulting harm.

 

HOW TO CONTACT US FOR MORE INFORMATION

If you have questions regarding your rights under CCPA or Kinesso’s data collection, use and disclosure practices, you may contact us by phone, mail, or email.

Our telephone number is 1-888-914-9661, Pin #894002. Our email address is peoplecare@kinesso.com

Our mailing address is:

Kinesso LLC
People Care
Attention:  CCPA Requests
100 W 33rd Street
3rd Floor
New York, NY 10001

You may also contact the California attorney general.  Please visit https://www.oag.ca.gov/home, for more information.

This CCPA Privacy Notice is effective April 2, 2021. 

 

Other Important Information

European Union Model Contracts: As a global company, Kinesso complies with many countries’ privacy laws. Kinesso maintains an industry-recognized leadership role in consumer privacy. In addition to being certified under the EU-US Privacy Shield Framework, Kinesso has executed EU-approved model clauses with its EU affiliates to ensure ongoing compliance with the international transfer principle as set out in the EU’s General Data Protection Regulation.

Accuracy: Kinesso maintains quality control procedures to ensure the information we collect and process is as accurate and complete as possible. Kinesso responds promptly to questions from clients and consumers about the accuracy of information.

Security: Kinesso maintains security procedures designed to keep information we own, license and process from being accessed by any unauthorized person or business. We use a variety of multi-level security systems to control access to our services and data products. All users at client locations, as well as all Kinesso associates, must have the appropriate access codes and be authorized to access certain data and applications.

Kinesso conducts risk assessments and regular audits on our internal and external information systems to assess our ability to maintain the integrity of client and Kinesso data. Our enterprise security operations center maintains real-time monitoring for information system vulnerabilities and unauthorized access attempts into our internal systems. We also maintain physical security for our facilities and limit access to certain critical areas of our business.

We take reasonable precautions to ensure that our security procedures are adequate for the protection of our computer systems and data, but this does not eliminate the possibility that our security will be breached. If a security breach causes Kinesso leadership to believe individual consumers are at actual risk for identity theft or other fraudulent activities that may cause substantial harm or inconvenience to consumers or if such breach otherwise requires public notification, Kinesso will post a security alert notice on our website (www.Kinesso.com) that will provide relevant information for consumers and Kinesso clients to consider to protect against fraudulent and other harmful actions that may result from the unauthorized access.

Compliance: Kinesso participates in industry efforts to establish fair and workable guidelines above and beyond current laws and regulations and believes such actions are an effective way to protect privacy in the marketplace. We also support legislation and regulatory efforts to introduce fair and workable guidelines that protect privacy of people.

We actively work to ensure that such guidelines are consistent with and complement established self-regulatory measures and that they enable the consumer to continue receiving the benefits that appropriate information use, sophisticated marketing and advertising techniques, and transaction-processing services provide.

When Kinesso provides marketing and advertising services to our clients, we process their information in strict accordance with the terms and conditions of the contract. Some of the services we provide companies such as financial institutions and healthcare organizations are governed by laws including the Fair Credit Reporting Act, Gramm-Leach-Bliley, the USA PATRIOT Act, and the Health Insurance Portability and Accountability Act. In these and similar situations, Kinesso works closely with our clients to ensure the processing we perform is in accordance with all the laws governing those activities.

Awareness: Kinesso is committed to privacy education. We provide education to our clients, our associates, and the industry about the issues, guidelines and laws surrounding privacy and the responsible use of personal information, along with corresponding responsibilities and Kinesso’s privacy policies and practices. Kinesso provides education and consultation to clients about privacy compliance and about the laws and industry guidelines that protect consumers. Kinesso advocates speak at various events and emphasize the importance of responsible data collection and use.

Privacy Policy Changes: From time to time, Kinesso may update and revise our privacy policy based on changes in our business environment and changes to applicable law. We urge consumers and clients to periodically visit our website to understand any changes that may have occurred.

Our privacy policy contains an “effective date” reflecting when the last changes occurred.

Effective Date: April 2, 2021