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Kinesso Products and Services Privacy Notice

Kinesso Products and Services Privacy Notice

Effective Date: October 6, 2021

 

Kinesso, LLC and Matterkind, an operating division of Kinesso, (collectively, “Kinesso”) respect the privacy of every individual we process or maintain information about in our products and services. Kinesso provides digital 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 is transparent, accountable, and trustworthy.  We call this Digital Responsibility.

This privacy notice describes our product and service offerings, the personal information we collect, how we process and use personal information, the partners we work with, and how individuals can contact us about our privacy practices and exercise their rights in connection with Kinesso’s products and services. Our People Care Center links to resources to express your preferences and exercise control over the use of your personal information in the advertising ecosystem.  Please also see our Privacy Center for privacy notices that cover other aspects of Kinesso’s business and operations.

For California consumers, please click here for a description of your state-specific disclosures.

 

ABOUT KINESSO

Kinesso’s products and services include three areas of capability: connection solutions 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. Data enables these capabilities.

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 solutions 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 SOLUTIONS

Foundational to Kinesso’s digital advertising solutions is the ability to accurately, permissibly, and securely connect disparate data sets together.  Whenever possible, we store and process information pseudonymously, which means the information can no longer be attributed to an individual without additional information which is kept separately.  We receive, maintain, and process permissible personal information to do two things:  create our own Kinesso pseudonymous match keys and to perform connections of disparate data sets both internally and with external partners. 

Pseudonymization:

Kinesso maintains a restricted system containing directly identifiable personal information sourced from our affiliates and other third-party partners on behalf of Kinesso.  We use this system to match information from our clients and partners in a one-way operation that replaces all directly-identifying information they provide with a pseudonymous Kinesso Intelligent Identifier (“Kii”).  We maintain the Kiis in a separate data processing environment and use them to perform matching, and to connect to partners’ pseudonymous match keys.  Directly identifying personal information is kept separate and apart from non-directly identifying personal information for secure processing.

Connecting disparate data sets:

We use Kiis in order to store, process, and connect information pseudonymously in different data processing environments. For example, we use our Kiis to match across connected channels where we have established relationships with digital platforms. This connection capability enables our clients to reach people in connected channels in more responsible, accountable, and efficient ways.

We perform three types of connections: 1) connecting directly-identifiable data sets to other directly-identifiable data sets; 2) converting directly-identifiable data sets into pseudonymously-keyed data so that it can then be matched to other pseudonymously keyed data sets; and 3) connecting pseudonymous data sets to other pseudonymous data sets. 

Connecting directly-identifiable data sets to other directly-identifiable data sets: For directly-identifying matching, we process limited and specific data elements (such as name, address, and email) in a secure, segregated environment. We also perform secure matches of directly identifying information with a small number of external partners.

Converting directly-identifiable data sets into pseudonymously-keyed data so that it can then be matched to other pseudonymously keyed data sets:  When we receive directly identifying personal information from clients or other third parties, whenever possible we match this information against our database in a one-way process that removes directly identifiable personal information and re-keys the remaining information with our pseudonymous Kii.  The Kiis are then used for internal processing and external connections to the pseudonymous keys used by our partners as described below. Once we complete the conversion of directly identifying personal information to Kii, we delete the directly identifying personal information within a reasonable time.

Connecting pseudonymous data sets to pseudonymous data sets: Each partner has its own pseudonymous partner-specific match key.  We match partner-specific match keys to our Kiis and maintain partner-specific connectors (i.e., mappings between a partner’s match keys and our Kiis) for each of the partners in our partner ecosystem. 

 

AUDIENCE SOLUTIONS

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

 

DATA-ENABLED SOFTWARE

Data-enabled audience software combines pseudonymized attribute data about people and data processing capabilities.  The software contains pseudonymized attribute data about people’s possible interests, demographics, and other characteristics that enables a brand to group their own customers or prospective customers into interested audience groups and help find new audience groups that might be interested in their products or services.  To develop an audience for a client, we use permissible demographic and interest attribute data related to individuals and households from our affiliate and third party data partners that meet our quality and responsibility standards.  We process this data in pseudonymized form using our Kiis.

Some of our attribute data is collected using survey partners we hire to periodically conduct a marketing survey that collects information from survey respondents, including demographic data and information about their personal interests.  In select markets and only where the survey respondent expressly consents, we also collect directly identifiable personal information about the respondents such as their name, address, and email address. We pseudonymize the marketing survey response data using our Kiis or, when necessary, via third party match partners.  We then match the pseudonymized marketing survey response data with other pseudonymized demographic, interest and attribute data we control as described above. We use this marketing survey data for the purposes of powering our data enabled software and media planning tools; performing audience research, analysis, and modeling; and other marketing activities or analysis for our clients, partners, and Kinesso affiliates.

 

MATTERKIND’S ADDRESSIBLE ADVERTISING SERVICES

Matterkind takes a purposeful, people-first approach to help our clients engage audiences and drive brand growth across connected channels.  To that end, Matterkind only works with pseudonymous information and does not work with directly identifying personal information such as names, email addresses or phone numbers through our 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 helps our clients develop audiences most likely to be interested in their products or services.  Matterkind then activates, monitors, measures, analyzes, and reports on the delivery of relevant, addressable advertising.

In providing our services to clients, Matterkind relies on Kinesso’s connections solutions and data-enabled software, as well as capabilities provided by external advertising technology (“adTech”) partners to organize personal information into groups or audience segments and activate addressable advertising to these audience groups.  In some circumstances, our adTech partners are responsible for determining the legal basis for their processing of information as required under applicable law.

Matterkind’s advertising services include processing pseudonymized personal information to analyze trends, understand audience composition, and predict the audience most likely to have a positive experience with a client’s advertisement. This analysis helps our clients plan and place digital adverting campaigns onto the most appropriate, respectful, and cost-effective sites and apps across connected channels and perform measurement, reporting, and analysis during and after the campaigns. 

As instructed by our clients, we place tracking technologies, such as tags, cookies, pixels, beacons, locally stored objects, and other bits of code, on our clients’ websites, apps, and ads that allow our adTech partners to serve ads, collect information to measure ads, and help clients reconnect with people in the future. These technologies collect IP address, mobile advertising ID, browser type, operating system, referral URLs, date/time stamps, pages viewed, and simple keyword tags.

On behalf of clients, we also receive and analyze data from social media platforms and similar partners 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 adTech partners, such as ad servers, demand-side platforms and sell-side platforms, we receive engagement data related to how people engage with our clients’ advertising.  This information helps our clients understand engagement with an online advertisement (if an ad was viewed or clicked) or other relevant interactions (e.g., products purchased). We analyze this information on behalf of clients to designate different audiences for different client brand messages, products and services, measure and report on advertising campaigns, and optimize for efficiency and effectiveness.

 

CHILDREN’S PERSONAL INFORMATION

Kinesso’s services are designed for a general audience and not directed to individuals under the age of 18. We do not knowingly collect or solicit personal information from individuals under 18 years old in connection with our services.  We do hold and process attribute information related to an adult or household with the presence of individuals under 18 years old, but not the directly identifiable personal information of that individual under 18 years old.  This information is processed only for the purpose of creating insights into possible advertising interests of the adults in the household (e.g., a new parent’s interest in diapers).  If you have any questions about our practices related to individuals under the age of 18, please contact us as specified in the How to Contact Us section of this Privacy Notice.

 

PURPOSES FOR PROCESSING PERSONAL INFORMATION

We use the personal information we obtain for legitimate business purposes, including to:

  • Pseudonymize personal information, which minimizes both the risk of misuse and the onward transfer of directly identifying personal information.
  • Enable our clients to accurately apply people’s expressions of preference and control to their digital advertising campaigns.
  • Provide our services to clients; process, evaluate, and respond to requests and inquiries; and send administrative information, such as changes to our terms, conditions, and policies. We will engage in these activities to manage our contractual relationships and/or to comply with a legal obligation.
  • Enable our clients to market their products and services across connected channels. We will engage in this activity with there is appropriate expressions of consent or where we have a legitimate interest.
  • Operate, evaluate, and improve our business (including developing new services; enhancing and improving our services; analyzing our services; managing our communications; performing data analytics and market research; and performing accounting, auditing, and other internal functions). We will engage in these activities to comply with a legal obligation and/or because we have a legitimate interest.
  • Protect against, identify, and prevent fraud, security breaches, and other criminal activity and risks. We will engage in these activities to comply with a legal obligation and/or because we have a legitimate interest.
  • Comply with and enforce applicable legal requirements, relevant industry standards, and our policies, including this Privacy Notice and/or Agency’s Terms and Conditions or Terms of Use. We will engage in these activities to comply with a legal obligation and/or because we have a legitimate interest.
  • Aggregate and/or anonymize Personal Information so that it will no longer be considered personal information. We do so to generate other data for our use, which we may use and disclose for any purpose.

If you are based in the European Economic Area (“EEA”) or the United Kingdom (“UK”), Kinesso, LLC is responsible for processing your personal information on the basis of our legitimate interests to do so and, in some cases, express consent.  Kinesso is a data controller under the relevant data protection laws when we collect personal information to:

  • Maintain a restricted system containing directly identifiable personal information sourced from our affiliates and other third-party partners for purposes of matching information we receive from our clients, affiliates, partners, and other third parties
  • Maintain a separate restricted system containing pseudonymous demographic, attribute, and interest data sourced from our affiliates and other third-party partners for purposes of powering our data-enabled software
  • Source data from third-party marketing survey providers who collect information from survey respondents, including demographic data and information about their personal interests, which helps power our data-enabled software
  • In some markets, we also collect directly identifiable personal information from survey respondents under express consent for purposes of matching marketing survey response data to other demographic, attribute, and interest data within our data-enabled software
  • Maintain mappings between our pseudonymous Kiis and the pseudonymous match keys used by our adTech partners

 

SHARING INFORMATION

We share personal 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 provide recommendations to clients on media planning. We also share personal information with our affiliates and other service providers to perform analytics or other services on our or our clients’ behalf, to power tools used by our affiliates, to enable the delivery of advertisements tailored to individuals’ predicted interests, to improve placement of advertisements and to improve our services.

In addition to disclosures of information in the ordinary course of business, we also 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 (“US”), 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.

 

ADDITIONAL INFORMATION REGARDING THE EUROPEAN ECONOMIC AREA (“EEA”): Some non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here. For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission, to protect your personal information.  You may obtain a copy of the EU’s Standard Contractual Clauses here.

With respect to historical transfers of personal information from the EEA, UK and Switzerland to the US under the EU/Swiss-US Privacy Shield framework, Kinesso remains certified and continues to process the personal information in accordance with the EU/Swiss-US Privacy Shield framework.  Click here to view our EU/Swiss-US 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

Where Kinesso acts as controller or covered business under the relevant data protection laws, 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 or would like to exercise your rights, including the right to review, correct, object to processing, opt-out of use, or delete your personal information, please complete the Web form on our People Care portal, or contact us as specified in the How to Contact Us section of this Privacy Notice. We will respond to your request as quickly as possible and consistent with applicable law. 

To protect your privacy and maintain security, we 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 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:

  • 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 WE PROTECT PERSONAL INFORMATION

We use reasonable administrative, technical and physical safeguards designed to protect personal information within our organization. We hold our employees accountable for complying with policies, procedures, and regulations regarding the protection and confidentiality of personal information. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the How to Contact Us section of this Privacy Notice.

 

UPDATES TO OUR PRIVACY NOTICE

From time to time, Kinesso may update and revise this privacy notice 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.

 

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. In addition, Kinesso’s affiliates include localized operating companies in countries around the world where Kinesso does business.

If you wish to exercise any of your privacy rights in connection with personal information processing as a data controller or covered business, 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 complete this form on our online People Care portal. You may also contact us using the following contact details:

 

ATTN: Digital Responsibility
Kinesso: peoplecare@kinesso.com
Matterkind: peoplecare@matterkind.com

Or for any query or issue, our Data Protection Officer for the UK and the EU can be contacted via email using the following details:

UK or EU DPO
Interpublic Group Limited

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.

 

 

 

CCPA CONSUMER PRIVACY NOTICE

Effective Date: October 6, 2021

Kinesso, LLC and Matterkind, an operating division of Kinesso (collectively “Kinesso,” “we,” “us,” or “our”) provide this CCPA Consumer Privacy Notice that applies to California residents who are not Kinesso employees, employee applicants, owners, directors, officers or contractors of Kinesso, including as applicable, those individuals’ emergency contacts and beneficiaries. 

This CCPA Consumer Privacy Notice sets forth our privacy practices as required by California Consumer Privacy Act of 2018 (“CCPA”).  Please note, there may be additional or different privacy notices or disclosures that govern our use of Personal Information beyond the CCPA.  Where the collection, use and disclosure of Personal Information is subject to the CCPA, this Privacy Notice must be construed in addition to and not in lieu of the Kinesso Products and Services Privacy Notice.  In the event of any conflict between this CCPA Consumer Privacy Notice and the Kinesso Products and Services Privacy Notice, this CCPA Consumer Privacy Notice shall prevail.  For collection, use and disclosure of Personal Information not subject to the CCPA, those separate and relevant privacy notices and disclosures shall prevail.  Any terms defined in the CCPA have the same meaning when used in this disclosure. 

Kinesso employees, applicants, owners, directors, officers or contractors of Kinesso, including as applicable, those individuals’ emergency contacts and beneficiaries in California should refer to the CCPA Employee Privacy Notice.

The CCPA confers privacy rights to California consumers and imposes corresponding obligations to covered businesses subject to the CCPA.  The privacy rights conferred to consumers include:  the right to know what Personal Information is collected about them and how that Personal Information is being used and shared; the right to delete Personal Information held by covered businesses; the right to object to the sale of Personal Information as “sale” is defined under CCPA; and the right to non-discrimination in service and price when exercising CCPA privacy rights.

Pursuant to the CCPA, we provide the following details regarding the categories of Personal Information we have collected or disclosed within the preceding twelve (12) months.

Categories of Personal Information Collected

    • Identifiers such as name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, state identification card number, or similar identifiers;
    • Personal information, as defined in the California safeguards law, including, without limitation, name, physical characteristics or description, address, telephone number, education, employment indicators, employment history, other financial related information, or predicted health and well-being interest indicators;
    • Characteristics of protected classifications under California or federal law (e.g., race, ethnicity, gender, marital status, pregnancy interests, childbirth interest indicators, breastfeeding interest indicators, and other health and well being indicators), religion or creed, ancestry, national origin, disability interests, citizenship, primary language, political affiliation/activities;
    • Commercial information, including records of personal property, products or services purchased, obtained or considered, or other purchasing or shopping interests;
    • Internet or other electronic network activity, including but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website, application or advertisement;
    • Geolocation data, such as device location;
    • Professional or employment-related information, such as work history and prior employer
    • Education information subject to the federal Family Educational Rights and Privacy Act, such as student records and directory information; and
    • Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, about a consumer’s preferences and characteristics.

We did not collect this personal information directly from California residents, but rather from publicly available databases, affiliate companies and third-party sources such as independent data providers, social media platforms and other third-party services. 

We collected the above personal information for the following business and commercial purposes:

  • Performing services on behalf of a client or affiliate
  • Developing and improving our services and programs for our clients;
  • Establishing a direct connection with our adTech partners;
  • Conducting research, analytics, media planning, and data analysis;
  • Maintaining our facilities and infrastructure;
  • Undertaking quality and safety assurance measures;
  • Conducting risk and security controls and monitoring, such as detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, etc.;
  • Detecting and preventing fraud; performing identity verification;
  • Performing accounting, audit, and other internal functions, such as counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, etc.;
  • Complying with law, legal process, and internal policies; maintaining records; and
  • Exercising and defending legal claims.
  • Activating addressable marketing messages and advertisements on partner platforms
  • Helping clients find customers or prospective customers interested in their products or services
  • Keeping Personal Information up to date and relevant

Disclosure and Sale of Personal Information

We disclose the above personal information for the business and commercial purposes discussed above to the following categories of recipients: service providers and third parties such as cloud computing and storage vendors, onboarding partners, publishers, demand-side platforms, supply-side platforms, and other adTech platforms and marketplaces, and partners, including clients’ partners, which help us with activation, measurement, fraud prevention, and analytics.  We also disclose the above personal information for the business and commercial purposes discussed above to our affiliates and clients. 

During the last year, Kinesso has not sold Personal Information, as broadly defined under the CCPA, to our service providers, third parties, affiliates or clients. 

Right to Access, Delete, or Opt Out of Sale

Pursuant to the CCPA, California consumers have the right to request Kinesso disclose the Personal Information we collect about you, delete the Personal Information we collect from you or opt out of the sale of your Personal Information.    Kinesso will verify your identity in order to fulfill your request.  If we are unable to verify your identity, we will be unable to fulfill your request.

To submit a request to access or delete your Personal Information, please complete this form on our online People Care portal.

You can also submit your request by mail or telephone using the contact information below:

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

Telephone: 1-888-914-9661, Pin #894002

Please note, Kinesso will retain certain Personal Information as necessary to comply with a legal obligation (including ensuring the deletion request is honored), 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 and only use the remaining data for the purposes provided by the statutory or regulatory exception.

Right to Not Be Discriminated Against

Pursuant to the CCPA, California consumers have a right to be free from discriminatory treatment when exercising privacy rights.  Kinesso will not discriminate against California consumers as a result of exercising a right to access, delete or opt out of the sale of their Personal Information.

Authorized Agents

The CCPA allows California consumers to use authorized agents to submit requests to Kinesso on their behalf.  Kinesso requires 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 California Secretary of State 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

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

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

Updates to our Privacy Notice

From time to time, Kinesso may update and revise this privacy notice 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.