Dentsu is a global media, creative and customer experience management group made up of several brands. We help our clients to improve how they advertise and market, whether by print, post, email or in the digital world. We believe that the responsible use of data supports business growth and builds strong relationships between brand and consumer. As a business, we are committed to respecting and protecting the privacy of all individuals we interact with. We are committed to being always transparent in our handling and processing of Personal Data in accordance with applicable privacy and data protection laws.
dentsu does business through its subsidiaries and affiliates worldwide. The privacy laws in some countries require a Controller (the legal entity (who defines the purposes for which the processing of personal information takes place and how that information is processed) to be selected.
Where this is relevant for the privacy laws in your country, the dentsu group company who acts as the Controller of your Personal Data, and who is responsible for processing your Personal Data will be the dentsu group company operating in your country or region unless dentsu International or another dentsu company identifies itself as the Controller for a specific interaction with you. The relevant dentsu group company is referred to as “our”, “us” and “we” in this notice.
If you have any questions or are unsure about who your Controller is, please review the additional information provided for your market below or contact us DPO@dentsu.com and we will ensure your details reach the correct entity.
This privacy notice explains in detail the types of Personal Data we may collect about you when you interact with us through our websites, digital experiences, business relationship management, events, B2B marketing activities or where you visit our offices. By using our website or services and providing your Personal Data to us, you are allowing our collection, use and disclosure of your Personal Data for the purposes set forth in this privacy notice based on the lawful basis set out in this privacy notice.
"Personal Data" means any information about the personal or material circumstances of an identified or identifiable individual. Your Personal Data therefore includes all data related to you that enables identification, such as your name, your address, your telephone number or your e-mail address.
This Privacy Notice does not cover:
These are all covered in separate privacy notices, or cookie notices which can be found through the relevant site of the market they operate in.
We may process Personal Data you provide directly to us, Personal Data we collect through automated means, or Personal Data we obtain through other sources. You are not required to provide any Personal Data, however, if you choose not to do so, we may not be able to provide you with our products or services or respond to your requests. Generally speaking, we will collect Personal Data relating to you and/or your use of our services in the following ways:
(A) Personal Data you provide to us:
We collect contact details when you sign-up to receive email alerts, attend one of our events, visit our offices, work with us, download our content, subscribe to our newsletters or where you ask us to respond to a query you have. The Personal Data we collect may include your name, email address, phone number, job title, and workplace location.
We collect Personal Data relating to your preferences regarding receiving marketing information from us and your communication preferences (where permitted under applicable privacy laws).
We may ask you where you are located as part of our marketing activities, or when you sign up to events or ask to attend meetings. This will not be tracked through your device at all and will only ever include what you have shared with us.
(B) Personal Data we collect through automated means:
We collect Personal Data about how you use our website(s). This includes Personal Data relating to the pages you visit on our website(s), the services or information you search for and the links and content you choose to access.
We may use the Personal Data you provide through your use of our website(s)to provide you with relevant content and to inform our marketing strategy. This type of activity is sometimes known as “profiling” – using automated means to process your Personal Data to analyse or predict your personal preferences, interests or behaviours. You can object to profiling (where entitled under applicable privacy laws).
We collect Personal Data about the device(s) you use to access our website(s) as well as other related information. You may find more information on the cookies we use and the purposes for which we use them on our separate Cookie Notice
(C) Data we collect from other sources:
We may collect Personal Data about you from third parties. Such third parties may include analytics providers, affiliate partners and third-party platforms such as LinkedIn. We may also collect Personal Data where you register and/or attend an event which we host or are a named affiliate partner of. We do not buy Personal Data lists.
Note that we do not actively seek to collect information about children or minors, or anyone’s sensitive Personal Data. Please see more details below.
We do not actively seek to collect the Personal Data of children or minors (as defined under the applicable law in your jurisdiction). If you have any concerns about your child’s privacy in relation to our services, or if you believe that your child may have entered Personal Data onto our website(s), please contact us at dpo@dentsu.com. We will delete such Personal Data from our records within a reasonable time.
We do not intentionally collect sensitive Personal Data as part of the processing activities carried out under this privacy notice.
Except where required by law, we use and process the Personal Data we collect about you for the following purposes:
Under various data protection laws we are required to advise you on the legal basis for processing your personal data. In the table below we set out further information about the purposes for which we use your personal data and the legal basis we rely on for its use (where required under applicable privacy laws). Note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.
In APAC we usually rely on Consent as our lawful basis in accordance with local laws. Where this is the case, we will have explicitly asked you to consent, and you will have the ability to withdraw your consent at anytime. Where we rely on a lawful basis other than consent, it will be as listed below.
Processing Activity
To arrange and run events: The process by which invitations are sent to, acceptances are received from and attendance at dentsu events, are managed.
To generate leads: We may use Personal Datacollected from visitors to and users of our website(s), attendees of events, or client contacts to locate potential leads.
To send you our newsletters and information relating to our brands and services: The distribution of dentsu's own commercial content to potential customers, leads and prospects, and anyone else who has subscribed to receiving such collateral.
To manage our relationship with you: The processing of basic contact details of clients and suppliers for the purpose of relationship, account and/or project management.
To arrange and manage visits to our offices: the process of ensuring we keep an appropriate record of all visitors to the office, as well as possible accidents or incidents that may have occurred.
To ensure our website(s) are kept relevant and useful: We conduct statistical analysis on your usage of our website(s) e.g. to enable us to improve our website(s), offer new features and material.
To ensure our website(s) remain secure: This process protects against malicious web activity and blocks access to our website(s) that violate enterprise policy. Cloud and endpoint web filtering service.
To respond to any enquiries or feedback that you send us: To update you with any changes to our terms and conditions/other policies
To respond to, and manage, data subject rights requests: The process of responding to data subject rights requests such as data subject access requests, data erasure requests, requests to opt out from specific type of processing and other, as legally required under relevant data protection laws.
To analyse and improve our services: this processing enables us to utilise our interactions with you to ensure we continue to provide the best service possible.
To maintain and update our records: we are required to keep up to date records to ensure we can operate efficiently and effectively as a business.
To protect and defend our legal rights / respond to complaints: This process involves complaints submitted to dentsu by regulators and/or individuals whistleblowing regarding dentsu Personal Data protection and management practices.
To facilitate acquisitions and potential acquisitions of or by our business, including any related transitional and business integration activities.
Types of data used
Contact data, data we collect from other parties, location data.
Contact data, data we collect from other parties, Personal Data relating to your use of our website(s).
Contact data, data we collect from third parties, location data, marketing and communications data.
Contact data, location data, marketing and communications data, technical Personal Data
Contact data, location data.
Personal data relating to your use of our website(s), Personal Data processed through automated means, technical Personal Data.
Personal data relating to your use of our website(s), technical Personal Data.
All Personal Data we collect may be relevant.
All Personal Data we collect may be relevant.
Personal data relating to your use of our website(s), email, name, phone, company name, job title.
Contact data, location data, marketing and communications data.
All Personal Data we collect may be relevant.
All Personal Data we collect may be relevant.
Lawful basis (where applicable)
Legitimate Interests
Legitimate interests or consent (where you have expressly provided it)
Consent
Contractual Necessity
Legitimate Interests
Legitimate interests (to study how clients use our service and engage with our content. To develop our service, to grow our business and to inform our marketing strategy) where permitted under applicable privacy laws.
Legitimate interests
Legitimate Interests or Contractual Necessity
Legal Obligation
Legitimate Interests or consent where cookies are used
Legitimate Interests or Legal Obligation
Legal Obligation or Legitimate Interests
Legitimate Interests
We will keep your Personal Data for as long as is necessary for the relevant service, in accordance with our legal obligations. After this time, your Personal Data will either be securely deleted or anonymised so that it can be used for analytical purposes. You may request further information about our retention periods via the contact details given in this privacy notice or request that we delete your data in accordance with your rights as set out below.
We maintain appropriate organisational and technological safeguards to help protect against unauthorised use, access to or accidental loss, alteration or destruction of personal data whether in physical or electronic form. We also seek to ensure our service providers and/or any approved external Third-parties who store or process personal data on our behalf do the same. The safeguards we use, depending on the circumstances, may include firewalls, penetration testing, vulnerability scans, encryption and restricted access to our IT systems.
Whenever we share Personal Data, access is controlled on a need-to-know basis, and is only provided where it is necessary to provide you with requested services or to allow us to perform any necessary or legitimate functions.
We will only transfer your Personal Data outside the market in which you are located where we are satisfied that adequate levels of protection are in place to protect the integrity and security of any Personal Data being processed and in compliance with applicable privacy and data protection laws. This may be through a contract we have in place with the importing company, or because we know that where the importing company is based has even stricter data protection laws than the one you are based in/ it was received in.
We take internal data protection very seriously. Our employees and the service companies commissioned by us have been contractually bound to treat personal data with appropriate confidentiality and to act in compliance with data protection regulations.
We use a number of third parties to perform business functions on our behalf, such as sending our newsletters and hosting our online services and customer relationship management. We will only disclose the information necessary to enable these third parties to perform their services. Our service providers are contracted to comply with our instructions.
We might share information with third parties who help us with our marketing efforts, including social media platforms, advertising networks, and ad tech companies. For example, we may share email addresses or other contact information with social media platforms so they can serve our advertising to you on their platform. Personal data received by our partners may also be subject to their privacy policies and the tools they provide for you to manage how your Personal Data is used for advertising purposes.
Dentsu International is a globally operating media group consisting of multiple companies. Therefore, we may from time to time disclose your Personal Data within our group of companies.
Where we transfer Personal Data between our group companies, we have covered these transfers by entering into an Intra-Group Data Transfer Agreement. This provides us with a mechanism to transfer Personal Data around the globe where necessary.
We may also disclose personal information with any successor to all or part of our business. For example, if part of our business is sold, we may give our customer list as part of that transaction.
Where required or permitted by law, Personal Data may be provided to others, such as regulators and law enforcement agencies, for example in response to a court order or a subpoena, or in response to a law enforcement agency request, or where we believe it is necessary to investigate, prevent or act regarding illegal activities, and as otherwise required by law.
We may also collect Personal Data from the parties described in this section.
You may request further information on the measures used for such transfers via the contact details given in this Privacy Notice.
Depending on the applicable privacy law of the market you are in, you may have several rights in relation to your Personal Data, including:
If you exercise the rights above, the request should include your contact information and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. In addition, you should provide adequate information that we can reasonably verify that you are the person about whom we collected the personal information (including information that enables us to verify the identifying information we possibly maintain about you).
We will respond to requests within the required timeframes. If we need extra time to respond, we will let you know why, and how long we require, in writing. To protect your Personal Data, we will only honour requests if we have been able to verify your identity or authority to make the request and confirm the Personal Data relates to you. The method used to verify your identity will depend on the type, sensitivity and value of the information, including the risk of harm to you posed by any access or deletion. Verification will usually be performed by matching the identifying information provided by you to the personal information that we already have.
Note that if you are in a market where these rights do not exist, we reserve the right to deny your request.
This privacy notice is limited to the Personal Data collected by us. We do provide links within our website(s) to other websites, including social media websites such as Facebook, Twitter and LinkedIn, or links to the sites of other dentsu entities. If you follow these links, your use of these websites will be governed by their applicable user and privacy notices since their data practices fall outside the scope of this privacy notice. Further, we can have no responsibility for or control over the Personal Data collected by any third-party website and we cannot be responsible for the protection and privacy of any information which you may provide on such websites.
This privacy notice may be updated from time to time to reflect changes in law, best practice, changes in what we do, or changes in the way we treat Personal Data. The date of the most recent revision will appear at the top of this page. If you do not agree to the changes, please stop using our services and refrain from sharing your Personal Data with us. You should check this notice frequently for updates.
If you have any questions about this privacy notice, our approach to privacy or you would like to exercise any of the rights mentioned in this privacy notice you can contact our Data Protection Officer in any of the following ways:
Note if your request relates to any Merkle data processing in the USA please go here.
We provide additional information about our controllers and data protection officers (as applicable), the privacy, collection, and use of personal information data subjects of dentsu located in certain markets.
(a) Transfers
The dentsu entities and other parties with which we share Personal Data may be located in European Economic Area, United Kingdom, United States of America, India, Singapore, New Zealand, and other countries. While they will often be required to comply with obligations to protect that Personal Data, we will are not responsible for ensuring they comply with the specific requirements of your country’s privacy and data protection laws.
(b) Data Subject Rights
Requesting correction or updating of your Personal Data. This enables you to have any incomplete or inaccurate Personal Data we hold about you corrected. In Australia, you have related rights, including asking us to tell third parties about the correction if we had disclosed the uncorrected Personal Data to them, or, if we decline to make a correction, to ask us to note your disagreement together with the data.
Belgium (dentsu)
Local Controller: Dentsu Belgium BV. Boulevard du Souverain 24, 1170 Watermael-Boitsfort, Belgium
KBO 0766.997.311
Contact us: E-mail: dpo@dentsu.com
Local data protection authority: Gegevensberschermingsautoriteit
https://www.gegevensbeschermingsautoriteit.be/burger/startpagina
(a) Your Brazil Rights
You have the following rights in relation to your personal data, including:
If you exercise the rights above and there is any question about who you are, we may require you to provide information from which we can satisfy ourselves as to your identity.
If you would like to access more specific information related to the processing of your personal data if the Brazilian law applies, we recommend that you access our Brazilian Privacy Policy.
If you would like to exercise any of the rights mentioned in this privacy notice you can contact our Data Protection Officer in any of the following ways:
Address: Data Protection Officer, Dentsu Brasil, 949 Brigadeiro Faria Lima Avenue. Pinheiros. 11º floor. São Paulo, SP. 05426-100.
Email: brasil.dpo@dentsu.com
Denmark (dentsu)
Local Controller: Dentsu Danmark A/S
Overgaden Neden Vandet 7, 1414 Copenhagen
CVR: 58 22 78 11
Contact us: E-mail: dpo@dentsu.com
Local data protection authority: Datatilsynet
You will find Datatilsynet’s contact information at www.datatilsynet.dk
Denmark (Merkle)
Local Controller: Merkle Denmark A/S
Meldahlsgade 5,5., 1613 Copenhagen CVR: 25 53 32 67
Contact us: E-mail: dpo@dentsu.com
Local data protection authority: Datatilsynet
You will find Datatilsynet’s contact information at www.datatilsynet.dk
Der Verantwortliche im Sinne der DSGVO ist:
Carat Deutschland GmbH Speicherstraße 53 60327 Frankfurt am Main
Vetretungsberechtigte Geschäftsführer: Andrea Beninde, Jens Erichsen, Nina Brit Brando, Giulio Malegori
Amtsgericht Frankfurt am Main HRB 117248 UST-IdNr. DE 813 252 362
Für Fragen zur Verarbeitung Ihrer personenbezogenen Daten durch uns oder zum Thema Datenschutz allgemein wenden Sie sich bitte an datenschutz_germany@dentsuaegis.com.
Impressum
Dentsu Germany GmbH
Speicherstrasse 53
D-60327 Frankfurt am Main
Tel: +49 (0)69 505026-100
Fax: +49 (0)69 505026-500
Authorized managing directors:
Karin Zimmermann, Georg Berzbach, Werner aus den Erlen, Walter Hassler, Giulio Malegori, Nathalie Schubert, Rosemary Alexander, Björn Osterndorff, Robin Jansen
District Court of Frankfurt am Main HRB 117289
VAT ID No. DE 815 235 688
Ι) EDEE/HACA, Hellenic Association of Communications Agencies. EDEE/HACA is the national trade body representing all communications disciplines in Greece: Advertising, Media, PR, Integrated Marketing Communications, Branding & Design. EDEE/HACA is a member of: European Association of Communications Agencies (EACA), International Communications Consultancy Organisation (ICCO), Federation of European Direct & Interactive Marketing (FEDMA), Integrated Marketing Communications Council Europe (IMCCE), (Website: http://www.edee.gr/).
ΙΙ) SEE (Advertising Self-Regulation Council). SEE is the independent national self-regulatory organization of the Greek advertising industry, officially established by law in 2003. Its main goal is the right implementation of the ethical rules of the Greek Code of Advertising and Communications Practices by the industry, to ensure that consumers are protected, and marketing communication maintains its credibility. SEE is a member of the: European Advertising Standards Alliance (EASA), International Council for Ad Self-Regulation (ICAS), Institute of Communication. SEE is fully and legally recognized by the Greek regulators as having the exclusive responsibility for upholding the provisions of the Greek Code of Advertising and Communications Practices and has won EASA’s Bronze Best Practice Award in 2019. SEE’s services include: 1. Receiving and acting on complaints regarding marketing communications, 2. Providing copy advice for unpublished advertising material, 3. Issuing sector/issue based Best Practice Recommendations, 4. Informing companies and consumers about the Advertising Code, 5. Providing training of SEE’s Committee members, 6. Offering educational seminars to companies wishing to learn more about the Code and good advertising practices, (Websitehttp://www.see.gr/). The purpose of the organization is both the suppressive and voluntary control of the content of all forms of commercial communication in order to ascertain consultatively, preventively or repressively compliance with the provisions of the ‘GREEK ADVERTISING – COMMUNICATION CODE’, always within the framework of the applicable Greek legislation. The organization is also responsible for the establishment and proper functioning of the crisis management committees. The Primary Committee (5 members) consists of representatives of EDEE and SDE (Hellenic Advertisers Association). The Secondary Committee (12 members) is complemented by representatives of the Μedia.
III) Hellenic Data Protection Authority (DPA). The Hellenic Data Protection Authority is a constitutionally established independent public authority, which has as its mission the supervision of the application of the General Data Protection Regulation (GDPR), national laws 4624/2019 and 3471/2006, as well as other regulations concerning the protection of the individual from the processing of personal data. The Hellenic DPA is competent to handle complaints and investigate, if deemed necessary in cooperation with supervisory authorities of other EU member states, cases of alleged violations of data protection law. Data Subjects, especially if Greece is their habitual residence or place of work, or the place of the alleged infringement, shall fill in all required fields in the appropriate form depending on the case/subject-matter of the complaint and attach any documents directly linked to the complaint. Data subjects have the right to assign non-profit bodies or organizations or unions or associations that legally operate, have statutory goals of general interest and operate in the field of protection of rights and freedoms of data subjects with regard to data protection, to submit a complaint, to the Hellenic DPA, on their behalf. (Website: https://www.dpa.gr/en/individuals/complaint-to-the-hellenic-dpa/).
Dentsu is represented by dentsu Hungary Kft. in Hungary, contact details:
Address: 1027 Budapest, Kacsa u. 15-23.
Phone number: +36 1 411 2200
Email: privacy.hungary@dentsu.com
If you are an Israeli resident, by approving this privacy policy or by using the services on the website you provide consent to the processing of your personal data hereunder.
We note that you are not legally required to provide such consent, but without it, we will not be able to provide the services offered.
Local Controller: Italy
Italian DPO: Avv. Lapo Curini Galletti
email: lapo.curinigalletti@dentsu.com
Netherlands (dentsu)
Local Controller: Dentsu Netherlands BV
Moermanskkade 85, 1013BC Amsterdam, the Netherlands
KvK 33202665
Contact us: E-mail: dpo@dentsu.com
Local data protection authority:
Autoriteit Persoonsgegevens (AP) https://www.autoriteitpersoonsgegevens.nl/
Local data protection authority:
Autoriteit Persoonsgegevens (AP) https://www.autoriteitpersoonsgegevens.nl/
(a) Transfers
Some of our dentsu entities may be subject to privacy laws that do not provide the same level of protection as your local privacy laws. By providing Personal Data to us, you consent to the disclosure of your Personal Data to dentsu entities in such other jurisdictions.
Norway (dentsu)
Local Controller: Dentsu Norge AS
Kristian Augusts gate 23, 0164 Oslo, Norway
Reg. No. 927 445 875
Contact us: E-mail: dpo@dentsu.com
Local data protection authority: Datatilsynet
You will find Datatilsynet’s contact information at www.datatilsynet.no
(a) Your Rights
As a supplement to the rights mentioned above, you have the following rights under the Data Privacy Act of 2012 and its implementing rules and regulations:
(1) Right to Access. You may have the right to reasonable access to, upon demand, the following:
(2) Right to Damages. You may have the right to be indemnified for any damages sustained due to such inaccurate, incomplete, outdated, false, unlawfully obtained or unauthorized use of personal data, taking into account any violation of your rights and freedoms as data subject.
(3) Right to Lodge a Complaint. You may also have the right to lodge a complaint before the National Privacy Commission for any violation of your data privacy rights.
Le informamos también de que nos encontramos adheridos al Código de Conducta de Protección de Datos en la Actividad Publicitaria de AUTOCONTROL, acreditado por la Agencia Española de Protección de Datos y, por tanto, que estamos vinculados a su sistema extrajudicial de tramitación de reclamaciones cuando las mismas estén relacionadas con protección de datos y publicidad. Si no has quedado conforme con la respuesta que hemos dado a tu solicitud, además de presentar una denuncia ante la Agencia Española de Protección de Datos, puedes formular una reclamación ante el Jurado de la Publicidad de AUTOCONTROL en el plazo no superior a un mes natural desde la finalización del proceso, contactando a través del siguiente correo electrónico: reclamaciones.pd@autocontrol.es.
Sweden (dentsu)
Local Controller: Dentsu Sweden AB
BOX 4125, 102 63 Stockholm
Reg. No. 556259-6733
Contact us: E-mail: dpo@dentsu.com
Local data protection authority: Integritetsskyddsmyndigheten
You will find Integritetsskyddsmyndigheten’s contact information at www.imy.se/
Sweden (Merkle)
Local Controller: Merkle Sweden AB
BOX 4125, 102 63 Stockholm
Reg. No. 556807-5641
Contact us: E-mail: dpo@dentsu.com
Local data protection authority: Integritetsskyddsmyndigheten
You will find Integritetsskyddsmyndigheten’s contact information at www.imy.se/
(a) Your Thailand Rights
This section describes the data privacy rights of Thailand residents. Below you will find the additional information required as per applicable data protection legislation.
Section 10 - Contact us
You may contact our representative in any of the following ways
Address: 968 U-Chu Liang Building, 27th- 28th Floor, Rama 4 Road, Kwaeng Silom, Khet Bangrak, Bangkok 10500, Thailand
Telephone: 02 238 6654
Email: THDPO@dentsu.com
The Rights of the Data Subject
Under Article 11 of the Turkish Personal Data Protection Law numbered 6698 ("PDPL"), you, as a data subject, have the right to:
- Learn whether your personal data has been processed,
- Request information if your personal data has been processed,
- Learn the purposes of such processing of your personal data and whether processed data is being used in accordance with these purposes,
- Learn the third persons to whom your personal data has been transferred within or outside the country,
- Request correction in case the processing of your personal data is incomplete or inaccurate,
- Pursuant to the Article 7 of the PDPL, request the erasure or destruction of your personal data and request notifying to them to whom the personal data is transferred,
- Object to the occurrence of a result against you by analyzing the data processed solely through automated systems
- Request compensation if you suffered damages due to unlawful processing of your personal data.
You, as the data subject, may send an e-mail to dpo@dentsu.com (using your e-mail address previously provided to Dentsu or your registered e-mail address) to exercise the above rights. If the execution of the requests requires additional costs, such costs will be charged to you by Dentsu in accordance with the price list established by the Personal Data Protection Authority. The explanations of the data subject in the application form regarding your request for exercising the above-mentioned rights should be clear and comprehensible.
In case the application is made by the data subject directly, the application should contain their name, surname, Turkish ID number (passport number for foreigners), address (so that our response can be conveyed) and documents evidencing the identity.
In case the application is made by a third party who acts on behalf of the data subject, such person should be specifically authorized on this matter and should submit a document as a proof of representing their authority. In this case, the application should contain the names, surnames, Turkish ID numbers (passport numbers for foreign persons), addresses (so that our response can be conveyed) of both the applicant and the data subject and documents evidencing their identities.
Moreover, data subjects may send a request to exercise their right to complaint before the Personal Data Protection Authority with the contact information below:
Address : Nasuh Akar Mah. Ziyabey Cad. 1407. Sok. No: 4 06520 Balgat - Çankaya / Ankara
Phone Number : +90312-216-5000
Website : http://www.kvkk.gov.tr/
Please refer to our United States-specific privacy policy and product privacy policy.