[m]PLATFORM Privacy Notice

This is the global [m]PLATFORM privacy policy. Please read our EU and language specific versions here.

Effective Date: Feb 2, 2022

[m]PLATFORM Privacy Notice

This Privacy Notice describes the information [m]PLATFORM collects from web sites, applications, and other digital properties, we refer to all of these as “Sites”. We explain how we use this information in our “Platform” and to provide “Services” to our clients. We also explain how you can manage your privacy choices and exercise your rights in relation to certain data about you collected and used by [m]PLATFORM.

For purposes of this Privacy Notice, “device” includes computers, smartphones, tablet computers, e-readers, connected television and/or over-the-top television devices (“OTT TV Devices”) and other digital devices capable of maintaining an Internet connection; and “mobile device” includes smartphones and tablet computers.

Who are we?

[m]PLATFORM is a business which operates globally as part of the GroupM group of companies. In the European Economic Area (EEA) and Switzerland the [m]PLATFORM legal entity responsible for the data that [m]PLATFORM collects is Choreograph Limited.  Outside of the EEA and Switzerland the responsible legal entity is Choreograph LLC.

[m]PLATFORM is an audience intelligence and activation solution that builds personalized consumer relationships at scale. In addition to the technology suite, it is a worldwide service organization comprised of analysts, data strategists, search and social specialists, and product and media experts focused on ensuring consistent delivery in all markets where our clients do business. [m]PLATFORM is part of GroupM’s technology stack and is used by WPP group companies including Choreograph.  For more information about Choreograph, see here.

If you have any questions or comments regarding this Privacy Notice, including any request to exercise your legal rights, please see the “Contact Us” section at the bottom of this Privacy Notice. Please note that this Privacy Notice has been translated from English into multiple different languages. If there are any conflicts or inconsistencies between the different language versions of this Privacy Notice, the English version will prevail.

What are our Services?

[m]PLATFORM owns and operates a technology platform (the “Platform”) that provides various advertising-related services (collectively, “Services”) for its clients, which consist of other GroupM agencies and businesses as well as other companies within the WPP plc group of companies including Choreograph. [m]PLATFORM does not provide services directly to consumers, our clients are corporate businesses who work with GroupM agencies to plan and buy media campaigns (advertising).

GroupM agencies and Choreograph use our Platform and Services, for their own clients, to help them understand the advertising they deliver online (e.g. what sites it was delivered on, who saw it and whether or not anyone interacted with it) and to improve the effectiveness of that advertising. We also help them to try deliver advertising to consumers who are more likely to be interested in their products and services.

When we help clients select audiences to deliver their advertising to, we use certain demographic information (such as age, gender, education, income and household status (e.g., number of children)), geography, interests, activities, and similar information (“User Information”). We call this type of advertising “Interest-Based Advertising”.

What Categories of Information Are Collected by [m]PLATFORM?

The Platform is designed to collect and/or use information about the type of web pages you visit and about interactions you have with Sites and with our clients’ advertisements. We also collect information that identifies the browsers and devices of users who have viewed our clients’ advertising. This information includes the following categories of data:

Technical Identifiers

These can be used to identify a user’s browser, mobile advertising environment, and/or device and typically include:

• Cookie IDs
• Mobile advertising IDs (e.g., IDFAs and Google Advertising IDs)
• OTT TV Device Identifiers for Advertising (a unique ID assigned by an OTT TV provider)
• [m]PLATFORM’s “[mP]ID” proxy identifier for the above IDs

Additional Technical Information

• Internet protocol address (“IP address”) and data derived from an IP address, such as non-precise geolocation data that indicates the country, region, city, and/or postal code of a device
• Type of Internet browser, browser language, and operating system
• Connection type (wired or Wi-Fi), network to which the device is connected, and mobile carrier (if available)
• Latitude/longitude of a mobile device

Online Activity Information

[m]PLATFORM collects the information explained below about your online browsing activity to determine what types of activities, services and products you and other users may be interested in and how you and other users interact with certain advertisements. This information includes:

• Internet domain level information and/or content topics about the Sites and pages viewed (i.e., in order to ascertain interests)
• Site/page you came from before viewing an advertisement
• Date and time of online activity
• Frequency of visits to a Site
• Search terms used on a Site
• Interaction with an advertisement (e.g., whether you click on an advertisement)

The User Information collected directly by [m]PLATFORM is solely collected online from Sites as further discussed below in the “How Do We Collect Information?” section.

How Do We Collect Information?

We collect information and receive information on behalf of our clients about you when you visit the online properties of the advertiser clients for whom [m]PLATFORM provides services, or third-party publishers (e.g., news sites). In order to do this we use cookies, advertising IDs, pixels, and other technologies. Here are some explanations of these terms:

The following chart provides information about our Mookie cookies, all of which are “persistent” cookies (meaning they are stored until they expire or are deleted/removed by a user) mapped to the mookie1.com domain:

What Categories of Information Are Used By [m]PLATFORM and What Are the Sources of That Information?

User Information Collected by [m]PLATFORM 

User Information collected directly by [m]PLATFORM is solely collected online from Sites as further discussed in the “How do Do We Collect Information?” section.

User Information Received from Third Parties

In addition to the User Information [m]PLATFORM collects directly from users, we also receive both online and offline User Information collected by third parties, including demographic and interest information for use in our Services. These third parties include our clients and carefully selected partners and service providers.  When we receive offline User Information, this information is provided to us via a partner or service provider in conjunction with a cookie ID, advertising ID, or similar user ID that identifies a user to us, the client, partner or service provider (through a process called “cookie syncing”.) We may also receive any names, mailing addresses, phone numbers, email addresses or similar data connected with these IDs.

How Does [m]PLATFORM Use This Information? 

[m]PLATFORM processes the information it collects and receives for the purposes of providing the Services to clients as explained above, as well as for administrative, security and compliance purposes. Specifically, we carry out the following activities:

Ad Selection, Delivery, Reporting

We analyze the information collected when client advertising is delivered through [m]PLATFORM and information received from our partners. We organize this information into collections of IDs (which we call segments), based on various components of the User Information we explained above.  For example, we may have segments of IDs that visit sport websites. GroupM agencies then use these segments within the Platform to deliver Interest-Based Advertising for their clients, using our partners and service providers. This advertising may be delivered across devices.

We may also integrate (and use for the same purposes) User Information obtained from other carefully selected companies (including Site owners, data providers and data aggregators).

We also maintain our own internal identifier, which we call “[mP]ID”. We use the [mP]ID to associate information relating to browsers, environments, and/or devices that we reasonably believe belong to the same user. This helps us to provide more useful and relevant advertising to a specific user, regardless of the browser, device, or environment.

Personalization

In order to provide our client-specific personalization Services, we:

• collect information on each client’s Sites (this includes websites, apps, and other digital properties) – as described above in the “How Do We Collect Information?” section;
• access or store this information on devices (via cookie IDs and advertising IDs, as applicable); and
• analyze the information collected, sometimes with other information received from the client and organize it into segments of IDs, based on the various User Information we have

Our clients can then use these segments to deliver, on their own behalf or on behalf of their clients, Interest-Based Advertising to users on their devices (this is through a variety of means).

Where we are providing this client-specific personalization, the segments that we build for one client are logically segregated from the segments and data of other clients. Data collected in this way, and the segments produced, can only be used on behalf of that specific client.

Measurement

We process User Information to deliver advertisements and measure the delivery of these advertisements, to learn about what factors make advertising successful or unsuccessful for advertisers and generate reports to understand and improve Service usage and advertising effectiveness.

Storage and Access of Information

In order to provide our Services, we store our Mookie cookies on the browser(s) of individuals to whom we have delivered advertising and then recognize the Mookie cookies, when your browser is used to access websites of our clients and publishers we work with.  Sites on which we are dropping and/or reading, or seek to drop and/or read, Mookie cookies should tell you about the use of third-party cookies, and in particular Mookie cookies where required by law, on those Sites. In the data feed we receive from our partners in connection with the delivery of digital advertising in mobile application environments we also receive Advertising IDs associated with users’ mobile device platforms/operating systems and recognize these Advertising IDs.

We use the information collected and received for Interest-Based Advertising, such as:

• Matching Data to Offline Sources – as indicated above under the “User Information Received From Third Parties” section:
  • We receive offline User Information, including demographic and interest information, from other companies, including our clients, partners and service providers, that is collected outside the Platform and is provided to us for use in our Services. It is the responsibility of those companies collecting that data to do so in an appropriate and legal way, and to permit sharing that information with us for our purposes.
  • When we receive offline User Information, this information may be provided to us via a partner or service provider in conjunction with a cookie ID, advertising ID, or similar user ID that identifies a customer or consumer to the client or service provider.
  • In addition, we may receive names, mailing addresses, phone numbers, email addresses or similar data connected with the IDs we receive.
• Linking Devices – we make use of our own [mP]ID identifier to associate information relating to browsers, environments, and/or devices that we reasonably believe belong to the same user, in order to help provide more useful and relevant advertising regardless of browser, environment, or device.
• Precise Geographic Location Data – when we have the necessary rights to do so we may receive and/or use a user’s precise geographic location data for the purpose of bidding on and/or delivering “moment in time” advertising. [m]PLATFORM does not store or otherwise save precise geographic location data.

What Categories of Third Parties Do We Share Data With?

[m]PLATFORM shares data with GroupM agencies and Choreograph and their clients for purposes of delivering Interest-Based Advertising, analytics, and the other Services described above. We may also share data with third-parties that perform services and functions on our behalf and/or on behalf of our clients, in the provision of the Services such as companies that are responsible for the actual delivery of Interest-Based Advertising – including demand-side platforms, advertising networks, advertising exchanges, and ad servers.

If we reasonably believe we are obliged by law or legal process to disclose information to a third party (including law enforcement), then we will do so. In addition, we may disclose information to a third party (including an auditor or other service provider) in order to investigate, prevent, or take action regarding suspected or actual prohibited activities and/or in order to review, evaluate, or address the integrity or security of our Platform and Services.

Sale of Personal Information

[m]PLATFORM collects information from or about you, including personal information, through the provision of its Services as described in this Privacy Notice. We may disclose certain information we collected about you for purposes that may be considered a “sale” under the California Consumer Privacy Act (“CCPA”). Under the CCPA, you have the right to opt out of the “sale” of your personal information. If you are a California resident and want to exercise this right, please see the instructions below in the “California” section.

Memberships

We are a member of the Digital Advertising Alliance (DAA), the European Interactive Digital Advertising Alliance (EDAA), and the Digital Advertising Alliance of Canada (DAAC). In connection with these memberships, we adhere to the DAA’s self-regulatory framework, the IAB Europe EU Framework for Online Behavioural Advertising, and the DAAC’s Canadian Self-Regulatory Principles for Online Behavioural Advertising, respectively, in those markets where the applicable self-regulatory framework applies, and we support deployment of the Advertising Option icons (AdChoices and, where available, AppChoices). Advertisements that are provided by organizations that participate in these frameworks display the icon shown below when technologically feasible. Clicking on the icon provides you with information about Interest-Based Advertising.

We participate in the IAB Europe’s Transparency & Consent Framework as a “global vendor” (ID number 98).

Opt-Out/Right To Withdraw Consent

You may opt out of [m]PLATFORM Interest-Based Advertising through several mechanisms. If you opt out, you will still see ads, but those ads are less likely to have anything to do with products or services you care about. With Interest-Based Advertising, you receive ads and offers that are more likely to be of interest to you.

You may choose not to receive customized third-party advertisements via [m]PLATFORM targeting cookies on the browser you are using by clicking below. If you do this the [m]PLATFORM targeting cookies will be replaced with a set of “opt-out” cookies. Any Interest-Based Advertising data linked to the replaced [m]PLATFORM targeting cookies will not be used for Interest-Based Advertising on that device or browser.

If you use multiple browsers or devices and wish to limit the data that [m]PLATFORM collects and do not wish to receive [m]PLATFORM Interest-Based Advertising on any of them, you must opt out from each browser and device individually.

To opt-out of data collection via cookies from [m]PLATFORM please click here.

Our opt-out cookies are programmed to expire ten years after they are initially issued. If you buy a new device, upgrade or change web browsers or clear your cookies (i.e. delete these opt-out cookies), you will need to perform the opt-out process again. In order for the opt-out process to work, your browser must be set to accept third-party cookies. If cookies are not enabled in your browser, including if third-party cookies are disabled, or if you use certain ad-blocking tools, our opt-out mechanism may not work properly.

In browser environments, you may also refuse or remove cookies from both [m]PLATFORM and other service providers, via the following methods:

• Adjusting your browser settings to refuse or remove cookies, which would result in the cessation of Interest-Based Advertising via cookies from [m]PLATFORM and from other providers. However, by doing so, you may not be able to use certain features on certain web sites or take full advantage of all web site offerings and Interest-Based Advertising. You may refuse or remove cookies by following the directions provided in your browser settings. Further information about cookies is available at aboutcookies.org, www.youronlinechoices.com, and www.aboutads.info/consumers#cookies.
• Adjusting the cookie settings at the level of the web site owner where you granted us consent to our cookie usage; cookie settings options may vary by web site owner.
• Opting out of Interest-Based Advertising via our targeting cookies, as well as the targeting cookies of other service providers, at the following web sites:
• aboutads.info/choices/
• youradchoices.ca/choices/
• youronlinechoices.com (by clicking the “Your ad choices” link after selecting the appropriate country)

You may also limit ad tracking in mobile and OTT TV Device app environments. For the most effective and up-to-date methods for doing so, you should consult instructions provided by those device manufacturers. The following information is solely for informational purposes, and we cannot guarantee that the methods below are the most current:

• Going to the privacy setting on your mobile device as well as on your OTT TV Device and selecting “Limit Ad Tracking” via your device settings, which will result in the elimination of Interest-Based Advertising via the applicable advertising ID from [m]PLATFORM and from other providers in addition to [m]PLATFORM.
• Opting out of Interest-Based Advertising via the applicable advertising ID from [m]PLATFORM and/or other providers via the AppChoices app. Please note that, in order for the AppChoices app to function properly, the “Limit Ad Tracking” device setting must not be selected. Interest-Based Advertising data previously collected or received in association with the replaced advertising ID will not be used via [m]PLATFORM for Interest-Based Advertising on any other device or browser that we have reasonably linked to the mobile app environment where the information was collected. Additional information regarding the AppChoices app is available at http://www.aboutads.info/consumers and http://www.youradchoices.ca/choices/.

For further information about what data [m]PLATFORM holds about you, please click here.

Children’s Privacy

[m]PLATFORM’s Services are not directed at children (as defined by applicable law) or at Sites primarily directed to children. [m]PLATFORM does not knowingly collect information from children (determined in accordance with the age requirement for the applicable country). If you believe a child has provided us with personal data and would like to have the information removed, please contact us using any of the methods set forth below in the “Contact Us” section.

Transfer of Data In The Event Of Acquisition

In the event that another company acquires all or substantially all of our assets or all or substantially all of the assets of our Platform business through a consolidation, merger, asset purchase, corporate reorganization, or other transaction, we reserve the right to transfer all information or all Platform information, as applicable, that is in our possession or under our control to the acquiring party.

Information Security and Global Data Transfers

We follow generally accepted online advertising industry standards to protect against unauthorized access to, unlawful processing of, unauthorized retention of, and unauthorized disclosure of data. These standards include undertaking necessary physical, electronic, and management activities required to protect data integrity, access, and use. Please keep in mind, however, that despite these efforts to protect data on our servers, no method of transmission over the Internet is guaranteed to be secure.

[m]PLATFORM Services and the Platform are used globally and therefore we may transfer data to countries around the world, including countries outside your country. We will, where necessary, put in place appropriate safeguards to ensure such data is protected. When we transfer personal data from the EEA or Switzerland or the UK either to an affiliate or an unaffiliated entity (e.g. a service provider performing services on our behalf) outside the EEA or Switzerland or the UK, we enter into standard (“model”) contractual clauses with the recipient in order to ensure an appropriate level of data protection.

Data Retention

We maintain the information we collect through our Services in non-aggregated form for a period of not more than 13 months, and we retain much of this data for shorter periods of time. This data includes domain level information, content topics, ad interactions, browser type and language settings.  We maintain this information for the 13-month period to enable our clients to perform year-over-year analyses. For example, a retailer may wish to compare the effectiveness of its online advertising activities at Christmas for the current year vs. the effectiveness in the prior year. A 13-month retention period enables that client to perform such comparison.

We maintain information we collect through our Services in an aggregated form for a period longer than 13 months.

California

Section 1798.100 of the California Civil Code provides residents of California with additional rights with regard to their personal information. If you are a California resident, you may exercise the following rights regarding your personal information, subject to certain exceptions and limitations:

How to Exercise Your CCPA Rights

To submit a request to exercise any of these rights, please contact us by email at [email protected]  or by mail to Choreograph LLC, 175 Greenwich Street, 3 WTC, New York, NY 10007, USA, Attn: Privacy.

In order to process your request, we may need you to provide additional information to allow us to confirm your identity or the authority of any third party submitting the request on your behalf. We do this as a security precaution and to ensure that we do not disclose personal data to the wrong person.

Do Not Track

California law requires us to disclose how we respond to browser “Do Not Track” signals or other choice mechanisms relating to Interest-Based Advertising. We have not yet developed a response to browser “Do Not Track” signals, and do not change any of our data collection practices when we receive such signals. We will continue to evaluate potential responses to “Do Not Track” signals in light of industry developments or legal changes.

For more information on opting-out of Interest-Based Advertising, please see the “Opt-Out/Right to Withdraw Consent” section above.

Changes to this Privacy Notice

Please note that because of the changing nature of privacy laws and regulations, digital technologies, and our business, we may modify this Privacy Notice from time to time. Please review this Privacy Notice periodically to become aware of any changes that may have occurred (we will update the effective date at the top of the page to help you know when changes have been made).

About Us

Other than when acting at the direction of a client or other third party, [m]PLATFORM is a data controller responsible for your personal data (as this term or similar term is defined by applicable law) when you interact with our Services.

Contact Us

Europe (Choreograph Limited )

• By email to [email protected]
• By post to Choreograph Limited, c/o GroupM, Sea Containers, 18 Upper Ground, London, United Kingdom, SE1 9GL Attn: Privacy

 Worldwide (Choreograph LLC)

• By email to [email protected]
• By post to Choreograph, 175 Greenwich Street, 3 WTC, New York, NY 10007, USA, Attn: Privacy