PUBLICIS® COSMOS Privacy Policy 2018-03-09T18:57:46+00:00

PUBLICIS® COSMOS Privacy Policy

What is PUBLICIS® COSMOS?

PUBLICIS® COSMOS is an intelligent marketing platform powered by artificial intelligence and machine learning algorithms that learn from customer data to help Marketers (as defined below) analyze, better understand and engage with their customers across all marketing channels.

What Activities does this Policy Cover?

This Privacy Policy governs the activities and functionality associated with the PUBLICIS® COSMOS technology platform and its use on behalf of PUBLICIS® COSMOS’s advertiser clients and their agencies (“Marketers”) and others (collectively “PUBLICIS® COSMOS Clients”).  PUBLICIS® COSMOS may use technology resources and capabilities including PUBLICIS® COSMOS cloud on Azure, data, proprietary algorithms, data models, APIs and other and software, and machine learning to enable Marketers to:

1) Create a single view of their customers across devices and channels;

2) Amplify and enrich their understanding of their customers using data which may come from PUBLICIS® COSMOS’s data partner Adobe and/or Microsoft;

3) Interact with and engage their customers more effectively, deepening their understanding of the customers; and

4) Learn about their audiences from many perspectives, and help them understand how to deliver the most relevant and effective advertising to the right audiences at the right time.  PUBLICIS® COSMOS analyzes customer data, creates cross-device and cross-channel mapping using an ID graph, and predicts intent-driven micro-moments for relevant experience, customer segmentation and other related services.  The same tools may also help other PUBLICIS® COSMOS Clients understand and better serve other groups of people.

This Privacy Policy explains how PUBLICIS® COSMOS collects data about Clients’ customers and potential customers (“Users” or “You”) and how PUBLICIS® COSMOS uses data, which it analyzes with software and technology to help Clients learn how to deliver their messages most effectively.

What Data Does PUBLICIS® COSMOS Collect or Receive, and How is that Data Used?

PUBLICIS® COSMOS gathers and analyzes data on behalf of Clients from several sources.  Different data sources may be used for different Clients, and even for different advertising campaigns or other activities.  Data sources may include a Client’s own customer lists, data derived from the delivery of advertising (data that PUBLICIS® COSMOS receives from ad servers and mobile apps about Users’ viewing of and interaction with ads, for example), data provided on behalf of Marketers by demand side platforms  and ad networks, which may include User attributes and behavior (including interaction and engagement with content and advertising), and other online and offline data that is or can be linked to Clients’ User data.

When You sign up to receive information from a Marketer, or You view or click on an advertisement, the Marketer or its service providers may collect information about that interaction, using cookies, IP addresses, and other identifiers, and may share it with PUBLICIS® COSMOS and others who assist in selling, planning, delivering and accounting for ads.  PUBLICIS® COSMOS may receive information about websites and content viewed, mobile apps used, search terms, engagement with ads, contextual and demographic (age, gender and income) information from Marketers, their service providers or other third parties.

Clients may provide PUBLICIS® COSMOS with lists of customers who have purchased their products, email addresses of customers who have agreed to receive marketing messages, and other customer information.  Customer names and email addresses are examples of information that identifies individuals.  This is known as “personally identifiable information,” or “PII.”

Clients may also authorize their service providers, such as the ad networks that deliver their ads to websites, or loyalty programs that track their customers’ purchases, to provide PUBLICIS® COSMOS with information associated with a unique identifier, such as a cookie or—on a mobile device— a platform-generated advertising ID.  These identifiers are generally considered non-personal information.

PUBLICIS® COSMOS may also license directly certain third-party data, such as demographic data or shopping data, which it may associate with identifiers it receives from Clients or others, or identifiers that PUBLICIS® COSMOS creates for a Client.  PUBLICIS® COSMOS also licenses analytics and insights about certain audience segments, and information about whether individual customers fit in those segments, from media companies and others.

PUBLICIS® COSMOS enables Marketers to understand the people they want to reach and helps other Clients interact more effectively with groups of people.  PUBLICIS® COSMOS may also use the knowledge it gains about Users in the aggregate to refine and improve its own services.

PUBLICIS® COSMOS links the data it receives about Users’ activities on different platforms or devices, such as mobile phones, computers, tablets, and TVs, in order to help Marketers better understand Users’ interests for the purpose of delivering targeted “Interest Based Advertising,” or “IBA.”  Sometimes this data is linked “deterministically,” meaning that PUBLICIS® COSMOS knows with certainty that an identified User is associated with different device IDs because the User has signed in to use a feature or service, or has made a purchase, disclosing his or her identity along with the device ID.

Sometimes the linkage of different devices is merely “probabalistic,” based on factors like the devices appearing in the same locations, being connected through the same IP address, and/or reflecting very similar transactional patterns.  PUBLICIS® COSMOS uses its proprietary cross-device algorithm to analyze multiple data sets and create these linkages.

PUBLICIS® COSMOS compiles a device graph for each Client, linking different devices thought to be associated with the same User, without necessarily knowing or inferring the identity of that User.  PUBLICIS® COSMOS creates an identifier that can be used to reach that individual across all of his or her devices unless the User has opted out of cross-device tracking from the Client (See Choice).

When PUBLICIS® COSMOS collects or receives behavioral data from Users (interaction with websites, mobile apps, and advertisements) such information is generally associated with non-personal information such as cookies, pixels, mobile advertising IDs (Google’s Android Advertising ID and Apple’s ID for Advertising, or IDFA), or other unique IDs that do not directly identify a person.  When PUBLICIS® COSMOS receives PII, such as email addresses provided by Clients, such PII may be used to link different sets of data about individual Users. Email addresses may also be used to help Clients select the best audiences for email marketing campaigns.

When PUBLICIS® COSMOS receives data about Users’ engagement with content and advertising, such data may also include information collected from Users’ devices (if they have consented, see below) which discloses their precise geolocation at a particular moment.

PUBLICIS® COSMOS does not knowingly collect, or permit others to share with it, any data about children under 13. PUBLICIS® COSMOS does not assist Marketers in directing ads to children under 13.

PUBLICIS® COSMOS may also make available to some Clients certain technology and services that can help analyze content, in order to help Clients better serve their Users, for example by recognizing audio or visual cues in content and communications (including recognizing faces in photos or video), and by analyzing text.  These services may make a Client’s apps or messages more useful to Users, and may help Users understand and interact with a Client’s products or services.  When information from Users is analyzed in this way, it may be provided to a third-party technology service provider, either directly by the Client, or with assistance from PUBLICIS® COSMOS.  If PUBLICIS® COSMOS helps pass this data to a technology service provider, and receives information back on behalf of the Client or User, PUBLICIS® COSMOS may add any insights it receives through this process to the analysis of Users that PUBLICIS® COSMOS produces for the Client.

User Choices

PUBLICIS® COSMOS does not generally interact directly with Users, including the audiences for a Marketer’s ads.  PUBLICIS® COSMOS requires Clients to acquire any legally required consent from Users before sharing information with PUBLICIS® COSMOS.   PUBLICIS® COSMOS does not manage opt-outs from the Marketer’s data collection.  Below, we describe some of the choices the Marketer and other third parties that interact with You directly and share data with PUBLICIS® COSMOS may offer.

Opting out of IBA. It isn’t possible to opt out of all data collection for IBA with one action.  Online data is generally collected through cookies (small pieces of software code), and when You opt out of this data collection for a Marketer, an opt-out from the Marketer’s cookies will be stored in another cookie on Your web browser.  If You change devices or browsers, You may need to opt out again.  This opt out from online tracking for IBA will not affect the collection of data from apps on Your mobile devices.  In order to prevent Your activities on a mobile device from being used to track You for IBA, You must go to “Settings” on a Mobile device and turn on “Limit Ad Tracking” for iOS devices or “Opt Out of Interest Based Ads” for Android devices.

Consent to use Location Data. PUBLICIS® COSMOS does not collect Location Data directly from device Users.  However, as for IBA, PUBLICIS® COSMOS relies on Clients to obtain User consent.  PUBLICIS® COSMOS requires Clients and other third parties that provide us with data to obtain Users’ affirmative consent to collect and share information about their precise geolocation.

Opting out of Cross-Device Tracking. PUBLICIS® COSMOS’s Clients should disclose to You in their privacy policies whether they collect data for ad targeting across different devices.  You have the right to choose (i) not to have a particular device be part of any data collection for advertising on other devices, or (ii) not to receive advertising on a particular device based on data collected about You on different devices.  When a Marketer offers an opt out from IBA through the Digital Advertising Association (“DAA”), that will also allow You to remove the device You are using from any cross-device tracking by that Marketer, which must instruct its service providers (including PUBLICIS® COSMOS) not to use that device to assist with cross-device tracking on its behalf.

If You remove one device from cross-device tracking, You may still receive ads on other devices that are based on data collected on devices that were not removed from cross-device tracking.  For example, if You remove Your phone from cross-device tracking, data from both Your computer and Your tablet may still be used to target advertising on both of those devices.  In addition, the devices may still be linked by PUBLICIS® COSMOS and other third parties.  That linkage may then be used for purposes other than targeting IBA.

Sharing and Disclosure of Information

PUBLICIS® COSMOS may share non-personal information with other companies that help a Marketer plan, purchase and deliver ads, including agencies, networks, exchanges, business partners and other third parties who provide services to the Marketer.  We may also disclose both non-personal information and PII to companies with whom we contract to help us perform services, including Microsoft and Adobe, but those companies will be required to use the information only to assist us, and not for their own purposes. PUBLICIS® COSMOS may disclose or transfer any or all types of information it possesses under the following circumstances: 1) if most or all of PUBLICIS® assets are acquired by another company; 2) if we become bankrupt, insolvent, or reorganize, or our assets are assigned for the benefit of creditors, 3) if we need to do so in connection with an investigation or proceeding to enforce our legal rights; or 4) to comply with valid legal process, such as a search warrant, subpoena, or court order.

Security

We use reasonable measures that are commonly used in our industry to protect data we process from unauthorized access, disclosure or modification.  We take industry standard precautions and follow generally accepted procedures to protect the security of data we process, store and transmit.  However, no transmission or storage of data can ever be perfectly secure, so while we can assure You and our Clients that we work hard to protect data in our control, we are not able to provide legal guarantees of data security.

Important Information for California Residents

California residents may request and obtain a list of the third parties, if any,  to which our Services have disclosed personal information (as defined by California law) for their direct marketing purposes during the immediately prior calendar year (e.g. requests made in 2017 will receive information about 2016 sharing activities). California residents also have the right to opt out of having their personal information shared for direct marketing purposes. As described in this Privacy Policy, we honor the choices our Clients’ customers have made and require that PII of customers who have chosen not to share their information with third parties for marketing purposes not be provided to us.  We do not share any personal information with others for their marketing purposes, and did not operate PUBLICIS® COSMOS during the prior calendar year.  Nonetheless, if in the future, You wish to request a list of any parties with whom We may have shared personal information, or confirm that we have not shared such information in the prior calendar year, You may do so by sending an email to info@cosmos.ai, using this Privacy Policy as the subject line, and include Your full name, e-mail address, phone number and postal address in your message, or you may contact us at the postal address below, including the same information

Do Not Track

As described in this Privacy Policy, PUBLICIS® COSMOS does not interact directly with Users.  Therefore, we do not receive or respond to Users’ Do Not Track settings in browsers.  Our Clients’ policies with respect to Do Not Track are disclosed in their own privacy policies.

Use Limited to the United States

PUBLICIS® COSMOS is based in the United States and complies with United States Law. PUBLICIS® COSMOS is not available to Clients outside the United States, and PUBLICIS® COSMOS will not knowingly collect, and does not intend to use or receive, any information about users who reside outside the United States.

Changes to this Privacy Policy

We may change this Privacy Policy at any time.  We will post with this Privacy Policy notice of any changes before they take effect, and will tell You when they will become effective.  We will maintain an archive of any prior versions of the Privacy Policy for You to review.  Even if we change the Privacy Policy, we will handle data we collected before in accordance with the Privacy Policy that was in effect at the time we collected the data unless we get your permission to treat it differently.

Contact Us

If You have any questions about this Privacy Policy or wish to review any PII of Yours that You believe we may have, please contact us at:

info@cosmos.ai or
PUBLICIS® COSMOS Global Development and Research Center
424 2nd Avenue West
Seattle, WA 98119