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Welcome to JCDecaux North America! This Privacy Notice describes the practices of JCDecaux North America, Inc. (“JCDecaux”, "we", "us", or "our") regarding the collection and use of information about individuals who visit our website located at www.jcdecauxna.com ("Site") or who view the content available on the Site or in our publications, or interact with us, through emails or otherwise in connection with the Site (collectively, "Service").
This Privacy Notice is part of, and is governed by, the terms set forth in our Terms and Conditions.
This Privacy Notice does not apply to the information that we may collect as part of our out-of-home advertising business when we provide services to our business customers. Such activities are governed by the Privacy Policy for JCDecaux Digital Advertising Services.
For the Privacy Policy that covers services provided outside of North America by JCDecaux entities, please see the Privacy Policy located here. Accessibility: For more information about how users with disabilities can access this Privacy Notice in an alternative format, contact us at privacy-usa@jcdecaux.com.
1. Consent to Privacy Notice
In this Privacy Notice, we describe the information we collect when an individual ("user" or "you") uses or accesses our Site or interacts with us in connection with the Site. By accessing or using this Site or interacting with us, you consent to the information collection, disclosure and use practices described in this Privacy Notice. If you do not agree with the terms of our Privacy Notice, please do not access or use the Site.
2. Changes to our Privacy Notice
We may update our Privacy Notice from time to time. If we make any changes to the Privacy Notice, we will post the notice of the changes and the updated Privacy Notice on this Site, along with its effective date, and notify users to the extent required by law.
If you do not agree with the proposed changes, you should discontinue your use of Services. Your continued use of the Service after we have posted changes to the Privacy Notice will indicate that you agree to be bound by such changes.
3. Information We Collect
We collect information from you, including personal information, when you access and interact with the Site or the Service. Personal information is information that directly or indirectly identifies you as an individual, such as your name, email address, telephone number or unique identifiers (such as cookies). Non-personal information is information that cannot be used to identify you, such as aggregate statistics or de-identified personal information. As used in this policy, personal information also does not include information that is publicly available, de-identified or aggregated.
The following are the categories and types of personal information that we may collect from or about you, depending on how you interact with the Services:
- Identifiers and contact information;
- Characteristics and demographics; * Commercial information;
- Device and online identifiers and related information, including internet protocol (IP) address, mobile ad identifiers, data collected from cookies, beacons, and pixel tags, and similar unique identifiers; and
- Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with an internet website, application, mobile app, or advertisement.
The information collected falls into two categories:
(i) Information you voluntarily provide to us directly:
- Electronic Communications: We may collect information that you choose to share with us via email or by completing a form, such as the ‘contact us’ form. We use this information to understand and respond to your questions.
- Surveys and Questionnaires: We may invite you to participate in surveys or to respond to a particular questionnaire. Participation in such surveys and questionnaires is voluntary. If you do decide to participate, we may request certain personal information from you, such as your name, email address or physical address. We will use this information for analytics purposes.
- Employment: You may choose to provide personal information in connection with an employment application or similar inquiry. In such event, you will be redirected to a site provided by a third-party service provider. You may be required to create an account to submit your application.
(ii) Information automatically collected through your use of the Site
We automatically collect information from your device when you use our Site. This may include:
- Device Information and Browsing Information: We record your IP address, the time of your visit to the Site, and information regarding the browser and operating system that you use. We collect certain information about how you use the Site or Service, which may include information on when and how you interact with the Site and the actions you take on the Site, the pages you visit, the links on which you click, or whether you open our emails.
- Mobile Device Users: When you access the Site via your mobile device we collect information about your device, such as the type of device you use, your device's unique device ID, the IP address of your device, your device's operating system and the type of browser you use. In addition, our service providers may be able to identify the location of your mobile device. You may choose not to share your location details with us by making the necessary adjustments to your device's location services setting.
The technology we use to collect information automatically from users includes the following:
- Cookies and similar devices: We may use cookies, web beacons and scripts to identify a returning user, identify the pages visited that by user, facilitate a user's log-in, as navigation aids, as session timers, to track online activity, collect information about your use of the Site and develop other analytics. We also use the information collected through cookies in the aggregate, to understand how many users are using our Service and to determine for what purposes they are using the Service.
You may choose to block certain categories of cookies. Most browsers contain information on how to control or delete cookies. These settings will typically be found in the "options" or "preferences" menu of your browser. Please note that blocking or disabling certain cookies may interfere with certain functionalities of our Site. Further, while disabling a cookie may prevent the future collection of information, it does not prevent the use of the information collected prior to the cookie being disabled. For more general information about cookies, you can visit http://www.allaboutcookies.org. - Third Parties' Use of Cookies and Web Beacon: Our Site includes third party services used to provide us with analytics about the use of our Site. An example of such third party is Google Analytics, which we use to collect and analyze demographic and other information, and through which Google will collect certain information to be used according to Google’s privacy practices. . To opt-out of the use of Google Analytics, click here.
4. How We Use Information
In addition to some of the specific uses that we describe elsewhere in this Privacy Notice, we may use the information that we have collect to:
- Facilitate your use of the Site;
- Send emails about the Service or to respond to inquiries or requests for information;
- Process your personal information in connection with our marketing, human resources and other databases, as applicable.
- To maintain a record of contact information and correspondence;
- Improve, test, and monitor the effectiveness of Service;
- Develop Site features that may be of interest to you;
- Optimize our marketing efforts, for example to compile statistics regarding the users of the Site, to identify usage trends, and to determine the effectiveness of our promotional campaigns;
- Perform data analysis, audit, fraud monitoring and prevention;
- Conduct other functions as otherwise described at the time when the information is collected; and
- Perform any other function that we believe in good faith is necessary to protect the security or proper functioning of the Site.
5. Sharing and Disclosure of Information
In addition to our use of the information collected for our internal purposes, we may share information about users with third parties in the following circumstances:
1. Employees, Third-Party Processors and Third-Party Service Providers: We will share this information with our employees, contractors, affiliates, distributors, dealers, vendors, and suppliers ("Service Providers") who provide certain services to us or on our behalf, such as operating and supporting the Service, conducting data analytics, or performing marketing or consulting services. These Service Providers will only have access to the information needed to perform the functions that we have requested them to carry out on our behalf. Our contracts with these Service Providers prohibit them from using or sharing with others, for purposes other than as directed by us, the information that we provide to them or that they collect directly from our users.
2. In Connection with Business Transfers or Bankruptcy: We may transfer users' information to a third party in case of the sale, merger, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stocks, corporate restructuring, or bankruptcy, and as part of the due diligence process with any potential acquiring entity.
3. Responding to Legal Requests and Preventing Harm: There may be times when we use, share, or disclose information about a user (a) if required to do so by law, or in response to a search warrant, subpoena, or a court order and we believe that such request is facially valid; (b) if we believe that disclosure is reasonably necessary to protect against suspected illegal or fraudulent activity, to protect the safety, property and other rights of JCDecaux; our service providers, other users or the public; and/or (c) to enforce our Terms and Conditions, or to defend against legal claims, or to allow us to pursue available remedies or limit the damages that we may sustain.
4. For the Administration of Contests and Promotions: From time to time, we may offer contests and other promotions for which registration may be required. If you chose to enter a contest or promotion, your personal information may be disclosed to third parties or to the general public in connection with the administration of the contest or promotion, such as in connection with publication of winner selection.
5. Aggregate or Anonymized Information: We may share information relating to users of the Service with affiliated or unaffiliated third parties on an anonymous or aggregate basis for research, analytical or strategic purpose. This information is not intended to allow the identification of any specific user of the Service. We require parties with whom we share aggregate information to agree that they will not attempt to re-identify, re-associate, de-aggregate or make this information personally identifiable, for example, by combining it with information from other third-party databases.
6. Information Storage and Retention
We will retain information about our users as needed to provide you with the Service, or as necessary to comply with our legal obligations, resolve disputes and enforce our rights or agreements unless a longer retention period is required or permitted under applicable law.
7. Information Security
We use reasonable technical, organizational and administrative measures to protect the information that we collect and store against unauthorized or unlawful processing and against accidental loss, destruction and/or damage. We believe that these measures are reasonably adapted to the nature of the information in our custody. However, as no method of transmission over the Internet, or method of electronic storage is 100% effective, we cannot guarantee and do no warrant the security of any information we may have collected.
8. Users Located Outside North America - Consent to Transfer
This Site is directed to users located in North America. Our affiliated entities offer websites located outside North America. If you reside outside of North America and choose to use this Site or our Services or to provide information to us, please be aware that your personal information may be transferred to, processed and maintained on servers or databases located in the United States. Information stored in the United States may be subject to lawful requests by the courts or law enforcement authorities in the United States. By accessing and using this Service, you consent to our collection and use of your information, as described in this Privacy Notice, outside of your country of residence, including the transfer of your information across international boundaries. If you do not want your information to be transferred to, or processed or maintained in the United States, you should not access or use the Service.
9. Data Access, Opt-out and Your Choices About Your Information
We provide you with choices regarding the information you provide to us.
- Personal User Information - If you would like to delete or modify your personal information, or to receive a copy of your personal information, you may contact us at privacy-usa@jcdecaux.com. Please see the Additional U.S. State Privacy Rights below for more information about the rights that you may have under applicable laws.
- Browsing Information - You may stop or restrict the placement of cookies or similar devices on your device or flush them from your browser by adjusting your web browser preferences, in which case you may still use our Site, but it may interfere with some of its functionality. Further information on cookies is available at www.allaboutcookies.org.
Some browsers have a Do Not Track (“DNT”) feature that lets users signal to websites that they do not want to have their online activities tracked. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers, except as required by applicable law.
10. Additional U.S. State Privacy Rights
If you reside in California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana or another state with a similar comprehensive consumer privacy law (collectively, “Covered States”), under the California Privacy Act (“CCPA”) Virginia Consumer Data Protection Act, Colorado Privacy Act, Connecticut Data Privacy Act, Utah Consumer Privacy Act, Texas Data Privacy and Security Act, Oregon Consumer Privacy Act, Montana Consumer Data Privacy Act, and similar laws in other U.S. states (collectively, "State Privacy Laws"), you have specific rights regarding your personal information. This section describes the rights that consumers of Covered States have and explains how to exercise those rights. To be clear, these rights are granted only to the extent that you are considered a consumer of Covered State, and we are acting as a “controller” or “business” (as applicable) under State Privacy Laws with respect to your personal information.
The categories of personal information we process, our purposes for processing your personal information, the categories of personal information that we share with third parties, and the categories of third parties with whom we share it are set forth in the terms of the Privacy Policy above.
Information We Collect; How We Collect It; How We Use It
General information regarding our collection, use, and disclosure of personal information is set forth in the Privacy Policy above.
In the past 12 months, we have collected categories of personal information described in the section of the Privacy Policy above titled Information We Collect, and we have collected this information from the sources described in the section titled Information We Collect. Depending on your level of interaction with us, we may not have collected your personal information from all of the categories listed in the Privacy Policy above. We collect and use your personal information for the business or commercial purposes described in the section titled How We Use Information, and retain it pursuant to the section titled Information Storage and Retention.
We disclose the following categories of personal information for business or commercial purposes to the categories of recipients listed below:
- Identifiers and contact information – We disclose this information to third- party vendors to facilitate your application for a position with JCDecaux;
- Characteristics and demographics – We disclose this information to third- party vendors to facilitate your application for a position with JCDecaux.
- Internet or other electronic network activity information, such as device information and unique identifiers – We disclose this information to third- party vendors to personalize your Web Sites experience; to enhance or otherwise improve the Web Sites.
We do not collect any sensitive personal information from you within the scope of State Privacy Laws.
Rights to Your Information
In addition to the rights set forth in our Privacy Policy, State Privacy Laws may, depending on your state of residence, provide you with the following rights:
- Right to Know About Personal Information Collected, Disclosed or Sold. You have the right to request that we disclose certain information to you about our collection, use, disclosure or sale of your personal information. Once we receive and confirm your verifiable consumer request (see “Exercising Access and Deletion Rights” below), and subject to certain limitations that we describe below, we will disclose such information to you. You have the right to request any or all of the following: The categories of personal information we collected about you.
º The categories of sources from which the personal information is collected.
º Our business or commercial purpose for collecting or selling that personal information.
º The categories of third parties with whom we share that personal information.
º The specific pieces of personal information we collected about you. - Right to Data Portability. You have the right to request a copy of personal information that we have collected and maintained about you. Some State Privacy Laws allow you to request your information from us up to twice during a twelve (12) month period. We will provide our responses in a readily usable format, which is usually electronic.
- Right to Correct. You have the right to correct inaccuracies in the personal information we collect from you, taking into account the nature of the personal information and the purposes for which we process it.
- Right to Request Deletion. You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions under State Privacy Laws. Once we receive and confirm your verifiable consumer request (see “Exercising Access and Deletion Rights” below), we will delete (and direct our service providers to delete) your personal information from our records. However, we may retain personal information that has been de-identified or aggregated. Furthermore, we may deny your deletion request if retaining the information is necessary for us or our service provider(s) in order to perform certain actions, set forth under the State Privacy Laws, such as detecting security incidents and protecting against fraudulent or illegal activity.
- Right to Opt Out. We do not “sell” personal information collected through this Site, as that term “sell” is defined under State Privacy Laws or use such information for targeted advertising with third parties.
- Right to Non-Discrimination. We will not discriminate against you for exercising any of your rights under State Privacy, including, but not limited to, by:
º Denying you goods or services.
º Charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
º Providing you a different level or quality of goods or services.
º Suggesting that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Exercising Access and Deletion Rights. To exercise the rights described above, please submit a request to us by either:
- Emailing us at privacy-usa@jcdecaux.com
- Or by mail addressed to JCDecaux North America, Inc. 350 Fifth Avenue, 73rd floor, New York, New York 10118 attn: General Counsel
Only you, or a person or business entity you authorize to act on your behalf (an “authorized agent”), may make the requests set forth above. If you use an authorized agent to make a request, you must provide the authorized agent written permission to do so, and we may require that you verify your identity directly with us. You may also make a request on behalf of your minor child, but we may ask you to submit reliable proof of your identity.
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 sufficient information (including name and email address) that allows us to reasonably verify that you are the person about whom we collected the personal information or an authorized representative. In addition, we ask that you provide us with the following information to allow us to reasonably verify that you are the person about whom we collected the personal information or an authorized agent: whether receive marketing communications from us; whether you or your business has purchased advertising from JCDecaux; and, if you are an authorized agent, confirmation that you have been authorized to act in such capacity. When providing us this information, you represent and affirm that all information provided is true and accurate.
We will respond to consumer requests within forty-five (45) days from when you contacted us. If you have a complex request, State Privacy Laws allow us up to ninety (90) days to respond. We will still contact you within forty-five (45) days from when you contacted us to let you know we need more time to respond.
In order to protect the security of your personal information, we will not honor a request if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. The method used to verify your identity will vary depending on the nature of the request. Generally speaking, verification will be performed by matching the identifying information provided by you to the personal information that we already have.
We are not obligated to provide the information set forth above under “Right to Know About Personal Information Collected, Disclosed or Sold” more than twice in a 12-month period. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
If we decline to take action on a request that you have submitted, we will inform you of our reasons for doing so and provide instructions for how to appeal the decision. Depending on your state of residence you may have the right to appeal within a reasonable period of time after you have received our decision. If you have this appeal right, within 60 days (45 days for residents of Colorado) of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If we deny your appeal, we will provide you with a method for contacting your state attorney general’s office to submit a complaint.
11. Children's Privacy
This Site is a general audience service. Our content is not directed towards children under the age of 13. We do not knowingly collect personal information from children under the age of 16. If we become aware that a child under the age of 13 has provided us with personal information without parental/guardian consent, that information will be deleted. Parents/guardians who have questions about personal information that may have been submitted by a child under the age of 13 should contact us at privacy-usa@jcdecaux.com. By accessing and/or using the Site you represent that you are at least 13 years old. If you are under 13 years of age, do not send any information about yourself to JCDecaux.
12. Links to Other Sites
This Site may contain links to third party websites or display social networking buttons linking to third party websites that JCDecaux does not own or control. If you have a previous relationship with a third party, such as a social media platform, then they may recognize you and combine information collected through this Site with information they already possess about you. These links are provided for your convenience only and should be used at your discretion. Links from our Site to third party websites do not constitute sponsorship, endorsement, or approval of the content, policies or practices of such third-party websites. JCDecaux is not responsible for the data collection and the privacy practices of these third parties’ websites and our Privacy Notice does not apply to information provided to or gathered by the third parties that operate them.
13. How to Contact Us
If you have any questions about this Privacy Notice or the use of your information, please contact us: via email at privacy-usa@jcdecaux.com or by mail addressed to JCDecaux North America, Inc. 350 Fifth Avenue, 73rd Floor, New York, NY 10118, attn: General Counsel.