Merkle UK One Limited, a company with registered office at 10 Triton Street Regents Place London NW1 3BF (“Merkle” or “we”, for the purposes of this privacy policy) is a digital data analytics agency with a global presence operating under the denomination of Divisadero in Spain. We help our clients optimize the way they approach their business and management strategies. We believe that responsible use of data fosters business growth by building strong brand-customer relationships. As a company, we are committed to respecting and protecting the privacy of all individuals with whom we interact. We are also committed to the treatment of personal data always in a transparent way and in accordance with the applicable law regarding the protection of personal data.
This privacy policy explains in detail the types of personal data that we collect when you interact with us. Merkle is the controller of the personal data that you provide us, among others, through this website.
This Privacy Policy explains:
- What information do we collect?
- How we use your information
- How long do we keep your personal information?
- How do we protect your personal data?
- With whom do we share your information?
- Information transferences among group brands
- Your rights
- Our responsability regarding web links
- Updates
- Contact us
In the Additional Information section we explain the meaning of "personal data", as well as other terms used in this policy.
1. What information do we collect?
The type of information we collect will depend on the circumstances and the services you use. In general terms, we will obtain information about you and / or about your use of our services as follows:
- Information about the use of our website
We obtain information about how you use our website, the services or information you are looking for and the links and content you access. We may use the information you provide us through your use of the website to provide you with content of your interest and to help determine our marketing strategy. This type of activity, known as “profiling”, consists of the use of automated means to analyze your personal data and predict your preferences, interests and habits. To object to profiling, read section 7 of this Privacy Policy.
- Technical data
We obtain information about the devices you use to access the website, which includes the unique ID code of your mobile phone or the IP address from which you access the website that uniquely identifies the specific device from which you access the internet. We receive and process this information by means of a cookie ID. You can find more information about the cookies we use and the purposes for which we use them in our Cookies Notice.
- Contact information
We obtain your contact information when you request us to send you notices through your email, when you download our content, when you subscribe to our newsletters, when you send us an inquiry or when you send us your curriculum vitae. The personal data included would be your name, email address, position in the company and location.
- Marketing data
We obtain information about your preferences regarding the delivery of promotional information and communications
- Data when you exercise your rights
We process information related to your name, your email or postal address, as well as your telephone number. In addition, we can manage data to verify your identity such as your ID or your passport.
Under the age of 16
We try not to obtain information about children under 16 years of age. If you are concerned about the privacy of your children in relation to our services or if you think that your child may have provided us with personal data, please contact us at dpo@merkleinc.com. We will delete such information from our records within a reasonable time.
2. How do we use that information?
Except for legal obligations, we will only use the personal data you provide us for the following purposes:
- Respond to your requests and comments;
- Allow the download of our content;
- Analyze and / or improve our services;
- Share your data with group companies for administrative and management purposes;
- Comply with legal obligations.
The legislation on data protection makes us communicate the legally established bases that allow us to process your personal data. For the most part, the processing of your personal data is based both on (a) our legitimate interests in relation to the provision of the services you request or your relationship with us as a consumer, or (b) your consent, when this has been requested.
In the table below we inform you of the purposes for which we process your data and the legitimizing bases on which the treatment depends. Please note that the processing of your data may be based on more than one legitimizing basis, depending on the specific purposes for which we use such data.
| Purpose/Activity | Type of processed data | Legitimizing basis, including legitimate interests |
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It is included in our legitimate interests the answer to those communications that you send us requesting information about our services. We will also use your personal data to improve our business. |
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We process your data to give you a response as a consequence of the legal obligation that we have. |
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When you send us your resume, you give us your consent to access the data that you decide to include in it in order to analyze whether your profile fits any vacancy. |
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When you visit third-party pages, we can show you advertisements from our company, always based on your consent. |
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Improve and develop the website: We carry out statistical analyzes on your use of the website, e.g. For example, to know how to improve the website, offer new features and content, etc. |
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Necessary for our legitimate interests (defining the type of customer of our services, keeping the website updated and relevant, developing our services and determining our marketing strategy). If we use Google Display Network Impression Reporting to perform the analysis, we will do so based on your prior consent. |
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Share information with our service providers. |
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Our legitimate interests allow us to share information with trusted companies that provide us with services for the maintenance of the website. |
Sharing information between companies of the Dentsu Aegis Network Group. |
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Due to the global presence of Dentsu Aegis Network, our legitimate interests allow us to share data with other Group companies in order to provide our products and services effectively. |
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Share information with other third parties, such as legally competent authorities and public administrations. |
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We will share your data when any legal provision requires us to do so or for the purpose of satisfying our legitimate interests |
3. How long do we keep your personal information?
We will keep your personal data for the time necessary to provide the corresponding services, in accordance with our legal obligations. Once the treatment is finished, your personal data will remain blocked and only at the disposal of the competent authorities until they prescribe the responsibilities that may arise from the treatment, being later safely eliminated, or anonymized so that we can continue to use them for analytical purposes. You can request more information at the contact points indicated in this Privacy Policy.
4. How do we protect your personal data?
We employ appropriate organizational and technological measures to protect your data from unauthorized access and use, and accidental loss, alteration or destruction. We also try to get our suppliers to do the same.
Merkle warranties include robust systems and processes designed to ensure that we only collect the minimum necessary personal information, and that only Merkle personnel who need to see your personal information can view it.
We carry out checks to make sure we are adhering to any restrictions on the use of information (for example, when you have not agreed to receive marketing).
5. With whom do we share the information?
Information shared with our service providers
We use third parties to carry out certain functions of our business on our behalf, such as sending newsletters, storing our internet services on servers and managing our relationship with consumers. We will only give them access to the information necessary to provide the contracted services. Our service providers are contracted to carry out our instructions and we require them not to use personal data for their own purposes.
Information shared with other entities
The law may require or enable us to provide personal data to third parties such as competent public authorities and administrations, for example, in response to judicial orders or requests from competent authorities in the exercise of their legally attributed functions, or when we believe that it is necessary to investigate, prevent or take action in relation to illegal activities. We will not sell or rent your personal data to third parties.
6. Information transfer among group companies
Merkle belongs to a global media group made up of different companies. Therefore, from time to time we will communicate your personal data to other group companies. Access to your data will always be limited by the need to use the data to provide the requested services or to carry out necessary or legitimate actions (the need-to-know principle). Some of the group companies are located outside the European Union (USA, China or other countries), but we will always ensure that such communications and transfers are carried out with the security required by the applicable legislation on data protection.
We will only transfer your personal data outside the European Union after having verified, in accordance with the applicable data protection legislation, that there is an adequate level of security to protect the integrity and security of any information processed. These measures may include the use of the standard contractual clauses approved by the European Commission or your consent. All transfers of personal data between group companies have been protected by signing the standard contractual clauses approved by the European Commission.
You can request more information about the measures taken to protect said transfers by contacting us through the contact points indicated in this Privacy Policy
- Opposition to the processing of your personal data when such processing is based on our legitimate interest or third parties, in the case that you wish to oppose a specific processing considering that it has a negative impact on your fundamental rights and freedoms. You can also assert your right to object to the processing of your personal data for direct marketing or profiling purposes. You can exercise your right to object at any time, after which we will stop processing the data that you have objected to, unless we can demonstrate that the treatment can continue based on priority legitimation reasons.
- dentro del plazo legalmente exigido. Access to your personal data. If you send us this type of request and, in effect, we have personal data about you, we are obliged to provide you with such information by means of a copy of the personal data processed and together with a description of the treatment, including the purposes thereof. In order to meet your request, we may require you to prove your identity. We will process your request within the legally required period.
- Portability of your personal data. You can ask us to pass on your personal data to any third party that you have chosen. Such data will be transmitted in a structured, commonly used and machine readable format. We ask you to bear in mind that this right will only apply to the personal data that you have provided us and that we are treating on the basis of consent to fulfill a contract that you have signed with us.
- Suppression (cancellation) of your personal data. You have the right to ask for the deletion or withdrawal of your personal data when we have accepted your request to object (see above) or when, under applicable law, we are obliged to delete your personal data. Please note that we may retain certain information when required or enabled by law or when we are entitled to do so based on our legitimate interests. In any case, we will inform you of this circumstance.
- Rectification or updating of your personal data. This right allows you to correct any incomplete or inaccurate information that we have about you.
- Limitation of the processing of your personal data in certain situations. You can exercise this right so we temporarily cease the treatment, keeping the blocked data in the meantime.
- Withdrawal of consent. When the processing of your data is based on your consent, you can withdraw it at any time. In case you withdraw your consent, keep in mind that this circumstance will not affect the legality of the treatments carried out previously.
- File a claim. We will do what we can to resolve your claims. However, if you consider that we have not been able to resolve them, you can file a claim with the corresponding territorial control authority. For example, in the case of Spain, the corresponding authority is the Spanish Agency for Data Protection.
When you exercise the aforementioned rights and we have doubts about your identity, we may require you to identify yourself effectively, for example, by attaching a copy of your ID number to your request.
8. Our responsability regarding web links
This Privacy Policy is limited to the personal data collected by Merkle. Therefore, we must refer to the links enabled on the website that redirect to third-party websites, including social networks such as Facebook, Twitter and LinkedIn. If you follow these links, you must use the websites you access according to their own privacy policies, since the processing of personal data that the owners of these websites carry out are not included in the scope of this Privacy Policy. Therefore, we have no responsibility or control over the information collected by third parties or over the protection and privacy of the information that you provide through these websites.
9. List of Advertising Exclusion
If you do not want us to send you commercial communications, you can request it through the existing advertising exclusion lists. These lists will reduce the volume of marketing you receive from companies with whom you do not have an existing relationship (but not from companies that you have given permission to contact you). To request information on these lists, you can contact the Spanish Agency for Data Protection.
10. Updates
This Privacy Policy may be updated from time to time in order to reflect changes in the law, in good practices, or in our personal data processing activities. The date of the last modification will appear in the heading of this Privacy Policy. If you do not agree with the changes made, please do not continue to use our services or share your personal data with us. We recommend that you regularly check if this Privacy Policy has been updated.
11. Contact us
If you have any questions about this Privacy Policy, about how we protect your privacy or if you wish to exercise any of the rights mentioned in this Privacy policy, you can contact our Data Protection Officer through any of the following contact points:
Address: Calle Menorca, 3, Planta 2, CP 28009, Madrid, España.
Phone: +34 985 09 51 10
ADDITIONAL INFORMATION
In this additional information section we define some of the terms used in this Privacy Policy.
Responsible for the treatment: the natural or legal person who determines the purposes and means of the treatment.
Personal data: any information that identifies you or makes you identifiable.
Treatment: any operation carried out with personal data. Collection, storage, disclosure or disposal, among others
Profiling: Data processing whose purpose is to decipher, by means of automated tools, certain qualities of people, such as predicting their performance at work, reliability, economic situation, personal preferences, interests, behavior, location or movements.
Transfer: Communication of personal data to recipients located outside the European Economic Area (eg, when storing data on computers located outside the European Economic Area), or access to personal data by someone located outside the European Economic Area.
Last update: September 2020.
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