Date Last Updated: 2 November 2022

If you are a California resident, the California Consumer Privacy Act (“CCPA”) and, effective January 1, 2023, the California Privacy Rights Act provide you with certain rights regarding your personal information, including the right to know about personal information collected, disclosed, or sold; the right to request that we delete personal information that we have collected from you; the right to opt-out of the sale of your personal information; and the right not to be discriminated against. All of these rights are subject to certain exceptions.

To review our privacy practices in general, please review our Platform Privacy Policy.

Collection of Personal Information 

When you interact with our business (such as by using the Platform), we may collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”). We may have collected the following categories of personal information over the past 12 months:

  • Identifiers, such as your name, email address, or job title.
  • Categories of personal information described in subdivision (e) of California Civil Code Section 1798.80, such as your name and telephone number.
  • Internet or other electronic network activity information, such as cookies, web logs, IP addresses, and mobile device IDs. 
  • Professional or employment-related information, such as your company name and address or any information that you share with the us through the Platform. 

We collect the personal information listed above from the following sources:

  • From you directly, when you provide us with your personal information as part of using the Platform. 
  • From your operating system and platforms.
  • From your internet service provider.

Disclosure of Personal Information

In the last 12 months, we may have disclosed the following categories of personal information for our business or commercial purposes:

  • Identifiers, such as your name, email address, or job titles.
  • Categories of personal information described in subdivision (e) of California Civil Code Section 1798.80, such as your name and telephone number.
  • Internet or other electronic network activity information, such as cookies, web logs, IP addresses, and mobile device IDs.
  • Professional or employment-related information, such as your company name and address.

We may have shared any of the information listed above with:

  • Our affiliates, including WPP group companies (you can find further details on our group companies here).
  • Our service providers.
  • Data analytics providers.

We use or disclose your information for the following purposes:

  • To enable your employees to logon and to administer platforms we have given you and your employees access to as part of our Services and to monitor and improve these platforms and Services.

Please note that you may find additional information about any of the topics above in our Platform Privacy Policy.

Your Rights 

Right to Know

California residents have the right to request that we disclose certain information about our collection and use of your personal information over the past twelve months (“Right to Know”). Once we receive and confirm your verifiable consumer request, we will disclose to you the following information (unless an exemption applies): 

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • The categories of personal information that we have disclosed for a business or commercial purpose.
  • Our business or commercial purposes for collecting or selling personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (i.e., a data portability request).

Right to Delete

California residents have the right to request that we delete the personal information that we collected from you and retain, subject to certain exceptions (“Right to Delete”). Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. 

Right to Opt-Out of Sale

The CCPA provides California residents with the right to opt-out of the sale of their personal information. 

We do not sell the personal information we collect about or from California residents. We do not knowingly collect or sell personal information about California residents under the age of 16.

Right to Nondiscrimination

The CCPA provides California residents with the right not to receive discriminatory treatment for the exercise of their privacy rights conferred by the CCPA. We will not discriminate against you for exercising any of your CCPA rights. 

Exercising Your Rights

If you are a California resident and wish to request for us to provide you with your Right to Know or Right to Delete, you may submit a request to us through the following ways:

Upon receiving a request from you, we will first verify your identity by comparing the information you provide (your name, email address, or phone number) with the information we have on file. We may ask you for additional information to verify your identity or to comply with your request. We will also inform you if we are unable to complete your request due to an exemption. 

Authorized Agent

You may authorize an agent to make a request on your behalf. To designate an agent, please provide a written and signed document by you that authorizes the agent to act on your behalf. You may submit this document at the email address below. We may still require you to provide sufficient information to allow us to reasonably verify that you are the person about whom we collected personal information.

Contact for More Information 

If you wish to contact us regarding our California Privacy Addendum, you may do so through the following methods: By email at dpo@gaintheory.com


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