Media Plans Privacy Policy

Media Plans inc. (Media Plans) offers services in the marketing industry to better collect, manage and understand marketing investments data. Media Plans understands the importance of protecting Personal Information (as defined below) and, for this reason, strives to have business procedures and security safeguards in place to protect Personal Information under its control.  

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1. Scope of this policy 

This privacy policy (the “Policy”) describes Media Plans’s practices with respect to the collection, use and disclosure of Personal Information. 

This Policy is intended to establish responsible and transparent practices for the management of Personal Information, and to satisfy applicable legal requirements. This Policy sets out the standards, responsibilities and obligations of Media Plans in respect of any Personal Information collected, accessed or processed by Media Plans in the course of its business operations, and specifies Media Plans’s obligations arising from its terms of service (available at https://media-plans.com/terms-of-service/) (the “Terms”) entered into between Media Plans and its corporate customers (each, a “Customer”), whereby Media Plans might process or have access to Personal Information.

This Policy also governs Personal Information collected about Media Plans’s website users (the “Users”) and explains how Media Plans processes Personal Information collected from people who visit its website and otherwise interact with Media Plans through https://www.media-plans.com/ (the “Website”) or through the Media Plans platform (the “Product”). It also explains how Media Plans uses cookies and similar technologies. Users who do not agree with this Policy shall not access or use the Product, and any related services (collectively, the “Services”) or the Website. 

To the extent Media Plans provides the Services to an organization (e.g. to a User’s employer), Media Plans, as a data processor, processes such User’s Personal Information under such organization’s instructions as a data controller. Users of the Services should first direct their privacy inquiries to the administrator of the Product within their organization, as their use of the Services is subject to their organization’s own privacy policies.

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2. Definition of Personal Information

“Personal Information” refers to any data about an identifiable individual. This includes, but is not limited to, email addresses, contact details, and other similar information provided to Media Plans during its business activities or received through business inquiries. Information that has been aggregated or anonymized, and thus cannot be linked to an identifiable individual, is not considered Personal Information.

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3. International Compliance

Media Plans complies with: (i) data protection laws applicable to Media Plans; (ii) anti-spam legislation applicable to Media Plans; and (iii) applicable industry standards concerning data protection, confidentiality or information security. Media Plans has global operations and therefore, in some cases, information managed by Media Plans may be transferred to, processed and stored in other countries, although at all times Media Plans will ensure that Personal Information is protected by confidentiality and security procedures and protections that are, at a minimum, equivalent to those employed by Media Plans itself. 

Media Plans complies with this Policy as well as with applicable Canadian private sector data protection laws such as the Personal Information Protection and Electronic Documents Act (“PIPEDA”) and substantially similar provincial laws pertaining to the collection, use and disclosure of Personal Information. PIPEDA provides for an adequate protection of Personal Information according to the European Commission Decision of 20 December 2001 pursuant to Directive 95/46/EC of the European Parliament and the Council. 

Media Plans also complies with the General Data Protection Regulation (Regulation (EU) 2016/679) and the Data Protection Act 2018 and the GDPR as saved into United Kingdom law by virtue of Section 3 of the United Kingdom’s European Union (Withdrawal) Act 2018. Media Plans (or third parties acting on Media Plans’s behalf) may transfer Personal Information that Media Plans collects to countries outside of the European Economic Area. Where such transfer occurs, Media Plans will take steps to ensure that Personal Information is protected. Media Plans will make such transfers only if at least one of the following conditions is present: 

  • a. Media Plans has entered into a contract based on the “Standard Contractual Clauses” (including the United Kingdom’s International Data Transfer Addendum), provided that such contract, combined with technical and organizational measures, offers appropriate safeguards for the rights of the individuals whose personal data is being transferred; 
  • b. Such transfer is governed by “Binding Corporate Rules”, which have been approved by data protection authorities; or 
  • c. Such transfer is covered by a European Union Commission “adequacy decision”.
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4. Collection of Personal Information through the Services  

Media Plans collects information about its Users either directly from them, through their use of the Services or of the Website, or when they are provided by another source, as detailed below. 

  • a. Information provided by Users

    Users may provide Media Plans with Personal Information by inputting it directly into the Services or via another direct channel such as Media Plans’s support system. Such information may include: some text
    • Account and profile information: When Users register for an account, Media Plans may collect Personal Information such as contact information, information allowing Media Plans to better know who Users are, and information regarding User preferences, such as preferred language. Some Services may also allow Users to input a profile picture, a display name, job title, location and similar information. 
    • User-generated content: The Services may collect the content Users create and submit, such as feedback submitted in Media Plans. 
    • Content provided in a support context: By using the Services, Users may interact with Media Plans’s Customer Success team if they encounter a problem with the Services, or simply if they wish to learn more about Media Plans products. In doing so, Users may submit contact information and other Personal Information to Media Plans’s Customer Success in order for them to identify and better assist the Users. 
    • Payment information: Media Plans asks Customers to designate a representative for billing purposes. Media Plans thus collects that person’s name and contact information, together with the relevant payment details, which are collected through a trusted payment processing service. 
  • b. Information collected when Users use the Services

    In order to provide the Services, Media Plans collects information about how Users interact with the Services under certain circumstances. some text
    • Technical information about a User’s device: Media Plans collects information about the devices used to connect to, or interact with, the Services. This information may include the type of device used, the type of connection used to access the Services, a User’s IP address, browser type and device identifier. This information may be used to guess the User’s approximate location (i.e. country from where Services are accessed) so as to offer a better experience. 
    • Use of the Services: Media Plans collects information about its Users when they use the Services. Depending on the Services used, this information may include the features used, the links clicked on, information about other Users interacted with, and other similar information. 
    • Cookies: Media Plans uses cookies and other tracking technologies to provide certain security and product functionalities, and to recognize Users and their preferences across various platforms and devices. 
  • c. Information collected by Customers and through other third parties

    Media Plans may collect information about its Users through trusted partners, other Users, related companies and more importantly, from Media Plans’s Customers. some text
    • Information provided by Customers: Media Plans’s Customers may provide Media Plans with information about Users when they set up an account in their name in their capacity as the Users’ employer or service provider. Such information may include a User’s name, contact information and other personal characteristics kept in a Customer’s human resources information system. Personal Information may be collected directly from third parties via data integrations in accordance with a Customer’s instructions. 
    • Information provided by other Users: When Users submit content through the Services, they may submit Personal Information about other Users, such as their name, contact information, job title or similar information relating to their employment. 
    • Information provided by third-party services: Media Plans collects information about Users when they connect a third-party service to their account, for instance to facilitate login or to integrate the Services within an external platform. Media Plans may also collect information when Users authorize the Services to synchronize with their calendar or with a contact list. 
    • Information provided by Media Plans’s affiliated companies: Media Plans collects information from its affiliated companies in accordance with their own privacy policy. 
    • Information collected by partners and service providers: Media Plans may collect information about Users from its business and research partners who provide Media Plans with information on Users’ interests and engagement with Media Plans Services. Media Plans may also collect profiling information disclosed by its marketing and advertising partners, or by partners with whom Media Plans organizes and promotes events, insofar as this collection and disclosure are permitted by such partners’ privacy policies. 
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5. Collection and Use of Personal Information through the Website  

Media Plans generally collects and uses Personal Information from or about its Website Users as follows: 

  • a. Information Provided by Users

    In many cases, Media Plans collects Personal Information directly from Users when they visit or use the Website. For instance, Media Plans may collect the following types of information:  some text
    • Inquiries and Requests for a Trial or Service. Media Plans may collect a User’s name, contact information, email address and any other information provided when they make an inquiry or contact Media Plans through the Website, when they sign up to receive Media Plans’s newsletter or when they submit a request or an order for a Media Plans trial or service.  
    • Personalization of Website. When Users visit the Website, they may, from time to time, be invited to provide information, such as their job title, to help Media Plans personalize or customize the User’s experience when using the Website.
  • b. Technical Information.

    When Users visit the Website, Media Plans may collect technical information using electronic means such as cookies. This information may include information about visits to the Website, including the IP address of the User’s computer and which browser was used to view the Website, the User’s operating system, screen resolution, approximate location, browser language settings, the site the User came from, keywords searched (if arriving from a search engine), the number of page views, information entered, advertisements seen, etc. This data is used to measure and improve the effectiveness of the Website or to enhance the experience for Users. While most of the time this information is depersonalized, if this information relates to an identifiable individual, Media Plans will treat this information as Personal Information. Media Plans may also, without limitations, collect and use the following types of information when Users visit and/or interact with Media Plans on the Website:   some text
    • Google Analytics. Media Plans uses Google Analytics which allows it to see information on User website activities including, but not limited to, page views, source and time spent on the Website. This information is depersonalized and is displayed as numbers, meaning that it cannot be tracked back to individuals. Users may opt-out of Media Plans’s use of Google Analytics by updating their preferences.  
    • Interest-based Advertising. Media Plans may also allow a limited number of trusted third parties to install cookies on User’s hard drive from the Website. The Website may include third-party advertising and links to other websites which may be used to generate personalized advertisements. Personalized ads, sometimes referred to as interest-based or behavioral ads, are ads based upon information about Users, such as page views on the website, information requests or purchases on the website. Media Plans does not provide any Personal Information to advertisers or to third party sites that display interest-based ads on the Website. However, advertisers and other third-parties (including the ad networks, ad-serving companies, and other service providers they may use) may assume that Users who interact with or click on a personalized ad or content displayed on the website are part of the group that the ad or content is directed towards. Advertisers or ad companies working on their behalf sometimes use technology to serve the ads that appear on the Website directly to a User’s browser. They may also use cookies to measure the effectiveness of their ads and to personalize ad content. Media Plans does not have access to or control over cookies or other features that advertisers and third-party sites may use, and the information practices of these advertisers and third-party websites are not covered by this Policy. Please contact them directly for more information about their privacy practices. Users can also generally opt-out of receiving personalized ads from third-party advertisers and ad networks who are members of the Digital Advertising Alliance of Canada. Please visit the  DAAC opt-out page for more information.  
  • c. Choice with Cookies

    Users can block the use of cookies via the Website’s cookie banner, or via their browser’s settings. The “Help” feature on most browsers will tell Users how to prevent their browser from accepting new cookies, how to have the browser notify the Users when they receive a new cookie, or how to disable cookies altogether. If Users choose to withhold consent, or subsequently block cookies, they may not be able to access all or part of the content of the website. Additionally, Users can disable or delete similar data used by browser add-ons, by changing the add-on’s settings or visiting the website of its manufacturer.  
  • d. Privacy Policies of other Websites

    This Policy only addresses the use and disclosure of information by Media Plans. Other websites that may be accessible through the Website have their own privacy policies and data collection, use and disclosure practices.  
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6. Use of Personal Information

When providing the Services, Media Plans only processes Personal Information in accordance with the Terms and applicable laws. Media Plans generally uses Personal Information from or about its Customers and Users for the following purposes: 

  • a. to create, establish and administer Customer’s account, to process payments, to respond to Customer’s inquiries related to its account and to contact Customer about Media Plans’s Services or account-related matters; 
  • b. to provide Services, including to provide Customer and its Users with access and use of the Media Plans Products and customer support; 
  • c. to send transactional communications, such as purchase confirmation, renewal notifications, and information related to User activity on the Media Plans Products, such as technical notices, release notes, security alerts and other messages related to the administration of the Media Plans Products;
  • d. to measure and analyze User behavior;  
  • e. to monitor, maintain and improve Media Plans’s Services or features; 
  • f. to understand how Users interact with Media Plans and ensure its services, products or features work correctly; 
  • g. to develop new services, products, features, programs and promotions; 
  • h. to understand Customers’ and Users’ needs and preferences and customize how Media Plans tailors and markets products, programs and Services to its Customers and Users based on their interest; 
  • i. to meet legal and regulatory requirements and to allow Media Plans to meet contractual requirements relating to the Services provided to Customer;  
  • j. to conduct surveys on the quality of Media Plans’s Services or to collect feedback on the Services; 
  • k. to provide Users with offers for additional services, features and products that Media Plans believes may be of interest to Users (Users can opt-out of such communications by using the “unsubscribe” link provided in such communications); and 
  • l. to measure the effectiveness of Media Plans’s marketing. 

Whenever possible, Media Plans will use Personal Information in a depersonalized, aggregated and/or anonymized format. 

Unless required or authorized by law, Media Plans will not use Personal Information for any other or new purpose without obtaining prior consent.  
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7. Legal bases for processing Personal Information

Pursuant to privacy laws applicable in the European Economic Area and in the United Kingdom, Media Plans collects and processes Personal Information about individuals under a variety of legal bases, depending on the reason for such collection or processing. Media Plans shall only collect, process or use Personal Information where: 

  • Personal Information is required to provide the Media Plans Products and all services ancillary to the proper functioning of the Media Plans Products, such as support services, to provide a personalized experience, and to ensure the security of the Media Plans Products; 
  • The Customer or User gave Media Plans consent to use Personal Information for a specific purpose (including for a purpose listed under section 6 hereof); 
  • Processing of Personal Information is necessary to comply with a legal obligation; 
  • Processing of Personal Information is warranted by a legitimate interest of Media Plans (which is not overridden by your data protection interests), such as the purposes listed in paragraphs (d), (e), (f), (g), and (h) of section 6 hereof, or to protect Media Plans’s legal rights and interests.

If a User has consented to Media Plans’s use of their Personal Information, the User can withdraw their consent at any time, although this will not affect processing which took place prior to withdrawal. Where Media Plans processes a User’s Personal Information because it relies on Media Plans’s legitimate interests, objecting to the processing may mean the User will no longer be able to use or access the Services or the Website. 
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8. Disclosure of Personal Information  

Media Plans will not sell, rent or trade Personal Information to any third party. Media Plans does not share Personal Information with third-party tools, including AI models, except with permission from Customers or Users. However, Media Plans may disclose Personal Information when authorized and/or required by law or as follows: 

8.1. In the context of the Services. The content shared by Users on the Services and account or profile information linked to Users’ accounts may be accessed by other Users from within their organization, and sometimes from outside their organization provided they were granted permission by their organization to access this information. Customer administrators may use this information in accordance with their organization's policies. 

8.2 Within Media Plans. Media Plans may share Personal Information within Media Plans (i.e. between affiliates and subsidiaries) in Canada and the United States for the purposes described in Section 6 of this Policy.  

8.3 Service Providers. Media Plans may grant access to Personal Information to third-party service providers who process it on behalf of Media Plans to help provide and improve the Website and Services. Before disclosing any Personal Information with any of its third-party service providers, Media Plans will ensure that the third party maintains data management practices for maintaining the confidentiality and security of Personal Information and preventing unauthorized access which comply with applicable industry standards and privacy laws. 

8.4 As Permitted or Required by Law. Media Plans may disclose Personal Information as required by applicable law or by proper legal or governmental authority. Media Plans may also disclose information to its accountants, auditors, agents and lawyers in connection with the enforcement or protection of its legal rights. Media Plans may also release certain Personal Information when it has reasonable grounds to believe that such release is reasonably necessary to protect the rights, property or safety of others and itself, in accordance with or as authorized by law. In the event Media Plans receives a governmental or other regulatory request for any Personal Information, Media Plans will promptly notify Customer and/or Users, unless it is prohibited to do so, in order that Customer and/or Users shall have the option to defend such action. Media Plans shall reasonably cooperate with Customer and/or Users in such defense. 

8.5 Business Transaction. Media Plans may disclose Personal Information to a third party in connection with a sale or transfer of business or assets, an amalgamation, re-organization or financing of parts of its business. However, in the event the transaction is completed, Personal Information will remain protected by applicable data protection laws. In the event the transaction is not completed, Media Plans will require the other party not to use or disclose the Personal Information received in any manner whatsoever and to delete such Personal Information. 

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9. Security of Personal Information  

Media Plans will store and process the Personal Information in a manner consistent with industry security standards. Media Plans has implemented technical, organizational and administrative systems, policies, and procedures to help ensure the security, integrity and confidentiality of Personal Information and to mitigate the risk of unauthorized access to, or use of, Personal Information, including: (i) appropriate administrative, technical and physical safeguards and other security measures designed to ensure the security and confidentiality of the Personal Information it manages; (ii) a security design intended to prevent any compromise of its own information systems, computer networks or data files by unauthorized users, viruses or malicious computer programs; (iii) appropriate internal practices including, but not limited to, encryption of data in transit; using appropriate firewall and antivirus software; maintaining these countermeasures, operating systems and other applications with appropriate reasonable up-to-date virus definitions and security patches so as to avoid any adverse impact to the Personal Information that it manages; and (iv) permitting only authorized users access to systems and applications, and all persons with authorized access to Personal Information must have a genuine business need-to-know prior to access (together, “Security Program”).  

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10. Data Retention

Media Plans will retain the Personal Information as necessary for the purposes described in this Policy, unless a longer retention is required by law or justified by a legitimate business interest of Media Plans, subject to applicable laws. Personal Information related to a User’s Media Plans account is retained so long as the account is active, in accordance with Customer’s instructions. Some Personal Information about a User’s account may be retained after the account is deactivated in order for other Users to make full use of the Services. Notwithstanding the foregoing, upon termination of the Terms, Media Plans shall retain the Personal Information stored in the Media Plans Products until Customer instructs Media Plans to delete the Personal Information or until Customer’s access to the Services is terminated in accordance with the Terms, whichever occurs first.  

Upon expiry of the retention period, Personal Information is either deleted or permanently de-identified. Notwithstanding the applicable retention period, where Personal Information is kept in a backup, it will be stored in accordance with this Policy until it can be deleted, and it will not be used for any purpose other than as a backup copy. 

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11. Training and Supervision 

Media Plans maintains adequate training programs to ensure that its employees and any third parties acting on its behalf are aware of and adhere to its Security Program. Media Plans shall exercise necessary and appropriate supervision over its relevant employees to maintain the appropriate confidentiality and security of the Personal Information it manages. 

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12. Data Incidents Involving Personal Information

Media Plans shall promptly notify Customer of a data breach, of a loss of data or of a failure of Media Plans’s Security Program: 

  • (a) which has resulted or is suspected to have resulted in the loss, unauthorised access, disclosure, use or acquisition of Personal Information (including hard copy records); and 
  • (b)which presents a real risk of significant harm to individuals whose Personal Information is impacted (“Data Incident”). 

While the initial notice may be in a summary form, a comprehensive written notice shall be given to Customer within the legally required timeframe, where applicable. The notice shall summarize in reasonable detail the nature and scope of the Data Incident (including each data element type) and the corrective action taken or to be taken by Media Plans. Media Plans shall promptly take all necessary and advisable corrective actions, and shall cooperate with Customer in all reasonable efforts to mitigate the adverse effects of Data Incidents and to prevent their recurrence. 

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13. Users Legal Rights Regarding Personal Information 

To the extent that Media Plans’s processing of Personal Information is subject to the General Data Protection Regulation (Regulation (EU) 2016/679) or to the Data Protection Act 2018 and the GDPR as saved into United Kingdom law by virtue of Section 3 of the United Kingdom’s European Union (Withdrawal) Act 2018, Media Plans relies on the legal bases described under section 7 hereof to process Personal Information. Subject to applicable laws, all Users have the right to: (i) access and rectification or erasure of Personal Information, including erasure and deletion of their profile on the Media Plans Products, except to the extent that Media Plans may need to retain certain Personal Information, including for record keeping purposes or to comply with legal obligations; (ii) restrict or object to Media Plans’s use of Personal Information (though, in some cases, this may mean no longer using the Services or the Website) where Media Plans is relying on a legitimate interest (or those of a third party) and there is something about User’s particular situation which impacts on User’s fundamental rights and freedoms; (iii) lodge a complaint with their local data protection authority (contact details for data protection authorities in the European Economic Area are available here); and (iv) data portability. Users will not have to pay a fee to exercise such rights, however, Media Plans may charge a reasonable fee or refuse to comply if the request is unfounded, repetitive or excessive. 

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14. How to Contact Us 

Any questions, complaints or requests regarding this Policy or Media Plans’s handling of Personal Information can be addressed to Media Plans’s customer service at: 

Media Plans inc. 

Attention: Data Protection Officer 

1220, de la Visitation,
Montréal (Québec) H2L 3B4
email: support@media-plans.com

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A User who seeks to exercise their data protection rights referred to in Section 13, in respect of Personal Information stored or processed by Media Plans on behalf of a Customer (typically the User’s employer), must direct their query to such Customer, as being the data controller. If Media Plans receives such User’s request to exercise their data protection rights referred to in Section 13 (including for access to or correction of Personal Information), Media Plans shall redirect the User to Customer and, upon request from Customer, shall assist Customer in responding to such request, if applicable. 

Media Plans’s Data Protection Officer will respond to User requests within the legally applicable timeframe, and in any case no later than 30 days after receipt of such request. Media Plans will advise a User in writing of its response to their request. Should Media Plans refuse to grant a request, Media Plans will inform the User of the legal reason of its refusal, and will apprise the user of remedies available to them and of the time limit for exercising them. 

Should a user be unsatisfied with the outcome of their request, they may lodge a complaint with Media Plans’s supervisory authority, the Commission d’accès à l’information (https://www.cai.gouv.qc.ca/a-propos/nous-joindre/). 

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15. Change to Privacy Policy 

Media Plans will review and update its policies and procedures as required to keep current with rules and regulations, new technologies, standards and customer concerns. This Policy may therefore change from time to time.  If Media Plans makes changes that materially alter Users privacy rights, Media Plans may provide additional notice, such as via email or through the Services or the website. If Users disagree with the terms of this Policy, their only remedy is to discontinue use of the websites and the Services. 

This Policy was last updated on June 24th, 2024. 

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