Contentsquare Services Privacy Policy

See the list of Contentsquare entities, the registered address and contact details for each entity here.

The other Processing activities performed by Contentsquare in relation with our website, and job applicants are governed by separate Privacy Policies. For more information on such Processing of Personal Data please visit this link.

Controller’s representative

Customer as the Data Controller:
For information about the representative for data protection matters pursuant to Article 27 of the General Data Protection Regulation (“GDPR”) of a specific Contentsquare’s customer, we suggest you reach out to such customer’s representative at its dedicated privacy policy.

Contentsquare as the Data Controller:

Contentsquare has appointed DPOs to oversee the protection of your Personal Data. If you have any questions about this privacy policy or about our data protection practices, you can contact our DPOs at:

• Global DPO: Content Square SAS, Attn: EU DPO, 7 rue de Madrid 75008 Paris, France. 
• APAC DPO: Contentsquare Japan G.K., Attn: APAC DPO, Marunouchi Kitaguchi Building 9F Wework 1-6-5 Marunouchi Chiyoda-ku Tokyo 100-0005, Japan.

Each of our DPOs may be reached via email: privacy@contentsquare.com.

Data Protection Officer and contact details

Customer as the Data Controller:
For information about the DPO of a specific Contentsquare’s customer, we suggest you reach out to such customer’s DPO at its dedicated privacy policy.

Contentsquare as the Data Controller:
Contentsquare has appointed DPOs to oversee the protection of your Personal Data. If you have any questions about this privacy policy or about our data protection practices, you can contact our DPOs at:

• Global DPO: Content Square Inc., Attn: Global DPO, 53 Beach St New York, NY, 10013-2304 United States. Email to privacy@contentsquare.com.
• EEA DPO: Content Square SAS, Attn: EU DPO, 7 rue de Madrid 75008 Paris, France. Email to privacy@contentsquare.com.

We collect and process Personal Data about you from the following sources:

Contentsquare as a Data Processor

*Customers must refrain, and are contractually prohibited, from transferring to Contentsquare any Personal Data which is subject to specific regulatory or statutory protection regimes (e.g “special categories” of data under the EU GDPR, data of children under the age of 16, health data, financial data, social security information, etc.).

We may process all of the above personal data to comply with our various legal obligations (“Legal Obligations”). Our Legal Obligations include:

• Comply with applicable laws, regulatory requirements, and our internal policies
• Prevent, mitigate, and investigate data protection and security incidents, fraud, errors, or any illegal or prohibited activity relating to Contentsquare Services
• Protect the rights, safety, property, or operations of Contentsquare, you, or others
• Respond to regulator, law enforcement authorities or other government official/agency request or your data protection requests
• Enforce agreements with you, resolve disputes, and defend a legal claim

Contentsquare as a Data Controller

“Marketing Communications” means when we contact you about Contentsquare Services or send you communications about Contentsquare’s business and events (including communications based on your interests, personal and business characteristics, and location)

• For Customers and Prospects relations management: we use Personal Data to manage our Customers’ relationships by communicating about relevant topics, ensure current contact information is accurate, and promote events and contests which we arrange.
• For Sales and Marketing optimization: we use Personal Data that is collected during the Customer relationship, such as from Customer surveys and online behavioral data. Based on these Personal Data, we are able to make marketing more relevant and effective, and send you more personalized communications such as newsletters, special offers and sales, new product announcements, etc. or any other information we think you will find valuable. We may provide such notices through any of the contact means available to us (e.g. phone or email), through the Services, or through our marketing campaigns on any other means.

“Internal Development” means when Contentsquare improves and better develops the Services for our Customers including testing, research, reporting, benchmarking, machine learning, analysis about our Services performance, predictions and trend analysis in order to support our business decision-making, to analyze our Customers’ engagement with our Services, to assess the quality of our Services and to consider our Customers’ feedback and needs.

Please note that for our Internal Development, we process de-identified and aggregated data to the extent possible. We may use samples of real data, for example, to test the quality and the performance of our Services. If you do not wish to be part of this test, you can let us know at any time.

Below you will find a summary of the data retention related to each purpose of processing:

Contentsquare as a Data Processor

Contentsquare as a Data Controller

In connection with one or more of the purposes outlined in the Section 5 above, we may disclose your Personal Data to:

Contentsquare as a Data Processor

Contentsquare subsidiaries and affiliated companies
We may share, disclose and transfer your Personal Data with our current (please see the list here) and future subsidiaries and affiliated companies for all purposes mentioned in Section 4 above.

Service providers
We use third parties service providers to provide the Services to our Customers. These services include data hosting, data analytics, IT services and cybersecurity and support. Some of our service providers may perform the Services on our behalf, under our instructions, in accordance with our agreement and in compliance with appropriate technical and organizational security measures to protect your Personal Data.

Please see here for the current list of service providers used by Contentsquare as Sub-Processors.

Integrations and enrichment providers
Our tool allows you to integrate third-party tools to send or receive Personal Data to and from the Contentsquare solution in connection within the Contentsquare Services. Customers remain responsible for any Personal Data transmissions between these integration tools and Contentsquare.

Other third parties
We may disclose your Personal Data to third parties, including:

• Government authorities or public authorities, courts, intergovernmental or supranational bodies for legal processes or protection of life and safety where we believe that access, use, preservation, or disclosure of the information is reasonably necessary, including:
  • To comply with laws, regulations, legal processes or to respond to lawful requests;
  • To enforce or apply our agreements;
  • To protect the rights, interests, property, or safety of Contentsquare, our customers, you, and others;
  • In connection with claims, disputes, or litigation;
  • To protect you and others from fraudulent, abusive, or unlawful use of our Services, and other fraudulent activity. Such disclosure or access may occur if we believe in good faith that we are legally compelled to do so, or that it is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing.

Contentsquare as a Data Controller

Contentsquare subsidiaries and affiliates
We may share, disclose and transfer your Personal Data with our current (please see the list here) and future subsidiaries and affiliated companies for all purposes mentioned in Section 4 above.

Service providers
We use third parties service providers to perform services complementary to our own and support our business. These services include data hosting, data analytics, IT services and cybersecurity, customer services, payment services, consulting, development, support, marketing and advertising, events, promotions and contests. Some of our service providers may perform the Services on our behalf, under our instructions, in accordance with our agreement and in compliance with appropriate technical and organizational security measures to protect your Personal Data. We may also use data broking service providers for Marketing Communications purposes, including data enrichment, data matching, data cleansing and tracing. While some of these service providers may act as a Data Controller, we undertake appropriate and careful due diligence before using their services and they perform their services in accordance with our agreement.

Please see here for the current list of service providers used by Contentsquare as processors.

Other third parties
We may disclose your Personal Data to third parties, including:

• Partners for marketing, advertising, promotions, contests, events or other similar purposes. (please see here for the list of our current Partners);
• A buyer, investor, new affiliate or other third party in the event that Contentsquare, or any portion, group thereof, undergoes a business transition, such as a merger or acquisition, or during steps in contemplation of such activities (e.g., negotiations and due diligence).
• Government authorities or public authorities, courts, intergovernmental or supranational bodies for legal processes or protection of life and safety where we believe that access, use, preservation, or disclosure of the information is reasonably necessary, including:
  • To comply with laws, regulations, legal processes or to respond to lawful requests;
  • To enforce or apply our agreements;
  • To protect the rights, interests, property, or safety of Contentsquare, our customers, and others;
  • In connection with claims, disputes, or litigation;
  • To protect you and others from fraudulent, abusive, or unlawful use of our Services, and other fraudulent activity. Such disclosure or access may occur if we believe in good faith that we are legally compelled to do so, or that it is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing.

Contentsquare has implemented safeguards to ensure an adequate level of data protection where your Personal Data is transferred to countries outside the EEA, such as:

• the recipient country has an adequacy decision from the European Commission;
• the European Commission’s Standard Contractual Clauses for the transfer of Personal Data.

To see in detail the countries where your Personal Data may be transferred, please click here.

Subject to applicable data protection laws, you have multiple privacy rights in respect of the Personal Data we process about you:

• request confirmation that we are processing your Personal Data;
• request a copy of Personal Data we hold about you;
• request that we update Personal Data we hold about you or correct such data that is inaccurate or incomplete;
• restrict the way in which we use your Personal Data (e.g., if we have no legal right to keep using it) or limit our use of your Personal Data (e.g., if your Personal Data is inaccurate or unlawfully held);
• object to our processing of your Personal Data relating on grounds to your particular situation or if your Personal Data is processed by us for direct marketing purposes, object at any time to the processing of your Personal Data for such marketing;
• withdraw the consent that you have given us to process your Personal Data (where we process your Personal Data on the basis of your consent);
• request that we delete the Personal Data we hold about you; and
• lodge a complaint with the relevant data protection authority regarding our processing of your Personal Data.

If you want to exercise one or more of the rights mentioned above, you can submit your request using our Data Subject Request Form here. Please note that as part of your data subject request, we may require additional information and documents, including Personal Data, in order to authenticate and validate your identity and to process your request. Such additional data will be then retained by us for legal purposes (e.g. as proof of the identity of the person submitting the request), in accordance with Section 5 above.

Independent Dispute Resolution

To address inquiries or resolve complaints about our processing of Personal Data, residents of the EU, United Kingdom, or Switzerland should first contact Contentsquare via e-mail to privacy[at]contentsquare.com. 

The US CS entities have further committed to refer unresolved privacy complaints under the Data Privacy Framework to the American Arbitration Association’s International Centre for Dispute Resolution (“ICDR-AAA”), a non-profit alternative dispute resolution provider located in the United States to assist with the complaint resolution process. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://go.adr.org/dpf_irm.html for more information and to file a complaint. The services of ICDR-AAA are provided at no cost to you.

Enforcement

The US CS entities are subject to the investigatory and enforcement powers of the Federal Trade Commission (the “FTC”) to ensure our compliance with the Data Privacy Framework as outlined in this Website Privacy Policy.

Arbitration

You may be entitled, under certain conditions as described in the Principles, to invoke binding arbitration when other dispute resolution procedures have been exhausted.

Lawful Access Requests

The US CS entities may be required to disclose Personal Data in response to lawful access requests from public authorities, or to comply with national security or law enforcement requirements. Any such disclosure is made in accordance with our Public Authorities Access Request Policy, available at this link. 

Onward Transfers of Personal Data

The US CS entities remain responsible to you, as well as potentially liable to you under the conditions set forth in the Principles, for the processing of Personal Data received under the Data Privacy Framework and subsequently transferred to the third parties identified above.