Privacy Policy

Verilogue, a division of Publicis Health, LLC (“we”, “us”, or “our”), offers marketing and creative services. This Privacy Notice sets out how we collect, use, share, and protect any information we collect in connection with our products and services. This Privacy Notice also explains the measures we take to safeguard your information and describes how you may contact us regarding our privacy practices.

Please note, this Privacy Policy does not apply to the information collected through our general website, www.verilogue.com (the “Website”). For information about how we collect, use, share, and protect any information we collect through our Website, please see our Privacy Policy.

Please read this Privacy Notice thoroughly. If you disagree with the way personal information will be used, please do not use this Website.

Scope

This Privacy Notice describes the privacy practices of Verilogue and applies to all Verilogue products and services other than our Website, including:

Platforms, portals, or digital services operated by us (e.g. Physician Portal, Reveal MR, LW2);
Mobile and other software applications;
Social media pages that we control;
Email messages and other communications that we send to you; and
Other ways in which we communicate with you or collect Personal Information from or about you, via our online and offline programs and services.

Collectively, we refer to these operations in this Privacy Notice as the “Services”.

Please note that this Privacy Notice does not apply to applicants, employees, or other individuals with whom we interact in an employment-related capacity (our “Workforce”). Further, as highlighted above, this Privacy Notice does not apply to information collected through our Website. For information about how we collect, use, share, and protect any information we collect through our Website, please see our Privacy Policy.

Some portions of this Privacy Notice apply only to Clients and/or Consumers of particular regions, countries, or U.S. states. In those instances, we have indicated that such language applies only to certain Clients and/or Consumers.

Definitions

Consumer means any natural person, other than Clients and Workforce members. Consumers include patients who participate in Verilogue research studies.
Client means any natural person with whom Verilogue interacts in a business-related capacity, including physicians and other health care providers and users of our Services.
Individual includes both Consumers and Clients.
Personal Information means 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 includes “personal data” (or equivalent terms) as that term is defined by applicable privacy laws. Personal Information also includes “Sensitive Personal Information”, as defined below, except where otherwise noted.
Sensitive Personal Information means Personal Information that reveals a consumer’s social security, driver’s license, state identification card, or passport number; account log-in, financial account number, debit card number, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin, religious beliefs, or union membership; contents of email or text messages; and genetic data. Sensitive Personal Information also includes processing of biometric information for the purpose of uniquely identifying a consumer and Personal Information collected and analyzed concerning a consumer’s health, sex life, or sexual orientation. Sensitive Personal Information also includes “sensitive data” (or equivalent terms) as that term is defined by applicable privacy laws.
Supplier means a service provider, contractor, or processor as those terms are defined by applicable privacy laws.
Third Party means any entity that is not a Supplier.
U.S. Privacy Laws means the California Consumer Privacy Act of 2018 and California Privacy Rights Act of 2020, and their implementing regulations (collectively, the “CCPA”), the Colorado Privacy Act of 2021 and its implementing regulations (collectively, the “CPA”), the Virginia Consumer Data Protection Act of 2021 (the “VCDPA”), the Utah Consumer Privacy Act of 2022 (the “UCPA”), the Connecticut Data Privacy Act of 2022 (“CDPA”), the Iowa Consumer Data Protection Act of 2023 (the “ICDPA”), the Indiana Consumer Data Protection of 2023 (the “INCDPA”), the Montana Consumer Data Privacy Act of 2023 (the “MCDPA”), and the Tennessee Information Protection Act (the “TIPA”), collectively.

Other terms used herein that are defined terms under applicable privacy laws shall have the meanings afforded to them by applicable privacy laws, whether or not capitalized, unless the context indicates otherwise. As there are some variations between such definitions across global privacy laws, the definitions applicable to you are those provided in the statute for the region, country, or U.S. state in which you are a Client or Consumer. For example, if you are a California Consumer, terms used in this Privacy Notice that are defined terms in the CCPA shall have the meanings afforded to them in the CCPA as this Privacy Notice applies to you.

Overview of Personal Information Processing & Notice at Collection

This section of our Privacy Notice lists the categories of Personal Information Verilogue and our Suppliers collect and explains how we and our Suppliers process that Personal Information. This section also provides our notice at collection for Clients and Consumers.

Information We Collect and How We Use It

We collect the following categories of Personal Information from Clients and Consumers, and we have collected the following categories of Personal Information from Clients and Consumers in the past twelve months:

Identifiers, such as name, alias, IP address, online identifiers, browser and mobile application identifiers, account name; physician NPI #;
Contact and financial information, including phone number, address, and email address, financial information, medical information, health insurance information;
Characteristics of protected classifications under state or federal law, such as age, gender, race, physical or mental health conditions, and marital status;
Commercial information, such as transaction information and service history;
Biometric information, include voice recordings;
Internet or other electronic network activity information, such as browsing history, interactions with our websites or advertisements, and information collected via cookies, pixels, and similar digital tracking technologies;
Audio, electronic, visual and similar information, such as call and patient recordings;
Professional or employment-related information, such as work history and prior employer;
Sensitive personal information, including:
- Personal Information that reveals:
  - Racial or ethnic origin, religious or philosophical beliefs, or union membership;
  - Genetic data.
- Biometric data processed for the purpose of uniquely identifying a consumer;
- Personal Information collected and analyzed concerning a consumer’s health; and
- Personal Information collected and analyzed concerning a consumer’s sex life or sexual orientation.

We have not disclosed the categories of Personal Information listed in this Section to Third Parties for a business purpose in the past twelve months. We do de-identify and aggregate any Personal Information we collect about you and use and share the resulting aggregated and/or anonymized data for any purposes permitted by applicable law, including medical, pharmaceutical and related market research, speech recognition research, and product development.

Purposes & Legal Bases for Collection, Processing, & Disclosure

Verilogue and our Suppliers collect, process, and disclose the categories of Personal Information listed in Section “Information We Collect and How We Use It” for the below purposes. Please note that the references in the below chart to our legal bases for processing only apply to residents of the European Economic Area, United Kingdom, and other regions with privacy laws that require us to disclose our legal bases for processing. The references to our legal bases for processing do not apply to residents of the U.S.

Purpose	Description	Legal Basis
Medical, Pharmaceutical, & Related Market Research	Including using research and the insights gathered to impact direct-to-consumer (DTC) ad campaigns, patient messaging, internal marketing efforts, and educational information.	Consent
Customer Relationship Management	Includes providing Clients and Consumers access to our research Services; providing business intelligence and analytics based on research; ensuring access to the Services; communicating with Clients and Consumers about changes to programs, terms, and conditions; handling requests, inquiries, and complaints; consent management and administration.	Performance of Contract Legitimate Interests, including to manage our business operations and communicate with Clients and Consumers Legal Obligations
Operations & General Business	Includes engaging in product innovation and development; speech recognition research; monitor, record, and de-identify patient recording and other information; providing customer service to facilitate and address inquiries, comments, and complaints about any of our products or services; handling security and fraud prevention; conducting research and development activities; administering online services (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and the hosting of data); monitoring and analyzing usage of services and using data analytics to improve our services, programs, and overall Client and Consumer experience; gathering feedback; administering pilot programs for potential new services; developing new services and improving existing services; and facilitating mergers, acquisitions, and other reorganizations and restructurings of our business.	Performance of Contract Legitimate Interests, including to manage our business operations and communicate with Clients and Consumers Legal Obligations
Research Management	Communicating with Clients about research opportunities and requirements; preparing for and coordinating research opportunities; processing payments and expenses related to such research opportunities; and communicating with Clients during events; recruit participants into research and to parse out the research by health history markers; capture the primary research being conducted; consent/authorization management.	Performance of Contract Legitimate Interests, including to manage our business operations, communicate with Clients, and promote our products Legal Obligations
Legal & Compliance	Complying with applicable laws; complying with legal processes; responding to requests from public and government authorities; meeting national security or law enforcement requirements; enforcing our terms and conditions; protecting our operations; protecting the rights, privacy, safety, and property of Verilogue employees, visitors, and other relevant individuals; and pursuing available legal remedies, when appropriate.	Legal Obligations Legitimate Interests, including to comply with applicable law and protect Verilogue interests
Emergency, Incident Response, & Security	Ensuring the security of on-site services; responding to, handling, and documenting on-site accidents and medical and other emergencies; actively monitoring Verilogue sites and Services to ensure adequate incident prevention, response, and documentation; requesting assistance from emergency services; and sending notifications and alerts in the event of emergencies.	Performance of Contract Legitimate Interests, including to comply with applicable law, protect Verilogue interests, and protect our Clients and Consumers Legal Obligations
Contacting Patients and Other Consumers	If a patient consents to be contacted by Verilogue in the future for purposes of participating in future research opportunities, Verilogue uses the patient’s email address and/or telephone number to contact the patient for such purposes.	Performance of Contract Legitimate Interests, including to manage our business operations, communicate with Clients and Consumers, and promote our products Legal Obligations Consent (where required for compliance with applicable law)

We may also anonymize and aggregate any Personal Information we collect about you and use the resulting aggregated and/or anonymized data for any purposes permitted by applicable law.

Clients and Consumers are not required to disclose their Personal Information to Verilogue or our Suppliers. However, provision of Personal Information is necessary in some contexts (for example, participate in our research studies). Failure to disclose such Personal Information to Verilogue or our Suppliers may limit our ability to provide Services to you, or otherwise fulfill any applicable contract with you.

Purposes for Processing & Legal Bases for Collection, Processing, & Disclosure of Sensitive Personal Information

Verilogue and our Suppliers collect, process, and disclose the categories of Sensitive Personal Information listed in the “Information We Collect and How We Use It” for the below purposes, as permitted by US Privacy Laws. Please note that the references in the below chart to our legal bases for processing only apply to residents of the European Economic Area, United Kingdom, and other regions with privacy laws that require us to disclose our legal bases for processing. The references to our legal bases for processing do not apply to residents of the U.S.

Purpose	Legal Basis
Performing the services or providing the goods reasonably expected by an average Individual who requests those goods or services	Performance of Contract Legitimate Interests, including to manage our business operations Explicit Consent
Ensuring security and integrity to the extent the use of the Individual’s Personal Information is reasonably necessary and proportionate for these purposes	Legitimate Interests, including to comply with applicable law and protect Verilogue interests Processing necessary for the establishment, exercise, or defense of legal claims Processing necessary to vital interests of the data subject
Preventing, detecting, and investigating security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted Personal Information	Legitimate Interests, including to comply with applicable law and protect Verilogue interests Processing necessary for the establishment, exercise, or defense of legal claims Processing necessary to vital interests of the data subject
Resisting malicious, deceptive, fraudulent, or illegal actions directed at the business and prosecuting those responsible for those actions	Legitimate Interests, including to comply with applicable law and protect Verilogue interests Processing necessary for the establishment, exercise, or defense of legal claims
Ensuring the physical safety of natural persons	Legitimate Interests, including to manage our business operations and comply with applicable law Processing necessary to vital interests of the data subject
Short-term, transient use, including, but not limited to, nonpersonalized advertising shown as part of an Individual’s current interaction with us; provided that we will not disclose the Individual’s Personal Information to a Third Party and or build a profile about the Individual or otherwise alter the Individual’s experience outside the current interaction with the business	Legitimate Interests, including to manage our business operations, communicate with Clients and Consumers, and promote our products Explicit Consent
Performing services on our behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on our behalf	Performance of Contract Legitimate Interests, including to manage our business operations Explicit Consent
Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured by, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us	Legitimate Interests, including to manage our business operations and comply with applicable law Legal Obligations Processing necessary for reasons of public interest in the area of public health
Collecting or processing Sensitive Personal Information where such collection or processing is not for the purpose of inferring characteristics about an Individual	Legitimate Interests, including to manage our business operations Explicit Consent

We do not use automated decision-making, including profiling, to make decisions that have legal or similarly significant effects with respect to Clients or Consumers.

Sale, Sharing, & Processing for Purposes of Targeted Advertising

We do not sell or share for purposes of targeted advertising any of the categories of Personal Information listed in the section “Information We Collect and How We Use It” that we collect about Clients and Consumers.

Retention of Personal Information

We will retain each category of Personal Information listed in section “Information We Collect and How We Use It” for the time needed to fulfil our legitimate and lawful business purposes in accordance with our records retention policy and applicable laws and regulations.

The criteria used to determine our retention periods include:

The duration of our relationship with you and the time needed to provide the Services to you;
Whether there is a legal obligation to which we are subject; and
Whether retention is advisable for other legal and regulatory purposes.

Additional Processing Information

How We Disclose Your Personal Information

For each of the categories of Personal Information listed in section “Information We Collect and How We Use It”, we disclose and have disclosed such Personal Information to our Suppliers, and to Third Parties in connection with the Services in the past twelve months:

Suppliers: We disclose Personal Information to our Suppliers to provide services such as de-identifying, transcribing, and translating research information; sending email messages, managing data, hosting our databases, providing data processing services, providing customer service, conducting marketing activities, and similar purposes. Our Suppliers are restricted from using this data other than to provide services to us.
Third Parties: We may disclose Personal Information to respond to subpoenas or other lawful information requests from governmental authorities, or to comply with applicable law, including to report adverse events, respond to law enforcement requests, or manage security, emergencies, and incident response. We may also provide your Personal Information to a Third Party in connection with any sale, assignment, or other asset transfer, in which case we will seek assurances that the Third Party will treat the Personal Information in accordance with this Privacy Notice.

Sources of Personal Information

We collect Personal Information from the following sources:

Online Services: We collect Personal Information when you interact with our Services, including when you browse our Services; participate in research, including via the Services; communicate with us; post to social media pages; sign up for a study; participate in a research study; or otherwise communicate with us.
Visits and Offline Interactions: We collect Personal Information when we visit your place of business. We also collect Personal Information when you attend promotional events that we host, sponsor, or in which we participate.
Customer Service Centers: We collect Personal Information when you communicate with us, including by contacting our customer service department. These communications may be recorded for purposes of quality assurance and training.
Health Care Providers: We collect Personal Information from HCPs when you consent to participate in our research.
Research Studies: We collect Personal Information from you when you participate in our research studies.
Other Sources: We collect Personal Information from other sources, such as public databases; our Suppliers; and Third Parties, including joint marketing partners.

How We Secure Your Information

We provide reasonable physical, electronic, and procedural safeguards to protect Personal Information collected via our Services. For example, except as otherwise indicated in this Privacy Notice, we limit access to Personal Information to our Workforce members and Suppliers who need access to the Personal Information to perform the activities described in this Privacy Notice. We also use a variety of methods, such as firewalls, intrusion detection software and manual security procedures, designed to secure your information against loss or damage and to help protect the accuracy and security of your information and to prevent unauthorized access or improper use. Although we strive to provide reasonable security for Personal Information we process, no security system can prevent all potential security breaches. Accordingly, we cannot fully guarantee the security of the Personal Information you disclose to us via the Services. If you think that the Website or any Personal Data is not secure or that there has been unauthorized access to the Website or your Personal Data, please contact privacy@verilogue.com immediately.

International Transfers of Personal Information

Personal Information we collect from and about you may be transferred outside of your country of residence, including to the U.S. and other countries that may not provide the same level of data protection as your country of residence. Nonetheless, Verilogue will process your Personal Information in accordance with this Privacy Notice and applicable privacy laws. Further, when we receive or transfer Personal Information from or to our affiliates, Suppliers, and Third Parties, we implement appropriate safeguards to facilitate such transfers where required by applicable law.

To obtain additional information regarding and/or a copy of the safeguards Verilogue has implemented to facilitate cross-border transfers of Personal Information, please contact us at privacyofficer@publicisgroupe.com.

Your Rights & Choices

Residents of the European Economic Area & the United Kingdom

Residents of the European Economic Area and the United Kingdom have rights to access, correct, delete, restrict the processing of, and object to the processing of their Personal Information. Residents of the European Economic Area and the United Kingdom also have rights to obtain their Personal Information in a structured, commonly-used, and machine-readable format for transmission to another data controller, to not be subject to a decision based solely on automated processing, including profiling, that produces legal or similarly significant effects, and to lodge a complaint with a supervisory authority. Further, where we rely on consent as our legal basis for processing, Clients and Consumers who reside in the European Economic Area or the United Kingdom may withdraw their consent at any time. Withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.

Residents of the US

Residents of states with applicable US Privacy Laws have the following rights regarding our collection and use of their Personal Information, subject to certain exceptions.

Right to Receive Information on Privacy Practices

You have the right to receive the following information at or before the point of collection: (1) the categories of Personal Information to be collected; (2) the purposes for which the categories of Personal Information are collected or used; (3) whether or not that Personal Information is sold or shared; (4) if the business collects Sensitive Personal Information, the categories of Sensitive Personal Information to be collected, the purposes for which it is collected or used, and whether that information is sold or shared; and (5) the length of time the business intends to retain each category of Personal Information, or if that is not possible, the criteria used to determine that period. We have provided such information in this Privacy Notice, and you may request further information about our privacy practices by contacting us as at privacy@verilogue.com.

Right to Access

You may request that we provide you with the following information about how we have handled your Personal Information: (1) the categories of Personal Information we collected about you; (2) the categories of sources from which we collected such Personal Information; (3) the business or commercial purpose for collecting, selling, or sharing Personal Information about you; (4) the categories of Third Parties to whom we disclosed such Personal Information; and (5) the specific pieces of Personal Information we have collected about you.

When exercising the right to access Personal Information, you have the right to obtain materials in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.

When we receive and verify your request to access your Personal Information, we will make best efforts to fulfill your request unless an exception applies. We will not disclose your government identification numbers, financial account numbers, health insurance or medical identification numbers, account passwords, security questions and answer, or unique biometric data; however, to the extent we have this information, we will inform you that we have collected this information. You are permitted 2 access reports every 12 months.

Right to Deletion

You may request that we delete any Personal Information about you we that we collected from you, subject to certain exceptions. For example, we may retain Personal Information for certain important purposes, as set out by applicable law. We will also retain a record of your deletion request in order to keep your Personal Information deleted, unless and until you provide consent for the processing of your Personal Information post your deletion request.

Right to Correction

You may request that we correct any inaccurate Personal Information we maintain about you. We may ask for documentation showing that the information you submit is accurate and the Personal Information we hold is inaccurate. Once we receive your request, we will verify your identity and, taking into account the type of personal information and the purposes of our holding that personal information, we will make best efforts to complete your request. We may deny your request if we determine that the contested Personal Information is more likely than not accurate. Additionally, we may choose to delete your Personal Information in response to your request to correct your Personal Information if the deletion of your Personal Information would not negatively impact you.

Right to Opt-Out of the Sale and Sharing of Personal Information

You have the right, at any time, to direct us not to sell or share your Personal Information. To exercise that right, please contact us by clicking here or sending an email to privacy@verilogue.com.

Additionally, you may choose not to receive targeted advertising from ad networks, data exchanges, and other digital advertising providers by opting out of targeted advertising via YourAdChoices powered by the Digital Advertising Alliance.

Right to Limit the Use of Sensitive Personal Information

You may request that we limit the use and disclosure of your Sensitive Personal Data. However, we may deny your request in part of in full under uses authorized by applicable law.

Right to Receive Information About Onward Disclosures

You may request that we disclose to you: (1) the categories of Personal Information that we have collected about you; (2) the categories of Personal Information that we have sold or shared about you and the categories of Third Parties to whom the Personal Information was sold or shared; and (3) the categories of Personal Information we have disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.

Right to Opt-Out of Automated Decision Making and Profiling

It’s your right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect. However, we do not use automated decision making, including profiling, when processing your Personal Information.

Right to Non-Discrimination

You have the right not to be discriminated against for exercising your data subject rights. We will not discriminate against you for exercising your data subject rights.

Residents of Canada

Residents of Canada have the following rights regarding our collection and use of their Personal Information.

Right to Request Access to Your Personal Information

You have a right to access your Personal Data in our control. We will also provide you with a description of what uses we have made of your Personal Information and which third parties we have shared it with. In some cases, we may not be able to provide you with access to your Personal Information, such as where:

Personal information about another person might be revealed and the other person’s personal information cannot be separated from yours;
Commercially confidential information might be revealed and the confidential information cannot be separated from yours;
The requested information is subject to solicitor and client privilege;
Someone’s life or security might be threatened as a result of giving you access and the personal information about the other person cannot be separated from yours;
The information was collected for purposes related to an investigation of a breach of an agreement or contravention of the law.

We will respond to your request within 30 days, unless we require more time to do so, in which case we will advise you of the date by which we will respond to your request within 30 days of receiving it.

Right to Request Correction to Your Personal Information

If you note any inaccuracies or wish to update any of your Personal Information, we will make those changes upon your request.

Right to Withdraw Your Consent

At any time, you may withdraw your consent for us to process your Personal Information for the purposes described at Section II of this Privacy Notice. However, this may affect our ability to offer you some of the services. For example, we may not be able to respond to your queries.

Exercising Your Rights

To exercise your data subject rights, you can submit your request here, by sending an email to privacy@verilogue.com or by contacting us at 1-833-983-0087.

For security purposes (and as required under US state laws), we will verify your identity, in part by requesting certain information from you, when you make a request to access, correct, or delete, your Personal Information. The verification process will utilize an email verification process, a telephone number verification process, and, if applicable, a request for any assigned ID number previously communicated to you. If we are unable to complete your request fully for any reason, we will provide you additional information about the reasons why we could not comply with your request.

Authorized agents may also submit requests via the methods described above, where permitted by applicable privacy laws. We will take steps both to verify your identity and to verify that your agent has been authorized to make a request on your behalf by requesting your agent to provide us with a signed written authorization or a copy of a power of attorney executed by you.

Further, to opt out of receiving marketing-related emails, you can use the unsubscribe link at the bottom of any of our email communications, or submit a request via the above methods.

We will not discriminate against you for exercising your data subject rights. For example, we will not deny goods or services to you, or charge you different prices or rates, or provide a different level of quality for products or services as a result of you exercising your data subject rights.

Appeals

It is your right to appeal a decision made on your data subject requests. You may appeal this decision within 60 days of receiving your response from us. To submit your appeal, click here or contact privacyofficer@publicisgroupe.com. We will respond to your appeal in accordance with applicable law.

Other Disclosures for California Clients and Consumers

California Residents Under Age 18

If you are a resident of California under the age of 18 and a registered user of our website, you may ask us to remove content or data that you have posted to the website by writing to privacy@verilogue.com. Please note that your request does not ensure complete or comprehensive removal of the content or data, as, for example, some of your content or data may have been reposted by another user.

Disclosure About Direct Marketing for California Residents

California Civil Code § 1798.83 permits California residents to annually request certain information regarding our disclosure of Personal Information to other entities for their direct marketing purposes in the preceding calendar year. To make such a request, please send an email to privacy@verilogue.com with the subject “Shine the Light Request”.

Financial Incentive

We do not provide financial incentives to consumers who allow us to collect, retain, sell, or share their Personal Information. We will describe such programs to you if and when we offer them to you.

Disclosure for Nevada Consumers

We sell “Covered Information” as defined under Nevada law, but we generally do not disclose or share “Personal Information” as defined under Nevada law for commercial purposes. Under Nevada law, you have the right to direct us to not sell your Covered Information to third parties, as defined under Nevada law. Sale is defined under Nevada law as “the exchange of covered information for monetary consideration by the operator to a person for the person to license or sell the covered information to additional persons”. To exercise this right, if applicable, you or your authorized representative may contact our Privacy Office at privacyofficer@publicisgroupe.com.

Emails

You can opt-out of receiving promotional emails from us at any time by following the instructions as provided in emails to click on the unsubscribe link, or emailing us at the email address set out in the “Further Information” section below with the word “unsubscribe” in the subject field of the email. Please note that you cannot opt-out of non-promotional emails, such as those about transactions, servicing, or our ongoing business relations.

Children

The Website is intended for general audiences and is not directed at children. We do not knowingly collect Personal Data (as defined by the U.S. Children’s Privacy Protection Act, or “COPPA”) from children. If you are a parent or guardian and believe we have collected Personal Data in violation of COPPA, contact us at privacy@verilogue.com. We will remove the Personal Data in accordance with COPPA. We do not knowingly “sell”, as that term is defined under the US state privacy laws, like CCPA or VCDPA, the Personal Data of minors under 16 years old without legally required affirmative authorization.

Use of Social Media and Social Media Plug-ins

Verilogue has a fan page or a company page on Twitter, Facebook, Instagram, YouTube and LinkedIn that you can use or visit. Verilogue acts as a joint data controller with the social media platform for the collection of your personal data when you visit our company page on the social media platform. We will collect Personal Data about you in order to understand our followers better and understand the public response to our products and services. We may use this information to contact you/ send you marketing information which we think may be of interest to you/ engage in social listening to identify and assess what is being said about us publicly to understand industry trends and market sentiment. Any information you provide to us when you engage with our content (such as through our brand page or via Facebook Messenger) is treated in accordance with this Privacy Notice. Also, if you publicly reference us or our Website on social media (such as by using a hashtag associated with us in a tweet or post), we may use your reference on or in connection with our Website.

You can read more regarding our joint controllership with the platforms at the following links:

We provide social media plug-ins on the Website to allow you to easily share content from our Website through social media, and in doing so, we may receive your Personal Data from the social media platform that you have authorized to share with us. When you share content using these buttons, a new page will pop up from the relevant social media platform. If you’re already logged into your account on that social media platform, then you will probably be automatically logged into this pop-up page, so that you don’t have to log in again. If, however, you are not logged in (or if you are not registered with the social media platform), the page will ask you for your information. Verilogue is joint data controllers with the social media platforms for the collection of your personal data that is collected by the platforms when you visit our website.

We have no control over how social media platforms use your Personal Data and they may independently collect information about you when you leave our Website. The information collected and stored by those parties remains subject to their own policies and practices, including what information they share with us, your rights and choices on their services and devices, and whether they store information in the U.S. or elsewhere. We encourage you to read the privacy notices on the various social media platforms you use.

Find out more about how these social media platforms use your Personal Data:

YouTube (Google’s general privacy policy)
LinkedIn
Facebook
Twitter
Instagram

Do Not Track

Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals. For more information on “Do Not Track”, visit All About DNT.

Annual Consumer Requests Reporting

From January 1, 2023 to December 31, 2023, we facilitated requests pursuant to the CCPA from individuals in the United States as follows:

	Requests to Know	Requests to Delete	Requests to Opt-out of Sale
Number of requests received	0	0	0
Number of requests complied with in full	0	0	0
Number of requests complied with in part	0	0	0
Number of requests denied	0	0	0
Mean number of days we took to substantively respond to requests	0	0	0

Changes to Our Privacy Practices

We may update this Privacy Notice from time to time. When we do so, we will make the updated notice available on this page. Verilogue encourages you to review this page regularly for any changes.

How to Contact Us

To contact us with questions or more information, you can email us at privacy@verilogue.com.

To contact our Data Protection Officer responsible for your country or region, please email us at privacyofficer@publicisgroupe.com. In your email, please indicate your country of residence.

Last Updated: July 30, 2024