Your California Privacy Rights

For purposes of the California Consumer Privacy Act of 2018 (CCPA), we are generally a service provider to our clients. Additionally, our websites are generally intended to provide information to our business clients and those who would like to learn more about our services such as job applicants. In rare instances in which we have not collected or processed personal information as a service provider or from job applicants, you as a California resident have the right to make the following requests with respect to your personal information:

· Access – You have the right to request that we disclose to you the categories of personal information we collected about you, the categories of sources from which we collected the personal information, the categories of personal information we sold or disclosed, our business or commercial purpose for collecting and selling the personal information, the categories of third parties with whom we shared the personal information, and the specific pieces of personal information we collected about you over the past 12 months.

· Deletion – You can request that we delete your personal information that we maintain about you, subject to certain exceptions.

Havas will not discriminate against you because you exercised any of these rights.

Note that for purposes of these rights, personal information does not include information about job applicants, employees and other of our personnel; information about employees and other representatives of third-party entities we may interact with; or information we have collected as a service provider to our clients.

California residents can exercise these rights online using the web form at the following link or by contacting us as set forth in the privacy policy. We may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations. For example, we may retain personal information as permitted by law, such as for tax or other record keeping purposes, to maintain an active account, and to process transactions and facilitate customer requests. We will take reasonable steps to verify your identity prior to responding to your requests. The verification steps will vary depending on the sensitivity of the personal information and whether you have an account with us. For example, if you request a copy of the specific pieces of information we collected about you, we may require that you provide at least three pieces of personal information that match personal information we maintain, together with a signed declaration that you are the consumer whose personal information is subject of the request. California residents may designate an authorized agent to make a request on their behalf. When submitting the request, please ensure the authorized agent is identified as an authorized agent.

For purposes of exercising these rights, please note the following regarding how we collect and use your personal information as described in this policy, including in the previous 12 months:

· We may collect, use, and disclose for our business and commercial purposes as described in the “We Use Information” section above, the following categories of personal information as set forth in applicable California law: Identifiers; commercial information; payment and customer records information; characteristics of protected classifications under California or federal law, such as demographic information like age and gender; professional or employment information; education information; internet or other electronic network activity information; geolocation data; and inferences.

· We collect the above categories of personal information from the sources described in the “We Collect Information In Different Ways” section in this privacy policy.

· We may disclose each of the foregoing categories of personal information for the business and commercial purposes described in this Privacy Policy to the categories of third parties as described in this Privacy Policy, including to our parents, affiliates, and subsidiaries; service providers; business and advertising partners; vendors, including, advertising networks, data analytics providers, and social networks; and successors to our business. We may also disclose each of these categories in order to comply with the law or to protect ourselves or third parties as well as for other reasons we may describe to you at the time of collection or to which we otherwise obtain your consent.

· We share personal information with third parties in various ways as described in this Privacy Policy. We do not currently consider the ways we shared your personal information in the past 12 months to comprise the “sale” of your information as defined in the CCPA. You can learn about ways in which you can control the collection of information about you through cookies and other tracking tools by reviewing the Cookies and Other Technologies section in the privacy policy.

If you reside in California, you also have the right to ask us one time each year if we have shared personal information with third parties for their direct marketing purposes. To make a request, please send us an email, or write to us at the address listed in the privacy policy. Indicate in your letter that you are a California resident making a “Shine the Light” inquiry.