Canadian Privacy Policy (EN)

Modified on Tue, 29 Apr at 11:37 AM

Our GTB Studio Privacy Policy

Updated January 8, 2025

The https://app-studio.gtb.com website and interconnected GTB Studio application (“GTB Studio Platform”) is operated and controlled by GTB lp (hereinafter referred to as “GTB”, “we” or “us”).

Use of the GTB Studio Platform is governed either by a Master Services Agreement (MSA), a Statement of Work, or online Terms of Service agreed between GTB and each respective GTB Customer (hereinafter referred to as the “Customer(s)” or “you”.

We respect the privacy of our Customers and recognise that when you choose to provide us with personal data, you trust us to act in a responsible manner with that information. Where Customers have chosen to sign up to the GTB Studio Platform, we act as the controller of any personal data that you provide to us and are responsible for processing it in accordance with the law. This excludes any personal data that your employer specifically asks us to process as part of the services we will provide.

This privacy policy contains important information about how we process the personal data of our Customers, which will cover the following data subjects:

Our Customers, either historical or existing who are natural persons; andrepresentatives or contact persons of our Clients who are legal entities.

Access to the GTB Studio Platform is restricted to those Customers who have been approved by GTB to access the GTB Studio Platform, via the GTB Studio sign up process.

What information do we collect?

At times, we may request that information is voluntarily supplied to us by our Customer themselves or by the legal entity appointed by the Customer.

We may gather the following information about you during the engagement of GTB Studio Platform:

Identification and contact information (Full Name, Business Email address, Mobile Phone Number)·
Dealership name, address and location.

Employers should ensure their employees are aware that their data is being shared with us, as described in this policy.

How do we use it?

The primary reason we process your personal data is to approve, manage, administer or effect an agreement between GTB and the entity you represent or work for. In this respect, we process your personal data to:

Issue invoices, perform accounting, manage our contracts or review the services or products we supply to you.
Meet our legal obligations (such as record keeping obligations).
Manage risks and operations (e.g. prevent and detect security threats, exercise or defend legal claims).

Legal basis for processing

We are also required by law to state a “legal basis for processing”, i.e. to tell you on what grounds we are allowed to use your information, and this is also set out below:

How we will use your personal data	Our legal basis for processing
Managing our relationship with our Customers.	Legitimate interest - in cases where we process data of representatives or contacts of our Customers who are legal entities, the processing of your data is necessary for our legitimate interest to communicate with our Customers' representatives in a customary, personal manner. Necessary for the performance of a contract – we use your personal data to liaise with you on matters relating to our relationship, if you, as our Customers, are a natural person. We will use your personal data to enable your employees to logon and to administer platforms we have given you and your employees access to as part of our Services.
Making decisions about supplying goods and services (e.g., determining invoices or the terms of our contractual agreement(s) etc).	Legitimate interest – in cases where our Customer is a legal person, we use your personal data to keep you updated throughout our relationship. Necessary for the performance of a contract – we use your personal data to supply goods and services to you, and to keep you updated throughout our relationship.
Upholding our company’s economic interests and ensuring compliance and reporting (such as adhering to our policies, local legislation and managing allegations of fraud or misconduct).	To comply with our legal obligations – in cases where our Customer is a natural person, we use your personal data to investigate and prevent fraud or misconduct and to protect our economic interests.
Any other purposes required by law and authorities.	Processing is necessary for compliance with a legal obligation to which we are subject.

Do we pass your information to third parties?

We may send your personal data to other GTB and WPP group companies, affiliates and third parties to help us process your personal data for the purposes set out in this policy. Further details of our group companies can be found on WPP.com

We may disclose your personal data if we or any of our assets are the subject of a sale or similar corporate transaction. We will ensure that the third parties who receive your personal data are required to keep it confidential.

We may disclose personal data to third parties when we reasonably believe we are required by law, and in order to investigate, prevent, or take action regarding suspected or actual unlawful or otherwise prohibited activities, including, but not limited to, fraud.

Where do we send your information?

We are a global company and therefore we may transfer your personal data to countries around the world including the US and other countries outside Europe. We will, where the country to which your data is transferred has not been found to provide an adequate level of protection, put in place appropriate safeguards (we use standard contractual clauses) to ensure your information is protected.

How long do we keep your information?

We only keep your personal data for as long as it is necessary to fulfill the purposes for which it was collected.

Third party platforms

The GTB Studio Platform may link to third party platforms (for example for payments) which we do not operate. These platforms may use cookies and collect your personal data in accordance with their own privacy policies. This privacy policy does not apply to third party platforms and we are not responsible for third party platforms.

How do we protect your information?

We take appropriate measures to ensure that your personal data disclosed to us is kept secure, accurate and up to date and kept only for so long as is necessary for the purposes for which it is used.

Your rights

Depending on the purposes of processing you may be entitled to ask:

for a copy of the personal data we hold about you, and details about how we are processing your personal data
to have any inaccuracies in your personal data corrected;
if we are processing your personal data by automated means and based on your consent (see “How do we use it?”, above), for us to provide your personal data to you in a structured, commonly-used and machine-readable format. You can also ask us to provide your personal data directly to a third party in this format, and, if technically feasible, we will do so;
to withdraw your consent at any time. The withdrawal of your consent will not affect the lawfulness of processing based on consent before withdrawal
to object, on grounds relating to your particular situation, at any time which is based on our legitimate interest; and
to have your personal data erased, or for our use of it to be restricted (for example, if your preferences change, or if you don’t want us to send you the information you have requested).

Please contact us using the details set out below if you would like to exercise any of these rights.

You also have the right to make a complaint to the supervisory authority in your country if you’re not happy with how we’ve handled your personal data.

How to contact us

If you wish to exercise any of your rights in relation to your personal data or if you have any queries about how we use your personal data, please let us know by contacting us at the following address:

GTB

Westfield World Trade Center

175 Greenwich St Floor 16, New York, NY 10007, United States

or by email at GTBStudio.Canada@gtb.com.

Changes to this privacy policy

We review this privacy policy on a regular basis to ensure that it is up-to-date with our use of your personal data, and compliant with applicable data protection laws.

We reserve the right, at our discretion, to revise this privacy policy at any time. The updated privacy policy will be posted on the GTB Studio Platform. You are encouraged to review this privacy policy from time to time.

Cookies

The GTB Studio Platform utilizes cookies to improve the function and performance of the GTB Studio Platform.

What are cookies?

We may use information obtained from cookies or similar technology. Cookies are text files containing small amounts of information which we download onto your computer or device when you access GTB Studio Platform. Therefore, when we refer to “you” in this section we mean your computer. We can recognise these cookies on subsequent visits and they allow us to remember you.

Cookies come in many forms. We have set out below the main types and categories of cookies that are used. This section refers to all types and categories of cookies and not just those we use on our website.

First and third-party cookies - whether a cookie is first-party or third-party refers to the domain placing the cookie. First-party cookies are those set by a website that is being visited by the user, the website displayed in the URL window e.g. app-studio.gtb.com. Third-Party cookies are cookies that are set by a domain other than that of the website being visited by the user. If a user visits a website and another entity sets a cookie through that website this would be a third-party cookie.

Persistent cookies – these cookies remain on a user's device for the period of time specified in the cookie. They are activated each time that the user visits the website that created that particular cookie.

Session cookie – these cookies allow website operators to link the actions of a user during a browser session. A browser session starts when a user opens the browser window and finishes when they close the browser window. Session cookies are created temporarily. Once you close the browser, all session cookies are deleted.

What cookies do we use?

Cookies fall into one or more of the categories set out below. The GTB Studio Platform uses Functional and Performance cookies.

Functional cookies

Functionality cookies – These cookies remember choices you make to improve your experience. These cookies allow GTB Studio Platform or website to remember choices you make and provide enhanced, more personal features. They may also be used to help provide services you have asked for such as watching a video or commenting on a blog. The information these cookies collect may be anonymised and they cannot track your browsing activity to other websites.

Host	Cookie Name	Description
fw-cdn.com	first_session	This is a third party session tracking cookie from Freshworks CDN. It contains a json object
freshchat.com	__cf_bm	This is a CloudFoundry cookie and its description is on this page: https://developers.cloudflare.com/fundamentals/reference/policies-compliances/cloudflare-cookies/
GTB	_zg	This cookie name _zg is associated with Freshworks/Freshdesk which is used to track Visitor/User identity and chat sessions performed by the user._zg
GTB	_fw_crm_v	This cookie name is associated with Freshworks which is used to track Visitor/User identity and chat sessions performed by the user.

Performance cookies

Performance cookies – These cookies collect information on the pages visited.

These cookies collect information about how users use the GTB Studio Platform or website, for instance which pages users go to most often, and if they get error messages from web pages. These cookies don't collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. They are only used to improve how the GTB Studio Platform or website works.

Host	Cookie Name	Description
	_ga_xxxxxxxxxx	NAUsed by Google Analytics to identify and track an individual session with your device.
	_ga	This cookie name is associated with Google Universal Analytics - which is a significant update to Google's more commonly used analytics service. This cookie is used to distinguish unique users by assigning a randomly generated number as a Customer identifier. It is included in each page request in a site and used to calculate visitor, session and campaign data for the sites analytics reports. By default it is set to expire after 2 years, although this is customisable by website owners. For more information about Google's processing of your personal data, please consult Google's <a href=https://business.safety.google/privacy/ rel="nofollow">Privacy & Terms</a> site.

If you want to delete any cookies that may already be on your computer or device, please refer to the instructions for your file management software to locate the file or directory that stores cookies. If you want to stop cookies being stored on your computer in future, please refer to your browser manufacturer’s instructions by clicking “Help” in your browser menu. Further information on cookies is available at www.allaboutcookies.org. By deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our website.

What other information do we collect through the GTB Studio Platform?

GTB may also collect and store aggregate or anonymous information about a user’s interaction with the GTB Studio Platform.

We may use this aggregate or anonymous information we collect about our customers, traffic patterns, and related site information to better design the GTB Studio Platform and to share with reputable third-party vendors. Please note, aggregate and anonymous information is not personal information and cannot directly or indirectly identify an individual on its own.

Analytics and Interest-based Advertising

We may disclose your information for analytics and interest-based advertising purposes, as described below.

Analytics. We partner with certain third parties to obtain the automatically collected information discussed above and to engage in analysis, auditing, research, and reporting. These third parties may use pixels or server logs, and they may set and access device IDs and IP addresses from your device.

Interest-based advertising. We may also enable third-party tracking mechanisms to collect information about you and your computing devices for use in online interest-based advertising. For example, third parties may use the fact that you visited our website to target online ads to you. In addition, our third-party advertising networks might use information about your use of our website to help target advertisements based on your online activity in general. For information about interest-based advertising practices, including privacy and confidentiality, visit the Network Advertising Initiative website or the Digital Advertising Alliance website.

The use of online tracking mechanisms by third parties is subject to those third parties’ own privacy policies, and not this policy. If you prefer to prevent third parties from setting and accessing cookies on your computer or other device, you may set your browser to block cookies. Additionally, you may remove yourself from the targeted advertising of companies within the Network Advertising Initiative by opting out here, or of companies participating in the Digital Advertising Alliance by opting out here. Although our Platform currently does not respond to “do not track” browser headers, you can limit tracking through these third-party programs and by taking the other steps discussed above.

You may also opt-out of interest-based by adjusting the advertising preferences on your mobile device (for example, in iOS, visit Settings > Privacy > Advertising > Limit Ad Tracking, and in Android, visit Settings > Google > Ads > Opt out of interest-based ads). Additionally, you may opt out for companies that participate in the Digital Advertising Alliance's AppChoices tool by downloading it here and following the instructions in the app.

How can I control cookies?

You have the right to decide if you want to accept or reject cookies through the following methods:

Browser Controls: You can accept or reject cookies through changing your web browser settings. If you want to reject cookies through your browser, you should visit your browser help menu for further information. In the scenario where you reject cookies, you may still be able to use our App or website, but some parts may be restricted.