Last Updated: June 2026
1. Purpose of this Privacy Notice
Omnicom Group Inc. and its subsidiaries Omnicom Management Inc., Omnicom Capital Inc., Cardinia Real Estate LLC, Crystal Vision LLC, TBWA Worldwide Inc., Engagement Arts Inc., Lucky Generals NY LLC, 180 LA LLC, GMR Marketing LLC, DDB Worldwide Communications Group LLC, TLP, Inc. (d/b/a Tracy Locke), Interbrand Corporation, Adam & Eve Inc. RAPP Worldwide, RAPP Worldwide California Inc., RAPP Worldwide Texas Inc., Omnicom Media Group Holdings Inc., Next Beauty Co-Lab LLC, Resolution Media Inc., OMD Worldwide Holdings Inc., OMG Entertainment & Sports LLC, PHD Media LLC, Media Services Inc., OMD USA LLC, Hearts and Science LLC, Creo Influencer LLC, Experience Worldwide, Inc. (d/b/a Story House), Snow Companies LLC and MyPatientStory.com LLC, d/b/a PatientWorthy, collectively “Omnicom”, respect your concerns about privacy. Omnicom participates in the EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. Data Privacy Framework and the Swiss-U.S. Data Privacy Framework (collectively, the “Data Privacy Framework” or “DPF”) administered by the U.S. Department of Commerce. Omnicom commits to comply with the DPF Principles with respect to Consumer Personal Data the company receives from the EU, UK and Switzerland in reliance on the DPF. If there is any conflict between the terms in this Privacy Policy (“Policy”) and the DPF Principles, the DPF Principles shall govern.
2. Definitions
For purposes of this Policy:
“Consumer” means any natural person who is in the EU, UK or Switzerland, but excludes any individual acting in his or her capacity as an Employee.
“Controller” means a person or organization which, alone or jointly with others, determines the purposes and means of the processing of Personal Data.
“DPF Principles” means the Principles and Supplemental Principles of the DPF.
“Employee” means any current, former or prospective employee, intern, temporary worker or contractor of Omnicom or any related individual whose Personal Data Omnicom processes in connection with an employment relationship, who is located in the EU, UK or Switzerland.
“EU” means the European Union and Iceland, Liechtenstein and Norway.
“Personal Data” means any information, including Sensitive Data, that is (i) about an identified or identifiable individual, (ii) received by Omnicom in the U.S. from the EU, UK or Switzerland, and (iii) recorded in any form.
“Processor” means any natural or legal person, public authority, agency or other body that processes Personal Data on behalf of a Controller.
“Sensitive Data” means Personal Data specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership (including trade union-related views or activities), sex life (including personal sexuality), information on social security measures, the commission or alleged commission of any offense, any proceedings for any offense committed or alleged to have been committed by the individual or the disposal of such proceedings, or the sentence of any court in such proceedings (including administrative proceedings and criminal sanctions).
“Supplier” means any supplier, vendor or other third party located in the EU, UK or Switzerland that provides services or products to Omnicom.
“UK” means the United Kingdom and Gibraltar.
3. DPF Certification
Omnicom’s DPF certification, along with additional information about the DPF, can be found at https://www.dataprivacyframework.gov. For more information about Consumer Personal Data processing with respect to information obtained through Omnicom’s website, please visit https://patientworthy.com/privacy-policy/.
4. Types of Personal Data We Collect
Omnicom collects Personal Data directly from Consumers. This collection occurs, for example, when a Consumer visits one of our websites. Omnicom may use this information for the purposes disclosed at the time it was collected or indicated in our Privacy Notice.
Omnicom collects the following types of Consumer Personal Data:
- Contact information, such as name, postal address, email address and telephone number;
- Personal Data in content Consumers provide on Omnicom’s website and other data collected automatically through the website (such as IP addresses, browser characteristics, device characteristics, operating system, language preferences, referring URLs, information on actions taken on our websites, and dates and times of website visits); and
- Sensitive Data, specifically health information such as medical diagnoses, treatment, symptoms, and side effects, provided voluntarily by Consumers when utilizing this website.
In addition, Omnicom obtains Personal Data, such as contact information and financial account information, of its Suppliers’ representatives. Omnicom uses this information to manage its relationships with its Suppliers, process payments, expenses and reimbursements, and carry out Omnicom’s obligations under its contracts with the Suppliers.
Omnicom also may obtain and use Consumer Personal Data in other ways for which Omnicom provides specific notice at the time of collection.
Omnicom’s privacy practices regarding the processing of Consumer Personal Data comply with the DPF Principles of Notice; Choice; Accountability for Onward Transfer; Security; Data Integrity and Purpose Limitation; Access; and Recourse, Enforcement and Liability.
5. Notice
Omnicom provides information in this Policy and the Privacy Notice about its Consumer Personal Data practices, including the types of Personal Data Omnicom collects, the types of third parties to which Omnicom discloses Personal Data and the purposes for doing so, the rights and choices Consumers have for limiting the use and disclosure of their Personal Data, and how to contact Omnicom about its practices concerning Personal Data. Relevant information also may be found in notices pertaining to specific data processing activities.
6. Choice
Omnicom generally offers Consumers the opportunity to choose whether their Personal Data may be (i) disclosed to third-party Controllers or (ii) used for a purpose that is materially different from the purposes for which the information was originally collected or subsequently authorized by the relevant Consumer. To the extent required by the DPF Principles, Omnicom obtains opt-in consent for certain uses and disclosures of Sensitive Data. Consumers may contact Omnicom as indicated below regarding the use or disclosure of their Personal Data. Unless Omnicom offers Consumers an appropriate choice, the company uses Personal Data only for purposes that are materially the same as those indicated in this Policy.
Omnicom shares Consumer Personal Data with its affiliates and subsidiaries. Omnicom may disclose Consumer Personal Data without offering an opportunity to opt out, and may be required to disclose the Consumer Personal Data, (i) to third-party Processors the company has retained to perform services on its behalf and pursuant to its instructions, (ii) if it is required to do so by law or legal process, or (iii) in response to lawful requests from public authorities, including to meet national security, public interest or law enforcement requirements. Omnicom also reserves the right to transfer Personal Data in the event of an audit or if the company sells or transfers all or a portion of its business or assets (including in the event of a merger, acquisition, joint venture, reorganization, dissolution or liquidation).
7. Accountability for Onward Transfer of Personal Data
This Policy and the Privacy Notice describe Omnicom’s sharing of Consumer Personal Data.
Except as permitted or required by applicable law, Omnicom provides Consumers with an opportunity to opt out of sharing their Personal Data with third-party Controllers. Omnicom requires third-party Controllers to whom it discloses Consumer Personal Data to contractually agree to (i) only process the Personal Data for limited and specified purposes consistent with the consent provided by the relevant Consumer, (ii) provide the same level of protection for Personal Data as is required by the DPF Principles, and (iii) notify Omnicom and cease processing Personal Data (or take other reasonable and appropriate remedial steps) if the third-party Controller determines that it cannot meet its obligation to provide the same level of protection for Consumer Personal Data as is required by the DPF Principles.
With respect to transfers of Consumer Personal Data to third-party Processors, Omnicom (i) enters into a contract with each relevant Processor, (ii) transfers Personal Data to each such Processor only for limited and specified purposes, (iii) ascertains that the Processor is obligated to provide the Personal Data with at least the same level of privacy protection as is required by the DPF Principles, (iv) takes reasonable and appropriate steps to ensure that the Processor effectively processes the Personal Data in a manner consistent with Omnicom’s obligations under the DPF Principles, (v) requires the Processor to notify Omnicom if the Processor determines that it can no longer meet its obligation to provide the same level of protection as is required by the DPF Principles, (vi) upon notice, including under (v) above, takes reasonable and appropriate steps to stop and remediate unauthorized processing of the Personal Data by the Processor, and (vii) provides a summary or representative copy of the relevant privacy provisions of the Processor contract to the Department of Commerce, upon request. PatientWorthy remains liable under the DPF Principles if the company’s third-party Processor onward transfer recipients process relevant Consumer Personal Data in a manner inconsistent with the DPF Principles, unless Omnicom proves that it is not responsible for the event giving rise to the damage.
8. Security
Omnicom takes reasonable and appropriate measures to protect Consumer Personal Data from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the Personal Data.
9. Data Integrity and Purpose Limitation
Omnicom limits the Consumer Personal Data it processes to that which is relevant for the purposes of the particular processing. Omnicom does not process Consumer Personal Data in ways that are incompatible with the purposes for which the information was collected or subsequently authorized by the relevant Consumer. In addition, to the extent necessary for these purposes, Omnicom takes reasonable steps to ensure that the Personal Data the company processes is (i) reliable for its intended use, and (ii) accurate, complete and current. In this regard, Omnicom relies on its Consumers to update and correct the relevant Consumer Personal Data to the extent necessary for the purposes for which the information was collected or subsequently authorized. Consumers may contact Omnicom as indicated below to request that Omnicom update or correct relevant Personal Data.
Subject to applicable law, Omnicom retains Consumer Personal Data in a form that identifies or renders identifiable the relevant Consumer only for as long as it serves a purpose that is compatible with the purposes for which the Personal Data was collected or subsequently authorized by the Consumer.
10. Access
Consumers generally have the right to access their Personal Data. Accordingly, where appropriate, Omnicom provides Consumers with reasonable access to the Personal Data Omnicom maintains about them. Omnicom also provides a reasonable opportunity for those Consumers to correct, amend or delete the information where it is inaccurate or has been processed in violation of the DPF Principles, as appropriate. Omnicom may limit or deny access to Personal Data where the burden or expense of providing access would be disproportionate to the risks to the Consumer’s privacy in the case in question, or where the rights of persons other than the Consumer would be violated. Consumers may request access to their Personal Data by contacting Omnicom as indicated below.
11. Recourse, Enforcement and Liability
Omnicom has mechanisms in place designed to help assure compliance with the DPF Principles. Omnicom conducts an annual self-assessment of its Consumer Personal Data practices to verify that the attestations and assertions Omnicom makes about its DPF privacy practices are true and that Omnicom’s privacy practices have been implemented as represented and in accordance with the DPF Principles.
Consumers may file a complaint concerning Omnicom’s processing of their Personal Data. Omnicom will take steps to remedy issues arising out of its alleged failure to comply with the DPF Principles. Consumers may contact Omnicom as specified below about complaints regarding Omnicom’s Consumer Personal Data practices.
If a Consumer’s complaint cannot be resolved through Omnicom’s internal processes, Omnicom will cooperate with JAMS pursuant to the JAMS DPF Program, which is described on the JAMS website at https://www.jamsadr.com/dpf-dispute-resolution. JAMS mediation may be commenced as provided for in the JAMS rules. Following the dispute resolution process, the mediator or the Consumer may refer the matter to the U.S. Federal Trade Commission, which has DPF investigatory and enforcement powers over Omnicom. Under certain circumstances, Consumers also may be able to invoke binding arbitration to address complaints about Omnicom’s compliance with the DPF Principles.
12. How to Contact Omnicom
To contact Omnicom with questions or concerns about this Policy or Omnicom’s Consumer Personal Data practices, write to:
PatientWorthy c/o
Snow Companies, LLC
Attn: Chief Legal and Privacy Officer
133 Waller Mill Road
Williamsburg, VA 23185
E-mail: [email protected]
or
Omnicom Group Inc.
Attention: General Counsel
280 Park Ave.
New York, NY 100177
