Services Privacy Policy

Last Updated September 8, 2020

Effective Date: September 22, 2020

Sovrn Holdings, Inc. with our affiliates (including those not under the Sovrn brand, and collectively, “Sovrn” or “we”) provides advertising technologies that allow websites and other internet-connected services to generate revenue by showing advertisements to their users, and allow marketers and other advertisers to show advertisements to individuals online who may be interested in their products or services. We also help our data partners meet their product and development needs by providing access to unique, diverse, and engagement-driven data from our network of 40,000+ high quality, content-rich, and independent Publishers. This includes providing data to our clients (who are advertisers, brands, retailers, and other businesses) to target their own advertising based on such information (referred to as “Interest-based Advertising”). Specific to Sovrn Commerce, Publishers add links on locations including, but not limited to, webpages, sites, software, social media, and mobile applications to merchant destinations. When a Reader clicks through Sovrn Commerce affiliated links to a merchant destination and then makes a purchase or submits a lead, the Publisher that generated the traffic is paid a referral fee or commission. We also provide services to analyze the effectiveness of these services through ad reporting, attribution, and analytics. Together, the activities described above are collectively known as “Sovrn Services”.

This Privacy Policy (“Privacy Policy”) describes how Sovrn collects, uses, and shares information from Publishers and about Readers in connection with Sovrn Services.

Our goal is to be transparent about our business by describing our technology and services in simple terms. If unsure about any of the information provided, please reach out to privacy@sovrn.com.

Sovrn Services contain links to websites or content operated and maintained by third parties over which we have no control. We encourage review of the privacy policies of such third-party websites and content before disclosing any information to them.

For information on how we collect, use and disclose information through other corporate activities, such as on our corporate website, please see the Sovrn Website Privacy Policy.

Capitalized terms are defined in this Privacy Policy, unless otherwise indicated. Throughout this Privacy Policy, we use the following terms:

  • “Publishers” are websites or publications that use Sovrn Services, or natural persons who interact with Sovrn on behalf of such websites or publications.
  • “Readers” are individuals who visit our Publishers’ websites.
  • “Personal Information” means any information that can be used to directly or indirectly identify a natural person, such as contact information (i.e., name, address, e-mail address, and/or phone number), and/or information that uniquely and persistently identifies a browser or device such as an IP address, mobile advertising identifier, cookie identifier, or email address that has been hashed to generate an alphanumeric identifier, or combination of information about a browser or device (such as IP address and browser type/settings). As explained below, Sovrn Services do not collect types of Personal Information about Readers that can be used to identify specific individuals.
  • “Non-Personal Information” means information that is not associated with or linked to Personal Information including aggregate or de-identified information.

Sovrn supports industry self-regulation and endorses industry best practices and self-regulatory standards. Sovrn follows and adheres to the industry Self-Regulatory Principles of the Digital Advertising Alliance (“DAA”).

Sovrn also adheres to the Interactive Advertising Bureau (“IAB”) Code of Conduct, and actively participates in the IAB Europe Transparency & Consent Framework (TCF 2.0). We comply with IAB’s Specifications and Policies under vendor identification number 13.

For more information about industry self-regulation of Interest-Based Advertising, please visit: www.networkadvertising.org and www.aboutads.info.

Sovrn Services collects both Personal Information and Non-Personal Information. Sovrn does not collect personally identifiable information (“PII”) about Readers such as names, email addresses (when collected these are hashed so that they are no longer readable), physical addresses, or phone numbers. The information we collect allows us to see the browsing habits at an individual level, but we do not attempt to identify the exact individual who is browsing.

The following provides more detail on the types of Personal Information we collect and use in conjunction with the Sovrn Services:

Cookie ID A randomly generated identifier (created by Sovrn) that is stored on a browser and allows us to understand Reader browsing behavior, without knowing the exact identity of the individual.
Device information Device information can include your browser agent, browser type, operating system, device type, use of ad blocking tools, and information about the possible relationships among different browsers and devices.
Hashed email Hashing is a way of making a piece of data, like an email address, into a hexadecimal string so that it is no longer readable. Each email address has its own unique hexadecimal string that remains consistent no matter where the email address is used.
IP address An Internet Protocol address (IP address) is a numerical label assigned by an Internet Service Provider (ISP) to each device connected to a computer network that allows the device to communicate on the Internet. Most IP addresses are dynamic, meaning they change every time the device is restarted.
General location information Using your IP address and third-party services, we may collect general location information such as your country, city or state. Collecting this information not only supports our services, but helps us to understand your data rights.
Mobile advertising ID In mobile apps, we use identifiers provided by the mobile device’s operating system that can be reset by users. Typical advertising IDs are AdID (Android) and IDFA (Apple). Mobile advertising IDs allow developers and marketers to track activity associated with a specific device for advertising purposes. They’re also used to enhance serving and targeting capabilities.
Precise location information Precise location information may include, for example, data obtained from cell tower or Wi-Fi triangulation techniques, or latitude-longitude coordinates obtained through GPS technology, if such data is sufficiently precise to locate a specific device.
Directly from Readers

The Personal Information we gather about browsing preferences using technologies such as cookies and tracking pixels helps us provide Sovrn Services to our Publishers, which in turn provides meaningful Interest-based Advertising to Readers.

Directly from Publishers

Publishers provide Personal Information when registering to use Sovrn Services. Alternatively, Publishers may register for Sovrn Services using an existing Google account, in which case Sovrn will receive personal information from Google as defined by Google’s privacy policy. Personal Information collected at registration may include: a valid email address, username and password, first and last name, telephone number, website(s) URLs, software, mobile applications, log-in IP address(es), physical address, ZIP code, and country of residence for the Publisher contact.

We collect Publisher payment information from those who purchase Sovrn Services. Sovrn provides a third-party service to manage revenue payments to Publishers. This service also provides transactional information to Sovrn for financial reporting purposes.

We may also collect and categorize information about the content on Publisher pages integrated with Sovrn Services and link this information to Personal Information collected through the delivery of Sovrn Services. A Publisher may also choose to provide us with log-in credentials for accounts with third-party services such as online advertising providers, in order for Sovrn to provide services, such as reporting, based on information from those third-party services.

Publishers can choose not to provide us with certain Personal Information, but this may limit the features of the Sovrn Services available for use.

Information Collected Through Internet-Connected Technology

As Publishers use the Sovrn Services or Readers browse websites within the Sovrn Publisher network, we may also collect web viewing and search activities across non-affiliated websites (including websites accessed through your television) and mobile applications (“apps”) over time. This information may be linked to Personal Information that identifies a browser or device, typically through cookies or tracking pixels/web beacons.

Cookies

The term ‘cookies’ is used as an umbrella term for various technologies used to identify browsers, such as HTML cookies, Flash cookies, or scripts. For convenience, these technologies are collectively referred to in this Privacy Policy as “cookies”.

We set cookies (where allowed) for first-time visitors to any of the sites that deploy Sovrn Services. If our cookie is already set on a browser, we recognize a returning visitor and log data using the existing cookie. Visitors may be able to use tools provided by browsers to configure a browser to decline to receive cookies or to clear cookies, which will result in us treating the Reader as a new visitor when encountering the Services. However, in order to stop Interest-based Advertising by Sovrn, individuals must explicitly opt-out as described in the “How to Opt-Out” section.

Sovrn may store cookies on your device:

  • For Publishers, to allow you to use our Sovrn Services, and access secure areas of the Sovrn Services. Without these cookies, it is not possible to load or offer key functionalities on our website, such as logging in to your account, displaying dynamic elements or uploading information.
  • For both Publishers and Readers, for statistical purposes and to analyze and improve the use and performance of our Sovrn Services and to do the same for our Publishers’ websites.
  • For Readers, to support the Sovrn Services that are described in this policy, such as for our analytics and data services and to provide Readers with Interest-based Advertising, including through Google’s Exchange Bidding service, and the ability to opt out of such advertising as further described in this Privacy Policy.

Sovrn Services may use both session cookies (which expire once the web browser is closed) and persistent cookies (which stay on a device until deleted). For more information about how cookies are used or what information we collect, please see our Cookie Notice.

Some of our business partners (for example, Google Analytics) or clients may set or use their own cookies on our Publisher websites or through the Services we provide. However, we have no access to or control over these cookies. Some of our business partners may engage in cross-device mapping. In other words, our business partners may link the cookie data we gather to device identifiers concerning the same user. Our business partners may then share the cross-device mapping or other user data with us, for the purpose of Interest-based Advertising.

Tracking Pixels (or Web Beacons)

Web beacons or “pixels” are electronic images that may be used on Publisher website(s) or in emails sent in Publisher campaigns. We use tracking pixels to collect hashed emails, deliver cookies, count visits, understand usage and effectiveness of offers, and tell whether an email has been opened and acted upon.

Information from Third-Party Sources

We may receive Non-Personal Information and/or Personal Information about you from other sources and combine it with the information that we collect through Sovrn Services. Sources may include information conveyed to us by telephone or fax, information that we receive from third-party data providers, or information provided to us by third parties through the Sovrn Publisher network.

For our legitimate business interests, and with your consent where this is required, we may process and disclose your Personal Information for the Sovrn Services including for Interest-based Advertising as described in this Privacy Policy.

Personal Information

We process Personal Information to enable our business, including, but not limited to, the following:

  • Monitor the use of Sovrn Services, and to improve and protect our products, content, services and websites.
  • Compliance with applicable laws and to protect Sovrn’s legitimate business interests and legal rights, including, but not limited to, use in connection with legal claims, compliance, regulatory, investigative purposes (including disclosure of such information in connection with law enforcement requests, legal process or litigation).
Readers:
  • Provide Interest-based Advertising and support third parties’ interest-based advertising activities.
  • Provide a variety of services to Publishers and other business partners (including analytics, data services, and data resellers), and to enable Publishers to offer choices related to the use of ad blocking technology and Reader ad experience on their websites.
  • Personal Information may be categorized to create audience segments with common interests, intent or other characteristics, but does not include PII.
  • For Sovrn Commerce and similar services, we will use Personal Information to optimize links, determine the best merchant destination for clicks, and set the appropriate language and region for click destinations.

We do not knowingly use information that comes from what we consider to be sensitive health information. We may use health-related segments that are inferred from data we collect but are not derived from sensitive health data.

We may also use political-affiliation segments that are inferred from data we collect but are not derived from specific voter registration information.

A list of the health-related and/or political-affiliation segments that may be used by our platform may be viewed on our Audience Segments page.

Publishers:
  • Provide requested products and services and respond to any comments or complaints.
  • Sovrn will use a Publisher’s payment account information to make payments as part of our Services, where applicable.
  • If a Publisher chooses to provide us with log-in credentials for accounts with third-party services such as online advertising providers, Sovrn will use the credentials to access and provide requested services, such as reporting on your use of those third-party services. Sovrn may also use aggregate data obtained in this way for our internal purposes to improve the Sovrn Services.
  • We may monitor any Publisher account to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime, in accordance with applicable law.
  • Provide electronic newsletters, transactional, or promotional emails, including invitations to take part in market research.
  • As part of Sovrn Services, we store and may display some of the information entered upon creation of a Publisher account, such as username (or display name) and bio, as well as network of connections. In order to access and remove or modify this bio and display name, and/or other contact information that is not displayed, you may login to your Sovrn account, select the “Account” option, and edit the contact details.
Non-Personal Information

We may collect Non-Personal Information through Sovrn Services or we may create Non-Personal Information from Personal Information by removing identifying information (such as email address or device identifiers).

We may use Non-Personal Information for a variety of purposes to operate and improve the Sovrn Services, such as testing our IT systems, analyzing usage patterns, market research, data analysis, and developing new products.

We may also use Non-Personal Information on Readers’ activities collected from Publisher websites (such as page views, use of ad blocking technology, and search queries) to provide aggregate information to Publishers so that they can improve their offerings.

We may use and disclose Non-Personal Information for any purpose in our discretion, to the extent permitted under applicable law. If we are required to treat Non-Personal Information as Personal Information under applicable law, then we may use or disclose it for all the purposes for which we use and disclose Personal Information.

Sovrn shares the Personal Information collected through our Services with the following:

Affiliates: Sovrn may share some or all Reader Personal Information with our Affiliates (i.e., companies which are under common control, such as subsidiaries or joint ventures), in which case we will require our Affiliates to honor this Privacy Policy in all material respects.
Business Transitions: In the event Sovrn goes through a business transition such as a merger, acquisition by another company, or sale of all or a portion of its assets including in bankruptcy, Personal Information may be among the assets transferred.
Law Enforcement: We may disclose Personal Information if we believe in good faith that such disclosure is necessary to (a) comply with relevant laws or to respond to subpoenas or warrants served on us; or (b) to protect and defend the rights or property of Sovrn, Publishers, or third parties.
Publishers: We may disclose Personal Information that identifies a device or browser to Publishers and their service providers in order to provide the Sovrn Services, such as measuring the effectiveness of advertising, advertising attribution, and preventing advertising fraud.
Other Third-Party Customers: We may disclose Personal Information that identifies a device or browser to our third-party customers that include, for example, other advertising services and data enrichment services, who will use and disclose the information for their own purposes. We may also share Non-Personal Information such as aggregated reports derived in part from the information we have collected. The information we share may also be combined with third-party data to provide an even broader service to our customers. Please see How to Opt-Out for more information on choices related to this practice.
Service Providers: We may provide Personal Information to third-party service providers (processors) who work on behalf of or with us to provide the Sovrn Services including to help us communicate with you. Examples of such services include our ability to send email, perform data analysis, provide marketing assistance, process payments (including credit card payments, through a third-party service), and provide customer service.
Readers

Opting Out of Sovrn’s Interest-based Advertising:
Sovrn collects, uses, and discloses web viewing data, app usage data, hashed emails, and precise location data across non-affiliated sites and apps over time for the purpose of delivering Interest-based Advertising to this device or different devices. Readers can choose to opt out of Sovrn’s Interest-based Advertising activities on their browser(s) or device(s). Your opt-out choice will apply to the browser or device where you make the choice. This means that Sovrn will not deliver Interest-based Advertising to this browser or device and we will not otherwise use or transfer data collected on this browser or device for Interest-based Advertising.

Readers who wish to opt out of Sovrn’s collection, use, or transfer of such data from a browser for Interest-based Advertising purposes can visit https://www.aboutads.info/ to learn more about Interest-based Advertising and to exercise opt-out choice with respect to Sovrn and other companies participating in the Digital Advertising Alliance (DAA) self-regulatory program.

Readers who wish to opt-out of Sovrn’s collection, use, or transfer of such data from apps on a mobile device for Interest-based Advertising purposes can download the DAA’s AppChoices app.

When using the opt-out tools above, choice will be effective only on the browser or device where choice has been exercised. If using a different device or browser, the opt-out choice(s) will need to be renewed for the new device or browser. Our opt-out tool for browsers is cookie-based, so that an opt-out choice can only be honored if a browser is set to accept third-party cookies. If the opt-out cookie is deleted, then the opt-out choice(s) must be renewed. Opting out of Interest-based Advertising does not prevent data collection–we may continue to collect, use and transfer such data for other purposes such as contextual advertising based on a current visit to a website, fraud prevention, improving site performance and other purposes referred to in this Privacy Policy.

Opting out also will not stop advertising from appearing in a browser. After opting-out, Readers may receive advertising from Sovrn Services when visiting websites of a Publisher who uses our Services, but that advertising will not be interest-based. After opting out of Sovrn’s Interest-based Advertising, Readers may also continue to receive Interest-based Advertising through other companies.

Using ‘Do Not Track’ Signals
Sovrn Services are designed to respect ‘Do Not Track’ (or “DNT”) signals from your browser.

Publishers

Unsubscribe instructions will accompany each promotional email we send. Alternatively, contact us directly to change promotional email preferences at marketing@sovrn.com.

Regardless of your promotional communication preferences, we will send messages related to our business relationship or transactions.

For any questions regarding a Sovrn account, please contact publishersupport@sovrn.com.

Sovrn does not knowingly collect personal information from or direct Sovrn Services to children under the age of 16.

Publishers:

We will keep Publishers’ Personal Information according to the terms and conditions of our business relationship. This includes maintaining Publishers’ Personal Information after our relationship ends to protect ourselves from legal claims, to comply with law, or to administer our business.

Readers:

Personal Information collected about Readers through Sovrn Services is generally retained for a maximum of eighteen months. However, laws, legal claims or other particular circumstances may require us to keep certain Personal Information longer.

Non-Personal Information:

We may retain Non-Personal Information for our business purposes, at our discretion or as permitted by law.

Sovrn has put in place commercially reasonable physical, electronic, and managerial procedures to safeguard and secure the Personal Information we collect.

Information for Residents of European Countries: Data Subject Rights

If located in the European Economic Area (“EEA”), the United Kingdom, or Switzerland (the “European Countries”), individuals have certain rights and protections under applicable law regarding the processing of Personal Information.

Role of Sovrn as a Controller or Processor
If located in one of the European Countries, Sovrn may act as a “controller” as defined under applicable law when processing Personal Information. Sovrn may also act as a “processor” as defined under applicable law to the extent that we process Personal Information on behalf of and at the instruction of another party, for example a Sovrn client.

Legal Basis for Processing
Sovrn’s legal basis for processing Personal Information depends upon the specific context in which we collect or use it. We rely on data subject (as defined under applicable law) consent to process Personal Information for Interest-Based Advertising, which we require Publishers using Sovrn Services to obtain for us. In some cases, we may rely on our legitimate interests to collect and use Personal Information, except where our interests are overridden by data-protection interests or fundamental rights and freedoms. For example, we will process Personal Information collected from Interest-Based Advertising in order to improve the Sovrn Services for our Publishers. Our legitimate interests are described in greater detail in the “How We Use Information” section of this Privacy Policy. These legitimate interests include the operation of our business and the provision of Sovrn Services to our Publishers as required by our agreements with them. Additionally, we may have a legal obligation to process Personal Information (such as for fraud prevention).

Exercising Data Subject Rights
Individuals may be entitled to exercise certain data subject rights available under applicable laws. These rights may include the right to request access to Personal Information we hold. Individuals may also have the right to object to, or request that we restrict, processing of Personal Information, such as profiling we perform for the purposes of direct marketing and interest-based advertising. Individuals may also have the right to ask that your Personal Information be corrected, erased, or transferred to another party. Where we have asked for consent to process data, consent may be withdrawn.

Anyone afforded any of these rights may exercise them by visiting our privacy center, or by contacting privacy@sovrn.com.

These rights may be limited in some situations–for example, where we can demonstrate that we have a legal requirement to process data. In some instances, this may mean that we are able to retain data even if consent is withdrawn. In other instances, we may provide the requested information with some portions redacted in order to adhere to obligations of confidentiality to others.

Where we require Personal Information to comply with legal or contractual obligations, provision of Personal Information is mandatory; in all other cases, provision of requested Personal Information is optional.

Data Transfers

Sovrn is a global company headquartered in Boulder, Colorado, with data centers located in the United States and Europe. By visiting Publisher’s sites who are using Sovrn Services, Personal Information may be transferred to, stored, and processed by us, our affiliates, and by those third parties with whom we may share your information, some of which are located outside of the European Countries.

These countries (including the United States) may have data protection or other laws that differ from those in European Countries. We ensure that where Sovrn or third-party service providers receive Personal Information outside of the EEA, appropriate safeguards are in place under European data protection legislation.

Sovrn may be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

IAB Europe Transparency and Consent Framework
Sovrn is registered as a vendor with, and supports and encourages our clients to use, the IAB Europe Transparency and Consent Framework (the “IAB Industry Framework”) to provide data subjects with dynamic transparency into and choice about the various vendors our clients use to serve you ads, including Sovrn Services. When visiting a website, the IAB Industry Framework is designed to allow a Publisher the means to choose which registered vendors they wish to allow to access a device and process Personal Information, and provide dynamic transparency and choice about each of these vendors (either an opportunity for an individual to consent to the vendor or opt out of data processing by the vendor, depending on that vendor’s legal basis and processing activities).

Questions or Complaints
Individuals located in one of the European Countries who have questions or concerns about how we process Personal Information may contact our Data Protection Officer at dpo@sovrn.com. If we are not able to resolve the issue, individuals have the right to lodge a complaint with their local data privacy authority. For contact details of local Data Protection Authorities, please visit the European Data Protection Board member list.

Information for California Consumers: Privacy Rights

This section contains disclosures for Readers required by the California Consumer Privacy Act or “CCPA” (California Civil Code Section 1798.100 et seq.). This section applies to the collection, use, and disclosure of “personal information” collected from California “consumers” (as those terms are defined by the CCPA) that are subject to the CCPA. (Publisher personal information is not “sold” under the CCPA and is otherwise exempt from the CCPA at this time.)

Personal Information We Collect, Disclose for a Business Purpose, and Sell
As described in this Privacy Policy, Sovrn collects, discloses and sells consumer personal information for our commercial and business purposes (as defined by the CCPA). The following outlines each practice in more detail by providing the categories of personal information collected, disclosed, or sold in the previous 12 months. To request information on specific pieces of personal information we may hold about a California consumer, please follow the instructions provided in the Exercising California Consumer Rights section below.

Personal Information we collect about consumers, and from Publishers, service providers, affiliates not under the Sovrn brand, or consumer data resellers:

  • Online identifiers
  • Commercial information* (such as records of personal property or products or services purchased, obtained or considered)
  • Internet or other electronic network activity (such as browsing history, search history, interactions with a website, email, application, or advertisement)
  • Geolocation information
  • Professional or employment-related information

Personal information we disclose for business purposes in performing Sovrn Services:

  • Online identifiers
  • Commercial information* (such as records of personal property or products or services purchased, obtained or considered)
  • Internet or other electronic network activity information (such as browsing history, search history, interactions with a website, email, application, or advertisement)
  • Geolocation information
  • Professional or employment-related information

    We disclose each category of personal information identified above to the following categories of recipients: service providers; affiliates not under the Sovrn brand; and advertising networks and other partners (such as Demand Side Platforms (DSPs) who buy ad space from Publishers).

Personal Information we sell to third parties:

  • Online identifiers
  • Characteristics of protected classifications under California or federal law (such as demographic information like age, gender, and race)
  • Commercial information* (such as records of personal property or products or services purchased, obtained or considered)
  • Internet or other electronic network activity information (such as browsing history, search history, interactions with a website, email, application, or advertisement)
  • Geolocation information
  • Professional or employment-related information
  • Inferences drawn from the above information about your predicted characteristics and preferences

    We sell each category of personal information identified above to the following categories of recipients: advertising/marketing companies; advertising networks; marketing data companies; data analytics providers; social networks; consumer data resellers; and publishing product companies.

    California consumers may opt-out of the sale of their personal information at any time. Please see “Exercising California Consumer Rights” below for more information.

*//Commerce services only

We use and disclose the personal information we collect for our commercial and business purposes (as defined by the CCPA), as further described in this Privacy Policy. These commercial and business purposes include, without limitation:

  • Providing Interest-based Advertising for and to Consumers; providing our Services to our Publishers as described in this Policy; and marketing our Services.
  • Auditing related to our interactions with Publishers;
  • Legal compliance;
  • Detecting and protecting against security incidents, fraud, and illegal activity;
  • Debugging;
  • Performing services (either by us or our service providers, as that term is defined by the CCPA) such as account servicing, processing orders and payments, and analytics;
  • Internal research for technological improvement;
  • Internal operations;
  • Activities to maintain and improve our services; and
  • Other one-time uses.

Sovrn does not knowingly sell the personal information of minors under 16 years of age.

Exercising California Consumer Rights

California consumers have certain rights with respect to the personal information collected by businesses. California consumers may exercise the following rights regarding personal information, subject to certain exceptions and limitations:

  • The right to know the categories and specific pieces of personal information we collect, use, disclose, and sell, the categories of sources from which we collected personal information, our purposes for collecting or selling personal information, the categories of personal information that we have either sold or disclosed for a business purpose, and the categories of third parties with which we have shared personal information;
  • The right to request that we delete the personal information that we have collected or maintain;
  • The right to opt out of our sale(s) of personal information. Please note that, when opting out of certain types of sales, we will be unable to provide the services that rely on such sales.
  • The right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA.

To exercise any of the above rights, please contact us by using our online form, contacting privacy@sovrn.com, or calling 1(888)799-5199 and providing the requested information.

Verification Process and Required Information

We may require additional information to verify a consumer’s identity or understand the scope of the request, depending on how we are contacted. We will only ask for information needed to verify a consumer’s identity, such as a different email address, mobile identifier, or cookie ID.

When submitting our online form, consumers have the opportunity to include multiple email addresses–each email address will require a separate response from the requestor in order to be included in the requested action.

Authorized Agent
Consumers may designate an authorized agent to exercise California data rights under the CCPA on your behalf by (i) verifying the consumer’s identity and (ii) providing evidence of the consumer’s written permission authorizing an agent to make a request on their behalf.

We may modify or amend this Privacy Policy from time to time at our discretion. When we make material changes to this Privacy Policy, we will amend the revision date at the top of this page and such modified or amended Privacy Policy shall be effective as to the Personal Information governed by this Privacy Policy as of that revision date. We encourage periodic review of this Privacy Policy to view any updates.

Please contact us at privacy@sovrn.com with questions or concerns regarding our Privacy Policy or how we process your data.

If located in the European Countries, our Data Protection Officer may be contacted at dpo@sovrn.com

Sovrn will respond in good faith to all privacy inquiries but may not be able to provide complete information if the request requires Sovrn to release confidential information of third parties, or otherwise imposes an undue burden or expense.

Sovrn U.S. Headquarters
5541 Central Avenue, Suite 100
Boulder, CO 80301
United States

Sovrn U.K. Headquarters
4th Floor Newland House
40 Berners Street
Fitzrovia, London
W1T 3NA
United Kingdom