Effective Date: January 01, 2023
Our products are used on websites and other internet-connected services (such as smart TV’s and mobile devices). A more in depth description of our Services can be found at our Publisher Products site.
If unsure about any of the information provided, please reach out to privacy@sovrn[.]com.
Definition of Terms
- “Advertiser” means an entity providing ads to be placed on Publisher websites.
- “Non-Personal Information” means information that is not associated with or linked to Personal Information including aggregate or de-identified information.
- “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 (commonly referred to as “PII”).
- “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 or the Site.
- “Sovrn” or “we” means Sovrn, Inc. with our affiliates (including those not under the Sovrn brand).
Description of Sovrn Services
The Sovrn Services that collect information from Readers are
- Sovrn Exchange and Ad Management for Interest-based Advertising;
- Commerce for affiliate marketing and price comparisons; and
- Signal for viewer engagement metrics.
Sovrn is a data broker, allowing us to provide commercial data products (“Data”) to our customers, which are also part of the Services. As a data broker we may share your Personal Information with other parties. Please refer to “Country and US State Specific Disclosures” for more information related to specific privacy rights related to disclosures through our data brokerage.
In order to provide the Services, we collect Personal Information from our Publishers as described in our Publisher contractual agreements.
Please note that the Services may 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.
Our Commitment to Good Advertising Practices
Sovrn supports industry self-regulatory principles and endorses industry best practices and self-regulatory standards. Read more about these principles and the organizations that authored them.
Sovrn follows and adheres to the industry Self-Regulatory Principles of the Digital Advertising Alliance (“DAA”) and the European self-regulatory Framework for Online Behavioural Advertising (“EDAA Framework”).
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, www.aboutads.info, and youronlinechoices.com.
The information we collect allows us to see browsing habits at an individual level, but we do not attempt to identify the exact individual who is browsing. Read more about the types of information used in Interest-Based Advertising, as well as what to expect when visiting our Site.
Sovrn Services and Site collects both Personal Information and Non-Personal Information. Sovrn does not collect personally identifiable information (“PII”) about Readers such as names, surnames, email addresses, physical addresses, or phone numbers, unless provided to us through the Site when requesting materials or information from us.
The following provides more detail into the types of Personal Information we collect (and in some instances purchase from partners) and use in conjunction with the Sovrn Services and Site:
|Cookie ID||A randomly generated identifier (including those 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. Also known as a third-party cookie.||All Services and Site|
|Unique online identifier||An identifier created by our Publishers to understand an individual’s browsing behavior on their own site, as well as across different websites. These identifiers are shared with Sovrn to help us understand the preferences of individuals so that we can provide our targeted advertising services.||Exchange, Ad Management, Signal, and Site|
|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.||All Services|
|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.||Data|
|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.||All Services and Site|
|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.||All Services and Site|
|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.||Data|
|Personally Identifiable Information (“PII”)||Personal Information that directly identifies an individual such as name, surname and email address. PII may be required for some inquiries through the Site. Sovrn will only collect PII you voluntarily provide.||Site|
Both session cookies (which expire once the web browser is closed) and persistent cookies (which stay on a device until deleted) are used to collect viewing and search behaviors by both Sovrn Services and the Site. For more information about how cookies are used or what information we collect, please see our Cookie Notice.
Through our Site
We collect Personal Information submitted to us voluntarily, such as name and contact information. For example, when signing up to receive our newsletter or to participate in a webinar we collect your email address. When contacting us via email, we will collect the email contents.
Through Sovrn Services
The information we gather about browsing preferences and purchasing behaviors using cookies helps us provide Sovrn Services to our Publishers, which in turn provides meaningful Interest-based Advertising to Readers.
Readers. We set cookies (where allowed) at the first visit to any of the Publisher sites that deploy Sovrn Services. If our cookie is already set on a browser, we recognize a returning Reader and log data using the existing cookie. Readers have the option to use tools provided by browsers to decline to receive cookies or to clear cookies, which will result in us treating the Reader as a new visitor when encountering Sovrn 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.
Some of our business partners (for example, Google Analytics) may set or use their own cookies on our Publisher websites or through Sovrn Services where Sovrn has no access to or control over these cookies. Specific to Google Analytics, opt-out by visiting https://tools.google.com/dlpage/gaoptout/
When using the Sovrn Platform to manage your account, we will also set cookies that allow us to remember your preferences, as well as to collect analytics about how our customers are interacting with the service.
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.
Publishers may choose not to provide us with certain Personal Information, but this may limit the features of the Sovrn Services available for use.
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 (also known as cross-device tracking). This information may be linked to Personal Information that identifies a browser or device, typically through cookies or tracking pixels/web beacons.
Sovrn may store cookies on your device:
- For Publishers, to allow you to use and access secure areas of Sovrn Services. Without these cookies, it is not possible to load or offer key functionalities, such as logging in to your account, displaying dynamic elements or uploading information.
In some instances, our business partners link the information we gather through cookies to device identifiers associated with the same Reader (also known as cross-device mapping). They will then share the cross-device mapping or other user data with us, for the purpose of Interest-based Advertising.
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 or Site. Sources may include information conveyed to us by telephone, information that we receive from third-party data providers, or information provided to us by third parties through the Sovrn Publisher network.
We use Personal- and Non-Personal Information collected through Sovrn Services and Site to support our commercial interests (Interest-based Advertising, affiliate marketing, and Data), internal business operations (such as improving the Services, fraud prevention and security), and business intelligence.
Commercial interests are activities that allow Sovrn and/or our customers and business partners (such partners include data services and data resellers) to earn revenue and include:
- Providing Sovrn Services, or any other materials requested through the Site (such as electronic newsletters or promotional emails) to Publishers.
- Creating audience segments* by categorizing Personal Information by common interests, intent or other characteristics (does not include PII).
- Specific to Sovrn Commerce, 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 may use Publisher contact information to invite you to take part in market research.
* We do not use Personal Information to derive audience segments that could be defined as ‘sensitive’ or ‘special categories’ under various data privacy laws and regulations. Please visit Sovrn’s Audience Segments page for more information.
Internal Business Operations
Internal business operations are activities that allow us to meet obligations to Publishers, Readers, and third-party partners (including regulatory bodies). Internal business operations do not directly benefit any one person or entity, and include:
- Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with various data privacy laws and regulations, as well as other standards.
- Debugging to identify and repair errors that impair existing intended functionality of our products, content, services and websites.
- Improve and protect our products, content, services and websites, to the extent the use of the Personal Information is reasonably necessary and proportionate for these purposes.
- Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying Publisher information, processing payments, or providing analytic services.
- We may use Publisher contact information to invite you to take part in market research.
- We may monitor any Publisher account to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime, in accordance with applicable law.
- 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).
- Responding to comments or complaints.
Business intelligence allows us to analyze and report on the performance of Sovrn Services and Site, as that performance relates to Publisher or Sovrn campaigns, and include:
- Monitoring the use of Sovrn Services to support Publisher analytics and reporting.
- Undertaking internal research for technological development and demonstration.
- Performing Analytical Analysis. We work with third parties that collect data about Reader use of the Site and other websites or online services over time for non-advertising purposes. For example, we use Google Analytics and other third-party services to improve the performance of Sovrn Services and for analytics and marketing purposes. For more information about how Google Analytics collects and uses data, visit https://policies.google.com/technologies/partner-sites. Opt-out of Google Analytics by visiting https://tools.google.com/dlpage/gaoptout/.
A Note on 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 functional testing, analyzing usage patterns, market research, data analysis (including in support of Interest-Based Advertising), 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 content and optimize advertising revenue.
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.
Our Information Sharing Practices
Sovrn shares the Personal Information collected through our Services, procured through our data partners, or our Site with the following:
- 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. Please see our Law Enforcement Request Policy for the requirements applicable to such requests.
- 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, or to indicate Reader preferences for Interest-Based Advertising.
- 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 (sub-/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.
Sovrn supports various opt-out mechanisms, where each option provides different results related to cross-device tracking and targeted advertising. While using these mechanisms may prevent Interest-based Advertising or the sale of your Personal Information, there are no mechanisms for preventing advertising altogether.
Opting Out of Sovrn’s Interest-based Advertising
Readers can choose to opt out of Sovrn’s Interest-based Advertising activities on their browser(s) or device(s). For more information on how to opt-out of the sale of personal information, please see the section, “Exercising California Privacy Rights” located in the “Country and US State Specific Disclosures” section, below or our webform found in the Privacy Center.
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.
To simplify the management of Interest-based Advertising preferences, Sovrn participates in the Digital Advertising Alliance (DAA) AdChoices program that allows a user to manage their Interest-based Advertising preferences across all participating DAA members. The DAA provides two tools, WebChoices to manage preferences on web browsers, and AppChoices to manage preferences on mobile platforms like Android or Apple iOS devices.
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 DAA’s 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.
When using DAA’s opt-out tools, 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.
Sovrn also participates in the European Interactive Digital Advertising Alliance (EDAA) YourOnlineChoices program which allows Readers in the European Union, Switzerland, Norway, Lichtenstein, Iceland, or the United Kingdom to exercise their choice with respect to the collection and use of data for Interest-based Advertising purposes and the transfer of such data to Third Parties for Interest-based Advertising. Readers may exercise their choices by visiting the Your Online Choices web portal.
Opting out of Interest-based Advertising prevents the collection of Personal Information, but does not prevent data collection of Non-Personal Information. We may continue to collect, use and transfer such Non-Personal Information for other purposes such as contextual advertising based on a current visit to a website, fraud prevention, or improving site performance.
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.
Opting Out of Sovrn’s Affiliate Marketing
Readers who wish to opt-out of Sovrn Commerce collection, use, or transfer of Personal Information from the websites you visit, the links you click, or the merchants you make purchases from, visit our Privacy Center and choose ‘Disable Tracking.’
Opting out of Sovrn Commerce cookies means that Sovrn Commerce will stop placing cookies on your device when you browse Sovrn Commerce enabled websites and/or links.
To honor your opt-out choice, we need to place a cookie on your device so that we know not to track your activity. Clearing your browser’s cache or cookies will remove this cookie, and you will be required to opt-out of tracking again. Similarly, if you access sites that use Sovrn Commerce from a different browser or device than the browser or device on which you opted-out of tracking, you will be required to opt-out again.
Using ‘Do Not Track’ Signals
Sovrn Services are designed to respect ‘Do Not Track’ (or “DNT”) signals from your browser, such as ad blockers. When a DNT signal is recognized, no Personal Information is collected or stored by Sovrn Services.
Opting Out of Sovrn Marketing
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 Publishers messages related to our business relationship or transactions.
For any questions regarding a Sovrn Publisher 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.
If you are not 16 years old, please do not use sovrn[.]com. Do not submit your name, email address, or other personal information using our web forms.
As operators of their own websites and content, our Publishers are solely responsible for compliance with law related to the collection and use of information from children under the age of 16. If, during routine review, Sovrn believes children under the age of 16 have submitted their personal information into our web forms or our customer’s websites, we will, in our sole discretion, delete the information believed to belong to those under 16 years old.
We will retain Personal Information for as long as necessary to fulfill the purpose of collection, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish and defend legal claims, for fraud prevention purposes, or as long as required to meet our legal obligations. To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.
Sovrn has put in place commercially reasonable physical, electronic, and managerial procedures to safeguard and secure the Personal Information we collect. For more information, please visit Sovrn’s Security page.
Country and US State Specific Disclosures
Notice to Residents of European and UK Countries: Data Subject Rights
If located in the European Union, Switzerland, Norway, Lichtenstein, Iceland, or the United Kingdom (the “European and UK Countries”), individuals have certain rights and protections under applicable law regarding the processing of Personal Information.f located in the European Union, Switzerland, Norway, Lichetenstein, Iceland, or the United Kingdom (the “European and UK 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 and UK 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
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.
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 and UK Countries.
These countries (including the United States) may have data protection or other laws that differ from those in European and UK Countries. We ensure that where Sovrn or third-party service providers receive Personal Information outside of the European and UK Countries, appropriate safeguards are in place under European and UK 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. Such requests are subject to Sovrn’s Law Enforcement Request Policy.
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 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 and UK 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.
IT Governance Europe Limited acts as our EU representative. If you wish to exercise your rights under the EU General Data Protection Regulation (EU GDPR), or have any queries in relation to your rights or general privacy matters, please email email@example.com Please ensure to include our company name (“Sovrn”) in any correspondence.
Notice to California Residents: Your Privacy Choices
Personal Information We Collect, Disclose for a Business Purpose, and Sell or Share
Only personal information collected through Sovrn Services, where Sovrn has a license to further disclose personal information to third parties, is included in our commercial Data so that Publisher personal information provided for account management is not ‘sold’ or ‘shared’ as defined under California privacy laws.
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.
- Identifiers: cookie ID; unique online identifiers; device information; hashed email; IP address, mobile advertising ID
- Customer Records: Publisher personal information provided when registering for Sovrn Services, such as name, surname, email address
- Commercial information: e.g. records of products or services purchased, obtained or considered
- Internet or Network Activity: e.g. browsing history, search history, interactions with a website, email, application, or advertisement
- Geolocation Data: country, state, city
- Professional or Employment-Related Information
- Education Information
- Inferences: assumptions drawn from the Personal Information identified above to create a profile reflecting preferences, characteristics or behavior
We do not collect or use sensitive personal information for any purpose, including to infer characteristics about California residents.
Personal information “sold,” “shared” or disclosed, where ‘sale’ is defined under California law as disclosing a California resident’s Personal Information to a third party for monetary or other valuable consideration. Where such disclosure is for cross-context behavioral advertising, whether or not for monetary or other valuable consideration, it qualifies as ‘sharing’ under the CCPA.
The table below describes how we “sell,” “share” or disclose Personal Information:
|Category of Personal Information||To whom the category of Personal Information is “sold” or “shared”||To whom the category of Personal Information is disclosed for a business purpose|
|Identifiers|| · Sovrn Publishers |
· Advertising partners
· Data partners (e.g., data services and resellers)
|· Service Providers|
|Customer Records||N/A||· Service Providers|
|Commercial Information|| · Sovrn Publishers |
· Advertising partners
· Data partners (e.g., data services and resellers)
|Internet or Network Activity|| · Sovrn Publishers |
· Advertising partners
· Data partners (e.g., data services and resellers)
|Geolocation Data|| · Sovrn Publishers |
· Advertising partners
· Data partners (e.g., data services and resellers)
|Professional or Employment-Related Information||N/A||Service Providers|
|Education Information||N/A||Service Providers|
|Inferences|| · Sovrn Publishers |
· Advertising partners
· Data partners (e.g., data services and resellers)
California consumers may opt-out of the sale or sharing of their personal information at any time. Please see “Exercising California Privacy Rights” below for more information.
Sovrn does not knowingly sell or share the personal information of California residents under 16 years of age.
Exercising California Privacy Rights
As a California resident, you have the privacy rights listed below. However, these rights are not absolute, and in certain cases we may not be able to respond to your request, such as when a legal exemption applies or if we are not able to verify your identity.
- Know/Access. You can request the following information about how we have collected and used your personal information:
– The categories of personal information that we have collected
– The categories of sources from which we collected personal information
– The business or commercial purpose for collecting, selling, or sharing personal information
– The categories of third parties with whom we disclose personal information
– A copy of the personal information that we have collected about you
- Delete. You can ask us to delete the personal information that we have collected from you.
- Correct. You can ask us to correct inaccurate personal information that we maintain about you
- Opt-out of sales/sharing. If we “sell” or “share” your personal information, you can opt-out.
- Nondiscrimination. You are entitled to exercise the rights described above without receiving discriminatory treatment.
You may request to exercise the California privacy rights described above as follows:
- Right to know/access, delete, or correct. You can request to exercise your access, deletion, or correction rights by:
– Visiting our Privacy Center and completing the data rights request webform;
– Emailing privacy@sovrn[.]com – Please put the statement “CCPA Consumer Request” in the subject line; or
– Calling +1 (888) 280-8085
- Right to opt-out of the “sale” or “sharing” of your personal information. You can request to opt-out of the “sale” or “sharing” of your personal information by clicking here: Do Not Sell or Share My Personal Information and completing the webform.
– Note that due to technological limitations, if you visit our Services from a different computer or device, or clear cookies on your browser that store your preferences, you will need to return to the opt-out page to submit your preferences.
– If you direct us not to sell/share your personal information, we will consider it a request pursuant to California’s “Shine the Light” law to stop sharing your personal information covered by that law with third parties for their direct marketing purposes.
Please visit our CCPA Metrics page for details around the type of data rights requests received during the previous calendar year.
Verification Process and Required Information
We reserve the right to confirm your California residence to process your requests and will need to confirm your identity to process your requests to exercise your right to know/access, delete, and correct. This is a security measure to, for example, help ensure we do not disclose information to a person who is not entitled to receive it. The identity verification process may vary depending on how you submit your request. We will only ask for information needed to verify your identity, such as a different email address, or cookie ID.
Consistent with California law, you may designate an authorized agent to make a request on your behalf. If you do so, we may require proof of your identification, the authorized agent’s proof of identification, and any other information that we may request in order to verify the request, including evidence of valid permission for the authorized agent to act on your behalf. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee or decline to comply with your request if your request is clearly unfounded, repetitive, or excessive.
Notice to Virginia Residents
This section applies only to Virginia residents. It describes how we collect, use, and share personal information of Virginia residents when we act as a “controller” as defined under Virginia privacy law, and their rights with respect to their personal information. For purposes of this section, “personal information” means “personal data” as such term is defined under Virginia privacy laws but does not include information exempted from the scope of such laws.
Under Virginia law, you may request the rights listed below. Please note, these rights are not absolute, and, in some cases, we may not be able to respond to your request, such as when a legal exemption applies or if we are not able to verify your identity.
- Access. You can request that we confirm whether we process your personal information and to access that personal information.
- Correct. You can ask us to correct inaccurate personal information that we maintain about you.
- Delete. You can ask us to delete personal information provided by or obtained about you.
- Port. You can request to obtain a copy of personal information that you have previously provided to us in a portable and, to the extent technically feasible, readily usable format.
- Opt-out of sales, targeted advertising, and profiling. If we “sell” your personal information, or use your personal information to engage in “targeted advertising” according to Virginia law, you can opt-out. For clarity, Sovrn does not process your personal information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects, as defined by Virginia law.
You may request to exercise your Virginia privacy rights described above by
- Visiting our Privacy Center and completing the data rights request webform; or
- Emailing privacy@sovrn[.]com – Please put the statement “VCDPA Consumer Request” in the subject line
If we decline to take action on your request, you may appeal such refusal by sending us an email to privacy@sovrn[.]com within a reasonable time period after our decision has been sent to you
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
Sovrn U.K. Headquarters
4th Floor Newland House
40 Berners Street
Sovrn Switzerland, S.A.
Via Cantonale 19, CH-
|Our Commitment to Good Advertising Practices & How to Opt Out||Added information related to our integration with the European Interactive Digital Advertising Alliance (EDAA) YourOnlineChoices program||August, 2022|
|Throughout||Revised email addresses throughout to reduce spam||August, 2022|
|Exercising California Consumer Rights||Replaced toll-free number with new toll-free number||August, 2022|
|Entire Policy||Consolidated Website and Service Privacy Policies, reordered sections, and updated internal links.||April, 2021|
|Information We Collect||Added ‘Universal ID’ to the list of Personal Information types||April, 2021|
|Personal Data Rights (throughout)||Separation of UK from EU personal data rights as a result of the enactment of the UK GDPR||February, 2021|
|Personal Data Rights: Questions or Complaints||Addition of EU representative as a result of the UK’s exit from the EU||February, 2021|
|Revision Log||New section added for clarity of changes over time||February, 2021|