Privacy Policy
Effective Date: April 07, 2023
Sovrn provides data and monetization tools to our customers that allow for revenue generation through digital advertising, affiliate network marketing and commercial data products. We believe in transparency and respecting consumer choice as a foundation of trust, so we have crafted this Privacy Policy to help you understand how we handle Personal Information, and your privacy choices.
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.
This “Privacy Policy” describes how Sovrn collects, uses, and shares personal information in connection with Sovrn Services and our public-facing business websites found at www.sovrn.com and other websites that we own and operate that link to this Privacy Policy (collectively, the “Site”).
If unsure about any of the information provided, please reach out to privacy@sovrn[.]com.
Definition of Terms
Throughout this Privacy Policy, we use some phrases that are unique to our business or the technology underlying our Services or may just be new to you. The following are definitions of some of the key terms that you’ll need to know to make it easier to understand this Privacy Policy:
- “Advertiser” means an entity providing ads to be placed on Publisher websites.
- Interest-Based Advertising” is an umbrella term used throughout this Privacy Policy to indicate cross-device targeting, targeted advertising, cross-contextual behavioral advertising, and similar activities related to the use of profiles to understand the browsing and/or purchasing behaviors of consumers. For more information, please see the BBB National Programs site.
- “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).
- “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,” “us,” or “our” 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
- Exchange and Ad Management for Interest-based Advertising;
- Commerce for affiliate network marketing, shopping galleries 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 for our commercial interests. 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.
In addition to the Services, Sovrn collects Personal Information through interactions with the Site. By visiting or submitting Personal Information through the Site, you acknowledge the processing of your Personal Information in accordance with this Privacy Policy.
Our Commitment to Good Advertising Practices
Sovrn supports industry self-regulatory principles and endorses industry recognized practices and self-regulatory standards.
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 device level, but we do not attempt to identify the exact individual who is browsing. Here we outline 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, plain-text email addresses, physical addresses, or phone numbers, unless provided to us through the Site when requesting materials or information from us. For clarity, none of the information collected through the Site is used in our commercial Data products.
The following provides more detail into the types of Personal Information we may collect (and in some instances purchase from partners) and use in conjunction with the Sovrn Services and Site:
Identifier | Description | Used by |
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 |
Connected television identifier (CTV ID) | Examples of connected televisions (CTV) include Xbox, PlayStation, Roku, Amazon Fire TV, and Apple TV. A CTV ID is a unique identifier that is generated by the CTV and is used for various purposes, including Interest-Based Advertising. | Exchange |
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 and Site |
General location information | Using your IP address and third-party services, we infer 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 |
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. | Signal and 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 |
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 AAID/GAID (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. | Exchange and 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 |
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 |
Sovrn uses various technologies to collect both Personal- and Non-Personal Information, such as cookies, web beacons, tracking pixels, or scripts. We also collect information voluntarily provided through our Site. The term ‘cookies’ is used as an umbrella term for these technologies; for convenience, these technologies are collectively referred to in this Privacy Policy as “cookies.”
Both session cookies (which expire once the web browser is closed) and persistent cookies (which stay on a device until deleted or expire) 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/
Publishers. Publishers provide Personal Information about themselves 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.
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 access or use digital properties within the Sovrn Publisher network (including websites or applications on internet-connected technology, such as computers, mobile devices, or internet-connected televisions), we may also collect web viewing and search activities across non-affiliated websites (including websites accessed through your television), directly through content viewed on an internet-connected 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 may not be possible to load or offer key functionalities, 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 Sovrn Services and the Site, and to do the same for our Publishers’ websites. We also use cookies for a better online experience, as cookies allow us to load or offer key functionalities on our Site, such as displaying dynamic elements or uploading information.
- For Readers, to support Sovrn Services, 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, all as further described in this Privacy Policy. We also use cookies for social media and multimedia functionalities, where videos and other media often rely on cookies to function correctly. In addition, social media platforms such as Facebook and Twitter can use cookies to see if you are logged in and enable you to “like” content or send it to your friends. When you use these features, such third-party companies can collect information from you. Depending on your settings, these external parties may also use such information for advertising purposes. If you would like to know more about this, please refer to the respective privacy policies of these third parties.
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.
We may also use web beacons or “pixels” to collect Personal Information, which are electronic images that may be used on website(s) (including Publisher websites and the Site) or in emails sent in Publisher campaigns or from Sovrn directly. We use tracking pixels to, for example, collect hashed emails, deliver cookies, count visits, understand usage and effectiveness of offers, and tell whether an email has been opened and acted upon.
In addition, we may use session replay technologies for certain automatic data collection from Publishers on the Sovrn Platform. Session replay technology is third-party software used to record a replay of users’ interactions on the Sovrn Platform (such as to troubleshoot how a Publisher interacts with our dashboard). The replay may include users’ clicks, mouse movements, scrolls, mobile app touches, typing, and other activity taken during the session. We use these replays for research and development purposes, such as to help us troubleshoot problems with the Sovrn Services, understand how Publishers interact with and use the Sovrn Services, and identify areas for improvement.
Information from Third-Party Sources
We may receive Personal- and Non-Personal Information about you from other sources and combine it with the information that we collect through Sovrn Services or the 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 to support our commercial interests (Interest-based Advertising, affiliate network marketing, and Data), internal business operations (such as improving the Services, fraud prevention and security), and business intelligence.
Commercial Interests
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, for example:
- Serving Interest-based Advertising to Readers on behalf of our Publishers and supporting third parties’ Interest-Based Advertising activities. Options for opting-out of such advertising may be found in the “How to Opt-Out” section of this Privacy Policy.
- Providing Sovrn Services, or any other materials requested through the Site (such as electronic newsletters or promotional emails) to Publishers. Options for opting-out of Sovrn marketing may be found in the “How to Opt-Out” section of this Privacy Policy.
- Creating audience segments* by categorizing Personal Information we have collected by common interests, intent or other characteristics (for clarity, PII is not used for this purpose). Audience segments are used to provide additional insights, enrichment of our Publisher’s first party data, and to attribute reader interests to browsers and devices to better inform advertising campaigns.
- 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, for example:
- 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.
- 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.
- Monitoring 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), protecting our and others’ rights, privacy, safety, or property, and enforcing our agreements.
- Responding to comments or complaints or sending service-related communications.
Business Intelligence
Business intelligence allows us to analyze and report on the performance of Sovrn Services and the Site, as that performance relates to Publisher or Sovrn campaigns, and includes:
- 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 third parties and as otherwise described in this Privacy Policy:
- 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. Please reference the Sovrn Careers page to view our affiliate locations.
- 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, Government Authorities, and Private Parties: 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; (b) to protect and defend the rights or property of Sovrn, Publishers, or third parties; or (c) for the other compliance, fraud prevention, and safety purposes described in this Privacy Policy. Please see our Law Enforcement Request Policy for the requirements applicable to law enforcement requests.
- Publishers: We may disclose Personal Information that identifies a device or browser to Publishers and their service providers 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.
- Advertising Partners: We may share your Personal Information with third parties that we partner with to engage in Interest-Based Advertising, including through the use of cookies and similar technologies. These third party advertising companies may collect information about your activity over time through the Services and across other online services to serve you advertisements. For a full list of our Exchange Advertising Partners, please visit https://www.sovrn.com/privacy-policy/third-parties/.
- Professional Advisors: We may share Personal Information with persons, companies, or professional firms providing Sovrn with advice and consulting in accounting, administrative, legal, tax, financial, debt collection, and other matters.
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, “Your 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 application.
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) Your Online Choices 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’ (“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. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
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.
Advertising Choices on the Site
Some of the Advertising Partners that collect data on the Site to help us advertise the Sovrn Services and our business may also participate in the DAA or may be members of the Network Advertising Initiative (NAI). You can obtain more information about these companies’ information collection practices, and opt-out of receiving interest-based advertising from participating NAI and DAA members, at the NAI’s website or the DAA’s website. You can also limit collection of your information for Interest-Based Advertising by blocking third party cookies in your browser settings or using privacy plug-ins or ad blocking software that help you block third party cookies.
Many of the opt-out preferences described in this section must be set on each device and/or browser for which you want them to apply. Please note that some of the Advertising Partners we work with may not participate in the opt-out mechanisms described above, so even after opting-out, you may still receive Interest-Based Advertising from other companies. If you opt-out of Interest-Based Advertising, you will still see advertisements online but they may be less relevant to you.
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 the Site. 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; however, no method of transmission over the Internet, or method of electronic storage, is 100% secure. As a result, we cannot guarantee the absolute security of your Personal Information. For more information, please visit Sovrn’s Security page.
Country and US State Specific Disclosures
Various data privacy laws require specific disclosures regarding the collection and use of your Personal Information. These disclosures are meant to supplement, and are consistent with, the practices described in this Privacy Policy.
Notice to Residents of European and UK Countries: Data Subject Rights
This section applies only to individuals located in the European Union, Switzerland, Norway, Lichtenstein, Iceland, or the United Kingdom (the “European and UK Countries”) and supplements the practices described in this Privacy Policy. It describes certain rights and protections under applicable law regarding the processing of Personal Information. For purposes of this section, “Personal Information” has the meaning given to “personal data” governed by European and UK Countries’ data protection legislation.
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
Sovrn’s legal basis for processing Personal Information depends upon the specific context in which it is collected or used. In some cases, we rely on data subject consent (as defined under applicable law) to process Personal Information for Interest-Based Advertising, which we require Publishers using Sovrn Services to obtain on our behalf. In other 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 also process Personal Information collected from Interest-Based Advertising in order to improve the Sovrn Services for our Publishers where permitted by law. 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 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[at]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 or the UK data protection regulator.
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 eurep@itgovernance.eu. Please ensure to include our company name (“Sovrn”) in any correspondence.
Notice to California Residents: Your Privacy Choices
This section applies only to California residents and supplements the practices described in this Privacy Policy. It describes how we collect, use, sell, share, and retain Personal Information of California residents, and their rights with respect to that Personal Information. For purposes of this section, “Personal Information” has the meaning given in the California privacy laws but does not include information exempted from the scope of those laws.
Personal Information We Collect and Purposes of Collection and Use
Personal Information we collect (or have collected in the 12 months preceding the “Effective Date” of this Privacy Policy) about California residents are listed below by reference to the categories specified under California privacy law. Examples in the list refer to the types of Personal Information described above in this Privacy Policy.
- Identifiers, such as cookie ID, unique online identifiers, device information, hashed email, IP address, connected television ID, and mobile advertising ID.
- Customer Records, such as Publisher PII and payment information.
- Commercial information, such as records of products or services purchased, obtained or considered.
- Internet or Network Activity, such as browsing history, search history, and interactions with a website, email, application, or advertisement.
- Inferences drawn from the Personal Information identified above to create a profile reflecting preferences, characteristics or behavior.
We may collect these categories of Personal Information directly from you and from your device as you visit our Site or Publisher sites in our network subscribing to Sovrn Services, or from other third parties as further described in this Privacy Policy under the section titled “How We Collect Information.”
The purposes, including the specific business and commercial purposes, for which we collect and use these categories of Personal Information are described in this Privacy Policy under the section titled “How We Use Personal Information.”
To the extent that we may collect any sensitive Personal Information (as defined under California privacy law), such as to provide account management for our Publishers, we only use or disclose it for purposes permitted under California law (i.e., to perform the Sovrn Services, process customer transactions, detect security incidents and prevent fraud, or to verify and maintain the quality of the Services). We do not collect or use sensitive personal information for the purpose of inferring characteristics about California residents.
We retain each of the categories of Personal Information listed above as described in this Privacy Policy under the section titled “Retention of Personal Data.”
Personal Information “Sold,” “Shared” or Disclosed for Business Purposes
“Sale” is defined under California privacy 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 California privacy law.
The following table describes the categories of Personal Information “sold” or “shared” for our commercial purposes to each of the categories of third parties listed, and includes our practices in the 12 months preceding the “Effective Date” of this Privacy Policy.
Each category of Personal Information listed in the following table may also have been disclosed for our business purposes (such as for internal use and business intelligence), and have in the preceding 12 months been disclosed, to each of the categories of third parties listed.
The categories of third parties listed, along with our business and commercial purposes for which we “sold,” “shared” or disclosed Personal Information, are described in this Privacy Policy under “Our Information Sharing Practices” within the section titled, “How We Use Information.”
Category of Personal Information | To whom the category of Personal Information is “sold” or “shared” |
Identifiers | · Sovrn Publishers · Advertising Partners · Other Third-Party Customers (i.e., Data partners, such as data services and resellers) |
Customer Records | N/A |
Commercial Information | · Sovrn Publishers · Advertising Partners · Other Third-Party Customers (i.e., Data partners, such as data services and resellers) |
Internet or Network Activity | · Sovrn Publishers · Advertising Partners · Other Third-Party Customers (i.e., Data partners, such as data services and resellers) |
Inferences | · Sovrn Publishers · Advertising Partners · Other Third-Party Customers (i.e., Data partners, such as data services and resellers) |
For clarity, Personal Information collected through Sovrn Services, from third parties, or Internet Connected Technology, (and where Sovrn has a license to further disclose Personal Information to third parties) is included in our commercial Data and “sold” or “shared.” Publisher Personal Information provided for account management is not “sold” or “shared” as defined under California privacy law.
California consumers may request to opt-out of the sale or sharing of their Personal Information at any time. Please see “Your 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.
Your California Privacy Rights
As a California resident, in addition to the rights described elsewhere in this Privacy Policy, 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: Your Privacy Choices and completing the webform or broadcasting the Global Privacy Control (GPC) signal through your browser settings.
– Our Services will honor the GPC signal you broadcast so that the Personal Information that you provide to the Publishers using our Services will be opted-out from “sales” or “sharing.”
– Note that due to technological limitations, if you visit our Services or the Site from a different computer or device, or clear cookies on your browser that store your preferences, you will need to return to the Your Privacy Choices page to re-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.
Authorized Agent
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 and supplements the practices described in this Privacy Policy. It describes how we collect, use, and share Personal Information of Virginia residents, and their rights with respect to that Personal Information. For purposes of this section, “Personal Information” means “personal data” as such term is defined under Virginia privacy law but does not include information exempted from the scope of such law.
We describe:
- the categories of Personal Information we process in this Privacy Policy under the section titled, “Information We Collect”
- the purposes for which we process Personal Information in this Privacy Policy under the section titled, “How We Use Information;” and
- the categories of Personal Information that we share with third parties and the third parties with whom we share this information in this Privacy Policy under the section titled, “Our Information Sharing Practices.”
We may “sell” your Personal Information to third parties or process your Personal Information for targeted advertising. For example, we may “sell” Reader Personal Information under Virginia law when we provide licensed datasets to our trusted partners, or when we provide our customers with tailored audience lists of consumers who may be interested in their products and services. We process your personal information for targeted advertising in the manner described throughout this Privacy Policy.
Under Virginia privacy 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 and targeted advertising. If we “sell” your Personal Information or use your Personal Information to engage in “targeted advertising” according to Virginia privacy law, you can opt-out.
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[at]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[at]sovrn.com within a reasonable time period after our decision has been sent to you.
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, as well as the revision log found at the end of this page.
Please contact us at privacy[at]sovrn.com with questions or concerns regarding our Privacy Policy or how we process your Personal Information.
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
Sovrn Switzerland, S.A.
Via Cantonale 19, CH-
6900 Lugano
Switzerland
Section | Revision summary | Version |
---|---|---|
Information We Collect; How We Collect Information & How We Use Information | Updated Privacy Policy to disclose additional identifiers processed due to new offered services | April, 2023 |
Throughout | Updated Privacy Policy for required disclosures under new US state privacy laws in effect Jan 1 2023, and for general readability | January, 2023 |
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 |