Effective Date: January 1st, 2020
“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), any other data that is associated with the contact information, and/or information that identifies a browser or device such as an IP address, mobile advertising identifier, cookie identifier, 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). “Other Information” means information that is not associated with or linked to your Personal Information including aggregate or de-identified information.
Information You Provide to Us
The Personal Information we gather from you helps us provide the Site and learn more about how the Site is used. We collect Personal Information that you submit to us voluntarily, such as your name and contact information.
For example, if you fill out a form on the Site or sign up for a newsletter, we collect your email address. When you contact us by sending us an email or providing other feedback, we will collect any information that is contained in your email or feedback.
You can choose not to provide us with certain Personal Information, but this may limit the features of the Site you are able to use.
Information Collected Via Technology
As you use the Site, certain information may also be collected passively (as described in this section), including your web viewing and search activities, browser type, operating system, cookie identifiers, and IP address. This information may be linked to Personal Information that identifies your browser or device, including through cookies.
For example, Sovrn (or our third-party partners) may store cookies on your device:
- To allow you to navigate our website. These cookies allow us to load or offer key functionalities on our website, such as displaying dynamic elements or uploading information.
- For statistical purposes and to analyze and improve the use and performance of the Site.
Our Site may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your device until you delete them). For more information about how cookies are used or what information is collected, please click here.
Information from Other Sources
We may receive Other Information as well as Personal Information about you from other sources and combine it with the information collected through the Site.
Analytics and Interest-Based Advertising
We work with third parties that collect data about your 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 the Service and for analytics and marketing purposes. For more information about how Google Analytics collects and uses data when you use the Service, visit https://policies.google.com/technologies/partner-sites, and to opt out of Google Analytics, visit https://tools.google.com/dlpage/gaoptout/. We also enable third-party partners to collect web viewing data on the Site for “interest-based advertising,” which is the process of showing you targeted ads on one or more devices that are more likely to be relevant to you based on inferences drawn from your Web viewing data collected across non-affiliated websites and online services, over time and across browsers and devices. These third-party partners may also use their own cookies to display and track their ads. To opt out of this type of advertising from companies participating in the Digital Advertising Alliance or European Digital Advertising Alliance self-regulatory programs, you can visit AboutAds (for U.S. residents) or https://www.youronlinechoices.eu (for UK and further EU residents). Sovrn adheres to the Digital Advertising Alliance’s Self-Regulatory Principles in connection with these activities.
Use of Personal Information
We process Personal Information to enable our business and pursue our legitimate interests, including but not limited to the following:
- We will use your Personal Information to provide products and services you have requested, and respond to any comments or complaints you may send us;
- We monitor the use of the Site, and use your Personal Information to help us monitor, improve and protect our products, content, services and websites;
- We may use your information to invite you to take part in market research.
We may also use the Personal Information you provide to provide you with electronic newsletters or promotional e-mails.
We may use your Personal Information for compliance with applicable laws and protection of 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).
Use of Other Information
We may collect Other Information through the Site or we may create Other Information records from Personal Information by excluding information (such as your name or email address) that makes the information identifiable to you or your device. We may use Other Information for a variety of purposes to operate and improve the Site.
As examples, we may use Other Information for purposes that include testing our IT systems, analyzing usage patterns, market research, data analysis, improving the Site and developing new products.
Disclosure of Information
- Service Providers: We may provide your Personal Information to third-party service providers (including agents and consultants) and data processors who work on behalf of or with us to provide the Site and to help us communicate with you. Examples include email marketing providers and analytics companies. Examples of such services include sending email, analyzing data, providing marketing assistance, and providing customer service.
- Law Enforcement: We may disclose your 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, you, or third parties.
- Other Information: We may use and disclose Other Information for any purpose in our discretion, to the extent permitted under applicable law. If we are required to treat Other 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 policy is to retain your other Personal Information for a maximum of one year. Laws, legal claims or other particular circumstances may require us to keep certain Personal Information longer.
We may retain Other Information for our business purposes, in our discretion or as permitted by law.
Unsubscribe instructions will accompany each promotional email we send you. You can also contact us in order to change your preferences with respect to promotional emails by emailing us at firstname.lastname@example.org. Even if you opt out, we will continue to send you messages related to our relationship or transactions.
Please see above for information on opting out of the collection of data on the Site for interest-based advertising purposes.
Additional Rights for California Residents
Our business customers who are California residents have certain rights under the California Consumer Privacy Act (“CCPA”) with respect to the personal information that we collect about you:
- The right to opt out of our sale(s) of your personal information. Please note that if you opt out of certain types of sales, we will be unable to provide you with the services that rely on such sales. [Note: If business data is not sold, replace the preceding sentence with “We do not and will not sell your personal information in any manner that requires an opt-out opportunity under the CCPA.” and omit the instructions below.]
- The right not to receive discriminatory treatment for the exercise of your opt-out right conferred by the CCPA.
To exercise any of the above rights, please contact us using the following information and submit the required verifying information, as further described below:
- By phone at 1(888)799-5199
- For access and deletion requests: Online at https://www.sovrn.com/your-data/
Additional Rights for Residents of the European Economic Area (EEA)
Where we require Personal Information to comply with legal or contractual obligations, then your provision of such data is mandatory: if such data is not provided, then we will not be able to manage our contractual relationship, or to meet obligations placed on us. In all other cases, provision of requested Personal Information is optional.
Access and Updates to Information
To review or keep your contact information accurate, current, and complete, please contact us at email@example.com. We will exercise commercially reasonable efforts to update or correct contact information in our possession that you have previously submitted to us.
Cross-border Transfer of Personal Information
Your Personal Information may be processed by us in the country where it was collected as well as other countries (including the United States) where laws regarding processing of Personal Information may be less stringent than the laws in your country.
Links to Third-Party Websites
Security and Confidentiality
Sovrn has put in place commercially reasonable physical, electronic, and managerial procedures to safeguard and secure the Personal Information we collect.
Sovrn U.S. Headquarters
5541 Central Avenue, Suite 100
Boulder, CO 80301
Sovrn U.K. Headquarters
4th Floor Newland House
40 Berners Street
If you have unresolved concerns, you also have the right to complain to your local data protection authority.