Effective Date: July 28, 2016.

sovrn Holdings, Inc. (“sovrn”) provides this policy to describe our information practices for our Publishers, Readers, and business operations in the United Kingdom. Our separate privacy policy for the United States can be accessed here.

Through the Sovrn Services including the sovrn.com website, the Sovrn publisher platform and other Sovrn publisher tools and widgets, the Sovrn ad exchange, Sovrn header bidding, Sovrn video products, sovrn, analytics and data services, and other Sovrn products and services, we may collect information about Publishers and Readers. Publishers are natural persons, websites or publications where Sovrn Services may reside. Readers are individuals who visit our publishers’ websites. We may use and disclose information collected from or about our Publishers and Readers as described in this privacy policy (Privacy Policy). Any capitalized terms not defined in this Privacy Policy are defined in the Legal Terms page or the other documents linked there.

What This Privacy Policy Covers

This Privacy Policy describes sovrn’s use of Personal Information and Other Information that we collect when you use the Sovrn Services. “Personal Information” means contact information (i.e., name, address, e-mail address, and/or phone number) and any other information that is associated with the contact information, including information associated with a browser or device. “Other Information” means information that is not associated with or linked to your Personal Information including aggregate or de-identified information. We collect and use Personal Information and Other Information as described in this Privacy Policy from both Publishers and Readers.

The Sovrn website may contain links to websites or content, including advertisements, operated and maintained by third parties, over which we have no control. We encourage you to review the privacy policy of a third-party website before disclosing any information to the website.

BY USING THE SOVRN SERVICES OR SUBMITTING PERSONAL INFORMATION THROUGH OUR SOVRN SERVICES, YOU AGREE TO THE TERMS OF THIS PRIVACY POLICY AND YOU EXPRESSLY CONSENT TO THE PROCESSING OF YOUR PERSONAL INFORMATION ACCORDING TO THIS PRIVACY POLICY.

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. BY USING THE SOVRN SERVICES OR SUBMITTING PERSONAL INFORMATION THROUGH OUR SOVRN SERVICES, YOU EXPRESSLY CONSENT TO THE TRANSFER OF YOUR PERSONAL INFORMATION INTERNATIONALLY.

Personal Information You Provide to Us

The Personal Information we gather from our Publishers helps us provide the Sovrn Services and learn more about how our Publishers use our Services. We collect the following Personal Information that our Publishers submit to us voluntarily:

Our Publisher registration process requires you to provide Sovrn with a valid email address and a username and password of your choice, among other information. We may also request optional information to support your use of the Services, such as your first and last name, year of birth, zip code, and country of residence. We may collect information about the categories of Content our Publishers typically make available to others on pages integrated with Sovrn services and link this information to your Personal Information. For example, we categorize the types of Content you make available. We may collect information related to your PayPal account or other payment information if you, as a Publisher, participate in our advertising services.

Publishers and Readers may choose to provide us with other Personal Information. For example, if you, as a Publisher or Reader, sign up for a Sovrn Alert or 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. A Publisher may also choose to provide us with log-in credentials for accounts with third-party services such as online advertising providers, in order for Sovrn to provide services, such as reporting, based on information from those third-party services.

You can choose not to provide us with certain Personal Information, but this may limit the features of the Sovrn Services you are able to use.

Information Collected Via Technology

As you use the Sovrn Services as a Publisher or Reader, certain information may also be collected passively (as described in this Section), including your Web viewing activities, Internet protocol (IP) address, browser type, and operating system.

sovrn stores a small text file called a Cookie on your computer: (1) to store your login information, if applicable, and (2) in conjunction with providing the Sovrn Services, including when you as a Reader choose to opt out of such services (see below). Sovrn may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them). Our website uses four cookies. A cookie is a small file of letters and numbers that we put on your computer if you agree. These cookies allow us to distinguish you from other users of our website, which helps us to provide you with a good experience when you browse our website and also allows us to improve our site. The cookies we use are “analytical” cookies. We also use other cookieless browser identification technologies, which collect, among other things, IP address and browser type and settings. These technologies allow us to recognize and count the number of visitors and to see how visitors move around the site when they are using it. In addition, these technologies helps us to improve the way our website works, for example by ensuring that users are finding what they are looking for easily. Read more about the individual analytical cookies we use and how to recognize them. For more information about how cookies are used or what information we collect, pleaseclick here.

With respect to Readers, we collect information about the pages you view as a Reader and the search queries you submit as a Reader through cookies and other technologies that may identify your browser across sites over time, but do not identify you as an individual. Unless a Reader voluntarily provides us with Personal Information (such as your email address for Sovrn newsletters or Sovrn Alerts), we collect only Other Information from Readers.

Information from Other Sources

We may receive Personal Information about our Publishers from other sources. These sources may include information conveyed to us by telephone or fax, information that we receive from third party service providers, or information provided to us by third parties that you add to your network. We may add this Personal Information to the information we have already collected from you via the Sovrn Services.

Interest-Based Advertising and Opting Out

We may enable advertisers and ad servers to collect data on the Sovrn Services and across other websites and online services for purposes that include “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 sites over time. These third-party advertisers and ad networks that participate in the Sovrn Services may also use their own cookies and other ad service technologies to display and track their ads. To opt out of this type of advertising from companies participating in industry self-regulation, UK residents can visit www.youronlinechoices.eu.

This Privacy Policy does not cover the privacy practices of any third-party advertisers or ad servers. We do not control and are not responsible for such third-party advertisers’ and ad networks’ information practices or their use of cookies and other ad service technologies. To learn more about the practices of these companies, please read their privacy policies.

Sovrn collects and discloses web viewing and other data across non-affiliated sites over time for the purpose of delivering interest-based advertising to this device or different devices. We make available a Sovrn “opt-out” cookie that you may download to your browser. If this cookie is installed on your browser, we will not collect or use Web viewing data on that browser for the purpose of interest-based advertising. However, we may continue to collect and use data for other purposes such as fraud prevention, improving site performance and other purposes. Click Opt-Out to install this cookie. You can visit www.aboutads.info to learn more about interest-based advertising and the effect of your opt-out choice.

Our opt-out tool is cookie-based. This opt-out tool is effective only on the browser on which it is installed, and will be installed only if your browser is set to accept third-party cookies. If you delete an opt-out cookie from a browser’s cookie files, or if you use a different device or browser, you will need to renew your opt-out choice.

Additionally, you may prevent us from collecting and using information via cookies on a browser for interest-based advertising purposes by blocking third-party cookies in that browser if the browser offers such tools. If you block third-party cookies from being set on your browser, you may not be able to enjoy some features or functionality of, and you may see the same content and advertisements repeatedly on, some Publisher sites. Even if you block third-party cookies on your browser, we will continue to collect certain information, including IP address and browser type and settings, for other purposes such as fraud prevention, improving site performance and such other purposes.

Even if you opt out, you still may receive advertising from the Sovrn Services when you visit websites of a Publisher who uses our Services, but that advertising will not be targeted to you. If you opt out of sovrn’s practices, you may also continue to receive interest-based advertising through other companies.

Use of Information We Collect

In general, we use Personal Information submitted to us by our Publishers to register our Publishers for the Sovrn Services, to respond to requests that our Publishers make, to operate and improve our Sovrn Services, and to offer you additional information, opportunities, and functionality. Sovrn will use a Publisher’s payment account information to make payments to you as part of our advertising network, if applicable. If a Publisher chooses to provide us with log-in credentials for accounts with third-party services such as online advertising providers, Sovrn will use the credentials to access and provide you with services you request such as reporting on your use of those third-party services. Sovrn may also use aggregate data obtained in this way for our internal purposes to improve the Sovrn services.

One of the features of the Sovrn Services is that our Publishers may aggregate existing information about themselves, such that it may be searched by others. Therefore, you should assume that any information you enter into or post on the Sovrn Services (excluding your registration information) will be shared with Readers. Please be aware that if you enter any Personal Information into publicly available sections of the Sovrn Services, this information will be displayed to anyone who has access to these sections.

We may also use the Personal Information provided by both Publishers and Readers to provide you with electronic newsletters, “sovrn Alerts”, or promotional e-mails, should you request to receive such communications from us.

We may create Other Information records from Personal Information by excluding information (such as your name or email address) that makes the information personally identifiable to you or your device. We may use Other Information for a variety of purposes including to analyze usage patterns so that we may enhance our Sovrn Services.

We use Other Information on Readers’ activities at Publisher websites, such as page views and search queries, to provide aggregate information to Publishers so that they can improve their offerings and we may link Other Information to a browser or device to present more relevant advertising to Readers on Publisher websites that participate in our advertising services.

Feedback

If you as a Publisher or Reader provide feedback to us, we may use and disclose such feedback for any purpose, provided we do not associate such feedback with your Personal Information. We will collect any information contained in such feedback and will treat the Personal Information in it in accordance with this Privacy Policy.

Disclosure of Information

We may provide your Personal Information to third party service providers who work on behalf of or with us to provide some of the services and features of the Sovrn Services and to help us communicate with you. Examples of such services include sending email, analyzing data, providing marketing assistance, processing payments (including credit card payments), and providing customer service. However, these service providers do not have any independent right to share this information (except pursuant to a legal requirement such as a subpoena or warrant).

Please note that we may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, then we may use it for all the purposes for which we use and disclose Personal Information.

We share Other Information with our partners, advertisers, and other third parties in our discretion, including to deliver more relevant advertising to Readers. For example, we may share information related to a specific cookie to enable advertisers or ad servers to display relevant ads, based on the Content, search terms, and demographic profile viewed in connection with that cookie.

Although we currently do not have a parent company, any subsidiaries, joint ventures, or other companies under a common control (collectively, “Affiliates”), we may in the future. We may share some or all of your Personal Information with these Affiliates, in which case we will require our Affiliates to honor this Privacy Policy. 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, your Personal Information may be among the assets transferred. You acknowledge that such transfers may occur, and that any acquirer of Sovrn or its assets may continue to process your Personal Information as set forth in this Privacy Policy.

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. You hereby consent to Sovrn sharing your Personal Information under the circumstances described herein.

Data Retention

Unless you contact us to request the deactivation of your Publisher account, we will retain data for as long as it is necessary to fulfill a legitimate business purpose or as required by law.

Your Choices

Unsubscribe instructions will accompany each promotional communication we send you. You can also contact us in order to change your preferences with respect to informational and/or promotional contacts by emailing us at support@sovrn.com.

We will send you messages related to our relationship (such as, but not limited to, notices of any updates to our Publisher Agreement or Privacy Policy) when it is necessary to do so. You may not opt-out of these communications, but if you do not wish to receive these announcements, you have the option to deactivate your account as discussed below.

Please see above for information on opting out of sovrn’s collection and use of data through cookies for interest-based advertising purposes.

Access and Changes to Your Personal Information

The Sovrn Services display some of the information you enter when you create your account by registering as a Publisher, such as your username (or display name) and bio, as well as your network of connections. In order to access and remove or modify your bio and display name, your email address, and/or other contact information that is not displayed, you may login to your Sovrn account, select the “Account” option, and edit your contact details. To prevent any other information from the account being displayed by the Sovrn Services, you may contact us at support@sovrn.com to deactivate your account. When we deactivate Personal Information about you, it will be deactivated from our active databases but may remain in our archives.

Cross-border Transfer

The Sovrn Services are controlled and operated by us from the United States, and are not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States. Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Sovrn Services you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have different data protection rules than those of your country.

Security and Confidentiality

sovrn has put in place commercially reasonable physical, electronic, and managerial procedures to safeguard and secure the Personal Information we collect. However, no company, including sovrn, can fully eliminate security risks associated with Personal Information.

Changes in this Privacy Policy

We reserve the right to modify this Privacy Policy at any time, in which case we will post the changes to this Privacy Policy page, and may also post the changes to the Website and other places as we deem appropriate. Changes will become effective from when they are posted.

Contact Us

If you have any questions or suggestions regarding our Privacy Policy please contact us at info@sovrn.com.