sovrn, Inc. Privacy Policy
Effective Date: 02/22/2018

sovrn Holdings, Inc. (“sovrn”) provides this privacy policy (“Privacy Policy”) to describe our information practices for our Publishers and Readers.

By using the sovrn Services or submitting Personal Information through our sovrn Services, you acknowledge and agree to the terms of this Privacy Policy and to the processing of your Personal Information in accordance with this Privacy Policy.

What This Privacy Policy Covers
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 (together the “sovrn Services”), we collect information about Publishers and Readers. “Publishers” are websites or publications where sovrn Services reside, or natural persons who interact with sovrn on behalf of such websites or publications. “Readers” are individuals who visit our Publishers’ websites. We use and disclose information collected from or about our Publishers and Readers as described in this Privacy Policy.

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 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, 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). “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 Services 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.

Personal Information You Provide to Us

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

Information from Publishers: Our Publisher registration process requires a valid email address and a username and password, among other information. We may also request optional information to support use of the sovrn Services, such as the first and last name, bio, year of birth, zip code, and country of residence for the Publisher contact. 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 Personal Information provided for that account. For example, we categorize the types of content that Publishers make available. We collect payment information from Publishers who purchase sovrn Services, including by participating in our advertising services. A Publisher may also choose to provide us with log-in credentials for accounts with third-party services such as online advertising providers, in order for sovrn to provide services, such as reporting, based on information from those third-party services.

Information from Publishers and Readers: You may choose to provide us with other Personal Information. For example, if you 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.

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, certain information may also be collected passively (as described in this section), including your web viewing and search activities across unrelated websites, browser type, operating system, mobile device identifiers, email address that has been hashed to generate an alphanumeric identifier, use of ad blocking tools, information about the possible relationships among different browsers and devices, and information about the precise location of your device (if you have allowed a website to collect your location through your browser). This information may be linked to Personal Information that identifies your browser or device, including through cookies.

The term ‘cookies’ is used as an umbrella term for various technologies used to identify browsers, such as HTML cookies, Flash cookies, scripts, web beacons and pixel tags. With each of these technologies, a small (text) file is placed by a web server on the device visiting the website or service, which can be read out during further use. For convenience, these techniques are collectively referred to in this Privacy Policy as “cookies”.

sovrn may store cookies on your device:

  • To allow you to navigate our website, use our sovrn Services, and access secure areas of the site. Without these cookies, it is not possible to load or offer key functionalities on our website, such as logging in to your account, displaying dynamic elements or uploading information;
  • To provide you with multimedia functionalities. 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. 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;
  • For statistical purposes and to analyze and improve the use and performance of our sovrn Services and to do the same for our Publishers’ websites; and
  • To provide our Readers with interest-based advertising and the ability to opt out of such advertising as further described in this Privacy Policy.

Our website and sovrn Services 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 we collect, please click here.

Information from Other Sources

We may receive Other Information as well as Personal Information about our Readers and Publishers from other sources. In addition to the types of information described above, this Personal Information may include, for example, mobile device identifiers, information about your activities across unrelated mobile applications, demographic information, email address that has been hashed to generate an alphanumeric identifier, information about the possible relationships between different browsers and devices, information about you from offline sources, and/or precise information about the past or present location of a mobile device. 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 in a Publisher network. We may add this Personal Information to the information we have already collected via the sovrn Services.

Interest-Based Advertising and Opting Out
For our legitimate business interests, and with your consent where this is required, we may process and disclose your Personal Information for interest-based advertising as described in this section.

Opting Out of sovrn’s Activities: sovrn collects, uses, and discloses web viewing data, app usage data, and precise location data across non-affiliated sites and apps over time for the purpose of delivering interest-based advertising to this device or different devices. 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, use, or transfer such data from or on that browser for the purpose of interest-based advertising. Click Opt-Out to install this cookie. Alternatively, you can visit www.aboutads.info to learn more about interest-based advertising and to exercise your opt-out choice with respect to sovrn and other companies participating in the Digital Advertising Alliance (DAA) self-regulatory program.

If you wish to opt-out of sovrn’s collection, use, or transfer of such data from your mobile device for interest-based advertising purposes, you can download the DAA’s AppChoices app from your device’s application store. If you opt out through AppChoices, we will not collect, use or transfer such data from or on that device for interest-based advertising.

When you use the opt-out tools above, your choice will be effective only on the browser or device where you exercised the choice. If you use a different device or browser, you will need to renew your opt-out choice. Our opt-out tool for browsers is cookie-based. It will be installed only if your browser is set to accept third-party cookies, and if you delete this cookie then you will need to renew your opt-out choice. Even if you opt out on your browser or your mobile device, we may continue to collect, use and transfer such data for other purposes such as contextual advertising based on a current visit to a website, fraud prevention, improving site performance and other purposes referred to in this Privacy Policy.

Opting out will not stop advertising from appearing in your browser [or application]. Even if you opt out, you still may receive advertising from the sovrn Services when you visit websites [or applications] 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.

Opting Out of Third-Party Activities: We enable third-party partners to collect web viewing data on the sovrn Services and across unrelated 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 and across browsers and devices. These third-party partners 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 the Digital Advertising Alliance or European Digital Advertising Alliance self-regulatory programs, you can visit www.aboutads.info/choices (for U.S. residents) or www.youronlinechoices.eu (for UK and further EU residents).

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.

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 interest-based advertising and to support third parties’ interest-based advertising activities as described above;
  • We will use your Personal Information to provide a variety of services to Publishers and other business partners, and to enable Publishers to offer you choices related to your use of ad blocking technology and your ad experience on their websites;
  • 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 use of the sovrn Services, and use your Personal Information to help us monitor, improve and protect our products, content, services and websites;
  • We may monitor any Publisher account to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime, in accordance with applicable law;
  • We may use your information to invite you to take part in market research.

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.

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.

We may use your Personal Information for compliance with applicable laws and protection of sovrn 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 sovrn Services or 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 to operate and improve the sovrn Services.

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

Feedback

If you provide feedback to us, we may use and disclose such feedback for any purpose, provided we do not associate such disclosed 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 disclose or provide your Personal Information to others as described in this Privacy Policy. Please see above for a description of how we may disclose Personal Information for interest-based advertising, and your choices related to this practice. We may also disclose Personal Information to Publishers and other business partners for a variety of other services, such as measuring the effectiveness of advertising and preventing advertising fraud.

We may provide your Personal Information to third party service providers who work on behalf of or with us to provide 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 or in response to a subpoena or warrant).

sovrn may share some or all of your 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. 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.

Please note that we may use and disclose Other Information for any purpose in our discretion, 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.

Data Retention

We will keep Publishers’ Personal Information for the length of any contractual relationship you have with us, and, to the extent permitted, after the end of that relationship for as long as necessary to perform the purposes set out in this Privacy Policy.

Our policy is to retain Readers’ Personal Information for a maximum of 90 days [counting from the moment of last interaction]. Laws, legal claims or other particular circumstances may require us to keep certain Personal Information longer.

In other cases, we may retain data for an appropriate period after any relationship with you ends to protect ourselves from legal claims, or to administer our business.

We may retain Other Information for our business purposes, in our discretion or as permitted by law.

Your Choices

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 (or other contacts if you are registered as a Publisher) by emailing us at publishersupport@sovrn.com. We will send you messages related to our relationship (such as, but not limited to, service messages, invoices and 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, use and transfer of data for interest-based advertising purposes.

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

Additional Rights for Residents of the European Economic Area (EEA)

You may be entitled to ask us for a copy of your Personal Information, to correct it, erase or restrict its processing, or to ask us to transfer some of this information to other organizations. As further detailed in other sections of this Privacy Policy, you also have rights to object to some processing, such as profiling we perform for the purposes of direct marketing and interest-based advertisement, and, where we have asked for your consent to process your data, to withdraw this consent. In some cases, you can exercise these rights through automated means. Where this is not possible you can contact us via info@sovrn.com and the details further on in this Privacy Policy. These rights may be limited in some situations – for example, where we can demonstrate that we have a legal requirement to process your data. In some instances, this may mean that we are able to retain data even if you withdraw your consent.

Where we require Personal Information to comply with legal or contractual obligations, then 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.

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.

Where Personal Information is transferred outside of the EEA to a data importer in a country that is not subject to an adequacy decision by the EU Commission, data is adequately protected by an appropriate safeguard such as approved standard contractual clauses (by the EU Commission, the European Data Protection Supervisor or a competent authority). More information on the relevant mechanism can be provided to you by contacting us through the details at the bottom of this Privacy Policy.

Security and Confidentiality

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

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 sovrn.com website and other places as we deem appropriate. When we change this Privacy Policy, we will update the effective date at the top of this Privacy Policy.

Contact Us

If you have any questions, concerns, or suggestions regarding our Privacy Policy or how we process your data, please contact us at info@sovrn.com.

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

Sovrn U.K. Headquarters
4th Floor
33 Charlotte Street
Fitzrovia, London
W1T 1RR
United Kingdom

If you have unresolved concerns you also have the right to complain to your local data protection authority.