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TRUST CENTER
* Overview
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* Data Processing Addendum (Sovrn as Data Importer)
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SOVRN PRIVACY
* Overview
* Legal
* Master Services Agreement
* Data Processing Addendum (Sovrn as Data Importer)
* Standard Contractual Clause Selections and Addendum
* Data Processing Addendum (Sovrn as the Exporter)
* Standard Contractual Clause Selections and Addendum
* Data Processing Addendum Archive
* Website Terms of Use
* Referral Terms
* Privacy
* About Our Cookies
* Your Privacy Choices
* Law Enforcement Request Policy
* Subprocessors
* Third-party providers
* Privacy Policy– Our Commitment to Good Advertising Practices– Information
We Collect– How We Collect Information– How We Use Information– Our
Information Sharing Practices– How To Opt Out– Children’s Privacy–
Retention of Personal Information– Security– Country and US State Specific
Disclosures– Changes in this Privacy Policy– Contact Us– Revision Log
* CCPA Metrics
* Audience Segments
* Service Policies
* Advertising Supply Policy
* Advertising Demand Policy
* Take Down Policy
* Commerce Publisher Code of Conduct
PRIVACY POLICY
Last Updated November 18, 2022
EFFECTIVE DATE: DECEMBER 19, 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 (i) Sovrn Services; and (ii) 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[at]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, unique online identifiers, 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.
Publishers are also Sovrn customers.
* “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, and this
Privacy Policy.
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”).
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 and www.aboutads.info.
INFORMATION WE COLLECT
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 that could directly identify them to Sovrn, 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:
IdentifierDescriptionUsed byCookie IDA 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 SiteConnected television
identifier (CTV ID) Examples of connected televisions (CTV) include Xbox,
PlayStation, Roku, Amazon Fire TV, Apple TV, and devices provided by
manufacturers such as Samsung and Vizio. A CTV ID is a unique identifier that is
generated by the CTV and is used for various purposes, including Interest-Based
Advertising.ExchangeDevice informationDevice 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 SiteHashed emailHashing 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.Ad Management and
Signal (collect); Data (procure)IP addressAn 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. IP addresses allow us to infer your general
location in order to help us understand your data rights.All Services and
SiteMobile advertising IDMobile advertising IDs are provided by the mobile
device’s operating system, and 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
targeted advertising purposes.Exchange (collect) and Data (procure)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.SiteUnique online identifierAn 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. All Services and SiteVoice RecordingsWhen our customers
interact with Sovrn through virtual meetings or by telephone, we may record the
call to assist with taking notes and for internal training purposesSovrn Sales
and Support Teams
HOW WE COLLECT INFORMATION
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 IN ORDER TO:
* 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 X 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, sync
unique online identifiers, 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.
When Publishers contact Sovrn by telephone or virtual meeting, we use a
third-party service to record the call (with your consent) to assist in
documentation and for training purposes. For clarity, we will only record those
actively in the call; if there are others in the vicinity, it is our expectation
that they are not recorded unintentionally, unless this Privacy Policy has been
provided and their approval to the recording has been obtained.
HOW WE USE INFORMATION
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. For a list of
our Service Providers, please visit
https://www.sovrn.com/legal/subprocessors/
* 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 list of our 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.
HOW TO OPT OUT
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
Just as there are different mechanisms for providing Interest-based Advertising
(such as through a web browser, apps on your mobile device and connected
televisions), there are multiple ways you can limit the use of your personal
information for targeted advertising purposes and the sale or sharing of your
personal information.
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 on their
browser(s) or device(s) across all participating DAA members.
For more information on how to opt-out of the sale or sharing 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.
Cookies and Unique Online Identifiers Used by Web Browsers
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.
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. There, you may also access the DAA WebChoices tool for managing
preferences on web browsers, and to exercise opt-out choice with respect to
Sovrn and other companies participating in the DAA’s self-regulatory program.
Identifiers used by connected TVs and mobile devices / apps
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 to manage preferences on mobile
platforms like Android or Apple iOS devices. More information on your options
for opting out of targeted advertising provided through your connected
television streaming devices can be found on the Network Advertising Initiative
(NAI) site.
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.
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 NETWORK 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.
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
support@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
and/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.
CHILDREN’S PRIVACY
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.
RETENTION OF PERSONAL INFORMATION
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.
SECURITY
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 THE EEA, SWITZERLAND AND UK: DATA SUBJECT RIGHTS
This section applies only to individuals located in the European Economic Area
(“EEA”), Switzerland or the United Kingdom (“Applicable 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 the Applicable Countries’ data
protection legislation.
ROLE OF SOVRN AS A CONTROLLER OR PROCESSOR
If located in one of the Applicable 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 customer.
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 (USA), 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
Applicable Countries.
These countries (including the United States) may have data protection or other
laws that differ from those in the Applicable Countries. We ensure that where
Sovrn or third-party service providers receive Personal Information outside of
the Applicable Countries, appropriate safeguards are in place under the
Applicable Countries’ 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 Applicable Countries who have questions or
concerns about how we process Personal Information may contact our Data
Protection Officer at dpo@sovrn.com. If we are not able to resolve the issue,
individuals have the right to lodge a complaint with their local data privacy
authority. For contact details of local Data Protection Authorities, please
visit the European Data Protection Board member list 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 InformationTo 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 RecordsN/ACommercial 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. Authorized agents may submit a request
through our Privacy Center, where instructions are provided for completing the
request.
FEES
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@sovrn[.]com – Please put the statement “VCDPA Consumer
Request” in the subject line.
If we decline to take action on your request, you may appeal such refusal by
sending us an email to privacy@sovrn[.]com within a reasonable time period after
our decision has been sent to you.
CHANGES IN THIS PRIVACY POLICY
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.
CONTACT US
Please contact us at privacy@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
53, 64 Chancery Ln,
London WC2A 1QU
United Kingdom
Sovrn Switzerland, S.A.
Via Cantonale 19, CH-
6900 Lugano
Switzerland
REVISION LOG
SectionRevision summaryVersionOur Commitment to Good Advertising Practices & How
to Opt OutRemoved information related to the European Interactive Digital
Advertising Alliance (EDAA) YourOnlineChoices programDec. 2023Information We
CollectUpdated Privacy Policy to disclose the collection of voice recordings to
support Publisher Sales and Support teamsSep. 2023Notice to Residents of the
EEA, Switzerland and UK: Data Subject Rights; ContactsUpdated semantics for
readability; updated Sovrn UK, Limited addressAug. 2023Information We Collect;
How We Collect Information & How We Use InformationUpdated Privacy Policy to
disclose additional identifiers processed due to new offered servicesAug.
2023Information We Collect; How We Collect Information & How We Use
InformationUpdated Privacy Policy to disclose additional identifiers processed
due to new offered servicesApr. 2023ThroughoutUpdated Privacy Policy for
required disclosures under new US state privacy laws in effect Jan 1 2023, and
for general readabilityJan. 2023Our Commitment to Good Advertising Practices &
How to Opt OutAdded information related to our integration with the European
Interactive Digital Advertising Alliance (EDAA) YourOnlineChoices programAug.
2022ThroughoutRevised email addresses throughout to reduce spamAug.
2022Exercising California Consumer RightsReplaced toll-free number with new
toll-free numberAug. 2022Entire PolicyConsolidated Website and Service Privacy
Policies, reordered sections, and updated internal links.Apr. 2021Information We
CollectAdded ‘Universal ID’ to the list of Personal Information typesApr.
2021Personal Data Rights (throughout)Separation of UK from EU personal data
rights as a result of the enactment of the UK GDPRFeb. 2021Personal Data Rights:
Questions or ComplaintsAddition of EU representative as a result of the UK’s
exit from the EUFeb. 2021Revision LogNew section added for clarity of changes
over timeFeb. 2021
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