Posted Date: December 18th, 2019
Effective Date: January 1st, 2020
Through the Sovrn Services including 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, the Sovrn Commerce affiliate linking services, and other Sovrn products and services (together the “Sovrn Services“), we collect information about Publishers and Consumers. “Publishers” are websites or publications that use Sovrn Services, or natural persons who interact with Sovrn on behalf of such websites or publications. “Consumers” are individuals who visit our Publishers’ websites.
Information You Provide to Us
The Personal Information we gather helps us provide the Sovrn Services and learn more about how you use Sovrn Services. You may choose to provide us with Personal Information by interacting with us. For example, if you sign up for a mailing list or otherwise request information, 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.
Information from Publishers: We collect additional Personal Information from Publishers. The Publisher registration process through Sovrn requires a valid email address and a username and password. For some of our Services, Publishers may register using an existing Google account. For Publishers who register through Google, we will receive your email address and profile information. We may also request information from you to support use of the Sovrn Services, such as the first and last name, bio, year of birth, telephone number, websites, software, mobile applications, log in IP addresses, physical address, 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.
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 browse websites within the Sovrn Publisher network as a Consumer, certain information may also be collected passively (as described in this section), including your web viewing and search activities across unrelated websites, mobile application usage, browser agent, browser type, operating system, IP address (which may be used to generate your approximate geographic location), device type, 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 or have enabled location services on a mobile device). This information may be linked to Personal Information that identifies your browser or device, including through cookies.
Sovrn Commerce enables Publishers to add links on locations including, but not limited to, webpages, sites, software, social media, and mobile applications to merchant destinations. When a Consumer clicks through Sovrn Commerce affiliated links to a merchant destination and then makes a purchase or submits a lead, the Publisher that generated the traffic is paid a referral fee or commission.
Sovrn may store cookies on your device:
- For Publishers, to allow you to use our Sovrn Services, and access secure areas of the Sovrn Services. 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.
- For both Publishers and Consumers, 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.
Our 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 you from other sources, and combine it with the information that we collect through the Sovrn Services. In addition to the types of information described above, this Personal Information may include, for example, mobile advertising identifiers, information about your activities across unrelated websites or 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 data providers, or information provided to us by third parties in a Publisher network.
For Consumers: 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. You can choose to opt out of Sovrn’s interest-based advertising activities on your device. If you choose to opt out, we will not collect, use, or transfer such data from or on the device that you opted out, for the purpose of interest-based advertising.
If you wish to opt out of Sovrn’s collection, use, or transfer of such data from your browser for interest-based advertising purposes, you can visit https://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.
Opting out will not stop advertising from appearing in your browser. 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.
Opting Out of Sovrn Commerce: If you want Sovrn Commerce to stop collecting or storing personal data about the websites you visit, the links you click, or the merchants you make purchases from, you can choose to opt-out out of Sovrn Commerce cookies using our opt-out page. 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 you opted out of tracking on, you will be required to opt-out again.
Use of Personal Information
We process Personal Information to enable our business, including but not limited to the following:
- For Consumers:
- 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 including analytics and data services, and to enable Publishers to offer you choices related to your use of ad blocking technology and your ad experience on their websites.
- For Sovrn Commerce and similar services, we will use your Personal Information to optimize links, determine the best merchant destination for clicks, and set the appropriate language and region for click destinations.
- For Publishers:
- 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.
- Sovrn will use a Publisher’s payment account information to make payments to you as part of our Services, 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 monitor any Publisher account to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime, in accordance with applicable law.
- We may also use the Personal Information you provided to provide you with electronic newsletters, transactional, or promotional e-mails.
- For Everyone:
- We monitor the 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 use your information to invite you to take part in market research.
- We may use your Personal Information to comply with applicable laws and protect 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 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 Sovrn Services and developing new products.
We may also use Other Information on Consumers’ 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.
Disclosure of Information
- Publishers: We may disclose Personal Information to Publishers and their service providers in order to provide the Sovrn Services, such as measuring the effectiveness of advertising, advertising attribution, and preventing advertising fraud.
- Other Third-Party Customers: We may disclose Personal Information that identifies your device to our third-party customers, who will use and disclose the information for their own purposes. Please see above for more information on how we may disclose Personal Information for interest-based advertising, and your choices related to this practice.
- Service Providers: We may provide your Personal Information to third-party service providers and data processors who work on behalf of or with us to provide the Sovrn Services and to help us communicate with you. Examples include other advertising services and data enrichment services. Examples of such services include sending email, analyzing data, providing marketing assistance, processing payments (including credit card payments), and providing customer service.
- Law Enforcement: We may disclose your Personal Information if we believe in good faith that such disclosure is necessary to (a) comply with relevant laws or to respond to subpoenas or warrants served on us; or (b) to protect and defend the rights or property of Sovrn, you, or third parties.
- Other Information: We may use and disclose Other Information for any purpose in our discretion, to the extent permitted under applicable law. If we are required to treat Other Information as Personal Information under applicable law, then we may use or disclose it for all the purposes for which we use and disclose Personal Information.
For Consumers: For Personal Information collected through our Sovrn Commerce services, our policy is to retain Consumers’ Personal Information for a maximum of eighteen months. Consumer Personal Information collected through all other Sovrn Services is to be retained for a maximum of one year. However, laws, legal claims or other particular circumstances may require us to keep certain Personal Information longer.
We may retain Other Information for our business purposes, in our discretion or as permitted by law.
Unsubscribe instructions will accompany each promotional email we send you. You can also contact us in order to change your preferences with respect to promotional emails (or other contacts if you are registered as a Publisher) by emailing us at email@example.com. We will send you messages related to our relationship or transactions with you. 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.
For Consumers, please see above for information on opting out of Sovrn’s collection, use and transfer of data for interest-based advertising purposes.
For Publishers: Access and Changes to Your Personal Information
Connected to the Sovrn Services, we 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 firstname.lastname@example.org 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)
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.
For Publishers: Nevada Privacy Rights
Under Nevada law, Publishers who are Nevada residents may submit a request directing us not to make certain sales of personal information we maintain about them that is covered by Nevada law, if we make such sales in the future.
To exercise this right, please contact us by email at privacy@Sovrn.com.
For Consumers: California Privacy Rights
This section contains disclosures for Consumers required by the California Consumer Privacy Act (“CCPA”). This section applies only to “personal information” that is subject to the CCPA. (Publisher personal information is not “sold” under the CCPA and is otherwise exempt from the CCPA at this time.)
Consumers with disabilities may access this notice by using a standard screen reader.
Personal Information We Collect, Disclose for a Business Purpose, and Sell.
We collect the categories of personal information about California Consumers identified in the chart below. As further set forth in the chart below, in the past 12 months, we have disclosed and sold California Consumers’ personal information to third parties for business or commercial purposes.
|Categories of Personal Information||Collected in the last 12 months:||Categories of sources from which information is collected:||Business or commercial purposes for collection, use, and sharing:||Disclosed for business purposes to the following categories of third parties:||Sold to the following categories of third parties:|
|Personal and online identifiers (such as first and last name, email address, or unique online identifiers)||Yes||All categories listed below.||All purposes listed below.||All categories listed below.||All categories listed below.|
|Characteristics of protected classifications under California or federal law (such as sex, race, or gender)||Yes||All categories listed below.||All purposes listed below.||All categories listed below.||All categories listed below.|
|For Commerce services, commercial or transactions information (such as records of personal property or products or services purchased, obtained or considered)||Yes||All categories listed below.||All purposes listed below.||All categories listed below.||All categories listed below.|
|Internet or other electronic network activity information (such as browsing history, search history, interactions with a website, email, application, or advertisement)||Yes||All categories listed below.||All purposes listed below.||All categories listed below.||All categories listed below.|
|Geolocation information||Yes||All categories listed below.||All purposes listed below.||All categories listed below.||All categories listed below.|
|Professional or employment-related information||Yes||All categories listed below.||All purposes listed below.||All categories listed below.||All categories listed below.|
|Education information||Yes||All categories listed below.||All purposes listed below.||All categories listed below.||All categories listed below.|
|Inferences drawn from the above information about your predicted characteristics and preferences||Yes||All categories listed below.||All purposes listed below.||All categories listed below.||All categories listed below.|
|Other information about you that is linked to the personal information above||Yes||All categories listed below.||All purposes listed below.||All categories listed below.||All categories listed below.|
Categories of Sources.
We collect this personal information from the following categories of sources:
- Service providers;
- Affiliates not under the Sovrn brand; or
- Consumer data resellers.
Why We Collect, Use, and Share California Information.
- Our commercial purposes, including providing interest-based advertising for and to Consumers; providing our Services to our Publishers as described in this Policy; and marketing our Services.
- Our business purposes as identified in the CCPA, which include:
- Auditing related to our interactions with you;
- Legal compliance;
- Detecting and protecting against security incidents, fraud, and illegal activity;
- Performing services (for us or our service provider) such as account servicing, processing orders and payments, and analytics;
- Internal research for technological improvement;
- Internal operations;
- Activities to maintain and improve our services; and
- Other one-time uses.
Recipients of California Personal Information.
We sell the categories of personal information designated above to the categories of third parties listed below:
- Our Publishers and third-party customers, which include the following categories of third parties:
- Demand Side Platforms;
- Advertising/marketing companies;
- Advertising networks;
- Internet service providers;
- Apparel & accessory companies;
- Marketing data companies;
- Data analytics providers;
- Operating systems and platforms;
- Social networks;
- Consumer data resellers;
- Publishing product companies;
- Technology/computer software companies;
- Consumer packaged goods companies;
- Affiliates not under the Sovrn brand.
We disclose the categories of personal information designated above to the categories of third parties listed below for business purposes:
- Our Publishers;
- Service providers;
- Affiliates not under the Sovrn brand;
- Advertising networks and other partners who buy ad space from Publishers;
- Internet service providers;
- Data analytics providers;
- Operating systems and platforms; and
- Consumer data resellers.
Your Rights Regarding Personal Information.
California Consumers have certain rights with respect to the personal information collected by businesses. If you are a California Consumer, you may exercise the following rights regarding your personal information, subject to certain exceptions and limitations:
- The right to know the categories and specific pieces of personal information we collect, use, disclose, and sell about you, the categories of sources from which we collected your personal information, our purposes for collecting or selling your personal information, the categories of your personal information that we have either sold or disclosed for a business purpose, and the categories of third parties with which we have shared personal information;
- The right to request that we delete the personal information we have collected from you or maintain about you.
- The right to opt out of our sale(s) of your personal information. Please note that if you opt out of certain types of sales, we will be unable to provide you with the services that rely on such sales.
- The right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA.
To exercise any of the above rights, please contact us using the following information and submit the required verifying information, as further described below:
- By phone at 1(888)799-5199
- For access and deletion requests: Online at https://www.sovrn.com/your-data/
Verification Process and Required Information.
Note that we may need to request additional information from you to verify your identity or understand the scope of your request, although you will not be required to create an account with us to submit a request or have it fulfilled. We will require you to provide, at a minimum, your email address, device identifier, and cookie identifier (which we collect automatically on our webform).
You may designate an authorized agent to make a CCPA request on your behalf by verifying your identity and giving the agent written permission to make a request for you.
Minors’ Right to Opt In.
We do not sell the personal information of minors under 16 years of age.
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.
Security and Confidentiality
Sovrn has put in place commercially reasonable physical, electronic, and managerial procedures to safeguard and secure the Personal Information we collect.
Sovrn U.S. Headquarters
5541 Central Avenue, Suite 100
Boulder, CO 80301
Sovrn U.K. Headquarters
4th Floor Newland House
40 Berners Street
If you have unresolved concerns, you also have the right to complain to your local data protection authority.