Effective as of June 6, 2017
The Information We Collect; The Purpose of Collection and Use
Sonobi collects information on behalf of its customers to help target online advertising to you based on your interests. This information may include information about your location, including your IP Address, your browser type (e.g. Chrome or Firefox), the date and time of the ad request, pages viewed, your operating system (e.g. Macintosh, Windows, Android, OSX), the URL or App you are using, and your Internet Service Provider (e.g. Verizon or Comcast).
If you are an advertiser or publisher that chooses to work with us, you may be required to provide us with certain information which may include your name and contact information (“Contact Information”). The Contact Information is used to provide the requested information, to provide our products and services and for the purposes of direct marketing of our current and future products and services.
We collect information using “cookie” technology. Cookies are small packets of data that a website stores on your computer’s or mobile device’s hard drive so that your computer will “remember” information about your visit. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to help us collect information. If you do not want us to place a cookie on your hard drive, you may be able to turn that feature off on your computer or mobile device. Please consult your Internet browser’s documentation for information on how to do this and how to delete persistent cookies. However, if you decide not to accept cookies from us, the Website may not function properly.
The Information We Collect from Users of our Media Brand’s/Publisher’s Website
Sonobi collects information about users’ online behavioral activity when users’ access and/or use our media brand’s/publisher’s website. We collect and store various signals from tracked and measured impressions, and we also use cookie technology to collect this information. We collect IP address, browser type, user agent, referring URL, and browsing activity information. We use this information in order to provide our services to our customers, and we may share this information with our customers for analytics, ad delivery and reporting and targeting purposes.
The Information We Receive from our Media Brands/Publishers
We may receive your information from our media brands/publishers including, but not limited to your email address and publisher issued identifier. This information will be stored temporarily on our servers during the processing of such information and will be permanently deleted once the processing is complete.
The Information Collected by or Through Third-Party Advertising Companies
We may use data we receive from advertising technology partners and customers, including publishers, to match multiple devices associated with the same publisher identifier as devices belonging to the same user or household. Where we are able to make such a match, we may use this information to deliver targeted advertisements across multiple devices on behalf of our customers.
In an ongoing effort to better understand our users, and the Website, we might analyze your information in aggregate form to operate, maintain, manage, and improve the Website. This aggregate information does not identify you personally. We may share this aggregate data with our affiliates, agents, and business partners. We may also disclose aggregated user statistics in order to describe our products and services, and the Website to current and prospective business partners and to other third parties for other lawful purposes.
Onward Transfer to Third Parties
Opt-In to Certain Onward Transfers
We will not transfer your personal information to third parties acting as controllers who may use your personal information for a purpose that is materially different from the purpose(s) for which it was originally collected or subsequently authorized by you without first providing you with information regarding the identity of such controller or the nature of such controller’s business, and obtaining your opt-in consent. When we provide this information regarding requested disclosure, we will include instructions for how to grant consent.We will not disclose your sensitive personal information to any third party without first obtaining your opt-in consent. When we provide this information regarding requested disclosure, we will include instructions for how to grant consent. In each instance, please allow us a reasonable time to process your response.
Related Entities; Business Transfers
We may share your personal information with any of our parent companies, subsidiaries, joint ventures, or other companies under common control with us for aggregation, analysis and benchmarking purposes.
Disclosure to Public Authorities
We are required to disclose the information that we have collected in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements. We may also disclose personal information to other third parties when compelled to do so by government authorities or required by law or regulation including, but not limited to, in response to court orders and subpoenas.
Opt-out for Direct Marketing
You may opt out at any time from the use of your personal information for direct marketing purposes by clicking here www.networkadvertising.org or by contacting us at email@example.com. Please allow us a reasonable time to process your request.
Access to Personal Information; Communication Preferences
Retention of Personal Information
How We Protect Your Information
We take commercially reasonable steps to protect your information from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in processing and the nature of such data, and compliance with applicable laws and regulations. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the information you supply will not be intercepted while being transmitted to and from us over the Internet. In particular, e-mails or messages sent to or from the Website may not be secure, and you should therefore take special care in deciding what information you send to us via those means.
Important Notice to All Non-U.S. Residents
Our servers are located in the U.S. If you are located outside of the U.S., please be aware that any information provided to us, including personal information, will be transferred from your country of origin to the U.S. Except in the case of data transfers under the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework, your decision to provide such data to us, or allow us to collect such data through our Website and our media brand’s/publisher’s website, constitutes your consent to this data transfer.
Important Notice For Residents of the European Economic Area and Switzerland
Sonobi has further committed to refer unresolved privacy complaints under the EU-U.S. and the Swiss-U.S. Privacy Shield Principles to BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by Sonobi, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint. If these processes do not result in a resolution, you may also contact your local data protection authority, the U.S. Department of Commerce, and/or the Federal Trade Commission for assistance. If your complaint still remains unresolved, then you have the right to invoke binding arbitration by the Privacy Shield Panel upon written notice to Sonobi at firstname.lastname@example.org.
Under California Civil Code Section 1798.83, California residents who have an established business relationship with Sonobi may choose to opt out of our sharing your Personal Information with third parties for direct marketing purposes. If you are a California resident and (1) you wish to opt out; or (2) you wish to request certain information regarding our disclosure of your Personal Information to third parties for the direct marketing purposes, please send an e-mail to email@example.com or write to us at:
915 Broadway, Suite 1802
New York, NY 10010
In addition, Sonobi does not monitor, recognize, or honor any opt-out or do not track mechanisms, including general web browser “Do Not Track” settings and/or signals.
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