Last Updated: May 20, 2020
Who we are
We value your privacy and want to be accountable and fair to you as well as transparent with you in the way that we collect and use your personal information. We also want you to know your rights in relation to your information.
THE INFORMATION WE COLLECT
In the course of operating the Site and providing our Services, Sonobi may collect and/or receive the following types of information.
Contact and other Personal Information
We collect contact information on our Site and through our Services; contact information typically includes your name, mailing address, email address, company, job title, phone number, date of birth, username and password, online account authentication details and any information you provide in messages and forms to us.
Like most websites today, the web servers for our Site keep log files that record data each time a device accesses those servers. The log files contain data about the nature of such access, including the device’s IP address, user agent string (e.g., operating system and browser type/version), and referral URL (i.e., the external source by which you arrived at our Site, or the pages you’ve clicked on while on our Site).
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 (or other storage medium) so that your computer or mobile device will “remember” information about your visit. We use both 1st and 3rd-party session cookies and persistent cookies. Below is a general primer on session and persistent cookies; information collected by cookies depends on its particular purpose. Also, please see the information regarding analytics providers discussed further below.
- Session Cookies: We use session cookies to make it easier for you to navigate our Site and Services. A session ID cookie expires when you close your browser.
- Persistent Cookies: A persistent cookie remains on your hard drive for an extended period of time or until you delete them. You can remove persistent cookies by following directions provided in your web browser’s “help” file. To the extent we provide a log-in portal or related feature on our Services, persistent cookies can be used to store your passwords so that you don’t have to enter it more than once. Persistent cookies also enable us to track and target the interests of our visitors to personalize the experience on our Site and Services.
The table below sets out how we use different categories of cookies and similar technologies and your options for managing the setting for these:
|Required Cookies – Strictly Necessary||These are required cookies that enable you to navigate the Website and sue its features.||There is no option to opt out of these cookies.|
|Functional Cookies – Not Strictly Necessary||Functional cookies allow us to remember information you have submitted or choices you have made and provide you with a more enhanced and personal experience.||To manage the use of functional cookies, please consult your browser settings. Opting out may impact the functionality you receive when using our Website. To adjust individual browser cookie settings, you make you may visit these pages:|
|Targeting or Advertising Cookies – Not Strictly Necessary||These tools allow us to provide targeted advertising in the future.||To learn how to opt out of particular targeted advertising see Your Choices section below.|
If you decide not to accept cookies from us, certain aspects of the Site and Services may not function properly or as intended.
Third-Party Analytics Providers
Third Party Advertisers/Remarketers
With your consent, we may automatically collect precise geolocation information from your device via your browser’s location services. This consent may be provided by you on the device level (e.g., you have consented to location services generally through your browser’s settings) or by accepting our request for geolocation access on the Site or through the Services.
ADDITIONAL INFORMATION WE COLLECT FROM END USERS
When an End User interacts with a Client Digital Property or a Client Advertisement, in the course of providing our Services we may collect, directly and indirectly through third party advertisers/remarketers and our Clients, the following types of information:
Web Browser Information
Information about an End User’s browser including: the type of web browser an End User uses, browser language, browser settings, and browser plug-in types and version and other cookie and pixel tag (also called web beacons or clear gifs) information.
Information about an End User’s device including device operating system version, connection type, device make, device model, device identifiers such as your IDFA or AAID, and the IP address from which the device accesses a Client Digital Property or a Client Advertisement.
Precise geographic location information when location services have been enabled for a Client Digital Property on an End User’s device that sends that information to our Services.
Activity on Client Digital Property
Information about an End User’s activity on a Client Digital Property including web pages or apps visited or used and the time those web pages or apps were visited or used, web page or app interaction information (such as scrolling, clicks and mouse-over), the website you visited before and after engaging with a Client Digital Property or a Client Advertisement, the methods used to browse away from the Client Digital Property or Client Advertisement. We may also obtain your email address and Client issued identifiers from the Client Digital Property.
Information about Client Advertisements served, viewed or clicked on, including the type of advertisements, where the advertisement was served, whether an End User clicked on it and whether an End User visited the Client’s website or downloaded the Client’s app.
Information regarding the content and data viewed, and/or connected TV identifiers, as applicable, may be collected from an End User’s connected television for tailored advertising purposes.
Internet Service Information
Information about an End Users internet service including information about which internet service provider is used by the End User.
HOW WE USE THE INFORMATION WE COLLECT
We may use your information that we collect and/or receive, including personal information, to provide you with and improve our Site and Services, to provide our Services to our Clients, to process any requests made by you, communicate with you, or to identify and fix problems with the Site and the Services. We may also use your information that we collect and/or receive, including personal information, for the following purposes:
- To operate, maintain, manage, and improve the Site and the Services
- To enable your use of the Site and the Services;
- To advertise and market the Site and the Services, and to otherwise provide you with information about the Site and the Services;
- To respond to your inquiries or issues you have about our Site and Services;
- To send you email alerts (including marketing emails) about our Site and Services such as service announcements and administrative messages;
- To measure Site and Services usage;
- To develop new features, content and materials for the Site and the Services;
- To monitor and troubleshoot errors and incidents and provide you with support in connection with the Site and the Services;
- To optimize your experience with the Site and the Services including to recognize you when you return to our Site and to store information about your preferences;
- To enhance the security of our Site and Services;
- To prevent, detect and investigate any activities that are potentially prohibited, malicious, fraudulent, unlawful or contrary to good practice on our Site or through our Services;
- To analyze web traffic to the Site and through the Services;
- To provide Services to our Clients which may include:
- compiling statistics about the advertising transactions occurring through our Services,
- analyzing campaign forecasts and projections to assist clients in their advertising efforts, and
- analyzing and reporting on campaign and ad and/or ad inventory performance;
- permitting our Clients and their third party vendors, which include third party advertisers/remarketers, to use End User information to engage in interest-based advertising, including to create inferences and profiles about an End User’s interests and serve ads based on those interests, frequency capping, ad sequencing, geo-targeting; contextual or viewed content targeting, and cross-app and cross-device mapping and advertising;
- To enable us to receive and manage services from you (including supplier due diligence, payment, expense reporting and financial audits);
- To conduct background checks as required by applicable law;
- To investigate and manage inquiries, disputes and legal proceedings;
- To comply with court orders, mandatory dispute resolution determinations and mandatory government authority or law enforcement orders or directions;
- As described to you when collecting your information;
- To evaluate or consummate a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which your information, including personal information, is among the assets transferred.
RETENTION OF PERSONAL INFORMATION
ONWARD TRANSFER TO THIRD PARTIES
Like many businesses, we hire other companies to perform certain business-related services. We may disclose personal information to certain types of third party companies but only to the extent needed to enable them to provide such services. The types of companies that may receive personal information, and their functions, consist of the following: hosting services, technical assistance, database management/back-up services, use analytics (as described above in Third Party Analytics Providers), email marketing platforms, third party advertisers/remarketers (as described above under Third Party Advertisers/Remarketers) and customer service.
Promotional and Marketing Partners
In order to provide our Site and Services and administer promotional programs, we may share your personal information with our third-party promotional and marketing partners, including, without limitation, businesses participating in our various programs.
We may also disclose personal information to our parent companies, subsidiaries, affiliates, joint ventures, or other companies under common control in order to support marketing, sale and delivery of any services.
We may share aggregated information with our affiliates, agents, and business partners. We may also disclose aggregated user statistics in order to describe the Site and Services to current and prospective business partners and to other third parties for other lawful purposes.
Disclosure to Public Authorities
We are required to disclose personal information in response to lawful requests by public authorities, including lawful requests seeking information to meet 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 of Direct Marketing, E-mail Management
You may opt out at any time from the use of your personal information for direct marketing purposes by emailing the instructions to email@example.com or by clicking on the “Unsubscribe” link located on the bottom of any Sonobi marketing email and following the instructions found on the page to which the link takes you. Please allow us a reasonable time to process your request. You cannot opt out of receiving transactional e-mails related to the Site and Services.
Opt Out of Interest-Based Advertising
To opt out of (i) our use of cookie technology for interest-based targeting advertising based on your web browsing behavior on our Site or (ii) if you are an End User, having Clients use our Services to select ads for your browsers based on your online web browsing behavior, please visit the Network Advertising Initiative (NAI) centralized opt out page at www.optout.networkadvertising.org. You can also review your opt in status or learn more about interest-based advertising by visiting the NAI opt out page.
Mobile device system software, such as Apple iOS or Google Play Services, provide mechanisms that allow users to opt out of the use of information about their usage of mobile apps to deliver targeted ads to their mobile device. For more information, or to opt out of the use these mechanisms, consult your device settings (“Opt out of Personalized Ads” on Android devices and “Limit Ad Tracking” on iOS devices). You may also visit the NAI’s mobile choice opt-out page at www.networkadvertising.org/mobile-choice for the NAI’s mobile opt out instructions.
Most mobile devices offer you the ability to stop the collection of location information at any time by changing the preferences on your device. You may also be able to stop the collection of location information by particular apps by adjusting the settings for individual apps or following the standard uninstall process to remove specific mobile apps from your device. Note when location services have not been enabled in any of your apps, we can still infer data about your location based on your IP address.
Other Internet Connected Devices
Your internet-connected device(s) (e.g. a smart TV or a set-top box) may give you the ability to opt-out of the use of information for advertising purposes. To determine if your Internet-connected device has these options, please visit your device’s settings menu. You may also visit the NAI’s connected tv opt-out page at www.networkadvertising.org/internet-connected-tv-choices for the NAI’s tv opt out instructions. Sonobi applies industry opt out signals for connected televisions.
Internet Advertising Bureau
Sonobi participates in the IAB Europe Transparency & Consent Framework and complies with its Specifications and Policies. Sonobi’s identification number within the framework is 104.
HOW WE PROTECT YOUR INFORMATION
IMPORTANT NOTICE TO ALL NON-US RESIDENTS
Our servers are located in the US and elsewhere. Please be aware that your information may be transferred to, processed, maintained, and used on computers, servers, and systems located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your country of origin. If you are located outside the United States and choose to use the Site or Services, you do so at your own risk.
IMPORTANT NOTICE TO CALIFORNIA RESIDENTS
If you are a resident of California you have additional rights under the California Consumer Privacy Act (the “CCPA”) and other California laws. For more information about your rights under the CCPA and other California laws, please visit our Privacy Notice to California Residents.
IMPORTANT NOTICE TO NEVADA RESIDENTS
If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. You can exercise this right by contacting us at firstname.lastname@example.org with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A (“Chapter 603A”).
IMPORTANT NOTICES TO EUROPEAN ECONOMIC AREA RESIDENTS
If you are a resident of the European Economic Area, you have additional rights under the General Data Protection Regulation (“GDPR”). For more information about your rights under the GDPR, please visit our GDPR Notice. The term “European Economic Area” will have the meaning set forth in the GDPR Notice.
Privacy Shield Framework
Sonobi is 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 BBB National Programs. 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 email@example.com. Pursuant to the Privacy Shield, Sonobi remains liable for the transfer of personal data to third parties acting as our agents unless we can prove we were not a party to the events giving rise to the damages.
LINKS TO EXTERNAL WEBSITES
HOW TO CONTACT US
444 West New England Ave.
Winter Park, Florida 32789