Privacy Policy • Sonobi

Privacy Policy

Last Updated: June 8, 2023

OVERVIEW

Who we are
We are Sonobi, Inc., an independent technology company serving both media brands/publishers and advertisers/agencies. We are a Delaware corporation, having an address at 444 W New England Avenue, Suite 220 Winter Park, FL 32789. All references in this Privacy Policy to “Sonobi,” “our,“ “us,” or “we,” refer to Sonobi, Inc. All references in this privacy policy (“Privacy Policy”) to “our website” means the website operated by Sonobi located at: www.sonobi.com (the “Site”).

Our values and the purpose of this Privacy Policy

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.

In line with these values, this Privacy Policy describes how we may collect information about you when you visit our Site, or the websites, mobile apps, and other internet connected digital media properties of our media brand/publisher clients (each, a “Client Digital Property”), or click on an advertisement from our advertising/agency clients (each, a “Client Advertisement”), purchase our Services, or otherwise communicate or interact with us in person or electronically. By visiting our Site, purchasing our using our Services, or otherwise interacting with us online or offline, you are agreeing to the terms of this Privacy Policy.

Who this Privacy Policy applies to

This Privacy Policy applies to (1) personnel at media brand/publisher clients, advertiser/agency clients, or other clients (together with media brands/publishers and advertisers/agencies, our “Clients”) that purchase access to our Jetstream Publisher Suite, Jetstream Agency Suite or other services we may offer from time to time (collectively, the “Services”), (2) visitors to our Site, (3) individuals who contact us with inquiries or requests, (4) our vendors, suppliers and service providers and their personnel, and (5) end users who are served advertisements on a Client Digital Property or Client Advertisements through our Services (collectively, “End Users”). Depending on our relationship, we may collect, receive, and/or use your information in different ways.

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.

Server Logs

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).

Cookies

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 1^st and 3^rd-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:

Type	Description	Managing Settings
Required Cookies – Strictly Necessary	These are required cookies that enable you to navigate the Website and use 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: Google Chrome Safari Mozilla Firefox Internet Explorer
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

We may use one or more third–party analytics services to evaluate your use of the Site and Services, as the case may be, by compiling reports on activity (based on their collection of IP addresses, Internet service provider, browser type, operating system and language, referring and exit pages and URLs, data and time, amount of time spent on particular pages, what sections of the Site and Services you visit, number of links clicked, search terms and other similar usage data) and analyzing performance metrics. These third parties may use cookies and other technologies to help collect, analyze, and provide us reports or other data.

By accessing and using the Site and purchasing our Services, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy. For more information on these third parties, including how to opt out from certain data collection, please visit their respective sites. Please be advised that if you opt out of any such service, you may not be able to use the full functionality of the Site and Services.

Third Party Advertisers/Remarketers

We may share or receive information about you with/from third parties, including, but not limited to, advertising and remarketing providers, or similar partners, for purposes of personalizing or otherwise understanding how you engage with ads or other content. These third parties may use cookies, pixel tags, or other technologies to collect information in furtherance of such purposes, including to tailor, target (i.e., behavioral, contextual, retargeting, and remarketing), analyze, report on, and/or manage advertising campaigns or other initiatives. For example, when a browser visits a site, pixel tags enable us and these third-parties to recognize certain cookies stored within the browser to learn which ads or other content bring a user to a given site. Information that we may receive from these third parties, including through their service providers, may include advertising identifiers, IP addresses, reports, and campaign data. By accessing and using the Site or purchasing our Services, you consent to the processing of data about you by these advertisers/remarketing providers in the manner and for the purposes set out in this Privacy Policy. If you are an End User, please see the ONWARD TRANSFER TO THIRD PARTIES section of this Privacy Policy for more about what our Clients’ third party vendors, which include third party advertisers/remarketers, collect about you through the Services and how we work with them.

Geolocation Information

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.

Device 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.

Geolocation Information

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.

Advertisement Engagement

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.

Connected TV

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 requested Services and communicate about our offerings;
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

We keep your personal information for no longer than necessary for the purposes for which the personal information is collected and processed, and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights. Typically, we retain your personal information for a period of 4 years. If your personal information is used for ad targeting purposes and is based on cookies, we will typically retain your personal information in a form that identifies you for no more than 30 days. At all times your personal information is subject to the protections set forth in this Privacy Policy. After the applicable time periods expire, we may either delete your personal information or retain it in a form such that it does not identify you personally.

You have the right to access, modify, or delete your personal information. If you have any questions or concerns about our Privacy Policy or the handling of your data, please contact us.

ONWARD TRANSFER TO THIRD PARTIES

Clients

If you are an End User that interacts with a Client Digital Property or a Client Advertisement, through our Services we may share your personal information with our Clients and, pursuant to our Clients’ instructions, with their third party vendors, for the purpose of tailoring, analyzing, managing, reporting, optimizing and otherwise engaging in interest-based advertising on their Client Digital Property or in connection with a Client Advertisement. When you interact with a Client Digital Property or a Client Advertisement, our Client may allow its third party vendors, which include third party advertisers/remarketers, to access your device and collect the information described in the ADDITIONAL INFORMATION FROM END USERS section of this Privacy Policy. Sonobi does not decide which of these third party vendors may receive your personal information. While we obtain assurances from Clients with whom we share your information that they will comply with applicable laws, when Clients use and/or remove information from the Services, their use of that information is governed by their own privacy policies and applicable laws, rules or regulations.

Service Providers

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.

Affiliated Companies

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.

Aggregate Information

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.

Business Transfers

In the event of a merger, dissolution, reorganization or similar corporate event, or the sale of all or substantially all of our assets, we expect that the information that we have collected, including personal information, would be transferred to the surviving entity in a merger or the acquiring entity. All such transfers shall be subject to our commitments with respect to the privacy and confidentiality of such personal information as set forth in this Privacy Policy. This Privacy Policy shall be binding upon Sonobi and its legal successors in interest.

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.

YOUR CHOICES

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 privacy@analyticpartners.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

Web Browsers

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.

You can also opt out of interest-based advertising across websites through the Digital Advertising Alliance (DAA) centralized opt-out page at https://youradchoices.com/control.

Mobile Apps

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.

Sonobi adheres to the DAA Self-Regulatory Principles for Interest Based Advertising.

Geolocation Data

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

Sonobi takes very seriously the security and privacy of the personal information that it collects and/or receives pursuant to this Privacy Policy. Accordingly, we implement reasonable and appropriate industry-standard security measures to protect your personal 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 comply with applicable laws and regulations. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases or the databases of the third parties with which we may share your information (as permitted herein), nor can we guarantee that the information you supply will not be intercepted while being transmitted over the Internet. In particular, e-mail sent to us may not be secure, and you should, therefore, take special care in deciding what information you send to us via e-mail.

CHILDREN

We do not knowingly collect personal information from children under the age of 16 through the Site or Services. If you are under 16, please do not give us any personal information. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children to never provide personal information without their permission. If you have reason to believe that a child under the age of 16 has provided personal information to us, please contact us at privacy@sonobi.com, and we will endeavor to delete that information from our databases.

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 support@sonobi.com 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.

LINKS TO EXTERNAL WEBSITES

The Site and Services may contain links to third-party websites (“External Sites”). Sonobi has no control over the privacy practices or the content of any such External Sites. As such, we are not responsible for the content or the privacy policies of such External Sites. You should check the applicable privacy policy and terms of use when visiting any such External Sites.

GOOGLE ADVERTISING

The Company may work with Google to deliver the best advertising opportunities to its Clients. Traffic Clients and other data subjects can consult Google’s policies to learn more about Google’s processing policies. In particular, Google may use remarketing tags (please visit How Google uses information from sites or apps that use our services to learn more about the third parties Google works with) and other advertising cookies.

FEEDBACK

We are always looking to improve the information we provide to our Clients, Site visitors and other contacts so if you have any feedback on this Privacy Policy, let us know by emailing us at privacy@sonobi.com.

CHANGES TO THIS PRIVACY POLICY

This Privacy Policy is effective as of the last updated date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time with or without notice to you. By accessing the Site or Services after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please be aware that, to the extent permitted by applicable law, our use of the information collected is governed by the Privacy Policy in effect at the time we collect the information. Please refer back to this Privacy Policy on a regular basis.

HOW TO CONTACT US

If you have questions about this Privacy Policy, please e-mail us at privacy@sonobi.com with “Privacy Policy” in the subject line, or contact us at the address below:

Sonobi, Inc.

444 West New England Ave.

Suite 220

Winter Park, Florida 32789

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