Trust Center

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.

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:

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:

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.

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.

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.