Sharethrough Consumer Privacy Notice

Last Modified: August 10, 2022

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Contents

1. Introduction2. Data Controller, Data Protection Officer, and Representative3. Children Under the Age of 134. Information We Collect About You and How We Collect It5. Lawful Basis for Processing Your Personal Data6. Special Categories of Information7. Lawful Basis for Processing Your Personal Data8. How We Use Your Information9. Disclosure of Your Information10. Choices About How We Use and Disclose Your Information11. Your Rights Regarding Your Information12. Jurisdiction-Specific Privacy Rights13. Data Security14. Consent to Processing of Personal Data in Other Countries Outside of Your Home Country15. Data Retention Periods16. Changes to Our Privacy Notice17. Contact Information18. Sharethrough Consumer Privacy Notice Addendum for California Residents

1. Introduction

This Privacy Notice describes how Sharethrough collects and uses Personal Data about you when third-party websites and mobile applications use our advertising platform. 

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2. Data Controller, Data Protection Officer, and Representative

Sharethrough is the data controller of your Personal Data that we collect and process through the Advertising Platform as a result of your interaction with Advertisements. Sharethrough has appointed a Data Protection Officer and a representative in the European Union in compliance with the General Data Protection Regulation. 

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3. Children Under the Age of 13

Our Advertising Platform may collect information from a child under 13 as a result of a child’s interaction with some Partner Sites. We do not control these Partner Sites, and the operators of those Partner Sites are solely responsible for obtaining any required parental consents and for all other compliance with law related to the collection and use of information from children under the age of 13.

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4. Information We Collect About You and How We Collect It

We collect several types of information from consumers who interact with Advertising on Partner Sites. The information that we collect as part of our service offering to advertisers and the operators of Partner Sites using the Advertising Platform to buy and sell advertising space may be considered “personal information” or “personal data” under the laws of Canada (PIPEDA), Quebec (Privacy Act), Europe (GDPR), or California (CCPA). 

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5. Lawful Basis for Processing Your Personal Data

You may have certain rights under applicable data protection laws, including the right to access and update your Personal Data, restrict how it is used, transfer certain Personal Data to another controller, withdraw your consent at any time, and the right to have us erase certain Personal Data about you, however, we generally provide these rights to visitors of our Websites, regardless of jurisdiction. Where applicable data protection law provides for a supervisory authority or other similar regulator, you also have the right to complain to such entity about our processing of your Personal Data. 

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6. Special Categories of Information

We generally do not request you provide and do not process any special categories of Personal Data. If you did provide this information, we do not show you Advertisements based on these special categories. 

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7. Automated Decision Making

We generally do not use your Personal Data with any automated decision making processes that may significantly affect you. 

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8. How We Use Your Information

We use your Personal Data for various purposes described below, including to:

  • Show you Advertisements that are relevant to your interests; and
  • Measure your interaction with Advertisements for billing and collection purposes with advertisers and publishers. 
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9. Disclosure of Your Information

We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Notice. We disclose your Personal Data to a few third parties, including:

  • Our subsidiaries and our affiliates;
  • Our third-party service providers that we use to support our business;
  • To a company we merge, acquire, or that buys us, or in the event of change in structure of our company of any form; 
  • To comply with our legal obligations;
  • To enforce our rights; and
  • With your consent.
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10. Choices About How We Use and Disclose Your Information

We offer you choices on how you can opt out of our use of tracking technology, disclosure of your Personal Data for third-parties to advertise to you, our advertising to you, and other targeted advertising. 

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11. Your Rights Regarding Your Information

You may have certain rights under applicable data protection laws, including the right to access and update your Personal Data, restrict how it is used, transfer certain Personal Data to another controller, withdraw your consent at any time, and the right to have us erase certain Personal Data about you. You also have the right to complain to a supervisory authority about our processing of your Personal Data. 

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12. Jurisdiction-Specific Privacy Rights

The law in certain jurisdictions may provide their residents with additional rights regarding our use of your Personal Information.

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13. Data Security

Information transmitted over the Internet is not completely secure, but we do our best to protect your Personal Data. You can help protect your Personal Data and other information by keeping your password to our Websites confidential. 

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14. Consent to Processing of Personal Data in Other Countries Outside of Your Home Country

We may process your Personal Data outside of your home country, including to the United States. We only do this when we are legally permitted to do so and when we have appropriate safeguards in place to protect your Personal Data. 

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15. Data Retention Periods

We retain your Personal Data only for long as necessary to provide you with relevant Advertisements. In some instances, we may keep it longer, for example we may keep it:

  • on our backup and disaster recovery systems;
  • for as long as necessary to protect our legal interests; and
  • and to comply with other legal requirements.
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16. Changes to Our Privacy Notice

We will post any changes to our Privacy Notice on our website. If we make material changes to our Privacy Notice, we will ask the operators of the Partner Sites to notify you and obtain any necessary consents. 

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17. Contact Information

You may contact us through the contact information below. 

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18. Sharethrough Consumer Privacy Notice Addendum for California Residents

Effective Date: May 4, 2021

Last Reviewed on: January 17, 2022

This Consumer Privacy Notice Addendum for California Residents (the “California Consumer Privacy Addendum”) supplements the information contained in Sharethrough’s Consumer Privacy Notice (the “Consumer Privacy Notice”) and describes our collection and use of Personal Information collected as a result of your interaction with Advertising on Partner Sites. This California Consumer Privacy Addendum applies solely to all such consumers who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this notice. 

Note that this California Consumer Privacy Addendum does not apply employment-related personal information collected from our California-based employees, job applicants, contractors, or similar individuals. Please contact your local human resources department if you are a California employee and would like additional information about how we process your Personal Information.

Where noted, this California Consumer Privacy Addendum also does not apply to personal information reflecting a written or verbal business-to-business communication (“B2B Personal Information”). If you are an advertiser or publisher that uses our Advertising Platform, please see our Advertising Platform Privacy Notice for more information on how we collect and use your personal information.

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