Sharethrough Website Privacy Notice

Last Modified: May 4, 2021

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Contents

1. Introduction2. Data Controller, Data Protection Officer, and Representative3. Children Under the Age of 184. 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 Information and Accessing and Correcting Your Information12. Jurisdiction Privacy Rights13. Do Not Track Signals14. Data Security15. Consent to Processing of Personal Data in Other Countries Outside of Your Home Country16. Data Retention Periods17. Changes to Our Privacy Notice18. Contact Information

1. Introduction

This Privacy Notice describes how Sharethrough collects and uses Personal Data about you through the use of our Website, and through email, text, and other electronic communications between you and Sharethrough. 

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2. Data Controller, Data Protection Officer, and Representative

Sharethrough is the data controller of the Personal Data you provide on the Websites. Sharethrough has appointed a Data Protection Officer (DPO) and a representative in the European Union.  

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3. Children Under the Age of 18

Our Websites are not intended for children under the age of 18 and children under the age of 18 are not permitted to use our Websites. We will remove any information about a child under the age of 18 if we become aware of it.  

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

We collect different types of information about you, including information that may directly identify you, information that is about you but individually does not personally identify you, and information that we combine with our other users. This includes information that we collect directly from you or through automated collection technologies. 

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5. Lawful Basis for Processing Your Personal Data

We have a lawful basis for our processing of your Personal Data, including processing for our legitimate interests (when balanced against your rights and freedoms), and required by law, and with your consent. 

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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.

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7. Automated Decision Making

We generally do not use your Personal Data collected on our through our Websites with any automated decision making processes. 

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8. How We Use Your Information

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

  • provide our Websites to you;
  • provide you with information you request from us;
  • enforce our rights arising from contracts;
  • notify you about changes; and
  • protect and improve our Websites. 
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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, our advertising to you, and other targeted advertising. 

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11. Your Rights Regarding Your Information and Accessing and Correcting 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, 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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12. Jurisdiction Privacy Rights

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

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13. Do Not Track Signals

We may use automated data collection technologies to track you across websites. We currently do not honor do-not-track signals that may be sent by some browsers.

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14. Data Security

Information transmitted over the Internet is not completely secure, but we do our best to protect your Personal Data. 

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15. 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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16. Data Retention Periods

We retain your Personal Data no longer than one (1) year after your last contact with us. In some instances, we may keep it after you close your account, 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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17. Changes to Our Privacy Notice

We will post any changes to our Privacy Notice on our Websites. If we make material changes to our Privacy Notice, we may notify you of such changes through your contact information and invite you to review (and accept, if necessary) the changes. 

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18. Contact Information

You may contact us through the contact information below. 

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19. Sharethrough Consumer Privacy Notice Addendum for California Residents

Effective Date: May 4, 2021

Last Reviewed on: January 17, 2022

This Website Privacy Notice Addendum for California Residents (the “California Privacy Addendum”) supplements the information contained in Sharethrough’s Website Privacy Notice (the “Website Privacy Notice”) and describes our collection and use of Personal Information on our Website. This California Privacy Addendum applies solely to all Website users 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. 

This California Privacy Addendum does not apply to any information we may collect through the use of cookies or otherwise as part of delivering targeted advertising on our customer’s websites. Our privacy practices with respect to such personal information is governed by our Behavioral Advertising Privacy Notice. 

Note that this California 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 Privacy Addendum also does not apply to personal information reflecting a written or verbal business-to-business communication (“B2B Personal Information”). Unless otherwise noted, this exemption will expire on January 1, 2023. In particular, this California Privacy Addendum does not apply to the use of Sharethrough’s products and services by publishers and advertisers.

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