SOVA Systems

            Privacy Statement

            Last updated December 30, 2017

            SOVA cares about your privacy

            SOVA Systems and its subsidiaries (sometimes referred to herein as SOVA or SOVA Systems) are committed to protecting the privacy of individuals who visit SOVA’s websites and interact with SOVA online (“Visitors”), individuals who register to use the Services as defined below (“Customers”), This Privacy Statement describes SOVA’s privacy practices in relation to the use of SOVA’s websites and the related products, applications and services (including support and education) offered by SOVA (the “Services”).

            You should also note that SOVA maintains the same privacy practices with respect to data that is collected off-line and this statement may be relied upon with respect to those methods of data collection and use.

            SOVA may modify or update this privacy statement at any time without prior notice. You can check the “Last Updated” date above to see when the statement was last changed. Your continued use of the website and/or the Services constitutes your consent to the contents of this Privacy Statement.

            Q1: What personal information does SOVA collect or maintain?

            In general, as a Visitor you will not need to identify yourself or reveal any personal information. However, SOVA does collect domain information from your visit to customize and improve your experience on our websites. The type of information SOVA may collect includes:
            • the date and time of your access
            • the pages you have accessed
            • the name of the Internet Service Provider and the Internet Protocol (IP) address that you use to access the Internet
            There are times when SOVA may collect personal information from you as a Visitor or Customer. This may include your name, email address, phone number and other contact information. In some cases SOVA may request additional information in which case you may receive a separate privacy statement at that time. Some of the ways in which SOVA may collect information from you are:
            • Registrations for webcasts, seminars, conferences, etc. sponsored by SOVA or a partner
            • Product support registration (for employee and/or customer log-ins)
            • Registering for courses or education
            • Requesting information regarding a lost and found item
            • Subscription to newsletters or other SOVA content-related materials
            • Services, purchases or trials (either on your own or on behalf of your company)
            • White paper or other downloads
            • Sweepstakes or contests

            Q2: How does SOVA use your information?

            SOVA uses the information collected to operate our websites, to provide you with the Services requested and to contact you about your interest in the Services, to verify your information, and to plan and host online forums and social networks. SOVA may also aggregate your information with data that is separately provided by you on social media and third party websites if visible to third parties. SOVA may also use data from Visitors and Customers for marketing purposes. For example, SOVA may use information you provide to contact you to further discuss your interest in the Services and to send you information regarding SOVA, its affiliates, and its partners, such as information about promotions or events.

            When SOVA collects information about you, such as your name or other details, it is SOVA’s practice to provide you with information on how the data will be used at the time you are asked for it if that is not immediately apparent. When SOVA asks you to provide your information through a registration page or otherwise, you will have the option of not doing so, in which case you may still be able to access other portions of this website, although you may not be able to access certain programs or services.

            See Question 7 “What other rights do you have in connection with the personal data SOVA collects?” for information on your rights, including rights to “opt out” of certain uses of your information.

            Some SOVA products or services use the Google Maps APIs and SOVA therefore incorporates by reference the Google privacy policy located at http://www.google.com/privacy.html, as amended by Google from time to time.

            SOVA’s Support Policy may include additional terms related to the collection of personal or confidential data provided as part of the provision of customer support.

            Q3: How does SOVA address data transfers from the European Economic Area (EEA)?

            Because SOVA is a global company that operates in different countries around the world, it’s important that we comply with data privacy laws in many jurisdictions. SOVA operates in the EEA (the EEA is an area made up of European Union Member States and other countries in Europe who adhere to similar rules). In order for SOVA to do business, SOVA customers in the EEA need to send personal data to SOVA Systems, a US based company. SOVA is generally a data processor when your company provides SOVA with access to personal data originating from your company, e.g., a file for product support or other Services, or data in a SaaS environment.

            Privacy Shield (SOVA as Processor)

            Where SOVA acts as a data processor, SOVA Systems and its U.S. subsidiaries, and all entities using the brand name SOVA Systems, comply with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States, respectively. SOVA has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the policies in this Privacy Statement and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view SOVA’s certification page, please visit https://www.privacyshield.gov/.

            Personal data covered by the Privacy Shield Framework may be provided to a third party as described in Q4 below. SOVA is accountable for personal data that it receives under the Privacy Shield Framework and transfers to a third party as set forth in the Privacy Shield Principles. SOVA remains liable under the Privacy Shield Principles if third-parties engaged to process personal data on its behalf do so in a manner inconsistent with the Privacy Shield Principles, unless SOVA proves that it is not responsible for the event(s) giving rise to the damage.
             
            Note that compliance by SOVA with the Privacy Shield Principles will be administered and monitored by the Department of Commerce and will be enforced by the Federal Trade Commission (FTC).

            If you have a complaint about SOVA’s use of your data under the Privacy Shield Framework, see Q11 “What should you do if you have a question or a complaint regarding how SOVA is handling your personal data?” for information on what to do.

            SOVA’s participation in the Privacy Shield Framework applies to all personal data that it receives from the European Union and Switzerland which is processed by SOVA as a data processor. It excludes HR data.

            Q4: How does SOVA share your information?

            SOVA may share your personal data with third-parties for the purposes described below. For example, your data may be shared with companies SOVA has hired to provide support or services relating to SOVA products or to assist SOVA in protecting its systems.

            SOVA Subsidiaries
             
            SOVA may share data about Visitors and Customers with other companies in order to work with them, including subsidiaries or SOVA Systems. For example, SOVA may need to share data about Visitors to help improve our website or share data about Customers for customer relationship management purposes.

            Suppliers

            SOVA Systems may share data about Visitors and Customers with SOVA’s contracted suppliers so that these suppliers can provide services on SOVA’s behalf, this may include those who are performing customer support and cloud service providers such as storage providers. In addition and not limiting the foregoing, SOVA may also share data about Visitors and Customers with SOVA’s suppliers to ensure the quality of information provided, and with third-party social networking and media websites, such as LinkedIn and Facebook, for marketing and advertising on those websites. Unless described in this Privacy Statement, SOVA does not share, sell, rent, or trade any information with third-parties for their promotional purposes.

            SOVA maintains contracts with these companies that require them to abide by our data privacy and security provisions and such companies are not allowed to use the personal data they receive from SOVA for any other purpose.

            Business Partners

            SOVA may use partners (including without limitation resellers and managed service providers) to offer its Services and may also jointly host corporate meetings and events with partners. SOVA may share data about Customers collected in connection with your purchase with SOVA where a partner is used. SOVA does not control its business partners’ use of the data about Customers collected, and their use of the information will be in accordance with their own privacy policies. If you do not wish for your information to be shared in this manner, you may opt not to purchase using a partner.

            SOVA may also disclose data to its business partners for marketing and other purposes which SOVA believes may be beneficial to you.

            Third Party Advertising

            Q8 and Q9 of this Privacy Statement specifically address the use of third parties to advertise and third party links.

            Disclosure

            SOVA may disclose information it has collected about you if required or advisable to do so under law, pursuant to lawful requests by public authorities, including for national security or law enforcement requirements, or when SOVA believes it is reasonably necessary in order to protect the rights of SOVA or its employees or to comply with a judicial proceeding or process.

            Q5: What are SOVA’s security levels for your data?

            SOVA’s intent is to strictly protect the security of your personal information; honor your choice for its intended use; and carefully protect your data from loss, misuse, unauthorized access or disclosure, alteration, or destruction. SOVA has taken appropriate steps to safeguard and secure information we collect, including the use of encryption when collecting or transferring sensitive data such as credit card information. However, you should always take into consideration that the internet is an open forum and that data may flow across networks with little or no security measures, and therefore such information may be accessed by people other than those you intended to access it.

            Q6: Can you update the information you provide to SOVA?

            You are entitled to know whether SOVA holds information about you and, if we do (subject to certain limitations), to have access to that information, have it corrected if it is inaccurate or out of date, or ask SOVA to delete it, if appropriate. Contact SOVA at privacy@sovasystems.com for any questions or to update your information.

            Q7: What other rights do you have in connection with the personal data SOVA collects?

            SOVA offers Visitors and Customers a means to choose how SOVA uses the personal data they provide. You may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located at the bottom of SOVA marketing and Customer notification emails. Additionally, you may send a request to privacy@sovasystems.com.

            Q8: What about other 3rd party links?

            This website contains links to other websites. SOVA is not responsible for the privacy practices or the content of such websites and their use of the information will be in accordance with their own privacy policies.

            Q9: What are SOVA’s practices regarding cookies and web beacons?

            A “cookie” is a small amount of data transferred to your browser and read by the web server that placed it there. It records your preferences and information you entered. By using cookies, the information you previously provided can be retrieved on your next visit to the website so that your use of the website is more efficient. Cookies are uniquely assigned to you and can only be read by a web server in the domain that issued the cookie.

            Web beacons may be used to deliver the cookie and to compile statistics about our website, such as how many people visited a particular page or clicked on certain links or to ensure the integrity of the registration process. While your particular use of the site will not be revealed and no personally identifying information will be collected, this information may be used, in an anonymous fashion, for preference marketing purposes, and SOVA’s third party advertising companies may use the information about your visit to the website(s) in order to provide advertisements about goods and services of interest to you, or to measure and improve the effectiveness of ads for their clients. This information can include: date/time of banner ad shown, related cookie, and the first three octets of the IP address. SOVA may share aggregated statistics about the use of the website with third parties.

            Cookies are either session-based (which disappear after you close your browser) or persistent (which remain on your computer after you close your browser or turn off your computer).

            Most browsers allow you to manage cookie preferences. If you choose to decline cookies, you may not be able to get the benefit of some of the features of this website or other websites that you visit.

            The following chart describes the types of cookies you may find on the SOVA website and your options for managing them.

            Types of Cookies
            Description
            Settings
            Required cookies

            Required cookies enable you to navigate SOVA’s websites and use its features, such as accessing secure areas of the websites and using SOVA Services.

            If you have chosen to identify yourself to SOVA, SOVA uses cookies containing encrypted information to allow SOVA to uniquely identify you. Each time you log into the Services, a cookie containing an encrypted, unique identifier that is tied to your account is placed on your browser. These cookies allow SOVA to uniquely identify you when you are logged into the Services and to process your online transactions and requests.

             

            Because required cookies are essential to operate SOVA’s websites and the Services, there is no option to opt-out of these cookies.
            Performance cookies

            These cookies collect information about how Visitors use SOVA’s website, including which pages visitors go to most often and if they receive error messages from certain pages. These cookies do not collect information that individually identifies a Visitor. All information these cookies collect is aggregated and anonymous. It is only used to improve how SOVA’s website functions and performs.

            From time to time, SOVA engages third parties to track and analyze usage and volume statistical information from individuals who visit SOVA’s websites. SOVA may also utilize Flash cookies for these purposes.

            To learn how to opt out of performance cookies using your browser settings click here.

            To learn how to manage privacy and storage settings for Flash cookies click here.

            Functionality cookies

            Functionality cookies allow SOVA’s websites to remember information you have entered or choices you make (such as your username, language, or your region) and provide more enhanced, more personal features. These cookies also enable you to optimize your use of SOVA’s Services after logging in. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize.

            SOVA uses local shared objects, also known as Flash cookies, to store your preferences or display content based upon what you view on SOVA’s websites to personalize your visit.

            To learn how to opt out of functionality cookies using your browser settings click here.

            Note that opting out may impact the functionality you receive when SOVA’s websites.

            To learn how to manage privacy and storage settings for Flash cookies click here.

            Targeting or Advertising cookies

            SOVA may engage third parties to track and analyze usage and volume statistical information from individuals who visit SOVA’s websites. SOVA sometimes uses cookies delivered by third parties to track the performance of SOVA advertisements, such as Google Analytics (click here for more information on how Google uses data). For example, these cookies remember which browsers have visited SOVA’s websites. The information provided to third parties does not include personal information, but this information may be re-associated with personal information after SOVA receives it.

            SOVA also contracts with third party advertising networks that collect IP addresses and other information from Web beacons (see below) on SOVA’s websites, from emails, and on third party websites. Ad networks follow your online activities over time and across different sites or other online services by collecting Web Site Navigational Information through automated means, including through the use of cookies. These technologies may recognize you across the different devices you use, such as a desktop or laptop computer, smartphone or tablet. Third parties use this information to provide advertisements about products and services tailored to your interests. You may see these advertisements on other websites or mobile applications on any of your devices. This process also helps SOVA manage and track the effectiveness of its marketing efforts. Third parties, with whom SOVA partners to provide certain features on its websites or to display advertising based upon your Web browsing activity, use Flash cookies to collect and store information. Flash cookies are different from browser cookies because of the amount of, type of, and how data is stored.

            To learn more about these and other advertising networks and their opt out instructions, click here and here.

            To learn how to manage privacy and storage settings for Flash cookies click here.


            Web Beacons

            SOVA uses Web beacons alone or in conjunction with cookies to compile information about Customers and Visitors’ usage of SOVA’s websites and interaction with emails from SOVA. Web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular website tied to the Web beacon, and a description of a website tied to the Web beacon. For example, SOVA may place Web beacons in marketing emails that notify SOVA when you click on a link in the email that directs you to one of SOVA’s websites. SOVA uses Web beacons to operate and improve SOVA’s websites and email communications.

            IP Addresses

            When you visit SOVA’s websites, SOVA collects your Internet Protocol (“IP”) addresses to track and aggregate information. For example, SOVA uses IP addresses to monitor the regions from which Customers and Visitors navigate SOVA’s websites. SOVA also collects IP addresses from Customers when they log into the Services as part of SOVA’s “Identity Confirmation” and “IP Range Restrictions” security features.

            Do Not Track

            Certain browsers like Internet Explorer, Firefox and Safari offer a “do not track” or “DNT” option that relies on a technology known as a DNT header, which sends a signal to websites’ visited by the user about the user’s browser DNT preference setting. SOVA does not currently commit to responding to browsers’ DNT signals with respect to SOVA’s websites, in part, because no common industry standard for DNT has been adopted by industry groups, technology companies or regulators, including no consistent standard of interpreting user intent. SOVA takes privacy and meaningful choice seriously and will make efforts to continue to monitor developments around DNT browser technology and the implementation of a standard.

            Q10: What if you post on SOVA's social media pages?

            Portions of this website make chat rooms, forums, blogs, message boards, and/or news groups available to Visitors. Please remember that any information that is disclosed in these areas could be made public so exercise caution when deciding to disclose any personal information.

            Use of these portions of our website may be subject to additional terms. Additional information about support sites can be found at our Terms for User Sites on support.sovasystems.com.

            In addition, SOVA’s websites may use social media functionality like the Facebook “like” button which may collect your IP address and which page you are visiting on SOVA’s website, and may set a cookie to enable the feature to function properly. You may be given the option by that social media site to post information about your activities on SOVA’s websites to your profile page on that social media site. Your interactions with these features are governed by the privacy policy of the company that is providing them.

            Q11: What should you do if you have a question or complaint regarding how SOVA is handling your personal data?

            If you have any questions, concerns, or comments about our privacy statement or practices, please contact SOVA via email at privacy@sovasystems.com with the words “PRIVACY POLICY” in the subject line. All emails will be read promptly and we endeavor to provide an initial response to the sender within 5-7 business days indicating the complaint will be investigated.

            You may also reach out by regular mail to:

            SOVA Systems
            PO Box 600063
            San Diego, CA  92160

            To the extent you have a question, request, inquiry or complaint regarding personal data for which SOVA acts as a data processor (which may include information provided to SOVA by your company or other third party), SOVA may have to reach out to our corporate customers in order to comply with requests relating to the handling of such personal data. For these reasons, we ask that if you wish to request access, to limit use, or to limit disclosure to such personal data, please provide the name of the SOVA customer who provided your data to SOVA. SOVA will then work with that customer to help ensure that your request is addressed.

            Privacy Shield Complaints

            In compliance with the EU-US and Swiss-US Privacy Shield Principles, SOVA commits to resolve complaints about your privacy and our collection or use of your personal information. European Union or Swiss individuals with inquiries or complaints regarding this Privacy Statement should first contact SOVA as set forth in the answer to Question 11 above. SOVA will provide an initial response to any Privacy Shield complaint within 45 days from the complaint. SOVA has further committed to refer unresolved Privacy Shield complaints under the EU-US and Swiss-US Privacy Shield Principles to the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgement of your complaint from SOVA, or if we have not addressed your complaint to your satisfaction, please contact or visit http://www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. The services of the BBB EU PRIVACY SHIELD are provided at no cost to you.

            If neither SOVA nor the Council of Better Business Bureaus resolves your complaint, you may have the possibility to engage in binding arbitration through the Privacy Shield Panel.

            All issues raised will be investigated until completion, and all matters will be handled in compliance with the Principles of Privacy Shield.
            Updated: 30 Dec 2017 11:37 AM
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