SOVA Support

            Services Privacy Policy


            LAST UPDATED: February 22, 2019


            SOVA Systems and its affiliates (“ SOVA ” or “ we ”) want our customers (“ Customers ” or “ you ”) to be familiar with how we collect, use, share and store information relating to your use of our services and to end users who interact with our web app via our services (“ Users ”).

            This SOVA Services Privacy Policy (“ Privacy Policy ”) describes SOVA's practices regarding information collected by our online products and services, such as Notifications, or third party services such as ZenCoder, (collectively, “ SOVA Services ”). Any use of SOVA Services, including the authenticated web portal accessible through the SOVA website (including sovasystems.com, sova.cc, sub-domains and directories of these root domains), is covered by this Privacy Policy. Those aspects of the SOVA website that do not form a part of the SOVA Services are covered by the SOVA Website Privacy Policy.


            We do not have a direct relationship with Users. Information collected from Users on Customers’ web portals or on the SOVA mobile app is subject to our Customers’ privacy policies. Users who have questions or concerns about information collected when they access their company web portal via SOVA Services, or about content found there, should contact our Customer through the web portal or app on which the data is available. Users who are uncertain about whom to contact may contact us at privacy@sovasystems.com.

            Contents of this Privacy Policy:



            Information We May Collect

            Information Collected from Users. In connection with our provision of SOVA Services, we may collect certain information about Users authorized by Customers (such as a Customer’s employees) to use SOVA Services. Such information may include personal information, which is information that identifies an individual or relates to an identifiable person. Information that may be collected when accessing the web portal via SOVA Services includes:

            • Unique IDs such as IP addresses or device ID.
            • Profile image, User name, name, address, phone number, email address and title. Note that SOVA collects this information about Users only if a Customer elects to use certain features of SOVA Services (such as Notifications) that are intended to collect such information.
            • Login credentials.
            • System information, such as device, browser and operating system type and version, screen resolution and preferred language.
            • Referring domain, destination domain and destination path.
            • Geolocation data.
            • Other personal information of a natural person that may be included in videos, images, PDF's, word-processing documents, or other data that our Customers and Users upload to SOVA Services.

            Cookies, Web Beacons and Other Tracking Technologies. We, and our third-party service providers, may use technologies such as cookies and beacons to quantify use, analyze viewing and engagement with the SOVA Services, conduct benchmarking, generate metrics, report to Customers and assess the quality of SOVA Services.

            Cookies. A cookie is a small text file that is stored on a user’s computer for record-keeping purposes. We may link the information we store in cookies to any personal information we obtain from your use of SOVA Services. SOVA Services may use both session cookies and persistent cookies. A session cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions of SOVA Services.

            Web Beacons. We may also use web beacons, tags and scripts in connection with SOVA Services. Web beacons, also known as clear GIFs or single-pixel GIFs, are small image files that SOVA uses to communicate analytics data on User activity and service usage. Alongside cookies, web beacons allow us to determine if emails have been opened so we can monitor email deliverability.

            HTTP Headers. HTTP headers are information that is transmitted whenever a webpage is viewed, and contain technical information required for communication between a browsing device and a website server. Other electronic communication protocols (such as those used for email) also use headers to transmit information. Information may be transmitted through HTTP (or other electronic communication protocol) headers to SOVA from the Customer’s use of SOVA Services or from User interaction with webpage, image or video. This may include information about the device browser, the requested webpage and the computer or device being used (such as a carrier or device identifier).

            Log Files. As is true of most online services, we gather certain information automatically and store it in log files. This information may include User IP address, browser type, device type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp and/or clickstream data. An IP address is identified and logged automatically in our server log files whenever a Customer uses SOVA Services, along with the time(s) of the visit(s) and the page(s) visited. We may combine this automatically-collected log information with other information we collect. We do this to improve the functionality of SOVA Services and for the other purposes described in this Privacy Policy.

            Analytics. We may use third party analytics services, such as Google Analytics, to track the use of SOVA Services by our Customers and Users. For information on how Google collects and processes information and how to opt out from Google’s collection of your information, please click here.

            Do Not Track. SOVA Services do not recognize if a browser sends a “do not track” signal or similar mechanism to indicate the user does not wish to be tracked or receive interest-based ads.

            Security. The security of personal information that SOVA collects while operating the SOVA Service is of great importance to SOVA. We use organizational, technical and administrative measures to protect personal information under our control. No data transmission over the Internet or data storage system, however, can be guaranteed to be 100% secure. If you have any questions about the security of your personal information, you can contact us at privacy@sovasystems.com.

             

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            How We May Use Information

            To the extent permitted by applicable law, we may use information about our Customers and Users for the following purposes or in the following ways:

            • To deliver SOVA Services.
            • To provide Customer and User support.
            • To enable Users to register with our Customers in order to be able to access Customers’ web portal and mobile app. SOVA collects this information at the direction of the Customer.
            • To personalize SOVA Services.
            • For internal business purposes, such as data analysis, benchmarking, audits, developing new products, enhancing SOVA Services, facilitating product, software and applications development, conducting research, analysis, studies or surveys and identifying usage trends.
            • To protect the security and integrity of SOVA Services, and our Customers’ content and data.
            • To meet our contractual requirements, to comply with applicable legal or regulatory requirements and our policies and to protect against criminal activity, claims and other liabilities.
            • We may also use information about our Customers: to send Customers information and updates regarding SOVA Services, programs and promotions; to fulfill Customer requests, such as to create SOVA Services accounts; or complete Customer purchases.
            • In other ways with appropriate consent.

             

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            How We May Share Information

            To the extent permitted by applicable law, we may share, disclose and transfer information, including personal information as follows:

            • With the Customer, as part of the SOVA Services.
            • With third-party service providers we use to support SOVA Services and our business. These parties include third parties providing us with services such as website hosting, data analysis, infrastructure provision, IT services, customer service, analytics and email and telephony delivery services. These third parties are authorized to use information related to you only as necessary to provide these services to us.
            • With third parties where the User or Customer has requested to use a third-party service (including applications) in connection with SOVA Services and has requested that we provide information to such third parties.
            • With our current affiliates and any future corporate subsidiaries or affiliates.
            • With a buyer, investor, new affiliate or other third party in the event that SOVA, or any portion, group or business unit thereof, undergoes a business transition, such as a merger or acquisition, or during steps in contemplation of such activities (e.g., negotiations and due diligence). You will be notified via email and/or a prominent notice on our website of any change in ownership, change in use of your personal information and choices you may have regarding any change in use of your personal information.
            • With third parties for marketing, advertising, promotions, contests or other similar purposes. If required by applicable law, we will share such data for advertising and marketing purposes only in an aggregate, anonymous and de-identified manner.
            • As we believe necessary: under applicable law, including laws outside the User’s or Customer’s country of residence; to comply with any law or directive, judicial or administrative order, legal process or investigation, warrant, subpoena, law enforcement or national security investigation, or as otherwise required or authorized by law; to respond to requests from public and government authorities, including public and government authorities outside the country of residence; to enforce our policies, terms and conditions; to protect our operations or those of any of our affiliates, customers, partners, agents or others; to protect our rights, privacy, safety or property and/or that of our affiliates, customers, partners, agents and any other person or organization; and/or to permit us to pursue available remedies or limit the damages that we may sustain.

            Payment Processing.  We use third-party payment service(s) (“ Payment Service” ) to process credit card payments for certain modules of SOVA Services. Customers acknowledge and agree within their SOVA Services agreement that when prompted to provide credit card information, that information gets transmitted directly to the Payment Service. SOVA does not have access to full credit card numbers and does not store such information in its own systems. Information transmitted to the Payment Service is encrypted using SSL technology. The Payment Service is required to comply with all applicable privacy and security laws and the rules and regulations issued by the payment card industry and the credit card companies. Please contact us at privacy@sovasystems.com if you would like SOVA to faciliate the correction or deletion of your personal information with the Payment Service.

            Cross- Device Tracking. When Customers or Users use devices to display and/or view content, we may receive information about their devices, including a unique identifier for each device. We and our service providers and third parties we collaborate with, including ad networks, may use cross-device/cross-context tracking. For example, a User might use multiple browsers on a single device, or use various devices (such as desktops, smartphones and tablets), which can result in the individual having multiple accounts or profiles across these various contexts and devices. Cross-device/cross-context technology may be used to connect these various accounts or profiles and the corresponding data from the different contexts and devices.

            Aggregate Information. To the extent permitted by applicable law, we may use, process, transfer and store any data about Users and Customers in an anonymous (or pseudonymous) and aggregated manner. We may combine personal information with other information, collected online and offline, including information from third-party sources. We may also use information in other ways with consent or as otherwise permitted by applicable law. By using SOVA Services, our Customers agree that we may collect, use, share and store anonymized (or pseudonymized) aggregated data collected through SOVA Services for benchmarking, analytics, metrics, research, reporting, machine learning and other legitimate business purposes.

            Automated Decisions. To the extent permitted by applicable law, we may collect data in an automated manner and make automated decisions, including using machine-learning algorithms, about Users, Customers and stored media in order to provide and/or optimize SOVA Services, for security or analytics purposes and for any other lawful purpose.

             

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            International Data Transfers

            SOVA Services may be provided using resources and servers located in various countries around the world, including the United States and other countries. Therefore, personal information about Users and Customers may be transferred, processed and stored outside the country where SOVA Services are accessed or performed, including to countries where the level of data protection may not be deemed adequate by the local legal or regulatory authority in the country of origin of the data. We will protect the privacy and security of personal information we collect in accordance with this Privacy Policy, regardless of where it is processed or stored.

            European Residents. If you are a resident of the European Union (“ EU ”), the European Economic Area or Switzerland, please see our Additional Notice for Certain European Residents and our Privacy Shield Notice below.

             

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            Other Important Notices Regarding Our Privacy Practices

            Opt-Out. If you no longer wish to receive transactional communications from us, Users may opt out by following the “unsubscribe” instructions in the latest such message received or by contacting us at privacy@sovasystems.com. Customers may not opt out of certain communications, such as those necessary to keep Customers aware of SOVA Service status and service issues.

            Retention Period. To the extent permitted by applicable law, we may retain information for as long as the account of the Customer for whom we collected the information is active, or as long as is reasonably necessary to provide SOVA Services, or as needed for other lawful purposes. We may retain cached or archived copies of information. We may retain anonymized or pseudonymized aggregated data indefinitely, to the extent permitted under applicable law. We also will retain information as long as reasonably necessary to comply with our contractual and/or legal obligations, resolve disputes and enforce our agreements.

            Accuracy of Information. Accuracy of data is very important to us. Customers should ensure that any information provided to us is up-to-date and Customers may correct information by either logging into their Customer account or by contacting SOVA's customer support team. In certain situations, Customers may need assistance from customer support in making a change. We will respond to requests to make changes to Customer or User records as soon as reasonably practicable. We may require Customer representatives or Users to prove their identity before granting access to, or agreeing to update, correct or delete personal information belonging to Customers or Users.

            You may request access to, or correction or deletion of personal information, by contacting us at privacy@sovasystems.com. We will attempt to answer all requests that we correct inaccurate personal information or delete personal information, unless we are required to retain it by law or for legitimate business purposes.

            Use of SOVA Services by Children. We recognize the importance of protecting the privacy and safety of children. SOVA Services are not intended for use by children under 13 years of age (who reside in the United States) or for children under 16 years of age (who reside in the EU, European Economic Area or Switzerland).

             

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            Right to Request Information

            You may request, and we will provide you with information about whether we hold any of your personal information. You may request access to, or correction or deletion of your personal information by contacting us at privacy@sovasystems.com. We will respond to your request within a reasonable timeframe.

             

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            Additional Notice for Certain European Residents

            The following European Privacy Policy applies to residents of the European Union, the European Economic Area and Switzerland who use SOVA Services.


            Personal Data and Processing. For the purposes of this European Privacy Policy:

            Personal Data ” means any information relating to an identified or identifiable natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of such natural person.

            Processing ” means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

            Purposes and Legal Bases for Processing Personal Data. SOVA Processes data for the purposes as set forth in this Privacy Policy, including to provide SOVA Services. To fulfill these purposes, SOVA may access data, including Personal Data, to provide SOVA Services, to correct and address technical or service problems, or in response to contractual requirements. Please see the Information We May Collect, How We May Use Information and How We May Share Information sections for additional details on how we collect, use, disclose and share data, make automated decisions and retain data, including Personal Data, about Users and Customers.

            Compelled Disclosures. SOVA may be required to disclose Personal Data in response to lawful requests by public authorities, including disclosures necessary to meet national security or law enforcement requirements, or pursuant to judicial orders.

            Our lawful bases for the Processing of Personal Data are: (i) consent and/or (ii) any other applicable legal bases, such as our legitimate interest in engaging in commerce, offering products and services of value to the customers of SOVA Services, preventing fraud, ensuring information and network security, direct marketing and advertising and complying with industry practices.

            Additional Rights for European Residents. As a resident of the EU or a country following substantially similar legislation regarding the protection of personal data, you may have one or more of the following additional rights available to you:

            • Access. To request a copy of the Personal Data we have collected about you by contacting us at privacy@sovasystems.com.
            • Rectification & Erasure. To request that we rectify or delete any of the Personal Data about you that is incomplete, incorrect, unnecessary or outdated.
            • Objection. To object, at any time, to Personal Data about you being Processed for direct marketing purposes.
            • Restriction of Processing. To request restriction of Processing of Personal Data about you for certain reasons, such as, for example, if you consider Personal Data about you collected by us to be inaccurate or you have objected to the Processing pending the verification of whether our legitimate grounds for Processing override yours.
            • Data Portability. To request and receive the Personal Data we have collected about you in a commonly used and machine-readable form.
            • Right to Withdraw Consent. If Personal Data about you is processed solely based on your consent and not for any other legitimate interest, to withdraw your consent at any time, without affecting the lawfulness of our Processing based on such consent before it was withdrawn, including Processing related to existing contracts for our products and services.
            • Right to Lodge a Complaint with a DPA. If you believe our Processing of Personal Data about you is inconsistent with the applicable data protection laws, to lodge a complaint with your local supervisory Data Protection Authority (“DPA”).

            To exercise any of the above-listed rights (with the exception of the right to lodge a complaint with a DPA, which you may do directly to a DPA), please contact us at privacy@sovasystems.com. We will process any requests in accordance with applicable law and within a reasonable period of time. We may need to verify your identity before processing your request. Certain information may be reviewed, corrected and updated by logging into your SOVA Service account and editing the profile information of Customers or Users.

            If SOVA receives a request from a User, we may refer the request to the Customer and support the Customer in responding to the request.

             

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            Additional Notice for Canadian Residents

            Canadian residents may have additional rights under Canadian law. Please see the information provided by the Office of the Privacy Commissioner of Canada for additional details.

            You, and we, confirm that it is our wish that this Privacy Policy and all other related policies be drawn up in English. Vous reconnaissent avoir exigé la rédaction en anglais du présent document ainsi que tous les documents qui s'y rattachent.

             

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            Additional Notice for California Residents

            Under California’s “Shine the Light” law, California residents who provide personal information in obtaining products or services for personal, family or household use may be entitled to request and obtain from us, once per calendar year, information about customer information we have shared, if any, with other businesses for such other businesses’ own direct marketing uses. If applicable, this information would include the categories of resident information and the names and addresses of those businesses with which we shared such resident information for the immediately prior calendar year. To obtain this information, please contact us at privacy@sovasystems.com. Please include sufficient personal identification information so that we can process the request, including evidence that you are a California resident.

             

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            Privacy Shield Notice

            EU-U.S. and Swiss-U.S. Privacy Shield Notice. We have certified our compliance with the EU-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield (collectively, the “ Privacy Shield Framework ”) with respect to the Personal Data of users of SOVA Services who are residents of the European Union (“ EU ”), European Economic Area (“ EEA ”) and Switzerland that we receive and process through SOVA Services. We certify that we adhere to the Privacy Shield Principles of notice, choice, onward transfer, security, data integrity, access and enforcement (hereinafter, “ Privacy Shield Principles ”) for personal data of Users and Customers in participating European countries. We are responsible for the processing of personal data we receive under the Privacy Shield Framework and subsequently transfer to a third party agent, and may be liable for onward transfers in violation of the Privacy Shield Principles. We may also process Personal Data relating to individuals in Europe via other compliance mechanisms, including use of the European Union Standard Contractual Clauses. 

            Questions and Complaints. If you are a resident of a country participating in the Privacy Shield Framework, you may direct any questions or complaints concerning our Privacy Shield compliance to our Privacy Shield and Data Protection Contact listed below. We will work with you to resolve your issue.

            If you have not received timely response to your concern relating to data processed under the Privacy Shield Framework, or we have not addressed your concern satisfactorily, you may contact our U.S.-based dispute resolution provider, at no cost to you, at https://www.jamsadr.com/file-an-eu-us-privacy-shield-claim. If neither SOVA nor our independent dispute resolution provider resolves your complaint, you may use the right to invoke binding arbitration through the Privacy Shield Panel. However, prior to initiating such arbitration, a resident of a country participating in the Privacy Shield Framework must first: (1) contact us and afford us the opportunity to resolve the issue; (2) seek assistance from our designated independent dispute resolution provider and (3) contact the U.S. Department of Commerce (either directly or through a European DPA) and afford the Department of Commerce time to attempt to resolve the issue. If such a resident invokes binding arbitration, each party shall be responsible for its own attorney’s fees. Pursuant to the Privacy Shield, the arbitrator(s) may only impose individual-specific, non-monetary, equitable relief necessary to remedy any violation of the Privacy Shield Principles with respect to the resident.

            Dispute Resolution. Except as otherwise expressly provided above, or otherwise required by applicable law, you agree that the exclusive jurisdiction of any actions arising out of, relating to, or in any way connected with, this privacy policy, shall be in the state or federal courts, as applicable, located in the City of San Diego, California, USA. Any dispute, controversy, or claim arising out of or relating to this privacy policy or the collection, use, storage or transfer of any of your information or data, including, but not limited to, the arbitrability of the matter or the formation, interpretation, scope, applicability, termination, or breach of this privacy policy, shall be referred to and finally determined by arbitration in accordance with the JAMS Streamlined Arbitration Rules and Procedures, or JAMS International Arbitration Rules, if the matter is deemed "international" within the meaning of that term as defined in the JAMS International Arbitration Rules. The arbitration shall be administered by JAMS, shall take place before a sole arbitrator, and shall be conducted in San Diego, California, USA. If the JAMS International Arbitration Rules apply, the language to be used in the arbitral proceedings will be English. Judgment upon the arbitral award may be entered by any court having jurisdiction. This section shall apply to and require arbitration of all disputes, controversies, and claims, regardless of whether such disputes, controversies, or claims concern a single individual, entity, or other person, multiple individuals, entities, or other people, or classes of individuals, entities, or other people. You hereby consent to receive service of process by electronic means or social media to the extent allowed by the applicable court. This constitutes express agreement of the parties regarding your consent pursuant to United States Federal Rule of Civil Procedure 5(b)(2)(E) and any applicable state (or other jurisdiction) equivalent.

            U.S. Federal Trade Commission Enforcement. SOVA's commitments under the Privacy Shield Framework are subject to the investigatory and enforcement powers of the United States Federal Trade Commission.

            Privacy Shield and Data Protection Contact. Your Privacy Shield and Data Protection Contact for the Personal Data that we Process in connection with SOVA Services is:

            Attn: General Counsel, Legal Dept.
            SOVA Systems
            PO Box 600063
            San Diego, CA 92160
            Phone: +1 619 892 6561  

            Please include sufficient information so we can understand and respond to your specific question.

             

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            Changes to This Privacy Policy

            We may update this Privacy Policy to reflect changes to our information and privacy practices. If we make any material changes, we will notify you by posting a notice on the Site prior to or simultaneously with the change becoming effective. Your continued use of the SOVA Services after any such modification constitutes acceptance of any such modified Privacy Policy. We encourage you to review this page periodically for the latest information on our privacy practices. The date of last revision is shown at the top of this Privacy Policy.

             

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            How to Contact Us

            If you have any questions regarding this Privacy Policy, please contact us by email at  privacy@sovasystems.com , or call +1 619 892 6561, or write to:

            Attn: Privacy Team
            SOVA Systems
            PO Box 600063
            San Diego, CA 92160

            Please be sure to include sufficient information so we can understand and respond to your specific question or request.

             

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            Updated: 06 Mar 2019 02:16 PM
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