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 ”).
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:
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.
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).
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 email@example.com.
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 the extent permitted by applicable law, we may share, disclose and transfer information, including personal information as follows:
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 firstname.lastname@example.org 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.
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.
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 email@example.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 firstname.lastname@example.org. 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).
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 email@example.com. We will respond to your request within a reasonable timeframe.
“ 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.
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:
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 firstname.lastname@example.org. 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.
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.
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 email@example.com. Please include sufficient personal identification information so that we can process the request, including evidence that you are a California resident.
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.
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:
Please include sufficient information so we can understand and respond to your specific question.
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