LAST UPDATED: February 22, 2019
SOVA Systems and its affiliates (“ SOVA ” or “ we ”)
want you to be familiar with the information we collect about users of
our websites, how we use and share that information, and the choices you
including those aspects of SOVA Services that are accessible via
this Site, including support pages. For
more information about information collected through SOVA
Services, please see our
Terms and Conditions.
practices generally, please contact us at email@example.com .
We may collect information from or about you, such as:
To the extent permitted by applicable law, we may also combine
information you provide to us, either via our Site or via another means
(such as at a trade show) with publicly-available information, such as
your organization’s name.
Information Collected by Automated Means. We may
collect certain information about you by automated means, such as your
MAC address, IP address, computer type, screen resolution, OS version,
and browser type and version. This information is collected by most
websites and is used to optimize your experience on the Site.
Job Applicants: You may voluntarily provide data
about yourself in connection with a job application. Such provision of
use to submit your application. You will have the opportunity to review
Cookies and other tracking technologies. We and our
collect information about you, such as personal information,
information about the devices you use to access the Site and your
interactions with the Site. For more information about the use of
cookies on the Site, please review our Cookies Policy.
We may also use web beacons on our Site and in email communications.
Web beacons, also known as clear GIFs or single-pixel GIFs, are small
image files that we, or our third-party service providers, place on our
Site and in emails. Alongside cookies, web beacons allow us to
accurately count the number of unique users who have visited a specific
page on the Site, or opened or acted upon an email. This information
allows us to measure the performance of our Site and our email
Advertising on Third-Party Websites and Ad Networks. We partner with third parties to manage our advertising on the Site and
third-party websites, which may include serving or tracking
advertisements on or relating to the Site. Our third-party service
providers may use technologies such as cookies to gather information
about your activities on the Site and third-party sites in order to
provide you advertising based upon your browsing activities and
interests. The privacy policies of those third parties will govern your
interactions with such third-party websites or ad networks. If you do
not want this information used by third parties for the purpose of
serving you interest-based ads, you may opt-out by clicking here (or if you are located in the European Union, click here ).
Following these processes will opt you out of receiving SOVA ads
that are targeted to you. You may, however, continue to receive generic
ads that are targeted to the general public.
Log Files. As is true of most websites, we gather
certain information automatically and store it in log files. This
information may include IP addresses, browser type, internet service
provider (ISP), referring/exit pages, the files viewed on the Site
(e.g., HTML pages, graphics, etc.), operating system, date/time stamp,
and/or clickstream data. Your IP address is a number that is
automatically assigned to the device you are using by your ISP and, in
many cases, IP addresses are shared by multiple people or computers and
may be dynamically generated (meaning they change over time). This
number is identified and logged automatically in our server log files
whenever you use the Site, along with the time(s) of your visit(s) and
the page(s) you visited. We may combine this automatically-collected log
information with other information we collect from you. We do this to
improve the functionality of the Site.
Analytics. We use third-party analytics provided by
Google Analytics. For information on how Google Analytics collects and
processes information about you and information on how to opt out from
Google’s collection of information from you, please click here .
Do Not Track. The Site does not recognize a “do not
track” setting (or similar mechanism) from your browser to indicate that
you do not wish to be tracked or to receive interest-based ads.
Security. The security of personal information that
SOVA collects from Site users 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. When you submit personal information via a
lead form on the Site (such as name, phone number, and email address),
we encrypt the transmission of that information. If you have any
questions about the security of your personal information, you can
contact us at firstname.lastname@example.org .
To the extent permitted by applicable law, we may use the information
collected about you for the following purposes or in the following
To the extent permitted by applicable law, we may share 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. You acknowledge and agree 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 email@example.com if you would like SOVA to faciliate the correction or deletion of your personal information with the Payment Service.
Third-Party Sites and the Site. We provide links to
other websites on this Site as a convenience for our users. We may also
inform users about third-party services or applications that can be used
in connection with SOVA Services, including services from
companies associated with SOVA’s partners program (as further
not responsible for, the privacy, information or other practices of any
third parties, or of other websites, applications or services operated
by such third parties. Your activities with, including your provision of
personal information to, any such third parties or such third parties’
websites, applications or services will be governed by the privacy
policy of such third parties. The inclusion of a link on the Site does
not imply endorsement of the linked website by SOVA. We
are not responsible for the use of any personal information you disclose
to or through our customers or partners or third-party sites,
applications or services.
Social Media Features. Our Site includes social
media features, such as LinkedIn, Twitter, Facebook, and Google Plus.
These features may collect information about you including, for example,
your IP address and which pages you visit on our Site, and may set a
cookie to enable the feature to function properly. Social media features
are either hosted by a third party or hosted directly on our Site. Your
the company providing the social media feature.
Cross-Device Tracking. When you use your mobile
device to interact with the Site, we may receive information about your
mobile device, including a unique identifier for your device. We and our
service providers and third parties we collaborate with, including ad
networks, may use cross-device/cross-context tracking. For example, you
might use multiple browsers on a single device, or use various devices
(such as desktops, smartphones and tablets), which can result in your
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.
The Site, and the features and functionality of the Site, 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 of the Site may be transferred,
processed and stored outside the country where you access the Site,
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. By using the Site, you consent to this
transfer. We will protect the privacy and security of personal
regardless of where it is processed or stored.
European Residents : If you are a resident of the European Union (the “ EU ”),
the European Economic Area or Switzerland, please see our Additional
Privacy Notice for Certain European Residents and our Privacy Shield
Opt-Out . If you no longer wish to receive
marketing-related emails from us, or you prefer that we not share
personal information about you in the future with our affiliates and/or
with third parties, you may opt out by following the “unsubscribe”
instructions in the latest such message you have received or by
contacting us at firstname.lastname@example.org .
Please specify whether you are opting out of receiving messages from us
or from us sharing your information with our affiliates and third
We will endeavor to comply with your request as soon as reasonably
practicable. If you opt out as described above, we will not be able to
remove your personal information from the databases of third parties
with whom your personal information has already been shared. If you wish
to cease receiving marketing-related emails from such third parties,
please contact them directly.
Retention Period . To the extent permitted by
applicable law, SOVA will retain personal information about you
for the period of time appropriate for us to fulfill the purposes
obligations, resolve disputes or enforce our agreements, whichever is
Use of the Site by Children . The Site is not
directed to children under the age of 16 (who reside in the EU, the
European Economic Area or Switzerland) and children under the age of 13
(who reside in the United States). Children under the applicable minimum
age should not provide personal information through the Site. If you
become aware that a child has provided us with personal information,
please contact us at email@example.com .
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 firstname.lastname@example.org . We will respond to your request within a reasonable timeframe.
The following Additional Notice applies only to residents of
the European Union, the European Economic Area and Switzerland who visit
Personal Data and Processing. For the purposes of this Additional Notice:
“ 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 providing the Site and other services to users as
explained in the How We May Use Your Information and How Your
Information Is Shared sections.
Our lawful bases for the Processing of Personal Data are: (i) consent
and/or (ii) any other applicable lawful bases, such as our legitimate
interest in engaging in commerce, offering products and services of
value to the users of the Site, preventing fraud, ensuring information
and network security, direct marketing and complying with industry
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.
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 email@example.com .
Rectification & Erasure. To request that we correct or delete any 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, if you consider Personal Data about you collected by
us to be inaccurate or if you have objected to the Processing in
accordance with your rights under Data Protection Laws and Regulations.
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 lawful basis, 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
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 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.
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 the Site who are residents of the European Union (“ EU ”), European Economic Area (“ EEA ”)
and Switzerland that we receive and process through the Site. We
certify that we adhere to the Privacy Shield Framework principles of
notice, choice, onward transfer, security, data integrity, access and
enforcement (the “ Privacy Shield Principles ”) for
Personal Data of users of the Site in the countries participating in the
Privacy Shield Framework. 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 have 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 indicated below; 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 a resident invokes binding arbitration, each party shall be
responsible for its own attorney’s fees. Pursuant to the Privacy Shield
Framework, the arbitrator(s) may impose only 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
Privacy Shield and Data Protection Contact . Your Privacy Shield and Data Protection Contact for the personal data that we process in connection with the Site is:
Please include sufficient information so we can understand and respond to your specific question.
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 Site after any such modification constitutes acceptance of any such
periodically for the latest information on our privacy practices. The
Please be sure to include sufficient information so we can understand and respond to your specific question or request.