This Advertising Platform Privacy Notice describes how Sharethrough collects and uses Personal Data about you through the use of our Services, and through email, text, and other electronic communications between you and Sharethrough.
Sharethrough, Inc. (“Sharethrough” or “we” or “us”) respect your privacy and are committed to protecting it through our compliance with this policy.
This Advertising Platform Privacy Notice (our “Advertising Platform Privacy Notice”) describes the types of information we may collect from you or that you may provide when you use the Camp, SFA, Maple, SFP, FLO, Pub IPA, Pub API and Pub Maestro platforms, and our other client-facing programmatic advertising applications and platform, whether as an advertiser or as a publisher (the “Platform”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.
This policy applies to information we collect:
It does not apply to information collected by:
This Advertising Platform Privacy Notice also does not apply to the information we collect as a result of consumers interaction with our advertisement. Please see our Consumer Advertising Platform Privacy Notice.
Please read this Advertising Platform Privacy Notice carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Platform. By accessing or using our Platform, you agree to this Advertising Platform Privacy Notice. This Advertising Platform Privacy Notice may change from time to time (see Changes to Our Advertising Platform Privacy Notice). Your continued use of our Platform after we make changes is deemed to be acceptance of those changes, so please check this Advertising Platform Privacy Notice periodically for updates.
Sharethrough is the data controller of the Personal Data you provide on the Platform. Sharethrough has appointed a Data Protection Officer (DPO) and a representative in the European Union.
Sharethrough is the data controller of your Personal Data. Sharethrough has appointed a Data Protection Officer and a representative in the European. Union in compliance with the general Data Protection Regulation. Sharethrough, its Data Protection Officer, and its representative may each be contacted in any manner set forth below in the “Contact Information” Section of this Advertising Platform Privacy Notice.
Our Platform is not intended for children under the age of 18 and children under the age of 18 are not permitted to use our Platform. We will remove any information about a child under the age of 18 if we become aware of it.
Our Platform is not intended for children under 18 years of age. No one under age 18 may provide any information to or on the Platform. We do not knowingly collect Personal Data from children under 18. If you are under 18, do not use or provide any information on our Platform or on or through any of its features, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received Personal Data from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information directly from a child under 18, please contact us through any of the contact information set forth below.
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.
We collect several types of information from and about users of our Platform (“Personal Data”):
We collect this information:
The information we collect on or through our Platform is:
The Personal Data we collect from you is required for your employer to enter into a contract with Sharethrough as an advertiser or as a publisher, for Sharethrough to perform under the contract, and to provide you and your employer with our products and services. If you refuse to provide such Personal Data or withdraw your consent to our processing of Personal Data (when appropriate), then in some cases we may not be able to enter into the contract or fulfill our obligations to you under it.
As you navigate through and interact with our Platform, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns:
The information we collect automatically may include Personal Data or we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties. It helps us to improve our Platform and to deliver a better and more personalized service by enabling us to:
The technologies we use for this automatic data collection may include:
Some content or applications on the Platform are served by third-party application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Platform. The information they collect may be associated with your Personal Data or they may collect information, including Personal Data, about your online activities over time and across different websites and other online services.
We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.
If you register to log into your account using your credentials of a third-party service that provides single sign-on functionality, we will have access to some of your third-party account information from that service, such as your name and other information in that account, as authorized by that service. These services may provide you with the ability to disable the connection between the Platform and your third-party service. We treat any information we receive from these services as 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), to fulfill our obligations to you under a contract with you, and required by law, and with your consent.
If you are in the European Union, the processing of your Personal Data is lawful only if it is permitted under the applicable data protection laws. We have a lawful basis for each of our processing activities (except when an exception applies as described below):
We generally do not request you provide and do not process any special categories of Personal Data.
Sharethrough does not ask you to provide, and we do not knowingly collect, any special categories of Personal Data from you.
We generally do not use your Personal Data collected on our through our Platform with any automated decision making processes.
Sharethrough does not use your Personal Data collected on or through our Platform with any automated decision making process that may produce a legal effect concerning you or similarly significantly affect you, including profiling.
We use your Personal Data for various purposes described below, including to:
We use information that we collect about you or that you provide to us, including any Personal Data:
With your consent, we may also use your information to contact you about our own goods and services that may be of interest to you. If you wish to consent to this use, please check the relevant box located on the form on which we collect your data. If you wish to change your choice, you may do so at any time by logging into the Platform and adjusting our user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request at dataprotection@sharethrough.com. For more information, see Choices About How We Use and Disclose Your Information.
We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Advertising Platform Privacy Notice. We disclose your Personal Data to a few third parties, including:
We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Advertising Platform Privacy Notice. However, we may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
We may disclose Personal Data that we collect or you provide as described in this Advertising Platform Privacy Notice:
We may also disclose your Personal Data:
We offer you choices on how you can opt out of our use of tracking technology, disclosure of your Personal Data for third-parties to advertise to you, our advertising to you, and other targeted advertising.
We do not control the collection and use of your information collected by third parties described above in Disclosure of Your Information. When possible, these organizations are under contractual obligations to use this data only for providing the services to us and to maintain this information strictly confidential. These third parties may, however, aggregate the information they collect with information from their other customers for their own purposes.
In addition, we strive to provide you with choices regarding the Personal Data you provide to us. We have created mechanisms to provide you with control over your Personal Data:
Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. You can also configure our cookie manage to refuse some browser cookies by clicking the cookie consent manager at the bottom of each page of the Platform. If you disable or refuse cookies, please note that some parts of our Platform may then be inaccessible or not function properly.
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 users of our Platform, 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.
Applicable data protection laws may provide you with certain rights with regards to our processing of your Personal Data, however we generally provide these rights to users of our Platform, regardless of jurisdiction.
The law in certain jurisdictions may provide their residents with additional rights regarding our use of your Personal Data.
The law in some states may provide you with additional rights regarding our use of Personal Data. To learn more about any additional rights that may be applicable to you as a resident of one of these jurisdictions, please see the privacy addendum for your jurisdiction that is attached to this Advertising Platform Privacy Notice, if any.
We may use automated data collection technologies to track you across online services. We currently do not honor do-not-track signals that may be sent by some browsers.
We also may use automated data collection technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities. At this time, we do not honor such signals and we do not modify what information we collect or how we use that information based upon whether such a signal is broadcast or received by us.
Information transmitted over the Internet is not completely secure, but we do our best to protect your Personal Data. You can help protect your Personal Data and other information by keeping your password to our Platform confidential.
We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Platform. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures deployed on the Platform.
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.
In order to permit you and your employer use and access of our Platform, we may send and store your Personal Data outside of the country where you reside or are located, including to countries that may not or do not provide an equivalent level of protection for your Personal Data. Your information may be processed and stored in the United States and in Canada and United States and Canadian federal, state, provincial, and local governments, courts, or law enforcement or regulatory agencies may be able to obtain disclosure of your information through the laws of the United States or Canada. By using our Platform, you represent that you have read and understood the above and hereby consent to the storage and processing of Personal Data outside the country where you reside or are located, including in the United States and Canada.
Your Personal Data is transferred by Sharethrough to another country only if it is required or permitted under applicable data protection law and provided that there are appropriate safeguards in place to protect your Personal Data. To ensure your Personal Data is treated in accordance with this Advertising Platform Privacy Notice when we transfer it to a third party, Sharethrough uses Data Protection Agreements between Sharethrough and all other recipients of your data where required by law. These Data Protection Agreements include, where applicable, the Standard Contractual Clauses adopted by the European Commission (the “Standard Contractual Clauses”). The European Commission has determined that the transfer of Personal Data pursuant to the Standard Contractual Clauses provides for an adequate level of protection of your Personal Data, but may need to be supplemented with additional measures on a case-by-case basis after an analysis that such supplemental measures can provide you with an essentially equivalent level of protection as afforded in the EU. When, as a result of this analysis, we believe this to be appropriate and necessary, these Standard Contractual Clauses have been supplemented in this way. Under these Standard Contractual Clauses, you have the same rights as if your data was not transferred to such third country. When applicable, you may request a copy of the Data Protection Agreement by contacting us through the Contact Information below.
We retain your Personal Data for as long as you keep your account open. In some instances, we may keep it after you close your account, for example we may keep it:
Sharethrough will retain your Personal Data for the entire time that your account remains open with your employer and you are provided access to it. After your account is closed, we may retain your Personal Data for one (1), or for any of the reasons listed below, whichever is longer:
We will post any changes to our Advertising Platform Privacy Notice on our Platform. If we make material changes to our Advertising Platform Privacy Notice, we may notify you of such changes through your contact information and invite you to review (and accept, if necessary) the changes.
We may change this Advertising Platform Privacy Notice at any time. It is our policy to post any changes we make to our Advertising Platform Privacy Notice on this page with a notice that the Advertising Platform Privacy Notice has been updated on the Platform’ home page. If we make material changes to how we treat our Platform users’ Personal Data, we will notify you by email to the email address specified in your account and through a notice on the Platform’ home page. The date this Advertising Platform Privacy Notice was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Platform and this Advertising Platform Privacy Notice to check for any changes.
You may contact us through the contact information below.
If you have any questions, concerns, complaints or suggestions regarding our Advertising Platform Privacy Notice, have any requests related to your Personal Data pursuant to applicable laws, or otherwise need to contact us, you may do so at the contact information below.
Sharethrough
5455 Gaspe Avenue, Suite 730
Montreal, Quebec,
Canada H2T 3B3
Attn: Legal Department
Email: dataprotection@sharethrough.com
Dr. Christian Schefold
Sharethrough Inc.
Dentons GmbH
Markgrafenstraße 33
10117 Berlin
Germany
Email: representation.sharethrough.europe@dentons.com
Chantal Bernier
99 Bank Street
Suite 1420
Ottawa, Ontario K1P 1H4
Canada
+1 (613) 783-9600
Email: chantal.bernier@dentons.com