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SOVRA Privacy Policy

This SOVRA Privacy Policy (“Privacy Policy”) is delivered on behalf of International Database Corp and all of its affiliated companies operating under SOVRATM (“SOVRA” or “we,” “our,” or “us”) and governs the data collected on our websites and online applications that link to this Privacy Policy and any data we collect in connection with delivering the services to you (collectively, the “Services”). Your privacy is important to us. We provide this Privacy Policy to explain our practices for collecting, sharing and using personal information and to tell you about the choices you may be able to make regarding the ways in which your information is collected, used and shared. This Privacy Policy does not apply to the practices of any third party, affiliate, or business partner that SOVRA does not own or control.

If you are a California resident, please also read our supplemental California Notice at Collection and Privacy Notice.

If you are a resident of Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, or Utah or Virginia, please also read our U.S. State Privacy Supplement.

If you are a resident of Canada, please also read our Canadian supplement.

Information We Collect

We collect information about you in different ways and from various sources. For example, you may provide personal information directly to us or an entity acting on our behalf, we may collect certain information about you automatically through your use of the Services, or we may obtain information about you from other sources.
Information You Provide To Us
When you use the Services, you may, among other activities, create an account; subscribe to a service; subscribe to our mailing lists; or submit an inquiry or communicate with us. The information that you provide to us and that we collect or receive depends on your relationship with us and your interaction with the Services, but may include your name, telephone number, email address, or job title. In addition, you may be asked to provide us or one of our vendors with payment information, such as your credit card or debit card number, where needed, such as when making a payment. If you apply to a position with us, we may collect your name, email address, and any other information you provide to us such as employment history and education, to assess your application.
Information We Collect Automatically
We, our partners, advertisers, advertising networks or other vendors or service providers may automatically collect certain information when you visit our websites, open our emails or otherwise use the Services. Information collected automatically may include:
  • The type of browser and operating system you are using.
  • Your IP address or mobile device identifier.
  • Unique online identifier or device identifier, such as Identifiers for Advertisers (“IDFA”).
  • The domain name of your internet service provider.
  • The date and time of a visit, information about the content you view and the features you access, the number of links you click within our websites, as well as your activity and behavior on our Services.
  • Location-based information regarding the city, state or country from which you accessed our Services.
  • Information regarding the advertisements you have interacted with, viewed or accessed, such as the number of times you view an advertisement.
  • Information reflecting your preferences, trends and/or behavior while using our websites or Services.
This personal information may be combined and linked with personal information from other sources. Please see the “Cookies, Online Tracking and Advertising” section below for additional information.
Information We Obtain From Other Sources
Your employer or other person or entity with which you are affiliated may provide us with certain information about you. For example, your company may provide us with your name and business contact details in connection with corporate accounts and product purchasing. We may also collect commercial information, such as information about products you purchase and where you purchase them. We collect information that you provide to us via social media platforms and other third-party platforms (“Social Media Platforms”). We collect and receive information from you when you interact with our social media pages, accounts or via posts you make on Social Media Platforms. This may include demographic information about users who “follow” our pages or information regarding how you engage with us, such as when you “like” our content. For more information, please see “Social Media and Other Platforms” below.

How We Use the Information

We may use the information collected pursuant to this Privacy Policy in the following ways:
  • To operate, facilitate, and provide the Services to you, or to fulfill any other purpose for which you provide us with information.
  • To process and facilitate payment.
  • To deliver the information, products or services you have requested from us.
  • To market to you and offer other information, products, programs or services that may be of interest.
  • To help us to improve our Services, including troubleshoot problems, and to deliver a better and more personalized, customized experience, including by enabling us to estimate our audience size and usage patterns, store information about your preferences and recognize you when you use our Services.
  • To evaluate your eligibility for certain products and Services.
  • To improve the design and content of our products and Services, which includes using analytics to develop new products and services.
  • To conduct research and analytics.
  • To enable us to customize your user experience and analyze site usage, including by tracking the Services you have used.
  • To offer you enhanced products, programs, or services.
  • To deliver targeted and other advertising to you. Please see the “Cookies, Online Tracking and Advertising” section below for further information about our and vendors and third parties’ use of cookies, web beacons, mobile ad identifiers, and other tracking technologies to provide you relevant ads, as well as information about how to disable cookies and make other choices related to targeted advertising.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and SOVRA, including for billing and collection, and as we believe is necessary or appropriate to protect, enforce or defend the legal rights, privacy, safety or property of SOVRA and its Services, its employees or agents, or other users or to comply with applicable law.
  • To detect and protect against error, fraud, and other criminal activity.
  • To communicate with you, including to notify you about changes to our Services.
  • To meet legal, regulatory, insurance, security and processing requirements.
  • To assess your application when you apply for a position with us.
  • In any other way we may describe when you provide the information or otherwise at your direction or with your consent.
  • As permitted or required by law or as we may notify you.
Use of AI
Please note that artificial intelligence (“AI”) may be used when processing your personal information. For example, we or service providers on which we rely may use AI tools to assist with the above uses, such as to improve service offerings and enhance user experience. We may also process your personal data in the course of assessing the performance of our AI tools.

How We Share the Information

We may share the information we collect about you or that you provide to us, including any personal information, as follows:
  • With our affiliates.
  • With our service providers, business partners and vendors. We may share your information with our service providers, business partners and vendors on which we rely to, for example, assist us in providing the Services to you. These entities, such as call center services, billing, marketing, information technology, data hosting, and processing services, may use your information as is necessary to provide us with their services.
  • With other entities in the context of a business transaction, in connection with the proposed or actual financing, securitization, insuring, sale, assignment, or other disposal of all or part of SOVRA, or our business or assets, for the purposes of evaluating and/or performing the transaction or proceeding. Assignees or successors of SOVRA, or our business or assets, may use and share your personal information for similar purposes as those described in this Privacy Policy.
  • We may disclose information to third parties as necessary to meet legal, regulatory, insurance, audit, and security requirements, including, if necessary, to (i) detect, prevent, or otherwise address fraud, security or technical issues; (ii) protect against harm to our Services; (iii) establish, exercise, or defend legal claims, or (iv) protect the rights and property of SOVRA and its affiliates and their respective agents, customers, and others, including to enforce our agreements, policies, and terms of use, or to protect the personal safety of any person.
  • We will disclose information we collect about you when required to do so by law, for example, in response to a court order or a subpoena. We also may disclose such information in response to a law enforcement agency’s request, such as to a verified request by law enforcement or other government officials relating to a criminal investigation or alleged illegal activity.

Storing and Transferring Personal Information

Any information we obtain about you in connection with your use of the Services may be processed and stored in the United States, Canada, or other countries. Entities based outside of the jurisdiction where you reside may not be subject to privacy laws that provide you with the same rights and protections as where you reside. As a result, when your personal information is used or stored in a jurisdiction other than where you are residing, it may be subject to the law of this foreign jurisdiction, including any law permitting or requiring disclosure of the information to the government, government agencies, courts and law enforcement in that jurisdiction.

Cookies, Online Tracking and Advertising

Cookies and Other Tracking Technologies
When you use our Services, we and third-parties we engage may use cookies (i.e., small text files that are stored on your browser, computer, or mobile device), web beacons, pixel tags, browser analysis tools, server logs, and other similar tracking technologies to automatically collect information from your browser, including personal information like your IP address, the date and time of your visit, the pages you visit, the features you use, the referring URL you came from and which one you go to after, clickstream behavior (i.e. the pages you view, the links you click, and other actions you take in connection with our website), your browser type, and selected language. We use cookies and other tracking technologies for a variety of purposes, including functional, analytics and advertising purposes. For example, we, our service providers and other third parties we engage use cookies and other tracking technologies:
  • For functional purposes, such as to provide the Services to you.
  • For analytics purposes, such as to provide us with information about which portions of our Services and offerings are the most popular, enabling us to see what web pages a user visits and how much time a user spends on each page, and what communications are of interest to a user.
  • For internal research purposes, such as to provide us with information on our users’ demographics, interests, and behavior to better understand, protect and serve users and SOVRA and to improve our Services.
  • To personalize your experience on our websites or in your use of our Services or in our interactions with you (e.g., to recognize you by name when you return to our websites, to save your password in password-protected areas, or to tailor content, or product and service offerings to you).
  • For advertising purposes, such as to provide advertisements to you (known as targeted advertisements) that we or third parties believe may be relevant to your interests.
We may use both session and persistent cookies. A “session cookie” expires immediately when you end your session (i.e., close your browser). A “persistent cookie” remains after you close your browser and may be accessed every time you use our websites or Services.
Google Analytics
Our Services may use Google Analytics, a web analytics service offered by Google. You may learn more about Google’s practices with Google Analytics by visiting Google’s privacy policy at https://www.google.com/policies/privacy/partners.
Targeted Advertising and Third-Party Rights to Your Information
We may engage third-party companies in an effort to serve targeted advertisements to you. We permit our third-party partners to obtain information about you when you use our Services. This information includes your IP address, mobile device ID and advertising ID. Such information is obtained through cookies and other tracking technologies. Such information and other similar information may be collected from you across other websites and over time. We, our third-party partners and others may use this information to engage in targeted advertising, to develop a profile about you and your perceived interests and display ads or other targeted content to you that is believed to be relevant to you. Such ads and targeted content may appear on our Services and/or across other domains. We take steps to contractually limit the rights our third-party partners have to the information they collect from you via cookies and other tracking technologies. However, we may grant some of our third-party partners independent rights to your personal information (e.g., your IP address), including rights to use your personal information for their own purposes. In such cases, we do not control those third parties’ further use of your personal information and such use is governed by those third parties’ respective privacy policies.
Your Choices
You can generally manage your cookies and other tracking technology preferences through the pop-up menu that appears when you first visit our site, and through your web browser. Most web browsers will tell you how to stop accepting new cookies and tracking technologies and how to disable such existing technologies. For more information regarding how to manage your preferences, please consult the information made available by your particular browser or visit www.allaboutcookies.org. With respect to Google Analytics, you can also view Google’s currently available opt-out options at https://tools.google.com/dlpage/gaoptout in an effort to opt-out of being tracked by Google Analytics. To learn more about targeted advertising and how you may be able to opt out of some of this advertising, you may wish to visit the Digital Advertising Alliance’s (“DAA”) resources and/or the Network Advertising Initiative’s (“NAI”) online resources, at http://www.aboutads.info/choices or http://www.networkadvertising.org/choices, and you can opt out of receiving some targeted advertisements on mobile apps by visiting http://www.aboutads.info/appchoices. Please note that choices are typically device and browser specific.

Social Media and Other Platforms

You may choose to engage with us on Social Media Platforms. We collect and receive information from you when you interact with our social media pages, accounts or via posts you make on Social Media Platforms. If you choose to make any of your activities or other content available through a Social Media Platform, including on our pages, or you engage in other activities in connection with a Social Media Platform, your friends and followers on those Social Media Platforms that you have enabled, and potentially the general public, will be able to view those contributions and activities. Please remember that the manner in which Social Media Platforms use, store, and disclose your information is governed by the policies of such third parties. SOVRA is not responsible for the privacy practices or other actions of any Social Media Platform through which we may engage with you.

Links to Third Party Sites or Other Services

Our websites on which a link to this Privacy Policy appears, and our Services, may offer or contain links to other third-party websites and services whose privacy practices may be different than ours. These third-party sites and services are not operated or controlled by us, unless specifically stated otherwise thereon. The entities operating these sites and services may use cookies and other similar technologies to collect information including about your navigation from our Services to the relevant third-party site or other service. We are not responsible for, nor do we accept any liability for the privacy practices of third-party sites and services, including how such other entities collect, use, and disclose personal information. You should consult the other third-party sites’ and services’ privacy policies in order to better understand their privacy practices.

Security

We have put in place reasonable administrative, technical, and physical safeguards to help prevent unauthorized access, maintain data security and correctly use the information we collect from and about you. However, no system can be completely secure, and we do not guarantee that unauthorized disclosures and access will not happen. Although we take reasonable measures to safeguard against unauthorized disclosures of information, we cannot assure you that your personal information or other information will never be disclosed in a manner that is inconsistent with this Privacy Policy. Please note that the safety and security of your information is also your responsibility. If, for example, you have chosen a password to access certain parts of the Services, you are responsible for keeping this password confidential.

Data Retention

We will retain your personal information for as long as necessary to fulfill the purposes for which it was collected and processed, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements.

Children’s Privacy

Our Services are not intended for users under the age of 16, and SOVRA does not knowingly collect information from anyone under the age of 16. No one under the age of 16 is permitted to access or use SOVRA Services or to provide SOVRA with personal information.

Privacy Policy Changes

This Privacy Policy is effective as of the last updated date above and may be revised from time to time. The revised Privacy Policy will be posted on the appropriate portion(s) of our websites and will indicate when it was most recently updated. We encourage you to periodically check back to review this policy so that you know what information we collect, how we use it and with whom we share it.

Contact Us

If you have any questions or concerns about this Privacy Policy or its implementation, please contact our Privacy Officer at privacy@sovra.com.

If you are a resident of Canada, please read our supplement for Canadian Residents

Canadian Residents: Your Rights Regarding Your Personal Information

It is important that the personal information we hold about you is accurate and up to date. Please keep us informed if your personal information changes. By law, you have the right to request access to and/or correction of the personal information we hold about you.

If you wish to review, verify, correct, or withdraw your consent to the use of your personal information, you may also send us an email to privacy@sovra.com. We may not accept a request to change information if we believe that the change would violate a law or legal requirement or result in incorrect information.

Before providing you with access to your information, we may ask you for specific information to help us confirm your identity and right of access, and to provide you with the personal information we hold about you, or to make the requested changes. In some cases, applicable law requires us to refuse to provide you with access to some or all of the personal information we hold about you, or that we may have destroyed, erased or made anonymous in accordance with our legal record-keeping obligations and privacy best practices. If we are unable to provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions. Such restrictions may include, for example, information about another individual that would reveal their personal information or confidential business information, or would be prohibitively costly to provide

Please note that if you withdraw your consent to our processing of your personal information, we may not be able to provide you with certain Services. We will explain the consequences of your request at that time to assist you in your decision.

If you are a California resident, please read our California Notice at Collection and Privacy Notice.

California Notice at Collection and Privacy Notice

This SOVRA California Notice at Collection and Privacy Notice (“California Privacy Notice”) supplements the information contained in our general Privacy Policy. It is delivered on behalf of International Database Corp and its affiliated companies operating under SOVRATM (“SOVRA” or “we,” “our,” or “us”) and governs the personal information we collect from California residents (“you”) on any website on which a link to this California Privacy Notice appears and any personal information we collect in connection with delivering services to you or communicating with you (collectively, the “Services”).

We have adopted this notice to comply with the California Consumer Privacy Act of 2018, as amended (“CCPA”). Please take the time to read and understand this California Privacy Notice. Please also read our general Privacy Policy which includes important information regarding how we collect, use and disclose your personal information.

Notice at Collection & Prior Collection, Use and Sharing of Personal Information

The CCPA requires us to give you specific information about the categories of personal information we collect about you, the sources from which we have obtained that information, the purposes for which we collect it and the categories of entities to whom we disclose it. This table sets out our relevant practices over the last 12 months. Our collection, use and disclosure of personal information depends on your relationship with us and your interaction with the Services. More information regarding the items set out in this table is included in our Privacy Policy.

Category of Personal Information  Categories of Sources From Which Collected  Business or Commercial Purpose for Collecting  Categories of Third Parties and Other Entities To Whom We May Disclose 

Identifiers, such as name, postal address, contact details, email address, IP address, online identifiers or personal preferences.

Categories in Cal. Civ. Code 1798.80(e), such as name, postal address, cookies or employment-related information 

Commercial Information, such as products or services obtained or considered, or other consuming histories or tendencies

Internet or other electronic network activity information, such as browsing history, search history and information regarding your interaction with a website or advertisement

Geolocation data, such as city, state or country  

Inferences drawn from this information, such as preferences or other consumer characteristics 

  • Directly from you, such as when you visit our website, become a subscriber or register for a SOVRA webinar, or via written forms
  • From your devices
  • Our affiliates
  • Our business partners, service providers and vendors
  • Via social media platforms and other third-party services
  • Via email or other correspondence with you
  • Via cookies and other tracking technologies
  • To operate,  facilitate, and provide the Services to you, or to fulfill any other purpose for which you provide us with information.
  • To process and facilitate payment.
  • To deliver the information, products or services you have requested from us.
  • To market to you and offer other information, products, programs or services that may be of interest.
  • To help us to improve our Services, including troubleshoot problems, and to deliver a better and more personalized, customized experience, including by enabling us to estimate our audience size and usage patterns, store information about your preferences and recognize you when you use our Services.
  • To evaluate your eligibility for certain products and Services.
  • To improve the design and content of our products and Services, which includes using analytics to develop new products and services.
  • To conduct research and analytics.
  • To enable us to customize your user experience and analyze site usage, including by tracking the Services you have used.
  • To offer you enhanced products, programs, or services.
  • To deliver targeted and other advertising to you. 
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and Sovra, including for billing and collection, and as we believe is necessary or appropriate to protect, enforce or defend the legal rights, privacy, safety or property of Sovra and its Services, its employees or agents, or other users or to comply with applicable law.
  • To detect and protect against error, fraud, and other criminal activity.
  • To communicate with you, including to notify you about changes to our Services.
  • To meet legal, regulatory, insurance, security and processing requirements.
  • In any other way we may describe when you provide the information or otherwise at your direction or with your consent.
  • As permitted or required by law or as we may notify you.
  • Our affiliates
  • Entities that provide marketing services
  • Our business partners, service providers and vendors
  • Legal authorities as required by law or to protect our rights
  • Advertising networks and analytics providers
  • Social media platforms
  • Affiliated and nonaffiliated third parties as may be permitted by law (such as in connection with the sale or restructuring of all or part of our business)

Audio, electronic, visual, thermal, olfactory or similar information

  • Via videoconferences
  • Via social media platforms and other third-party services
  • When we take or receive a photograph of you
  • To operate,  facilitate, and provide the Services to you, or to fulfill any other purpose for which you provide us with information.
  • To process and facilitate payment.
  • To deliver the information, products or services you have requested from us.
  • To market to you and offer other information, products, programs or services that may be of interest.
  • To help us to improve our Services, including troubleshoot problems, and to deliver a better and more personalized, customized experience, including by enabling us to estimate our audience size and usage patterns, store information about your preferences and recognize you when you use our Services.
  • To evaluate your eligibility for certain products and Services.
  • To improve the design and content of our products and Services, which includes using analytics to develop new products and services.
  • To conduct research and analytics.
  • To enable us to customize your user experience and analyze site usage, including by tracking the Services you have used.
  • To offer you enhanced products, programs, or services.
  • To deliver targeted and other advertising to you. 
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and Sovra, including for billing and collection, and as we believe is necessary or appropriate to protect, enforce or defend the legal rights, privacy, safety or property of Sovra and its Services, its employees or agents, or other users or to comply with applicable law.
  • To detect and protect against error, fraud, and other criminal activity.
  • To communicate with you, including to notify you about changes to our Services.
  • To meet legal, regulatory, insurance, security and processing requirements.
  • In any other way we may describe when you provide the information or otherwise at your direction or with your consent.
  • As permitted or required by law or as we may notify you.
  • Our affiliates
  • Entities that provide marketing services
  • Our business partners, service providers and vendors
  • Legal authorities as required by law or to protect our rights
  • Social media platforms
  • Affiliated and nonaffiliated third parties as may be permitted by law (such as in connection with the sale or restructuring of all or part of our business)

 

Professional or Employment related information, such as business contact details, job title, bio, achievements or employer 

  • Directly from you, such as when you visit our website, become a subscriber or register for a SOVRA webinar, or via written forms
  • Our affiliates
  • Our business partners, service providers and vendors
  • Via social media platforms and other third-party services
  • Via email or other correspondence with you
  • To operate,  facilitate, and provide the Services to you, or to fulfill any other purpose for which you provide us with information.
  • To process and facilitate payment.
  • To deliver the information, products or services you have requested from us.
  • To market to you and offer other information, products, programs or services that may be of interest.
  • To help us to improve our Services, including troubleshoot problems, and to deliver a better and more personalized, customized experience, including by enabling us to estimate our audience size and usage patterns, store information about your preferences and recognize you when you use our Services.
  • To evaluate your eligibility for certain products and Services.
  • To improve the design and content of our products and Services, which includes using analytics to develop new products and services.
  • To conduct research and analytics.
  • To enable us to customize your user experience and analyze site usage, including by tracking the Services you have used.
  • To offer you enhanced products, programs, or services.
  • To deliver targeted and other advertising to you. 
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and Sovra, including for billing and collection, and as we believe is necessary or appropriate to protect, enforce or defend the legal rights, privacy, safety or property of Sovra and its Services, its employees or agents, or other users or to comply with applicable law.
  • To detect and protect against error, fraud, and other criminal activity.
  • To communicate with you, including to notify you about changes to our Services.
  • To meet legal, regulatory, insurance, security and processing requirements.
  • In any other way we may describe when you provide the information or otherwise at your direction or with your consent.
  • As permitted or required by law or as we may notify you.
  • Our affiliates
  • Entities that provide marketing services
  • Our business partners, service providers and vendors
  • Legal authorities as required by law or to protect our rights
  • Social media platforms
  • Affiliated and nonaffiliated third parties as may be permitted by law (such as in connection with the sale or restructuring of all or part of our business)
How We Disclose Personal Information for Business Purposes

In the last twelve months, we have disclosed each of the categories of personal information listed above for business purposes, as set out above.

Sales of Personal Information

We do not sell your personal information for purposes of the CCPA and have not done so in the past twelve months.

Sharing Personal Information for Cross-Context Behavioral Advertising

Depending on the relationship we have with you, we may share, or in the last 12 months we may have “shared,” the following categories personal information for purposes of cross-context behavioral advertising:

  • Identifiers
  • Categories of personal information described in Cal. Civ. Code Section 1798.80(e)
  • Commercial information
  • Internet or other network activity
  • Geolocation data
  • Inferences drawn from this information

To make a request to opt-out of the sharing of your personal information for cross-context behavioral advertising purposes, go to the footer on www.sovra.com and once in the footer click the link entitled “Do Not Share My Personal Information” and decline the optional cookies.

Your Rights as a California Resident

As a California resident, you may have certain rights in relation to your personal information.

Right to Know

You may have the right to know how we have collected, used and disclosed your personal information. Specifically, you may have the right to know:

  • The categories of personal information we have collected about you.
  • The categories of sources from which we have collected your personal information.
  • The business or commercial purpose for which we collect, sell or share your personal information.
  • The categories of third parties to whom we have disclosed your personal information.
  • The categories of personal information that we disclosed for a business purpose and the categories of third parties to whom your personal information was disclosed for a business purpose.
  • The categories of personal information we have “sold” to or “shared” with third parties and the categories of third parties to whom we have “sold” or “shared” your personal information.

You may have the right to know the specific pieces of personal information we have collected about you. Subject to certain limitations, you may request that we provide this information dating back to January 1, 2022.

Right to Make a Deletion Request

You may have the right to request that we delete your personal information that we have collected about you. Subject to certain exceptions, we must delete your personal information and direct any service provider or contractor to delete your personal information.

Right to Correct Inaccurate Personal Information

You may have the right to request that we correct inaccurate personal information about you, taking into account the nature of the personal information and the purposes of the processing of the personal information.

Right to Opt-Out of Sales of Personal Information

If we were to sell your personal information for purposes of the CCPA, you may have the right to opt-out of the sale of your personal information.
Right to Opt-Out of Sharing of Personal Information
You may have the right to opt-out of us sharing your personal information for cross-context behavioral advertising purposes.

Right to Limit Use and Disclosure of Sensitive Personal Information

We do not collect sensitive personal information from you pursuant to this California Privacy Notice.

Right to Non-Discrimination

You have the right to not be discriminated against by us for choosing to exercise your rights under the CCPA.

Other Rights: Notice to California Consumers

You have other rights under California’s “Shine the Light” law. California Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the businesses’ practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes. Alternately, such businesses may have in place a policy not to disclose personal information of customers to third parties for the third parties’ direct marketing purposes if the customer has exercised an option to opt-out of such information sharing. We have such a policy in place. As discussed above, if you wish to opt-out of our sharing of your information with third parties for the third parties’ direct marketing purposes, please contact us at privacy@sovra.com.

How to Exercise Your California Privacy Rights

To exercise your right to know, delete or correct inaccuracies in your personal information, please submit a request to us at privacy@sovra.com.

To make a request to opt-out of the sharing of your personal information for cross-context behavioral advertising purposes, go to the footer on www.sovra.com and once in the footer click the link entitled “Do Not Share My Personal Information” and decline the optional cookies. Some cookies and tracking technologies that are necessary to our site or its functionality may still be placed on your device.

Information for Authorized Agents

In certain circumstances, you can authorize a person (“Authorized Agent”) registered with the California Secretary of State to exercise your California privacy rights and submit requests on your behalf. An Authorized Agent can also include a person who has power of attorney or is acting as a conservator. Any Authorized Agent can make a request on your behalf by sending an email to us at privacy@sovra.com.

Verifying Your Requests

We only respond to your requests to know, access the specific pieces of personal information we have about you, delete and correct inaccurate personal information when we can verify that you are a California resident exercising your rights regarding your personal information.

We may need additional information from you to verify your request. We may need additional information from you to match the information we already have about you in order to verify your request. If you provide us with new personal information that we did not already have about you, we will use it solely for the purpose of verifying your request. We will let you know via email if we need more information from you to verify your request. Please reply to our requests promptly.

We will communicate with you via email. We will use the email address you provided when submitting your request.

If we cannot verify your identity, we will let you know.

Responding To Your Requests

We aim to promptly verify and respond to your requests to know, access the specific pieces of personal information we have about you, delete and correct inaccuracies in your personal information within 45 days of receipt, but may require a total of 90 days to respond to your requests. If we require additional time beyond the initial 45 days and that time is reasonably necessary, we will let you know within the first 45 days.

We do not ordinarily charge a fee for our response to your requests. However, we may do so if your request(s) are excessive, repetitive, or manifestly unfounded. If we determine that charging a fee is warranted, we will let you know and will provide you with an estimate of the associated costs of responding to your request(s).

If we determine that we cannot or will not take the action that you requested, we will let you know. We will inform you of our reasons for not taking action and any rights you may have to appeal the decision.

We will respond to your requests via email. We will contact you at the email address you provided when submitting your request(s). If you would like to receive responses to a request to know or access personal information via postal mail rather than email, please let us know when submitting your request(s).

Limitations

The CCPA does not apply in full to all personal information we collect from California residents. As set out in “Scope” above, the CCPA is not fully applicable to some personal information collected from California residents. Therefore, even if you are a California resident and submit a verifiable request, we may not be required to comply with your request.

We are only required to respond to certain requests twice in any 12-month period. We are not required to provide you with access to specific pieces of personal information more than twice in any 12-month period. Similarly, we are not required to comply with your “requests to know more” than twice in any twelve-month period.

Do Not Track and Global Privacy Control (“GPC”) Signals

We rely on a third-party service provider to implement a tool in an effort to recognize and honor “do not track” and Global Privacy Control signals as requests to opt-out of “sharing” your personal information for cross-context behavioral advertising purposes (as such term is defined in the CCPA).

Changes to Our California Privacy Notice

This California Privacy Notice may be changed by SOVRA or its affiliates at any time and an updated policy will be posted to the website and relevant portions of the Services.

How to Contact Us

If you have any questions or concerns about this California Privacy Notice or its implementation, please contact us via email at privacy@sovra.com.

This California Privacy Notice was last updated on November 20th, 2025.

If you are a resident of Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, or Utah or Virginia, please read our U.S. State Privacy Supplement.

U.S. State Privacy Supplement

This  SOVRA U.S. State Privacy Supplement (“U.S. State Privacy Supplement”) supplements the information contained in our  U.S. Privacy Policy. It is delivered on behalf of International Database Corp and its affiliated companies operating under SOVRATM (“SOVRA” or “we,” “our,” or “us”) and governs the personal data we collect from residents (“you”) of U.S. states with data privacy laws, including, but not limited to, the Colorado Privacy Act (“CPA”), Connecticut Data Privacy Act (“CTDPA”), Delaware Personal Data Privacy Act (“DPDPA”), Indiana Consumer Data Protection Act (“INCDPA”), Iowa Consumer Data Protection Act (“ICDPA”), Kentucky Consumer Data Protection Act (“KCDPA”), Maryland Online Data Privacy Act (“MODPA”); Minnesota Consumer Data Privacy Act (“MCDPA”), Consumer Data Privacy Act (“MTCDPA”), Nebraska Data Privacy Act (“NDPA”), New Hampshire Privacy Act (“NHPA”), New Jersey Data Protection Act (“NJDPA”), Oregon Consumer Data Privacy Act (“OCDPA”), Rhode Island Data Transparency and Privacy Protection Act (“RIDTPPA”), Tennessee Information Protection Act (“TIPA”), Texas Data Privacy and Security Act (“TDPSA”), Utah Consumer Privacy Act (“UCPA”) and Virginia Consumer Data Protection Act (“VCDPA” and together with the CPA, CTDPA, DPDPA, INCDPA, ICDPA, KCDPA, MODPA, MCDPA, MTCDPA, NDPA, NHPA, NJDPA, OCDPA, RIDTPPA, TIPA, TDPSA, UCPA and VCDPA , and other applicable U.S. state data privacy laws, the “Relevant State Privacy Laws”) on any website on which a link to this U.S. State Privacy Supplement appears and any personal information we collect in connection with delivering services to you or communicating with you (collectively, the “Services”). Please take the time to read and understand this U.S. State Privacy Supplement. Please also read our U.S. Privacy Policy which includes important information regarding how we collect, process and disclose your personal data. 

If you are a resident of the State of California, please see our California Notice at Collection and Privacy Notice.

Collection, Processing and Disclosure of Personal Data

The Relevant State Privacy Laws require us to give you information about the categories of personal data we process, our purpose for processing it, the categories of third parties with whom we share personal data, and the categories of personal data we share with such third parties. This table sets out our relevant practices. Our collection, processing and disclosure of personal data depends on your relationship with us and your interaction with the Services. More information regarding the items set out in this table is included in our U.S. Privacy Policy.

Category of Personal Information  Categories of Sources From Which Collected  Purpose for Processing Categories of Third Parties and Other Entities To Whom We May Disclose 

Identifiers, such as name, postal address, contact details, email address, passport details, IP address, online identifiers or personal preferences 

Commercial Information, such as products or services obtained or considered, or other consuming histories or tendencies

Internet or other electronic network activity information, such as browsing history, search history and information regarding your interaction with a website or advertisement

Geolocation data, such as city, state or country 

Inferences drawn from this information, such as preferences or other consumer characteristics 

  • Directly from you, such as when you visit our website, become a subscriber or register for a Sovra webinar, or via written forms
  • From your devices
  • Our affiliates
  • Our business partners, service providers and vendors
  • Via social media platforms and other third-party services
  • Via email or other correspondence with you
  • Via cookies and other tracking technologies

 

  • To operate,  facilitate, and provide the Services to you, or to fulfill any other purpose for which you provide us with information.
  • To process and facilitate payment.
  • To deliver the information, products or services you have requested from us.
  • To market to you and offer other information, products, programs or services that may be of interest.
  • To help us to improve our Services, including troubleshoot problems, and to deliver a better and more personalized, customized experience, including by enabling us to estimate our audience size and usage patterns, store information about your preferences and recognize you when you use our Services.
  • To evaluate your eligibility for certain products and Services.
  • To improve the design and content of our products and Services, which includes using analytics to develop new products and services.
  • To conduct research and analytics.
  • To enable us to customize your user experience and analyze site usage, including by tracking the Services you have used.
  • To offer you enhanced products, programs, or services.
  • To deliver targeted and other advertising to you. 
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and Sovra, including for billing and collection, and as we believe is necessary or appropriate to protect, enforce or defend the legal rights, privacy, safety or property of Sovra and its Services, its employes or agents, or other users or to comply with applicable law.
  • To detect and protect against error, fraud, and other criminal activity.
  • To communicate with you, including to notify you about changes to our Services.
  • To meet legal, regulatory, insurance, security and processing requirements.
  • In any other way we may describe when you provide the information or otherwise at your direction or with your consent.
  • As permitted or required by law or as we may notify you.
  • Entities that provide marketing services
  • Our business partners, service providers and vendors
  • Legal authorities as required by law or to protect our rights
  • Advertising networks and analytics providers
  • Social media platforms
  • Affiliated and nonaffiliated third parties as may be permitted by law (such as in connection with the sale or restructuring of all or part of our business)

Audio, electronic, visual, thermal, olfactory or similar information

  • Via videoconferences
  • Via social media platforms and other third-party services
  • When we take or receive a photograph of you
  • To operate,  facilitate, and provide the Services to you, or to fulfill any other purpose for which you provide us with information.
  • To process and facilitate payment.
  • To deliver the information, products or services you have requested from us.
  • To market to you and offer other information, products, programs or services that may be of interest.
  • To help us to improve our Services, including troubleshoot problems, and to deliver a better and more personalized, customized experience, including by enabling us to estimate our audience size and usage patterns, store information about your preferences and recognize you when you use our Services.
  • To evaluate your eligibility for certain products and Services.
  • To improve the design and content of our products and Services, which includes using analytics to develop new products and services.
  • To conduct research and analytics.
  • To enable us to customize your user experience and analyze site usage, including by tracking the Services you have used.
  • To offer you enhanced products, programs, or services.
  • To deliver targeted and other advertising to you. 
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and Sovra, including for billing and collection, and as we believe is necessary or appropriate to protect, enforce or defend the legal rights, privacy, safety or property of Sovra and its Services, its employees or agents, or other users or to comply with applicable law.
  • To detect and protect against error, fraud, and other criminal activity.
  • To communicate with you, including to notify you about changes to our Services.
  • To meet legal, regulatory, insurance, security and processing requirements.
  • In any other way we may describe when you provide the information or otherwise at your direction or with your consent.
  • As permitted or required by law or as we may notify you.
  • Our affiliates
  • Entities that provide marketing services
  • Our business partners, service providers and vendors
  • Legal authorities as required by law or to protect our rights
  • Social media platforms
  • Affiliated and nonaffiliated third parties as may be permitted by law (such as in connection with the sale or restructuring of all or part of our business)

 

Professional or Employment related information, such as business contact details, job title, bio, achievements or employer 

  • Directly from you, such as when you visit our website, become a subscriber or register for a SOVRA webinar, or via written forms
  • Our affiliates
  • Our business partners, service providers and vendors
  • Via social media platforms and other third-party services
  • Via email or other correspondence with you
  • To help us to improve our Services, including troubleshoot problems, and to deliver a better and more personalized, customized experience, including by enabling us to estimate our audience size and usage patterns, store information about your preferences and recognize you when you use our Services.
  • To evaluate your eligibility for certain products and Services.
  • To improve the design and content of our products and Services, which includes using analytics to develop new products and services.
  • To conduct research and analytics.
  • To enable us to customize your user experience and analyze site usage, including by tracking the Services you have used.
  • To offer you enhanced products, programs, or services.
  • To deliver targeted and other advertising to you. 
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and Sovra, including for billing and collection, and as we believe is necessary or appropriate to protect, enforce or defend the legal rights, privacy, safety or property of Sovra and its Services, its employees or agents, or other users or to comply with applicable law.
  • To detect and protect against error, fraud, and other criminal activity.
  • To communicate with you, including to notify you about changes to our Services.
  • To meet legal, regulatory, insurance, security and processing requirements.
  • In any other way we may describe when you provide the information or otherwise at your direction or with your consent.
  • As permitted or required by law or as we may notify you.
  • Our affiliates
  • Entities that provide marketing services
  • Our business partners, service providers and vendors
  • Legal authorities as required by law or to protect our rights
  • Social media platforms
  • Affiliated and nonaffiliated third parties as may be permitted by law (such as in connection with the sale or restructuring of all or part of our business)
Sales of Personal Data

We do not sell your personal data for purposes of the Relevant State Privacy Laws.

Targeted Advertising

We may share the following categories personal data with third-party cookie, ad-tech providers and others throughout the online advertising ecosystem for purposes of targeted advertising:

  • Identifiers
  • Commercial information
  • Internet or other electronic network activity information
  • Geolocation data
  • Inferences drawn from personal information such as preferences, characteristics and behaviors

To make a request to opt-out of the sharing of your personal data for targeted advertising purposes, go to the footer on sovra.com and once in the footer click the link entitled “Do Not Share My Personal Information” and decline the optional cookies.

Your Privacy Rights

You may have certain rights in relation to your personal data.

Right to Know

You may have the right to confirm whether we process your personal data and to access such personal data.

Right to Make a Deletion Request

You may have the right to request that we delete your personal data that we have collected or received about you. Subject to certain exceptions, we must delete your personal data.

Right to Correct Inaccurate Personal Data

You may have the right to request that we correct inaccurate personal data about you, taking into account the nature of the personal data and the purposes of the processing of your personal data.

Right to Opt-Out of Processing of Personal Data for Targeted Advertising

You may have the right to opt-out of the processing of your personal data for purposes of targeted advertising.

Right to Opt-Out of the Sale of Personal Data

If we were to sell your personal data, you may have the right to opt-out of the sale.

Right to Opt-Out of Profiling

You may have the right to opt-out of the processing of your personal data for profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.

Right to Obtain a Copy of Your Personal Data

You may have the right to obtain a copy of your personal data that you previously provided to us.

Right to Non-Discrimination

You have the right to not be discriminated against by us for choosing to exercise your rights.

How to Exercise Your Privacy Rights

To exercise your right to confirm, delete, correct inaccuracies, opt-out of profiling (where relevant) or to obtain a copy of your personal data, please submit a request to us at privacy@sovra.com.

To make a request to opt-out of the sharing of your personal data for targeted advertising purposes, go to the footer on sovra.com and once in the footer click the link entitled “Do Not Share My Personal Information” and decline the optional cookies. Some cookies and tracking technologies that are necessary to our site or its functionality may still be placed on your device.

Authorized Agents

You may be permitted to authorize a person (“Authorized Agent”) to exercise your privacy rights on your behalf. To submit a request on behalf of another person as an Authorized Agent, please submit a request to us at privacy@sovra.com.

Authenticating Your Requests

We only comply with requests when we can authenticate that you are a resident of a jurisdiction subject to Relevant State Privacy Laws.

We may need additional information from you to authenticate your request. We may need additional information from you to match the information we already have about you in order to authenticate your request. We will let you know via email if we need more information from you to authenticate your request. Please reply to our requests promptly.

We will communicate with you about your requests via email. We will use the email address you provided when submitting your request.

If we cannot authenticate your identity, we will let you know.

Responding To Your Requests

We aim to promptly authenticate and respond to your requests within 45 days of receipt but may require a total of 90 days to respond to your requests. If we require additional time beyond the initial 45 days after we receive your request, we will let you know within the first 45 days.

We do not ordinarily charge a fee for our response to your requests. However, we may do so to the extent your request(s) are excessive, repetitive, or manifestly unfounded. If we determine that charging a fee is warranted, we will let you know and will provide you with an estimate of the associated costs of responding to your request(s).

If we determine that we cannot or will not take the action that you requested, we will let you know. We will inform you of our reasons for not taking action and any rights you may have to appeal the decision.

We will respond to your requests via email. We will contact you at the email address you provided when submitting your request(s).

Limitations

The Relevant State Privacy Laws do not apply in full to all personal data we collect. As a result, we may not be required to comply with your request in certain circumstances. 

Information provided in response to a consumer request shall be provided free of charge, up to twice annually per consumer. If requests are manifestly unfounded, excessive, or repetitive, we may charge a reasonable fee to cover the administrative costs of complying with the request or decline to act on the request.

Changes to Our U.S. State Privacy Supplement

This U.S. State Privacy Supplement may be changed by Sovra or its affiliates at any time and an updated policy will be posted to the website and relevant portions of the Services.

How to Contact Us

If you have any questions or concerns about this U.S. State Privacy Supplement or its implementation, please contact us via email at privacy@sovra.com.

This U.S. State Privacy Supplement was last updated on November 20th, 2025.

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