Personal information does not include:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
Use of Personal Information
We may use, “sell” for monetary or other valuable consideration, or disclose the personal information we collect and, over the prior twelve (12) months, have used, “sold” for monetary or other valuable consideration, or disclosed the personal information we have collected, for the purposes described in the Consumer Privacy Notice.
Sharethrough will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sources of Personal Information
Sharethrough obtains the categories of personal information listed above indirectly from you by observing your interaction with Advertisements on a Partner Site. We may also obtain the above categories of personal information from our synchronization of cookies with the providers of other digital advertising exchanges.
Sharing Personal Information
Sharethrough may disclose your personal information to a third party for a business purpose described in the Consumer Privacy Notice. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, Sharethrough has disclosed the following categories of personal information for a business purpose to the listed categories of third parties:
A. Identifiers:
Categories of Third Parties: Service Providers; Internet cookie information recipients, such as analytics and behavioral advertising services; Business partners; Affiliates, parents, and subsidiary organizations of Sharethrough; and Social media companies.
D. Commercial information:
Categories of Third Parties: Service Providers; Internet cookie information recipients, such as analytics and behavioral advertising services; Business partners; Affiliates, parents, and subsidiary organizations of Sharethrough; and Social media companies.
F. Internet or other similar network activity:
Categories of Third Parties: Service Providers; Internet cookie information recipients, such as analytics and behavioral advertising services; Business partners; Affiliates, parents, and subsidiary organizations of Sharethrough; and Social media companies.
G. Geolocation data:
Categories of Third Parties: Service Providers; Internet cookie information recipients, such as analytics and behavioral advertising services; Business partners; Affiliates, parents, and subsidiary organizations of Sharethrough; and Social media companies.
K. Inferences drawn from other personal information:
Categories of Third Parties: Service Providers; Internet cookie information recipients, such as analytics and behavioral advertising services; Business partners; Affiliates, parents, and subsidiary organizations of Sharethrough; and Social media companies.
Sales of Personal Information
As noted in our Consumer Privacy Policy, we do not sell your personal information as the term “sell” is commonly understood to require an exchange for money. However, the syncing of cookies between our Advertising Platform and that of other digital advertising exchanges may be considered a “sale” of Personal Information as the term “sale” is broadly defined in the CCPA to include both monetary and other valuable consideration. We continue to consider it a “sale” in order to be as transparent as possible with those that interact with the Advertisements served by our Advertising Platform and will comply with the restrictions of the “sale” of this information to the extent technologically feasible. This “sale” would be limited to our syncing of advertising cookies to provide you with relevant Advertisements on both our Partner Sites and other sites that may display targeted advertising.
In the preceding twelve (12) months, Sharethrough has “sold” the following categories of personal information to the following categories of third parties for monetary or other valuable consideration:
A. Identifiers:
Categories of Third Parties: Internet cookie information recipients, such as analytics and behavioral advertising services (including social media companies that provide behavioral advertising).
D. Commercial information:
Categories of Third Parties: Internet cookie information recipients, such as analytics and behavioral advertising services (including social media companies that provide behavioral advertising).
F. Internet or other similar network activity:
Categories of Third Parties: Internet cookie information recipients, such as analytics and behavioral advertising services (including social media companies that provide behavioral advertising).
G. Geolocation data:
Categories of Third Parties: Internet cookie information recipients, such as analytics and behavioral advertising services (including social media companies that provide behavioral advertising).
K. Inferences drawn from other personal information:
Categories of Third Parties: Internet cookie information recipients, such as analytics and behavioral advertising services (including social media companies that provide behavioral advertising).
We do not knowingly sell the Personal Information of minors under the age of 16 for monetary or other valuable consideration without affirmative authorization.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights. You may exercise these rights yourself or through your authorized agent. When these rights overlap with the rights described in our Consumer Privacy Notice, we will generally endeavor to provide you with the broader rights, unless doing so would be a violation of law.
Access to Specific Information and Data Portability Rights
You have the right to request that Sharethrough disclose certain information to you about our collection and use of your personal information over the past 12 months (a “Right to Know” request). You also have the right to request that we provide you with a copy of the specific pieces of personal information that we have collected or created about you. If you make a request for the specific pieces of personal information electronically, we will provide you with a copy of your personal information in a portable and, to the extent technically feasible, readily reusable format that allows you to transmit the personal information to another third-party. You must specifically describe if you are making a Right to Know request or a request for the specific pieces of personal information. If you would like both the information about our collection and use over the past twelve (12) months and a copy of the specific pieces of personal information, you must make both requests clear in your email. If it is not reasonably clear from your request, we will only process your request as a Right to Know request.
Once we receive your request and verify your identity (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:
For Right to Know requests:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
For requests for specific pieces of personal information:
- The specific pieces of personal information we collected about you (also called a data portability request). We will not provide this information if the disclosure would create a substantial, articulable, and unreasonable risk to your personal information, your account with Sharethrough, or the security of our systems or networks.
Deletion Request Rights
You have the right to request that Sharethrough delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the right to know, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
If you (or your authorized agent) submit a request to delete your information online, we will use a two-step process in order to confirm that you want your personal information deleted. This process may include verifying your request as much as possible based on the information we currently have.
If you fail to make your submission in accordance with the ways described above, we may either treat your request as if it had been submitted with our methods described above, or provide you with information on how to submit the request or remedy any deficiencies with your request.
Only you, or your agent that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, see Authorized Agents below. We may request additional information so we may confirm a request to delete your personal information.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We may also not be able to comply with your request if we are unable to identify the relevant personal information about you. Note that in many cases we may not be able to identify your personal information or we may have deleted your personal information as described in our Consumer Privacy Notice prior to your request. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
For instructions on exercising sale opt-out rights, see Opt-Out and Opt-In Rights.
Authorized Agents
You may authorize your agent to exercise your rights under the CCPA on your behalf by registering your agent with the California Secretary of State. You may also provide your authorized agent with power of attorney to exercise your rights. If you authorize an agent, we may require that your agent provide proof that they have been authorized exercise your rights on your behalf. We may request that your authorized agent submit proof of identity We may deny a request from your agent to exercise your rights on your behalf if they fail to submit adequate proof of identity or adequate proof that they have the authority to exercise your rights.
Response Timing and Format
We will confirm receipt of your request within ten (10) business days of its receipt. Our confirmation will include information about how we will process your request, including our verification process and when you may expect a response to your request. We will generally process these requests within forty-five (45) days of its receipt. If we require more time (up to 45 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any we provide disclosures related to a Right to Know request will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Opt-Out and Opt-In Rights Regarding the “Sale” of Your Personal Information
If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time. However, because we do not collect information directly from consumers and are unable to determine your age, generally the operator of our Partner Sites are required to obtain this consent where applicable.
To exercise the right to opt-out, you (or your authorized representative) may adjust your cookie preferences through the mechanisms provided by the Partner Site or by visiting the following Internet Web page link at the bottom of our homepage entitled “Do Not Sell My Personal Information”. You may also be able to opt-out of our “sale” of personal information through Network Advertising Initiative at www.networkadvertising.org; Digital Advertising Alliance at www.aboutads.info; or Your Online Choices (Europe) at http://www.youronlinechoices.com. You must have cookies enabled in your browser for this opt-out to work.
Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back into the sale of personal information at any time by following the above link that you used to opt-out. You do not need to create an account with us to exercise your opt-out rights.
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Other California Privacy Rights
California Civil Code Section 1798.83 (California’s “Shine the Light” law) permits individuals who interact with Advertising served by our Advertising Platform that are California residents and who provide personal information in obtaining products and services for personal, family, or household use to request certain information regarding our disclosure of personal information to third parties for their own direct marketing purposes. If applicable, this information would include the categories of personal information and the names and addresses of those businesses with which we shared your personal information with for the immediately prior calendar year (e.g. requests made this year will receive information regarding such activities for last year). You may request this information once per calendar year. To make such a request, please send an email to dataprotection@sharethrough.com.
Changes to This California Consumer Privacy Addendum
Sharethrough reserves the right to amend this California Consumer Privacy Addendum at our discretion and at any time. When we make changes to this California Consumer Privacy Addendum, we will post the updated addendum on our website and update the addendum’s effective date. Your continued use of the Partner Sites following the posting of changes constitutes your acceptance of such changes.
Contact Information
If you have any questions or comments about this California Consumer Privacy Addendum, the ways in which Sharethrough collects and uses your information described above, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at the contact information provided in the Consumer Privacy Notice.
