This Privacy Notice describes how Sharethrough collects and uses Personal Data about you through the use of our Website, and through email, text, and other electronic communications between you and Sharethrough.
Sharethrough, Inc. (“Sharethrough” or “we” or “us”) respects your privacy and are committed to protecting it through our compliance with this policy.
This Website Privacy Notice (our “Privacy Notice”) describes the types of information we may collect from you or that you may provide when you visit the websites https://districtm.net and https://www.sharethrough.com (each, a “Website”) 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:
Please read this 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 Websites. By accessing or using our Websites, you agree to this Privacy Notice. This Privacy Notice may change from time to time (see Changes to Our Privacy Notice). Your continued use of our Websites after we make changes is deemed to be acceptance of those changes, so please check this Privacy Notice periodically for updates.
Sharethrough is the data controller of the Personal Data you provide on the Websites. 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 Privacy Notice.
Our Websites are not intended for children under the age of 18 and children under the age of 18 are not permitted to use our Websites. We will remove any information about a child under the age of 18 if we become aware of it.
Our Websites are not intended for children under 18 years of age. No one under age 18 may provide any information to or on the Websites. 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 Websites 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 Websites, including any other data that may be deemed “personal data” or “personal information” under applicable law (“Personal Data”):
We collect this information:
The information we collect on or through our Websites are:
The Personal Data we collect from you is required to enter into a contract with Sharethrough, for Sharethrough to perform under the contract, and to provide you 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 Websites, 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 Websites 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, including advertisements, on the Websites are served by third-parties, including advertisers, ad networks and servers, content providers, and 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 Website. 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. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.
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.
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), 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 Websites with any automated decision making processes.
Sharethrough does not use your Personal Data collected on or through our Websites 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:
By filling out the “Contact Us” form on our Websites, you consent that we may also use your information to contact you about our goods and services that may be of interest to you. For more information about how to withdraw your consent, 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 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, 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. 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:
We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can learn more about interest-based advertisements and your opt-out rights and options from members of the Network Advertising Initiative (“NAI”) on its website (www.networkadvertising.org) and from members of the Digital Advertising Alliance on its website (www.aboutads.info).
California residents may have additional personal information rights and choices. Please see Jurisdiction-Specific Privacy Rights for more information.
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 visitors of our Websites, 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 visitors of our Websites, 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 states, please see the privacy addendum for your state that is attached to this Privacy Notice.
If you are a resident of California, you have the additional rights described in the California Privacy Addendum.
We may use automated data collection technologies to track you across websites. 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.
We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure.
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 Websites. 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 Websites.
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 provide our Websites to you, 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 United States federal, state, 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. By using our Websites, 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.
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 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 no longer than one (1) year after your last contact with us. In some instances, we may keep it after you close your account, for example we may keep it:
Sharethrough will retain your Personal Data that you provide through the “Contact Us” form on our Websites for a period of one year after your last communication with us. For data that we collect through automated data collection technologies, we generally keep this information for the minimum amount of time necessary to properly maintain and secure our Websites. After these periods, we may continue to retain your Personal Data for any of the reasons listed below:
We will post any changes to our Privacy Notice on our Websites. If we make material changes to our 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 Privacy Notice at any time. It is our policy to post any changes we make to our Privacy Notice on this page with a notice that the Privacy Notice has been updated on the Websites’ home page. If we make material changes to how we treat our users’ Personal Data, we will notify you by email to the email address you provided and/or through a notice on the Websites’ home page (unless we no longer maintain it as set forth above). The date this 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 Websites and this 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
Effective Date: May 4, 2021
Last Reviewed on: May 4, 2021
This Website Privacy Notice Addendum for California Residents (the “California Privacy Addendum”) supplements the information contained in Sharethrough’s Website Privacy Notice (the “Website Privacy Notice”) and describes our collection and use of Personal Information on our Website. This California Privacy Addendum applies solely to all Website users who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this notice.
This California Privacy Addendum does not apply to any information we may collect through the use of cookies or otherwise as part of delivering targeted advertising on our customer’s websites. Our privacy practices with respect to such personal information is governed by our Behavioral Advertising Privacy Notice.
Note that this California Privacy Addendum does not apply employment-related personal information collected from our California-based employees, job applicants, contractors, or similar individuals. Please contact your local human resources department if you are a California employee and would like additional information about how we process your Personal Information.
Where noted, this California Privacy Addendum also does not apply to personal information reflecting a written or verbal business-to-business communication (“B2B Personal Information”). Unless otherwise noted, this exemption will expire on January 1, 2023. In particular, this California Privacy Addendum does not apply to the use of Sharethrough’s products and services by publishers and advertisers.
Our Website collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, our Websites collect, and over the prior twelve (12) months have collected, the following categories of personal information from our consumers:
Personal information does not include:
We may use, or disclose the personal information we collect and, over the prior twelve (12) months, have used, or disclosed the personal information we have collected, for one or more of the business and commercial purposes described in our 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.
Sharethrough obtains the categories of personal information listed above from the categories of sources described in our Website Privacy Notice:
Sharethrough may disclose your personal information to a third party for the business purposes described in the Website 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.
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; Advertisers and advertising networks; Affiliates, parents, and subsidiary organizations of Sharethrough; Internet cookie information recipients, such as analytics and behavioral advertising services;
B. California Customer Records personal information categories:
Categories of Third Parties: Service Providers; Affiliates, parents, and subsidiary organizations of Sharethrough;
D. Commercial information:
Categories of Third Parties: Service Providers; Affiliates, parents, and subsidiary organizations of Sharethrough;
F. Internet or other similar network activity:
Categories of Third Parties: Service Providers; Advertisers and advertising networks; Affiliates, parents, and subsidiary organizations of Sharethrough; Internet cookie information recipients, such as analytics and behavioral advertising services;
G. Geolocation data:
Categories of Third Parties: Service Providers; Advertisers and advertising networks; Affiliates, parents, and subsidiary organizations of Sharethrough; Internet cookie information recipients, such as analytics and behavioral advertising services;
I. Professional or employment-related information:
Categories of Third Parties: Service Providers; Affiliates, parents, and subsidiary organizations of Sharethrough;
K. Inferences drawn from other personal information:
Categories of Third Parties: Service Providers; Affiliates, parents, and subsidiary organizations of Sharethrough;
As noted in our general Privacy Policy, we do not sell your personal information as the term “sell” is commonly understood to require an exchange for money. However, the California State Attorney General may issue guidance on whether the use of advertising and analytics cookies on our Website 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. Until such guidance has been issued, we continue to consider it a “sale” in order to be as transparent as possible with users of our Website and will comply with the restrictions of the “sale” of this information to the extent technologically feasible. This “sale” would be limited to our use of third-party advertising and analytics cookies and their use in providing you behavioral advertising and their use in understanding how people use and interact with our Website(s).
In the preceding twelve (12) months, Sharethrough has not “sold” your Personal Information for either monetary or other valuable consideration.
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.
This information supplements the information described in the Website Privacy Notice with respect to your rights regarding your personal information. If this section conflicts with the Website Privacy Notice, the sections that provide you with the broadest rights will control.
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 Data, 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:
For requests for specific pieces of personal information:
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:
In addition to the methods to exercise your rights described in the Website Privacy Notice, 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 through your email address on record, calling you on your phone number on record (which may include an automated dialer), sending you a text message and requesting that you text us a confirmation, or sending you a confirmation through US mail.
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. 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:
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.
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.
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.
We will respond to a verifiable consumer request within ten (10) days of its receipt. 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.
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.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
California Civil Code Section 1798.83 (California’s “Shine the Light” law) permits users of our Websites 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. This includes our sharing of your personal information to third parties for their own direct marketing purposes when you accept cookies. 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 or write us at: Legal Department, Sharethrough Inc. , 5455 Gaspe Avenue, Suite 730, Montreal; Quebec, Canada H2T 3B3.
Sharethrough reserves the right to amend this California Privacy Addendum at our discretion and at any time. When we make changes to this California Privacy Addendum, we will post the updated addendum on the Website and update the addendum’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.
If you have any questions or comments about this California 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 through the contact information provided in the Website Privacy Notice.