Sharethrough Advertising Platform Privacy Notice

Contents

1. Introduction
2. Data Controller, Data Protection Officer, and Representative
3. Children Under the Age of 18
4. Information We Collect About You and How We Collect It
5. Lawful Basis for Processing Your Personal Data
6. Special Categories of Information
7. Lawful Basis for Processing Your Personal Data
8. How We Use Your Information
9. Disclosure of Your Information
10. Choices About How We Use and Disclose Your Information
11. Your Rights Regarding Your Information and Accessing and Correcting Your Information
12. Jurisdiction Privacy Rights
13. Do Not Track Signals
14. Data Security
15. Consent to Processing of Personal Data in Other Countries Outside of Your Home Country
16. Data Retention Periods
17. Changes to Our Advertising Platform Privacy Notice
18. Contact Information

1. Introduction

This Advertising Platform Privacy Notice describes how Sharethrough collects and uses Personal Data about you through the use of our Services, and through email, text, and other electronic communications between you and Sharethrough.

Sharethrough, Inc. (“Sharethrough” or “we” or “us”) respect your privacy and are committed to protecting it through our compliance with this policy.

This Advertising Platform Privacy Notice (our “Advertising Platform Privacy Notice”) describes the types of information we may collect from you or that you may provide when you use the Camp, SFA, Maple, SFP, FLO, Pub IPA, Pub API and Pub Maestro platforms, and our other client-facing programmatic advertising applications and platform, whether as an advertiser or as a publisher (the “Platform”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

• When you register for or use our Platform, either as an advertiser or as a publisher;
• in email, text, and other electronic messages between you and Sharethrough.

It does not apply to information collected by:

• us offline or through any other means, including on any other website or other services operated by Sharethrough or any third-party (including our affiliates and subsidiaries and including any website operated by a publisher or an advertiser);
• us or any of our affiliates or subsidiaries related to your or any other individual’s employment or potential employment with us; or
• any third party (including our affiliates and subsidiaries and including any website operated by a publisher or an advertiser).

This Advertising Platform Privacy Notice also does not apply to the information we collect as a result of consumers interaction with our advertisement. Please see our Consumer Advertising Platform Privacy Notice.

Please read this Advertising Platform Privacy Notice carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Platform. By accessing or using our Platform, you agree to this Advertising Platform Privacy Notice. This Advertising Platform Privacy Notice may change from time to time (see Changes to Our Advertising Platform Privacy Notice). Your continued use of our Platform after we make changes is deemed to be acceptance of those changes, so please check this Advertising Platform Privacy Notice periodically for updates.

2. Data Controller, Data Protection Officer, and Representative

Sharethrough is the data controller of the Personal Data you provide on the Platform. Sharethrough has appointed a Data Protection Officer (DPO) and a representative in the European Union.

Sharethrough is the data controller of your Personal Data. Sharethrough has appointed a Data Protection Officer and a representative in the European. Union in compliance with the general Data Protection Regulation. Sharethrough, its Data Protection Officer, and its representative may each be contacted in any manner set forth below in the “Contact Information” Section of this Advertising Platform Privacy Notice.

3. Children Under the Age of 18

Our Platform is not intended for children under the age of 18 and children under the age of 18 are not permitted to use our Platform. We will remove any information about a child under the age of 18 if we become aware of it.

Our Platform is not intended for children under 18 years of age. No one under age 18 may provide any information to or on the Platform. We do not knowingly collect Personal Data from children under 18. If you are under 18, do not use or provide any information on our Platform or on or through any of its features, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received Personal Data from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information directly from a child under 18, please contact us through any of the contact information set forth below.

4. Information We Collect About You and How We Collect It

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. 

Generally

We collect several types of information from and about users of our Platform (“Personal Data”):

• by which you may be personally identified, such as your contact information;
• that is about you but individually does not identify you, such as your information about your employment and other information about your use of the Platform; and/or
• about your internet connection, the equipment you use to access our Platform and usage details.

We collect this information:

• directly from you when you provide it to us;
• from third parties that allow us to use single sign-on technology to permit you to log into the Platform using your user id and password from their system;
• automatically as you navigate through the Platform.

Information You Provide to Us

The information we collect on or through our Platform is:

• information that you provide by filling in forms on our Platform. This includes information provided at the time of registering to use our Platform, subscribing to our service, providing advertising material to be displayed on publisher’s websites; or requesting further services. This information includes name, work address, work email address, work phone number, your employer’s name, and your job title;
• records and copies of your correspondence (including email addresses), if you contact us;
• details of transactions you carry out through our Platform and of the fulfillment of your orders. You may be required to provide your company’s financial information before using our Platform. For advertisers, this financial information includes the information necessary to pay for advertising placement and for publishers, this may include the information necessary to provide you with revenue share.

The Personal Data we collect from you is required for your employer to enter into a contract with Sharethrough as an advertiser or as a publisher, for Sharethrough to perform under the contract, and to provide you and your employer with our products and services. If you refuse to provide such Personal Data or withdraw your consent to our processing of Personal Data (when appropriate), then in some cases we may not be able to enter into the contract or fulfill our obligations to you under it.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Platform, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns:

• details of your visits to our Platform. We collect traffic data, location data, logs, referring/exit pages, date and time of your visit to our Platform, error information, clickstream data, and other communication data and the resources that you access and use on the Platform; and
• Information about your computer and internet connection, i.e. your IP address, operating system, and browser type.

The information we collect automatically may include Personal Data or we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties. It helps us to improve our Platform and to deliver a better and more personalized service by enabling us to:

• store information about your preferences, allowing us to customize our Platform according to your individual interests;
• maintain your login state;
• speed up your searches; and
• recognize you when you return to our Platform.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. Our Platform may use both session cookies (which expire once you close your browser) and persistent cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Platform. We only place cookies on your hard drive with your consent. You may withdraw or change your consent at any time by clicking on the “cookies” link that the bottom of each page of the Platform. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. However, if you do not consent to our use of cookies or select this setting you may be unable to access certain parts of our Platform. You can find more information about cookies at www.allaboutcookies.org and www.youronlinechoices.eu. 

1. Session Cookies. Our use of cookies also includes “session cookies.” Each time you access the Platform, a session cookie containing an encrypted, unique identifier is placed on your browser. These session cookies allow us to uniquely identify you when you use the Platform and track which pages of the Platform you access. Session cookies are required to use the Platform.
2. Persistent Cookies. Our use of cookies includes the use of “persistent cookies.” These cookies remain on your computer after you leave our Platform and are used to recognize a visitor across multiple visits to our Platform. These persistent cookies allow us to adapt content, understand traffic patterns, measure advertising campaign efficiency, and enhance overall user experience.

• Web Beacons. Pages of our Platform and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Sharethrough, for example, to count users who have visited those pages or opened an email and for other related online statistics (for example, recording the popularity of certain online content and verifying system and server integrity).

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications on the Platform are served by third-party application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Platform. The information they collect may be associated with your Personal Data or they may collect information, including Personal Data, about your online activities over time and across different websites and other online services.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

Information We Collect from Third Parties

If you register to log into your account using your credentials of a third-party service that provides single sign-on functionality, we will have access to some of your third-party account information from that service, such as your name and other information in that account, as authorized by that service. These services may provide you with the ability to disable the connection between the Platform and your third-party service. We treat any information we receive from these services as Personal Data.

5. Lawful Basis for Processing Your Personal Data

We have a lawful basis for our processing of your Personal Data, including processing for our legitimate interests (when balanced against your rights and freedoms), to fulfill our obligations to you under a contract with you, and required by law, and with your consent. 

If you are in the European Union, the processing of your Personal Data is lawful only if it is permitted under the applicable data protection laws. We have a lawful basis for each of our processing activities (except when an exception applies as described below):

• Consent. By using our Platform, you consent to our collection, use, and sharing of your Personal Data as described in this Advertising Platform Privacy Notice. If you do not consent to this Advertising Platform Privacy Notice, please do not use the Platform; 
• Legitimate Interests. We will process your Personal Data as necessary for our legitimate interests. Our legitimate interests are balanced against your interests and rights and freedoms and we do not process your Personal Data if your interests or rights and freedoms outweigh our legitimate interests. Our legitimate interests are to: facilitate communication between Sharethrough and you; detect and correct bugs and to improve our Platform; safeguard our IT infrastructure and intellectual property; detect and prevent fraud and other crime; promote and market our business; check your credit and perform risk assessments; to manage our workforce, assets, and business; develop, improve, and enhance our product and services;
• To Fulfill Our Obligations to You under our Contract. We process your Personal Data in order to fulfill our obligations to you pursuant to our contract with you to deliver our goods and services to you; 
• As Required by Law. We may also process your Personal Data when we are required or permitted to by law; to comply with government inspections, audits, and other valid requests from government or other public authorities; to respond to legal process such as subpoenas; or as necessary for us to protect our interests or otherwise pursue our legal rights and remedies (for instance, when necessary to prevent or detect fraud, attacks against our network, or other criminal and tortious activities), defend litigation, and manage complaints or claims.

6. Special Categories of Information

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.

7. Automated Decision Making

We generally do not use your Personal Data collected on our through our Platform with any automated decision making processes. 

Sharethrough does not use your Personal Data collected on or through our Platform with any automated decision making process that may produce a legal effect concerning you or similarly significantly affect you, including profiling.

8. How We Use Your Information

We use your Personal Data for various purposes described below, including to:

• provide our Platform to you;
• provide you with information you request from us;
• enforce our rights arising from contracts;
• notify you about changes; and
• provide you with notices about your account

We use information that we collect about you or that you provide to us, including any Personal Data:

• to present our Platform and their contents to you;
• to provide you with information, products, or services that you request from us;
• to provide you with notices about your employer’s account, including expiration and renewal notices;
• to carry out our obligations and enforce our rights arising from any contracts entered into between your employer and us, including for billing and collection;
• to notify you about changes to our Platform or any products or services we offer or provide though them;
• to help maintain the safety, security, and integrity of our Platform, products and services, databases and other technology assets, and business;
• for internal testing, research, analysis, and product development, including to develop and improve our Platform, and to develop, improve, or demonstrate our products and services;
• detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
• provide you with analytics regarding your placement of advertisements as an advertiser, and your display of advertisements as a publisher;
• allow you to participate in the open real time bidding protocol and Sharethrough’s advertising exchange;
• in any other way we may describe when you provide the information;
• to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Sharethrough’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Sharethrough about our Platform users is among the assets transferred;
• to fulfill any other purpose for which you provide it; and
• for any other purpose with your consent.

With your consent, we may also use your information to contact you about our own goods and services that may be of interest to you. If you wish to consent to this use, please check the relevant box located on the form on which we collect your data. If you wish to change your choice, you may do so at any time by logging into the Platform and adjusting our user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request at dataprotection@sharethrough.com. For more information, see Choices About How We Use and Disclose Your Information.

9. Disclosure of Your Information

We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Advertising Platform Privacy Notice. We disclose your Personal Data to a few third parties, including:

• our subsidiaries and our affiliates;
• our third-party service providers that we use to support our business;
• to a company we merge, acquire, or that buys us, or in the event of change in structure of our company of any form; 
• to comply with our legal obligations;
• to enforce our rights; and
• with your consent.

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:

• to our subsidiaries and affiliates;
• to contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep Personal Data confidential and use it only for the purposes for which we disclose it to them. These entities provide IT and infrastructure support services, advertising support services, payment processing services, and other similar services;
• to a potential or actual buyer or other successor in the event of a planned or actual merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Sharethrough’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Sharethrough about our Platform users is among the assets transferred;
• to fulfill the purpose for which you provide it;
• for any other purpose disclosed by us when you provide the information; and
• with your consent.

We may also disclose your Personal Data:

• to comply with any court order, law, or legal process, including to respond to any government or regulatory request;
• to enforce or apply our terms of use or and other agreements with your employer, including for billing, payment, and collection purposes; and
• if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Sharethrough, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

10. Choices About How We Use and Disclose Your Information

We offer you choices on how you can opt out of our use of tracking technology, disclosure of your Personal Data for third-parties to advertise to you, our advertising to you, and other targeted advertising. 

We do not control the collection and use of your information collected by third parties described above in Disclosure of Your Information. When possible, these organizations are under contractual obligations to use this data only for providing the services to us and to maintain this information strictly confidential. These third parties may, however, aggregate the information they collect with information from their other customers for their own purposes.

In addition, we strive to provide you with choices regarding the Personal Data you provide to us. We have created mechanisms to provide you with control over your Personal Data:

Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. You can also configure our cookie manage to refuse some browser cookies by clicking the cookie consent manager at the bottom of each page of the Platform. If you disable or refuse cookies, please note that some parts of our Platform may then be inaccessible or not function properly.

11. Your Rights Regarding Your Information and Accessing and Correcting Your 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 users of our Platform, regardless of jurisdiction. Where applicable data protection law provides for a supervisory authority or other similar regulator, you also have the right to complain to such entity about our processing of your Personal Data.

Applicable data protection laws may provide you with certain rights with regards to our processing of your Personal Data, however we generally provide these rights to users of our Platform, regardless of jurisdiction.

• Access and Update. You can review and change your Personal Data by logging into the Platform and visiting your “Account” page when this choice is made available to you, or by logging into your third-party provider that you use to authenticate yourself to the Platform and adjusting your Personal Data. You may also notify us through the “Contact Information“ section below of any changes or errors in any Personal Data we have about you to ensure that it is complete, accurate, and as current as possible. We may also not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.
• Restrictions. You have the right to restrict our processing of your Personal Data under certain circumstances. In particular, you can request we restrict our use of it if you contest its accuracy, if the processing of your Personal Data is determined to be unlawful, or if we no longer need your Personal Data for processing but we have retained it as permitted by law.
• Portability. To the extent the Personal Data you provide Sharethrough is processed based on your consent and that we process it through automated means, you have the right to request that we provide you a copy of, or access to, all or part of such Personal Data in structured, commonly used and machine-readable format. You also have the right to request that we transmit this Personal Data to another controller, when technically feasible.
• Withdrawal of Consent. To the extent that our processing of your Personal Data is based on your consent, you may withdraw your consent at any time by closing your account. Withdrawing your consent will not, however, affect the lawfulness of the processing based on your consent before its withdrawal, and will not affect the lawfulness of our continued processing that is based on any other lawful basis for processing your Personal Data.
• Right to be Forgotten. You have the right to request that we delete all of your Personal Data. In some cases, we cannot delete your Personal Data except by also deleting your employer’s account. While we may suspend or otherwise close your employer’s account prior to deleting the information, we will only delete your Personal Data when we no longer need to maintain it as part of a decision to terminate our agreement with your employer or to otherwise cease communications with your employer or when we no longer need to retain it to comply with our internal record keeping policies or any applicable international, federal, state, or local law or regulation. Additionally, we may not accommodate a request to erase your Personal Data if we believe the deletion would violate any law or legal requirement or cause the information to be incorrect. In all other cases, we will retain your Personal Data as set forth in this policy. In addition, we cannot completely delete your Personal Data as some data may rest in previous backups. These will be retained for the periods set forth in our disaster recovery policies.
• Complaints. You have the right to lodge a complaint with the applicable supervisory authority in the country you live in, the country you work in, or the country where you believe your rights under applicable data protection laws have been violated. However, before doing so, we request that you contact us directly in order to give us an opportunity to work directly with you to resolve any concerns about your privacy. ‍
• How You May Exercise Your Rights. You may exercise any of the above rights by contacting us through any of the methods listed under the “Contact Information” section below and through the live chat feature of our Platform. If you contact us to exercise any of the foregoing rights, we may ask you for additional information to verify your identity. We reserve the right to limit or deny your request if you have failed to provide sufficient information to verify your identity or to satisfy our legal and business requirements. Please note that if you make unfounded, repetitive, or excessive requests (as determined in our reasonable discretion) to access your Personal Data, you may be charged a fee subject to a maximum set by applicable law.

12. Jurisdiction Privacy Rights

The law in certain jurisdictions may provide their residents with additional rights regarding our use of your Personal Data.

The law in some states may provide you with additional rights regarding our use of Personal Data. To learn more about any additional rights that may be applicable to you as a resident of one of these jurisdictions, please see the privacy addendum for your jurisdiction that is attached to this Advertising Platform Privacy Notice, if any.

13. Do Not Track Signals

We may use automated data collection technologies to track you across online services. We currently do not honor do-not-track signals that may be sent by some browsers.

We also may use automated data collection technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities. At this time, we do not honor such signals and we do not modify what information we collect or how we use that information based upon whether such a signal is broadcast or received by us.

14. Data Security

Information transmitted over the Internet is not completely secure, but we do our best to protect your Personal Data. You can help protect your Personal Data and other information by keeping your password to our Platform confidential. 

We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure. 

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. 

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Platform. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures deployed on the Platform.

15. Consent to Processing of Personal Data in Other Countries Outside of Your Home Country

We may process your Personal Data outside of your home country, including to the United States. We only do this when we are legally permitted to do so and when we have appropriate safeguards in place to protect your Personal Data. 

In order to permit you and your employer use and access of our Platform, we may send and store your Personal Data outside of the country where you reside or are located, including to countries that may not or do not provide an equivalent level of protection for your Personal Data. Your information may be processed and stored in the United States and in Canada and United States and Canadian federal, state, provincial, and local governments, courts, or law enforcement or regulatory agencies may be able to obtain disclosure of your information through the laws of the United States or Canada. By using our Platform, you represent that you have read and understood the above and hereby consent to the storage and processing of Personal Data outside the country where you reside or are located, including in the United States and Canada.

Your Personal Data is transferred by Sharethrough to another country only if it is required or permitted under applicable data protection law and provided that there are appropriate safeguards in place to protect your Personal Data. To ensure your Personal Data is treated in accordance with this Advertising Platform Privacy Notice when we transfer it to a third party, Sharethrough uses Data Protection Agreements between Sharethrough and all other recipients of your data where required by law. These Data Protection Agreements include, where applicable, the Standard Contractual Clauses adopted by the European Commission (the “Standard Contractual Clauses”). The European Commission has determined that the transfer of Personal Data pursuant to the Standard Contractual Clauses provides for an adequate level of protection of your Personal Data, but may need to be supplemented with additional measures on a case-by-case basis after an analysis that such supplemental measures can provide you with an essentially equivalent level of protection as afforded in the EU. When, as a result of this analysis, we believe this to be appropriate and necessary, these Standard Contractual Clauses have been supplemented in this way. Under these Standard Contractual Clauses, you have the same rights as if your data was not transferred to such third country. When applicable, you may request a copy of the Data Protection Agreement by contacting us through the “Contact Information” section below.

16. Data Retention Periods

We retain your Personal Data for as long as you keep your account open. In some instances, we may keep it after you close your account, for example we may keep it:

• on our backup and disaster recovery systems;
• for as long as necessary to protect our legal interests; and
• and to comply with other legal requirements.

Sharethrough will retain your Personal Data for the entire time that your account remains open with your employer and you are provided access to it. After your account is closed, we may retain your Personal Data for one (1), or for any of the reasons listed below, whichever is longer:

• for as long as necessary to comply with any legal requirement; 
• on our backup and disaster recovery systems in accordance with our backup and disaster recovery policies and procedures;
• for as long as necessary to protect our legal interests or otherwise pursue our legal rights and remedies; and
• for data that has been aggregated or otherwise rendered anonymous in such a manner that you are no longer identifiable, indefinitely.

17. Changes to Our Advertising Platform Privacy Notice

We will post any changes to our Advertising Platform Privacy Notice on our Platform. If we make material changes to our Advertising Platform Privacy Notice, we may notify you of such changes through your contact information and invite you to review (and accept, if necessary) the changes. 

We may change this Advertising Platform Privacy Notice at any time. It is our policy to post any changes we make to our Advertising Platform Privacy Notice on this page with a notice that the Advertising Platform Privacy Notice has been updated on the Platform’ home page. If we make material changes to how we treat our Platform users’ Personal Data, we will notify you by email to the email address specified in your account and through a notice on the Platform’ home page. The date this Advertising Platform Privacy Notice was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Platform and this Advertising Platform Privacy Notice to check for any changes.

18. Contact Information

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. 

To Contact Sharethrough (Controller)

Sharethrough
5455 Gaspe Avenue, Suite 730
Montreal, Quebec,
Canada H2T 3B3
Attn: Legal Department
Email: dataprotection@sharethrough.com

To Contact Our EU Representative (EEA)

Legal Army c/o Sharethrough Inc.
Enrique Extremera Maestro
C. de la Princesa, 31,
Moncloa – Aravaca,
Madrid, Spain, 28008
Email: dpo@sharethrough.com

To Contact Our Data Protection Officer (Canada)

Chantal Bernier
99 Bank Street
Suite 1420
Ottawa, Ontario K1P 1H4
Canada
+1 (613) 783-9600
Email: chantal.bernier@dentons.com