Sharethrough Website 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 Privacy Notice
18. Contact Information

1. Introduction

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 districtm.net and 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:

• on our Websites;
• 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 operated by Sharethrough or any third-party (including our affiliates and subsidiaries);
• us from you as an advertiser or publisher (see our Advertising Platform Privacy Notice);
• us through cookies and other automatic collection technologies when individuals interact with third-party advertising on websites that use our advertising network (see Consumer Privacy Notice);
• 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), including through any application or content (including advertising) that may link to or be accessible from or on the Websites.

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.

2. Data Controller, Data Protection Officer, and Representative

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.

3. Children Under the Age of 18

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.

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 Websites, including any other data that may be deemed “personal data” or “personal information” under applicable law (“Personal Data”):

• by which you may be personally identified, such as name, postal address, e-mail address, telephone number;
• that is about you but individually does not identify you, such as traffic data, location data, logs, referring/exit pages, date and time of your visit to our Websites, error information, clickstream data, IP address, and other communication data and the resources that you access and use on the Websites; and/or
• about your internet connection, the equipment you use to access our Websites and usage details.

We collect this information:

• directly from you when you provide it to us; and
• automatically as you navigate through the Websites. Information collected automatically may include information collected through cookies, web beacons, and other tracking technologies.

Information You Provide to Us

The information we collect on or through our Websites are:

• information that you provide by filling in forms on our Websites. This includes information provided at the time of requesting more information through the “contact us” page of the Websites or when you request a demonstration of our technology and services. We may also ask you for information when you report a problem with our Websites; and
• records and copies of your correspondence (including email addresses), if you contact us.

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.

Information We Collect Through Automatic Data Collection Technologies

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:

• details of your visits to our Websites. We collect traffic data, location data, logs, referring/exit pages, date and time of your visit to our Websites, error information, clickstream data, and other communication data and the resources that you access and use on the Websites; 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 Websites and to deliver a better and more personalized service by enabling us to:

• estimate our audience size and usage patterns;
• store information about your preferences, allowing us to customize our Websites according to your individual interests;
• provide you advertising on third-party websites when you visit other websites, such as search platforms, social media platforms, and other platforms that are supported in some way be digital advertising content.
• recognize you when you return to our Websites.

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 Websites may use session cookies (which expire once you close your browser) and persistent cookies (which stay on your computer until you delete them, including retargeting cookies) to provide you with a more personal and interactive experience on our Websites. We only place cookies on your hard drive with your consent. You may withdraw or change your consent at any time by logging into your account and accessing your “Account” page. 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 Websites. You can find more information about cookies at allaboutcookies.org and youronlinechoices.eu.

• Session Cookies. Our use of cookies also includes “session cookies.” Each time you access the Website, 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 Website and track which pages of the Website you access. Session cookies are required to use the Website.
• Persistent Cookies. Our use of cookies includes the use of “persistent cookies.” These cookies remain on your computer after you leave our Websites and are used to recognize a visitor across multiple visits to our Websites. These persistent cookies allow us to adapt content, understand traffic patterns, measure advertising campaign efficiency, and enhance overall user experience.
• Retargeting Cookies. Retargeting cookies are a special type of persistent cookies that record visits and navigation on our Websites and are used to potentially retarget visitors on subsequent visits to other digital properties, such as search, social platforms, or other third0party websites that are supported by digital advertising.

• Web Beacons. Pages of our Website 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 website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Third-Party Use of Cookies and Other Tracking Technologies

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.

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), 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 Websites, you consent to our collection, use, and sharing of your Personal Data as described in this Privacy Notice. If you do not consent to this Privacy Notice, please do not use the Websites;
• 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 Websites; safeguard our IT infrastructure and intellectual property; detect and prevent fraud and other crime; and promote and market our business; ‍
• 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 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.

8. How We Use Your Information

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

• provide our Websites to you;
• provide you with information you request from us;
• enforce our rights arising from contracts;
• notify you about changes; and
• protect and improve our Websites.

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

• to present our Websites and their contents to you;
• to provide you with information, products, or services that you request from us;
• to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, such as our Terms of Use;
• to notify you about changes to our Websites or any products or services we offer or provide though them;
• to help maintain the safety, security, and integrity of our Websites, products and services, databases and other technology assets, and business;
• for internal testing, research, analysis, and product development, including to develop and improve our Website, 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;
• 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 Websites users is among the assets transferred;
• to fulfill any other purpose for which you provide it; and
• for any other purpose with your consent.

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.

9. Disclosure of 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:

• 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, 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:

• 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. If you disable or refuse cookies, please note that some parts of our Websites may then be inaccessible or not function properly. You may also control the types of cookies that we place on your computer by clicking on the “Cookies” link and adjusting your preferences.
• Promotional Offers from Sharethrough. By filling out the “Contact Us” form on our Websites’, you provide us consent to use your contact information to promote our products and services. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions.

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 (networkadvertising.org) and from members of the Digital Advertising Alliance on its website (aboutads.info).

California residents may have additional personal information rights and choices. Please see Jurisdiction-Specific Privacy Rights for more information.

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 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.

• Access and Update. You can review and change your Personal Data by notifying 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 contacting us through the “Contact Information” section below. 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. We may not accommodate a request to erase information 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. Where applicable data protection laws provide for a supervisory authority or other regulator for the privacy of your Personal Data, you may have the right to lodge a complaint with the applicable regulator in the jurisdiction you live in, the jurisdiction you work in, or the jurisdiction 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 Websites. 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 states, please see the privacy addendum for your state that is attached to this Privacy Notice.

Your California Privacy Rights

If you are a resident of California, you have the additional rights described in the California Privacy Addendum.

13. Do Not Track Signals

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.

14. Data Security

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.

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 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” section below.

16. Data Retention Periods

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:

• 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 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:

• 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 Privacy Notice

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.

18. Contact Information

You may contact us through the contact information below.