SproutLoud Privacy Policy

A. Who We Are

SproutLoud is an online marketing platform (the “Engine”) operated by SproutLoud Media Networks, LLC, a company headquartered in the State of Florida in the United
States (“We”, “us” “our” and “SproutLoud”). The Engine enables our Users to advertise their products and services of the brands they sell (“Network Sponsors”) to their local community, prospects and customers. We collect performance data from these advertisements for reporting purposes for our Users and Network Sponsors. Find out
more about SproutLoud by reviewing our website, found here at https://www.sproutloud.com. We collect personal information that is relevant to the purpose of our website. This information allows us to provide you with better products and services, including a customized and efficient experience to serve you better.

B. Defined Terms

This privacy policy uses the following defined terms that have the associated meanings:

“Application Services” means the provision of electronic access to SproutLoud’s marketing services over a computer network and related technical support services.

The “Engine” means SproutLoud’s proprietary software and web-based application.

“Marketing Services” means all marketing products and services sold or ordered through the Engine to or by Users.

“Network Sponsor” means any business which provides content, artwork, and other marketing materials for your use through Marketing Services.

“Personal Information” means any information that identifies a User, a User Contact or a Visitor, directly or indirectly. Examples of Personal Information include, but are not limited to, first and last name, date of birth, email address, gender, occupation or other demographic information.

“Users” means any person or entity that is registered with SproutLoud to use the Engine.

“User Contact” is a person a User may contact through the Engine that is on a User List, which a User may use for advertising purposes. For example, if you receive a direct mail or email from a User through SproutLoud, you would be considered a User Contact.

“User List” is a list of User Contacts a User may upload (or in some cases purchase), collect through User Websites, or manage, which may contain names, contact information (email or addresses) and any other information associated with a User Contact.

“Vendors” means any and all third-party person(s) and/or entity(ies) that provides products and/or services to you via your access to the Engine.

“Visitor” means any person who visits any of our Websites.

“Websites” means any websites or web applications we own, or operate using third-party software, any web pages, interactive features, applications, web form plug-ins or other online offerings that post a link to this privacy policy.

“You” and “Your” means, depending on the context and your relationship to SproutLoud, either a User, a User Contact or a Visitor.

This section applies to the Visitors on SproutLoud Websites and the Personal Information we collect and process from each Visitor in the usual course of business, including: advertising our products and services, business development, and recruiting new SproutLoud employees. In this Section, “you” and “your” refer to Visitors.

A. Information Collected About You

(i) Information you provide to us on the Websites or otherwise:

Certain parts of our Websites may ask you to provide Personal Information voluntarily. For example, we may ask you to provide certain Personal Information (such as your name, contact details, company name, profile information) in order to:

(a) sign up as a User on the Engine

(b) sign up to receive marketing content or emails from SproutLoud

(c) apply for employment with SproutLoud

(d) or otherwise submit inquiries to us

We may also collect additional Personal Information in order to service our relationship with you, such as any additional details you submit to us, when you attend our events, take part in surveys, or through other business or marketing interactions we may have with you. You may choose to provide additional information when you communicate with us or otherwise interact with us, and we will keep copies of any such communications for our records.

The Personal Information that you are asked to provide will be made clear to you at the point we ask you to provide your Personal Information. We will also let you know prior to collection whether the provision of the Personal Information is required so that we have the relevant information in the context of the reason we are asking you to provide such information.

(ii) Information we collect automatically through the Websites:

When you visit our Websites, we may also collect certain information automatically from your device. In some countries, including countries in the European Economic Area, this information may be considered Personal Information under applicable data protection laws.

As an example, we may automatically register your IP address, your operating system, your browser ID, your browsing activity, the content you consume and other information about your system and connection and how you interact with our Websites, the Engine and any of the Marketing Services. We may collect this information as a part of log files as well as through the use of cookies or other tracking technologies.

We receive and store certain types of information whenever you interact with us. SproutLoud and its authorized agents automatically receive and record certain “traffic data” on their server logs from your browser including your IP address, SproutLoud cookie information, and the page you requested. SproutLoud uses this traffic data to help diagnose problems with its servers, analyze trends and administer the website. We may also use this data to better communicate with you based on your interests on our Website.

B. Information Collected Related to California Residents
During the last twelve (12) months, we have collected the following categories of personal information from consumers.

Category	Type of Identifiers We Collect	Collected
A. Identifiers.	First and last name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address.	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, address, telephone number, employment, employment history.	YES
C. Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	YES
D. Professional or employment-related information	Current or past job history or performance evaluations	YES

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, from form fields which you complete on our website.
• Activity on our website (www.sproutloud.com). For example, from website usage details that are collected automatically. In addition, like many companies, we use “cookies” which are small text files a website can use to recognize repeat users, facilitate the user’s ongoing access to and use of the site and to track usage behavior of, for example, the webpages you visit.
• From third parties that assist us in providing certain transactions and services (e.g. hosting), even though it appears that you may not have left our Site.

C. Use of Personal Information

We may use the information we collect through our Websites for a range of reasons, including:

– To operate, improve or maintain our Websites
– To send you information for marketing and sales purposes, in accordance with your marketing preferences or sales requests
– For recruitment purposes if you have applied for a career opening with SproutLoud
– To respond to your online inquiries and requests, and to provide you with information and access to resources or services that you have requested from us
– To manage our Websites and system administration and security
– To improve the navigation and content of our Websites
– To identify any server problems or other IT or network issues
– To compile aggregated statistics about site usage and to better understand the preferences of our Visitors
– To carry out research and development to improve our products and services
– To customize content and layout of the Websites
– To carry out other legitimate business purposes
– To comply with all applicable legal requirements
–To investigate possible fraud or other violations of our Terms of Use or this Privacy Policy and/or attempts to harm our Users

In addition, we may combine Personal Information with other information we collect or obtain about you (such as information we source from our third-party partners) to serve you specifically, such as to deliver content, a product or service according to your preferences or restrictions, or for advertising or targeting purposes in accordance with this privacy policy. When we combine Personal Information with other information in this way, we treat it as, and apply all of the safeguards in this privacy policy applicable to, Personal Information.

C. Public Information, Third-Party Websites and Vendors, Social Media

Our Websites include social media features that allow you to post content from our Websites to various social media properties, such as Google+, Twitter and Facebook integration widgets. These features may collect information about your IP address and which page you are visiting on our Website, and they may set a cookie to make sure the feature functions properly.

SproutLoud does not host these features, nor any Personal Information which you may submit to these social media platforms. Your use of these features is at your own risk without any expectation of privacy. Please be sure to review the privacy of such social media properties before using these widgets.

Links to third-party websites. Our Websites may reference third-party properties, containing hyperlinks that allow You to move to a different site. Each website may have privacy policies that differ from SproutLoud’s policies. We encourage you to carefully read the privacy policy of such websites you visit.

SproutLoud uses third-party technology and services to provide services to SproutLoud to help identify, track and/or monitor Your interactions with our Websites. In each case, when relevant and appropriate according to data security laws, SproutLoud has signed a Data Protection Agreement with such party acting as a Data Processor.

D. Visitor Privacy Choices

You may have certain rights relating to your Personal Information, subject to local data protection law. Whenever you choose to visit our Site, we aim to provide you with choices about how we use your Personal Information. Subject to applicable law, you may obtain a copy of Personal Information we maintain about you. In addition, if you believe that Personal Information we maintain about you is inaccurate, subject to applicable law, you may have the right to request that we correct or amend the information by contacting us as indicated here. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to the information.

• Privacy Rights Specific to California Residents

Under the California Consumer Privacy Act, California residents have specific rights regarding their personal information. This section describes Californians’ rights and explains how California residents can exercise those rights. For additional information on our practices with respect to California law, please see our Privacy Notice for Californians.

Below we further outline specific rights which California residents may have under the California Consumer Privacy Act.

1. Right to Access. You have the right to access the personal information we have collected about you. If requested, we will provide you with a copy of the personal information we have collected.
2. Right to Know. You have the right to request that disclose the following about your personal information in the preceding 12 months:
   a. What personal information we have collected;
   b. The categories of personal information we collected;
   c. The categories of sources from which we collected your personal information;
   d. The business purposes for collecting or sharing your personal information;
   e. The categories of personal information we may disclose for business purposes; and
   f. The categories of third parties to whom we share your personal information.
3. Right to Delete. You have the right to request that we delete your personal information. Upon verifying your identity and the validity of your request, we will delete your personal information from our records [and instruct our service providers, affiliates, or third parties to delete your information]. We may deny your deletion request if retaining the information is permitted under law.
4. Right to Correct. You have the right to correct inaccurate personal information. Upon verifying your identity and the validity of your request, we will use reasonable efforts to correct your personal information as directed. In certain circumstances, we may not be able to satisfy this request depending on the nature of the personal information and purposes for maintaining it.
5. Right to Opt-out of Selling.. [We do not sell personal information within the meaning of California law; for that reason, we do not offer a separate opt-out right.]
6. Right to Opt-Out of Sharing Sensitive Personal Information. You have the right to limit how your sensitive personal information is used and/or disclosed to third
   parties. [We do not store Sensitive Personal Information other than where we are required by law; for that reason, we do not offer a separate opt-out right.]
7. Right to Opt-Out of Sharing Personal Information for Behavioral Advertising. You have the right to opt of the sharing of your data for cross-context behavioral advertising purposes. Please visit our “Change cookie settings” at the bottom of any www.sproutloud.com webpage.

Please note that we may take steps to verify your identity before granting you access to information or acting on your request to exercise your rights. In connection with such verification, we may ask you to provide the information as specified in our Data Access Request Policy. We may limit our response to your exercise of the above rights as permitted by law.

We may not discriminate against you for exercising any of your rights under California law. This means that we may not deny you services, or charge you different prices or rates for services or provide you with a different level or quality of services (or suggest that we will do so), in response to a request made under California law. However, we may charge different prices or rates, or provide a different level or quality of services, where that difference is reasonably related to the value provided to us by your personal information.

• Exercising Your Rights

If you are a California resident who chooses to exercise your rights, you can:

1. Submit a request via email to [email protected], or
2. Call (877) 757-3727 to submit your request.

You may designate an authorized agent to make a request to know or request to delete on your behalf. An agent may be an individual, or a business entity. To designate an authorized agent, you must provide the agent with written permission to submit the request. We may still require you to confirm that you have authorized an agent to act on your behalf and to verify your identity directly (subject to certain exceptions). We may refuse a request if the agent does not provide adequate proof of their authorization.

• Privacy Rights Specific to European Union Residents

The European Union’s General Data Protection Regulation (“GDPR”), and corresponding legislation in the United Kingdom and Switzerland, provide European, Switzerland and United Kingdom residents with certain rights in connection with Personal Information you have shared with us. If you are resident in the European Economic Area, you may have the following rights:

1. The right to be informed. You are entitled to be informed of the use of your Personal Information. This Privacy Policy provides such information to you.
2. The right of access. You have the right to request a copy of your Personal Information which we hold about you.
3. The right of correction. You have the right to request correction or changes of your Personal Information if it is found to be inaccurate or out of date.
4. The right to withdraw consent. You have the right to withdraw a previously given consent for processing your Personal Information for a specific purpose.
5. The right to be forgotten. You have the right to request us, at any time, to delete your Personal Information from our servers and to erase your Personal Information when it is no longer necessary for us to retain such data. Note, however, that deletion of your Personal Information will likely impact your ability to use our services.
6. The right to object (opt-out). You have the right to opt-out of certain uses of your Personal Information, such as direct marketing, at any time.
7. The right to data portability. You have the right to a “portable” copy of your Personal Information that you have submitted to us. Generally, this means your right to request that we move, copy or transmit your Personal Information stored on our servers or information technology environment to another service provider’s servers or information technology environment
8. The right to refuse to be subjected to automated decision making, including profiling. You have the right not to be subject to a decision and insist on human intervention if the decision is based on automated processing and produces a legal effect or a similarly significant effect on you.
9. The right to lodge a complaint with a supervisory authority. You have the right to lodge complaints about our data processing activities by filing a complaint with us or with the relevant Supervisory Authority. A list of Supervisory Authorities is available here: http://ec.europa.eu/justice/dataprotection/bodies/authorities/index_en.htm.

You may exercise any of the rights described in this section by sending an email to [email protected]. Please note that we may ask you to verify your identity and request before taking further action on your request. We may respond to your request by letter, email, telephone or any other suitable method.

This section applies to the Users on SproutLoud’s Engine and the Personal Information we collect and process from each User in order to provide Application Services and Marketing Services or better serve a User request on the Engine. In this Section, “you” and “your” refer to Users.

A. Information Collected About You

You provide information to us when you use our Engine, our Marketing Services and/or our Application Services. We may sometimes collect and use Personal Information including your name, email, phone number, credit card information and physical mailing address as a way to communicate with you or fulfill your instructions or orders related to your use of the Engine or purchase of Marketing Services. By giving us this information, you agree to this information being collected, used and disclosed as described in our Terms of Use found here (wwww.sproutloud.com/legal/terms) and in this privacy policy. In order to send an email, text or direct mail campaign using Marketing Services, you may sometimes provide us information about your User Contacts. We use and process this information to provide the Marketing Services in accordance with your instructions.

We collect information automatically on you about the devices you use and the manner in which you interact with Application Services and the Engine. We use cookies and other tracking technologies, which may include recording your interactions for Engine usability studies, log data, device, IP information and product usage/interaction data.

We may collect information from other sources about you — most primarily your Network Sponsors. We use this information to provide Application Services, Marketing Services and access to the Engine accordingly.

SproutLoud and our partners may use various technologies to collect and store information when you use the Engine, and this may include using cookies and similar tracking technologies, such as pixels and web beacons. These web beacons track certain behavior such as how User Contacts or Visitors interact with the Marketing Services you purchase. They also allow us to collect information such as the recipient’s IP address, browser, email client type and other similar details. We use this information to measure the performance of your Marketing Services, and to provide analytics information and enhance the effectiveness of our Marketing Services. Reports are also available to us when we communicate to you, so we may collect and review that information.

B. Information Collected Related to California Residents
During the last twelve (12) months, we have collected the following categories of personal information from consumers.

Category	Type of Identifiers We Collect	Collected
A. Identifiers.	First and last name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address.	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, address, telephone number, credit card number, debit card number, or any other financial information.	YES
C. Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	YES

 

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from our Users. For example, when our clients engage our services.
• Indirectly from our clients or their agents. For example, through information we collect from our clients in the course of providing services to them.
• Directly and indirectly from activity when you use the Engine. For example, usage details that are collected automatically.
• From social media websites, such as Google, Twitter, and Facebook.
• From third parties that assist us in providing certain transactions and services (e.g. payment processing, and hosting), even though it appears that you may not have left our Site.

C. Use of Personal Information
We may use the information we collect through Marketing Services and the Engine for a range of reasons, including:

– To communicate with you about your account and provide customer support
– To improve the Engine, Application Services and our Marketing Services
– To provide User data, spend history and other reporting data back to your Network Sponsor about your performance in Marketing Services
– To bill you for monies owed
– To provide suggestions to you and to send you Engine alert messages
– To enforce compliance with our Terms of Use and other applicable laws, and to protect the rights and safety of our Users and third parties
– For our data analytics projects that consume data from multiple accounts of your Network Sponsor to provide collective insights, averages and other non-identifiable information to help improve every User’s marketing performance on the Engine
– To meet legal requirements; to respond to lawful requests by public authorities; to comply with our legal, account or security requirements by providing information to lawyers or accountants; to prosecute or to provide defense in a legal proceeding

D. User Privacy Choices

You may have certain rights relating to your Personal Information, subject to local data protection law. Whenever you choose to be a guest or visitor at one of our managed properties, we aim to provide you with choices about how we use your Personal Information. Subject to applicable law, you may obtain a copy of Personal Information we maintain about you. In addition, if you believe that Personal Information we maintain about you is inaccurate, subject to applicable law, you may have the right to request that we correct or amend the information by contacting us as indicated in the “How to Contact Us” section below. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to the information.

• Privacy Rights Specific to California Residents

Under the California Consumer Privacy Act, California residents have specific rights regarding their personal information. This section describes Californians’ rights and explains how California residents can exercise those rights. For additional information on our practices with respect to California law, please see our Privacy Notice for Californians.

Below we further outline specific rights which California residents may have under the California Consumer Privacy Act.

1. Right to Access. You have the right to access the personal information we have collected about you. If requested, we will provide you with a copy of the personal information we have collected.
2. Right to Know. You have the right to request that disclose the following about your personal information in the preceding 12 months:
   a. What personal information we have collected;
   b. The categories of personal information we collected;
   c. The categories of sources from which we collected your personal information;
   d. The business purposes for collecting or sharing your personal information;
   e. The categories of personal information we may disclose for business purposes; and
   f. The categories of third parties to whom we share your personal information.
3. Right to Delete. You have the right to request that we delete your personal information. Upon verifying your identity and the validity of your request, we will delete your personal information from our records [and instruct our service providers, affiliates, or third parties to delete your information]. We may deny your deletion request if retaining the information is permitted under law.
4. Right to Correct. You have the right to correct inaccurate personal information. Upon verifying your identity and the validity of your request, we will use reasonable efforts to correct your personal information as directed. In certain circumstances, we may not be able to satisfy this request depending on the nature of the personal information and purposes for maintaining it.
5. Right to Opt-out of Selling. [We do not sell personal information within the meaning of California law; for that reason, we do not offer a separate opt-out right.]
6. Right to Opt-Out of Sharing Sensitive Personal Information. You have the right to limit how your sensitive personal information is used and/or disclosed to third parties. [We do not store Sensitive Personal Information other than where we are required by law; for that reason, we do not offer a separate opt-out right.]
7. Right to Opt-Out of Sharing Personal Information for Behavioral Advertising. You have the right to opt of the sharing of your data for cross-context behavioral advertising purposes. Please visit our “Change cookie settings” at the bottom of any www.sproutloud.com webpage.

Please note that we may take steps to verify your identity before granting you access to information or acting on your request to exercise your rights. In connection with such verification, we may ask you to provide the information as specified in our Data Access Request Policy. We may limit our response to your exercise of the above rights as permitted by law.

We may not discriminate against you for exercising any of your rights under California law. This means that we may not deny you services, or charge you different prices or rates for services or provide you with a different level or quality of services (or suggest that we will do so), in response to a request made under California law. However, we may charge different prices or rates, or provide a different level or quality of services, where that difference is reasonably related to the value provided to us by your personal information.

• Exercising Your Rights

If you are a California resident who chooses to exercise your rights, you can:

1. Submit a request via email to [email protected], or
2. Call (877) 757-3727 to submit your request.

You may designate an authorized agent to make a request to know or request to delete on your behalf. An agent may be an individual, or a business entity. To designate an authorized agent, you must provide the agent with written permission to submit the request. We may still require you to confirm that you have authorized an agent to act on your behalf and to verify your identity directly (subject to certain exceptions). We may refuse a request if the agent does not provide adequate proof of their authorization.

• Privacy Rights Specific to European Union Residents

The European Union’s General Data Protection Regulation (“GDPR”), and corresponding legislation in the United Kingdom and Switzerland, provide European, Switzerland and United Kingdom residents with certain rights in connection with Personal Information you have shared with us. If you are resident in the European Economic Area, you may have the following rights:
10. The right to be informed. You are entitled to be informed of the use of your Personal Information. This Privacy Policy provides such information to you.
11. The right of access. You have the right to request a copy of your Personal Information which we hold about you.
12. The right of correction. You have the right to request correction or changes of your Personal Information if it is found to be inaccurate or out of date.
13. The right to withdraw consent. You have the right to withdraw a previously given consent for processing your Personal Information for a specific purpose.
14. The right to be forgotten. You have the right to request us, at any time, to delete your Personal Information from our servers and to erase your Personal Information when it is no longer necessary for us to retain such data. Note, however, that deletion of your Personal Information will likely impact your ability to use our services.
15. The right to object (opt-out). You have the right to opt-out of certain uses of your Personal Information, such as direct marketing, at any time.
16. The right to data portability. You have the right to a “portable” copy of your Personal Information that you have submitted to us. Generally, this means your right to request that we move, copy or transmit your Personal Information stored on our servers or information technology environment to another service provider’s servers or information technology environment.
17. The right to refuse to be subjected to automated decision making, including profiling. You have the right not to be subject to a decision and insist on human intervention if the decision is based on automated processing and produces a legal effect or a similarly significant effect on you.
18. The right to lodge a complaint with a supervisory authority. You have the right to lodge complaints about our data processing activities by filing a complaint with us or with the relevant Supervisory Authority. A list of Supervisory Authorities is available here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

You may exercise any of the rights described in this section by sending an email to [email protected]. Please note that we may ask you to verify your identity and request before taking further action on your request. We may respond to your request by letter, email, telephone or any other suitable method.

E. User Personal Information Is Not Sold

User Contacts you upload onto SproutLoud are owned by you. SproutLoud never sells or rents your customer data. For more information about our list policy, click here: https://sproutloud.com/legal/list-policy

F. Compliance with this Policy

Your acceptance of this privacy policy is included in SproutLoud’s Terms of Use and is critical in order to provide you access to the Engine and Marketing Services. To access, correct or update your Personal Information, you can access your Account on the Engine and do so on your own or request us to help you do so by contacting customer service. In the event you wish to delete access to your Personal Information, and this impedes our ability to serve you, we will give you the option to close your account and erase all Personal Information on our systems that are not necessary to comply with legal, tax, or government authorities, or as necessary to comply with the law or legal proceedings.

In addition, individuals who are residents of the EEA can object to processing of their Personal Information or ask to restrict processing of their Personal Information. If this impedes our ability to serve you, we will give you the option to close your account and erase all Personal Information on our systems that are not necessary to comply with legal, tax or government authorities, or as necessary to comply with the law or legal proceedings. In order to request portability of your information, please contact [email protected]. If any of your User Contacts wishes to exercise any of these rights, they should contact you directly, or contact us as described in the “User Contacts” section below.

Similarly, if we have collected and processed your Personal Information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.

You have the right to complain to a data protection authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. We may ask you to verify your identity in order to help us respond efficiently to your request.

This section applies to the User Contacts uploaded to SproutLoud’s Engine by Users, of which Personal Information may be used by SproutLoud or Vendors providing Marketing Services to Users. User Contacts may receive SMS messages, email, direct mail, cookie-tracking technologies or other re-targeting media from Users using SproutLoud, or may interact with User websites or landing page web forms generated by the Engine or Marketing Services ordered by Users. In this Section, “you” and “your” refer to Users.

A. Information Collected About You

SproutLoud may receive or collect Personal Information that falls into one of the following categories:

– Information we receive about User Contacts from our Users: Users may provide Personal Information about you to SproutLoud through the Engine, such as when a User uploads a User Contact List for Marketing Services to advertise to you, or when you may sign up on a web form or through any other means where you provide information to the User (through a SproutLoud Marketing Service). You may also have the opportunity to update your preferences of receiving such Marketing Services by providing your opt-out preferences through an email unsubscribe page, or providing such information directly to the User to include in a Do Not Contact List. Do Not Contact lists apply to SMS, email and direct mail Marketing Services only.

– Information we collect automatically: When you interact with a Marketing Service ordered by a User, such as an email or a Website, we may collect information about your device and interaction with such Marketing Service. We use cookies and other tracking technologies to collect this information. We may share this information with Users to help them advertise more relevant and timely offers that you may be interested in.

– Information we collect from other sources or Vendors: We may obtain information about you from Marketing Services provided by Vendors, such as call-tracking Vendors, or third-party data providers, that may provide us supplemental information about you.

We take steps to ensure that such third parties are legally or contractually permitted to disclose such information to us. We may share this information with Users to help them advertise more relevant and timely offers that you may be interested in.

B. Use of Personal Information

We may use the information we collect about you for a range of our legitimate business interests reasons, including:

– To provide data or communicate with Users and Network Sponsors about your responses to User advertisements
– To provide to Vendors for the processing of Marketing Services for our Users
– To provide to our Users based on a lead form request or call
– To improve the Engine and our Marketing Services
– To enforce compliance with our Terms of Use and other applicable laws, and to protect the rights and safety of our Users and third parties – For our data analytics projects that consume data from multiple Users to provide collective insights, averages and other non-identifiable information to help improve every User’s marketing performance on the Engine – To meet legal requirements; to respond to lawful requests by public authorities; to comply with our legal, account or security requirements by providing information to lawyers or accountants; to prosecute or to provide defense in a legal proceeding

C. Legal Basis for Processing

We manage and process Personal Information in accordance with our Terms of Use (www.sproutloud.com/legal/terms) and as such, in accordance with all data security and privacy laws, where such processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. Our legitimate interests typically include: improving, maintaining, providing and enhancing our technology, the Engine and Application Services; ensuring the security of the Engine and our Websites; and our Marketing Services activities.

D. Data Protection Rights

You have the following data protection rights:

– To access, correct, update, or request deletion of your Personal Information. SproutLoud takes reasonable steps to ensure that the data we collect is reliable for its intended use, accurate, complete and up to date. You may contact us directly at any time about accessing, correcting, updating or deleting your Personal Information, or altering your data or marketing preferences by emailing us at [email protected]. We will consider your request in accordance with applicable laws.

– In addition, if you are a resident of the EEA, you can object to processing of your Personal Information, ask us to restrict processing of your Personal Information or request portability of your Personal Information. Again, you can exercise these rights by emailing us at [email protected]. For much of the Personal Information we collect and process about you through the Application Services, we act as a processor on behalf of our Users. In such cases, if you are a User Contact and want to exercise any data protection rights that may be available to you under applicable law or have questions or concerns about how your Personal Information is handled by SproutLoud as a processor on behalf of our Users, you should contact the relevant User that is using the SproutLoud Engine, Application Services or Marketing Services, and refer to their separate privacy policies.

– If you no longer want to be contacted by one of our Users through our Services, please unsubscribe directly from that User’s email or contact the User directly to add you to their Do Not Contact list. If you contact us directly, we may remove or update your information within a reasonable time and after providing notice to the User of your request.

– You have the right to complain to a data protection authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. We may ask you to verify your identity in order to help us respond efficiently to your request.

This section applies to any additional relevant information on how we collect, process and store your Personal Information.

A. Who We Share Information With

We may share and disclose your Personal Information to third parties for the purposes described in this privacy policy. For purposes of this section, Users, User Contact and Visitors are referred to as “you” and “your”.

In the preceding twelve (12) months, we have disclosed the following categories of Personal Information for one or more business purposes:

• Identifiers;
• California Customer Records Personal Information categories;
• Internet or other network activity information.
• Professional or employment-related information

The categories of third parties to whom we have disclosed your Personal Information include the following:

– Hosting Services Vendors, Office System Vendors and Software Services Vendors as outlined here.
– Our Marketing Services Vendors may receive User Contact or User Personal Information to help them carry out the Marketing Services ordered. For example, our printers may receive physical addresses of individuals to send direct mail, or our email service providers may receive email addresses to deliver email.
– Our Engine service providers may receive or collect User Contact or User information in order to provide the operations of the Engine. For example, we may send information to our website analytics services provider to tell us which pages are frequented most by our Users, or which areas of the Engine are causing User frustration. We may also send information to our service providers to better serve our Users with offers and messages.
– Network Sponsors may receive User Contacts, Visitors and User information to help them understand the performance of Marketing Services made available through SproutLoud and other matters concerning our services.
– To support the operation of our services and websites, as well as to better personalize your experience and communications from SproutLoud via tracking technology as outlined by our Cookie Policy.
– Any competent law enforcement body, regulatory body, government agency, court or other third party where we believe disclosure is necessary (a) as a matter of applicable law or regulation, (b) to exercise, establish or defend our legal rights, or (c) to protect your vital interests or those of any other person.
– A potential buyer (and its agents and advisors) in the case of a sale, merger, consolidation, liquidation, reorganization or acquisition.
– Any other person whom you give approval to share such information.

B. Legal Basis for Processing Personal Information (EEA Persons Only)

If you are from the European Economic Area, our legal basis for collecting and using the Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it.

However, we will normally collect and use Personal Information from you where the processing is in our legitimate interests and not overridden by your data-protection interests or fundamental rights and freedoms. Usually, our legitimate interests typically include: improving, maintaining, providing and enhancing our technology, the Engine and Application Services; ensuring the security of the Engine and our Websites; and our Marketing Services activities.

If you are a User, we may need the Personal Information to perform a contract with you. In some limited cases, we may also have a legal obligation to collect Personal Information from you.

If we ask you to provide Personal Information to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Information is mandatory or not, as well as of the possible consequences if you do not provide your Personal Information.

Where required by law, we will collect Personal Information only where we have your consent to do so.

If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Information, please contact us at [email protected].

C. International Transfers

Our servers are located in the United States or on Google’s Cloud Platform. Our offices are located in the United States and Colombia. We also use a United States vendor, with offices in India, to help develop parts of the Engine and Application Services. We may use Vendors all over the world, in compliance with international export laws, to provide Marketing Services to Users in their respective countries. By submitting your information and Personal Information using the Sites, you agree to this transfer, storing or processing. We will take all steps necessary to ensure that your Personal Information is treated securely and in accordance with this Privacy Policy. We have put in place commercially reasonable technical and organizational procedures to safeguard the information and Personal Information we collect on the Sites. All our offices operate under our standardized data security policies and use best efforts to keep your data safe.

D. Our Data Security

SproutLoud takes commercially reasonable steps, both technical and organizationally in nature, to protect the Personal Information disclosed to SproutLoud from misuse, loss, unauthorized access, disclosure, alteration and destruction. We use industry standard encryption methods for encrypting confidential data during transmission and storage, and use best practices to protect certificates (including, without limitation, annual certificate changes). Once a year, we use a third-party, independent, nationally recognized, US-certified public accountant with applicable knowledge and experience as our Compliance Auditor. This Compliance Auditor provides a SSAE 16 Statement of Compliance at least annually covering our processes and operations in general and in matters related to data security.

E. Children

Our website is not intended for children under 16 years of age. We do not intentionally gather Personal information about visitors who are under the age of 16. If a child has provided us with Personal Information, a parent or guardian of that child may contact us to have the information deleted from our records. If you believe that we might have any information from a child under age 16 in the applicable jurisdiction, please contact us at [email protected]. If we learn that we have inadvertently collected the personal information of a child under 16, or equivalent minimum age depending on jurisdiction, we will take steps to delete the information as soon as possible.