Privacy Policy

Sovren Technologies, Inc., and its affiliates (“Company,” “Sovren,” “we,” “our,” and/or “us”) value the privacy of individuals who use our social news applications, the websites where this Privacy Policy is posted (“Websites”), and related services (collectively, our “Services”). This privacy policy (the “Privacy Policy”) explains how we collect, use, and share information from our users (“Users,” “you,” and/or “your”) to facilitate your commenting, social news, and influencer networking experience. By using our Services, you agree to the collection, use, disclosure, and procedures this Privacy Policy describes. Beyond the Privacy Policy, your use of our Services is also subject to our Terms of Service.

We neither sell your information to third parties nor share your information with governments except in the limited circumstances described in this Privacy Policy (see Section 2 “How We Share the Information We Collect” below for more detail).

We recognize that information privacy is an ongoing responsibility, and so we will from time to time update this Privacy Policy as we undertake new privacy practices or adopt new privacy policies.

1. Information We Collect

“Personal Information” is information that identifies, relates to, describes, or can be reasonably linked to, directly or indirectly, a particular individual or household. We may collect Personal Information (as we have done in the past) from you on or through the Services in a variety of ways, including when you register on the Services, sign up for communications, or make any purchases. We also may, from time to time, use Personal Information about you to improve the Services, and for the various purposes outlined in this Privacy Policy.

Information You Provide to Us

Registration and Profile Information. When you sign up for an account or update your profile information, we collect Personal Information you provide to us such as your name, email address, phone number, display name, profile photo, preferred language, date of birth, and any Personal Information you voluntarily provide in your profile biography, including gender and location. Note: either an email address or phone number is required for registration purposes, and both are recommended for account security and ease in recovery.

Content you Share. We collect any information you choose to provide on our Services, such as posts, follows, photos, videos, gifs, comments, votes, and shares.

Payment Information. If you make a purchase through our Services, your payment-related Personal Information, such as your credit and debit card or automated clearing house (ACH) information, is collected and stored by our third-party payment processor on our behalf.

Communications. If you contact us directly, we receive additional Personal Information about you. For example, if you contact us for customer support, we may receive your name, email address, phone number, the contents of any message or attachments you may send to us, and any other information you choose to provide.

Your Contacts. If you permit us to access the address book on your device or give us permission to import your contacts from an email account associated with your account, we may access and store names and contact information, including Personal Information, from your address book, to help you follow your contacts, and your contacts to follow you.

Information We Collect When You Use Our Services

We may collect information that may not reasonably identify you or your household personally but is linked to your computer or device (“Device Identifiable Information”). We collect Device Identifiable Information from you in the normal course of providing the Services. When you visit our Services to browse, read, or download information, we automatically collect information about your computer that your browser sends, such as your IP address, browser type and language, access times, pages visited, and referring website addresses. We may use Device Identifiable Information to analyze trends, help administer and improve the Services, to learn about and determine which pages of the Websites visitors view and for how long, how visitors navigate throughout the Services, and to gather broad demographic information for aggregate use. We may also collect Device Identifiable Information through “cookies” or “web beacons” as explained below.

Device and Location Information. We receive Device Identifiable Information about the device and software you use to access our Services, including IP address (from which approximate or “coarse” location may be inferred), device type, web browser type, operating system version, phone carrier and manufacturer, member agents, application installations, device identifiers, mobile advertising identifiers, and push notification tokens.

Usage Information. We automatically receive Device Identifiable Information about your interactions with our Services, such as the posts or other content you view, the searches you conduct, the people you follow, and the dates and times of your visits.

Information from Cookies and Similar Technologies. We may collect information using cookies, pixel tags, and similar technologies. Cookies are small text files containing a string of alphanumeric characters. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to our Services.

Cookies operate in the background, and you can turn them off by adjusting your Web browser settings, but doing so may make it difficult to use some of the features on the Websites or the features may not be available to you. We may use cookies to make your Service experience easier by, for example, remembering your preferences, or keeping track of your login name and password.

For more information on your choices regarding cookies, you can review the FTC’s guide to opting out of online tracking for computers and mobile devices. Your browser and our Services may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services that you do not want them to track your online activities.

2. How We Use the Information We Collect

We may use the Personal Information we collect:

• To fulfill or meet requirements inherent in the reason you provided the information. For example, we use the information about who you follow on Sovren to deliver you a feed of posts from those accounts; we use the information you put into posts to display it to those who follow you or users who share your post, or who visit your profile on Sovren.
• To create, customize, and secure your account for use of the Services.
• To provide, maintain, and improve our Services, including for testing, research, analysis and product development.
• To personalize your experience on our Services, such as by providing tailored content and recommendations.
• To understand and analyze how you use our Services and develop new products, services, features, and/or functionality.
• To communicate with you, provide you with updates and other information relating to our Services, provide information that you request, respond to comments and questions, and otherwise provide customer support.
• Sovren integrates blockchain technology into certain features of our platform to provide transparency, security, and enhanced user engagement. Blockchain-related activities may involve the recording of certain interactions or transactions on a public ledger. Users are responsible for managing their blockchain credentials, such as private keys or wallet addresses, as Sovren does not store or recover such information. Blockchain records are immutable and publicly visible, and users should exercise caution when engaging with blockchain-enabled features.
• For marketing and advertising purposes, such as developing and providing promotional and advertising materials that may be relevant, valuable or otherwise of interest to you, including providing you with targeted offers and ads through our Website, and via email or text message (with your consent).
• To send you text messages and push notifications.
• To facilitate transactions, redemptions, and payments.
• To verify your identity and determine your eligibility to join our influencer network.
• To find and prevent fraud and respond to trust and safety issues.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about our consumers is among the assets transferred.
• To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
• For compliance purposes, including enforcing our Terms of Service or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process, law enforcement or governmental agency.
• For other purposes for which we provide specific notice at the time the information is collected.

We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without updating this Privacy Policy to provide you with notice as set out in Section 11 “Changes to the Privacy Policy” below.

3. How We Share the Information We Collect

Vendors and Service Providers. We may share any Personal Information we receive with vendors and service providers retained in connection with the provision of our Services.

Content you Share. Our Services are social services which allow you to find, enjoy, and share content. Your name, display name, profile photo, about me section, and contacts (i.e., users you are following) will always be viewable and/or searchable by other users. The content you post to our Services will be displayed and viewable by other users by default. Although this content is public by default, in the “Your Choices” section below, we describe the account settings and controls you can use to limit the sharing of certain information. We are not responsible for other Members’ use of available information, so you should carefully consider whether and what to post and how you identify yourself on our Services.

Marketing. We do not share personal data or Information about you with nonaffiliated third parties for their direct marketing purposes unless we have your affirmative express consent.

As Required By Law and Similar Disclosures. We may access, preserve, and disclose your Personal Information if we believe doing so is required or appropriate to: (a) comply with law enforcement requests and legal process, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our, or others’ rights, property, or safety. For the avoidance of doubt, the disclosure of your Personal Information may occur if you post any objectionable content on or through our Services.

Merger, Sale, or Other Asset Transfers. We may transfer your Personal Information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets. The use of your Personal Information following any of these events will be governed by the provisions of this Privacy Policy in effect at the time of the acquisition or merger.

Consent. We may also disclose your Personal Information with your permission.

4. Your Choices

Sharing Preferences. We provide you with settings to allow you to set your sharing preferences for content you post to our Services. Certain Personal Information, such as your display name, may always be publicly available to others, and other Personal Information is made publicly available to others by default. To change whether certain information is publicly viewable, you can adjust the settings in your account.

SMS Messaging Preferences. If you opt to send SMS invitations via Sovren, you can manage your preferences for these communications within your account settings. Additionally, you can choose not to send SMS invitations or revoke permissions for such features at any time.

Marketing Communications. We send you marketing communications consistent with your choices. You can unsubscribe from our promotional emails by adjusting your account settings or via the link provided in the emails. Similarly, if you change your mind about receiving promotional text messages after having opted-in, you may follow the opt-out directions sent with each text. Note: Even if you opt-out of receiving promotional messages from us, you will continue to receive administrative messages from us.

Notifications. You can opt-out of receiving notifications for posts, shares, comments, and followers by adjusting your profile and/or operating system (i.e., iOS or Android) settings.

Correction. You may correct your Personal Information at any time by logging in to your account and updating any inaccurate information.

Additional Privacy Rights. In addition, State and European Economic Area consumer privacy laws may provide their residents with additional rights regarding our use of their personal information. Please see Sections 12 and 14 below for additional information.

5. Third Party Links and Sites

Our Services may contain links to other websites, products, or services that we do not own or operate. We are not responsible for the privacy practices of these third parties. Please be aware that this Privacy Policy does not apply to your activities on these third-party services or any information you disclose to these third parties. We encourage you to read their privacy policies before providing any information to them.

6. Security

We make reasonable efforts to protect your Personal Information by using physical and electronic safeguards designed to improve the security of the Personal Information we maintain. However, no method of transmission or storage of data is 100% secure and we will not be responsible for any damage that results from a security breach of data or the unauthorized access to or use of information, whether Personal Information or Device Identifiable Information. To the extent we provide your Personal Information to any third parties, we will request that they use reasonable security measures to protect your information.

7. Children’s Data

We do not knowingly collect, maintain, or use Personal Information from children under 18 years of age, and no part of our Services is directed to children. If you learn that a child has provided us with Personal Information in violation of this Privacy Policy, then you may alert us at support@sovren.com and we will delete such information.

8. International Transfers of Data

Our Services are hosted in the United States and intended for visitors located within the United States. If you choose to use our Services from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your Personal Information outside of those regions to the United States for storage and processing. By providing any information, including Personal Information, on or to our Services, you consent to such transfer, storage, and processing.

9. Update or Delete Your Information

You can update your account and profile information through your account settings. You can delete your account by selecting that option via your account settings.

10. Data Retention

We will retain your personal data only for as long as is necessary for the purposes set out in this privacy policy. We will retain and use your information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

We will also retain usage data for internal analysis purposes. Usage data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our service, or we are legally obligated to retain this data for longer time periods.

11. Changes to the Privacy Policy

We will post any adjustments to the Privacy Policy on this page, and the revised version will be effective when it is posted. If we materially change the ways in which we use or share Personal Information previously collected from you through our Services, we will notify you through our Services, by email, or other communication. Your continued use of our Services following our posting or notifying you of changes constitutes your acceptance of such changes.

12. Additional Rights in Your State

State consumer privacy laws may provide you with additional rights regarding our use of your Personal Information. California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, and Virginia residents may have rights to:

• Know what personal data is collected
• Access and obtain a copy of their personal data
• Correct inaccuracies in personal data
• Delete personal data
• Opt out of the sale or sharing of personal data
• Opt out of targeted advertising and profiling
• Appeal decisions related to these rights

Note that Personal Information does not include publicly available information from government records, deidentified or aggregated consumer information, or information excluded from the scope of consumer privacy laws.

Your Rights and Choices

Right to Know and Data Portability. You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months (the “right to know”). Once we receive your request and confirm your identity, we will disclose to you the categories and sources of Personal Information collected, our business purpose for collecting it, the categories of third parties with whom we share it, and the specific pieces of Personal Information we collected about you.

Right to Delete. You have the right to request that we delete any of your Personal Information that we have collected and retained, subject to certain exceptions (the “right to delete”). Once we receive your request and confirm your identity, we will review your request to see if an applicable exception allows us to retain the information.

Exercising Your Rights. To exercise your rights to know or delete described above, please submit a request by emailing support@sovren.com. Only you, or someone legally authorized to act on your behalf, may make a request related to your Personal Information. You may submit a request to know only twice within a 12-month period.

Response Timing. We will confirm receipt of your request within ten (10) business days. We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

Personal Information Sales Opt-Out. We do not sell your Personal Information to third parties. If this position changes, you will be given explicit notice and an opportunity to opt out of further sales.

Non-Discrimination. We will not discriminate against you for exercising any of your data privacy rights. Unless permitted by state legislation, we will not deny you goods or services, charge you different prices or rates, or provide you a different level or quality of goods or services for exercising your rights.

13. SMS Legal Requirements

Consent. By providing your phone number and opting in to receive SMS messages from us, you consent to the receipt of such messages. You may withdraw your consent at any time by following the instructions provided in our SMS messages or by contacting us directly.

Message Frequency. You may receive SMS messages from us with varying frequencies, including promotional offers, transactional updates, or account notifications.

Opt-Out. To stop receiving SMS messages from us, you can reply with the word “STOP” to any message you receive. Alternatively, you may contact us directly to request removal from our SMS messaging list.

Data Usage and Sharing. We will only use your phone number and other personal information collected for SMS messaging purposes in accordance with this Privacy Policy. We do not sell, rent, or lease your phone number or other personal information to third parties for SMS marketing purposes.

Legal Compliance. Our SMS messaging activities are conducted in compliance with relevant laws and regulations, including but not limited to the Telephone Consumer Protection Act (TCPA) in the United States and the General Data Protection Regulation (GDPR) in the European Union.

14. Your Additional Rights in the European Economic Area

If your personal data has been collected in connection with our activities in the European Economic Area (“EEA”), you have the following rights:

• Withdrawal of Consent: If consent is the lawful basis of our processing, you have the right to withdraw any consent that you have provided to us to process your personal data.
• Access: You have the right to access your personal data.
• Rectification: You have the right to rectify inaccurate personal data.
• Erasure: You have the right to have your personal data erased if it is no longer necessary for the purposes for which it was processed, you have withdrawn your consent to, or object to, its processing and there is no other legitimate grounds for processing it or you believe that it has been unlawfully processed.
• Restriction: You have the right to have the processing of your personal data restricted if you contest its accuracy, if its processing is unlawful, if we no longer need it but you need it preserved for purposes of a legal claim, or if you have objected to its processing and are awaiting verification of our legitimate grounds for processing it.
• Data Portability: You have the right to have certain personal data you provide to us transferred to another company in a machine-readable format.
• Objection: You have the right to let us know that you object to the further use or disclosure of your personal data for certain purposes.

Please note that the right to erasure is not absolute and it may not always be possible to erase personal data on request, including for example where the Personal Information must be retained to comply with a legal obligation.

If you are in the EEA, you may lodge a complaint with a supervisory authority that has authority in your country or region.

Sovren Technologies is the data controller with respect to processing of your Personal Information in connection with the Services.

15. Contact Information

If you have any questions, comments, or concerns about our processing activities, please email us at support@sovren.com or write to us at:

Sovren Technologies Privacy Request
2801 Network Boulevard
Suite 300
Frisco, TX 75034

To make a request for access or deletion of your personal Information as permitted by law, please submit a request to our Data Privacy Officer by emailing privacy@sovren.com.