Suforia respects Your preferences concerning the collection and use of Your Personal Information. The following privacy policies are tailored for the different ways Your Personal Information is collected by Suforia. If You would like to exercise preferences or learn more about how You can control Suforia’s collection and use of Your personal information, please refer to the Privacy Choices tab.

Suforia Privacy Policy

Suforia respects Your preferences concerning the collection and use of Your Personal Information. Suforia respects Your preferences concerning the treatment of Personal Information that we may collect. This Policy (“Policy”) lets You know how we collect and use Your Personal Information, how You can control its use, and describes our practices regarding information collected from the different Suforia sites that link or refer to this Policy (such as our websites, computer or mobile software applications, social media pages and HTML-formatted e-mail messages), as well as through offline sales and marketing activities which provide links to or the ability to connect with non-Suforia websites, services, social networks or applications. Clicking on those links or enabling those connections may allow the third party to collect or share information about You. Those third-party websites or services are beyond our control. We encourage You to check the privacy policies and terms of use of any non-Suforia websites or services before providing Your Personal Information to them.

Personal and Other Information We Collect

Suforia may collect Personal Information, which is information that identifies an individual or relates to an identifiable individual. Personal Information may include, but is not limited to:

• Your name and physical address, email addresses, and telephone numbers
• Behavioral or demographic attributes, when tied to personal identifiers
• Past transactional behavior
• Information obtained from third parties on Your interests
• Information about Your company such as the name, size and location of Your company and Your role within the company

Suforia may also collect Other Information through Your interaction with and use of non-Suforia websites, which does not reveal Your specific identity or does not directly relate to an individual. Other Information may include, but is not limited to:

• Unique IDs such as a cookie placed on Your computer, mobile or device IDs
• Internet Protocol address (“IP address”) and information derived from Your IP address such as Your geographic location
• Information about Your devices such as information contained in HTTP Headers (defined below) or other internet transfer protocol signals, browser or device type and version, operating system, user-agent strings and information about or from the presence or use of “apps” on Your mobile devices, screen resolution, and Your preferred language
• Behavioral data such as webpages clicked, websites and content areas visited, date and time of activities
• The web search You used to locate and navigate non-Suforia websites

In some instances, we may combine Other Information with Personal Information, such as deriving geographical location from Your IP address and combining behavioral data with Your name. If we combine Other Information with Personal Information, we will treat the combined information as Personal Information.

How We Use and Share Information

Personal Information

Suforia uses and shares the Personal Information it collects (unless otherwise restricted by applicable law), to:

Engage in Transactions. Suforia may use Personal Information to engage in transactions with You.

Process Transactions. Suforia may use Personal Information along with financial, credit card, and payment information, to process Your transactions.

Provide Support or Other Services. Suforia may use Your Personal Information to provide You support or other services You have ordered, as well as product updates, product patches and fixes and other similar operational communications.

Tailor Marketing to Your Needs. Suforia may use Your Personal Information and Other Information to notify You about new product releases and service developments, and to advertise Suforia’s products and services in accordance with this Policy. Your website visit, marketing experience, and communications may be tailored to Your interests based on Your Personal Information. Suforia may pass Your contact information to the appropriate Suforia distributor or reseller for further follow-up related to Your interests. In addition, Suforia may share Your Personal Information to specific partners that offer complimentary products and services and may share Other Information with third parties to facilitate interest-based advertising. Other Information uses specified above are not mandatory and may be controlled by You. Respond to Your Requests. Suforia may also use Personal Information in order to respond directly to Your information requests (including newsletter registrations or other specific requests) or other inquiries.

Provide Suforia Online Communities. Some third party websites permit You to: participate in interactive discussions; create a profile; post comments, opportunities or other content; communicate directly with another user; or otherwise engage in networking activities. Some of these services are moderated and all may be accessed for technical reasons. Suforia does not control the content that users post to these forums or social networks. You should carefully consider whether You wish to submit Personal Information to these forums or social networks and whether You wish to make Your profile available to other users, and You should tailor any content You submit appropriately. You should also review any additional terms and conditions that may govern Your use of these third party websites.

Interact with You on Third Party Social Networks. Suforia may use Your Personal Information to interact with You on third party social networks. Suforia’s interactions with You on a third party social network would be subject to that network’s privacy policies and terms of use.

Post Testimonials. We may post testimonials that may contain Personal Information. Prior to posting a testimonial, we will obtain Your consent to use Your name and testimonial.

Administer Product Downloads and Licensing Compliance. If You download products from us, Suforia uses Personal Information to: confirm certain information about Your order (for example, that You did not experience problems in the download process); discuss the downloaded products; or provide marketing or sales information about related products and services. Suforia also may use Personal Information to contact You, confirm compliance with licensing and other terms of use, and may share it with Your company.

Power Joint Sales or Product Promotions. Suforia and its partners may engage in joint sales or product promotions. Such promotions will always reference the partners involved. Both Suforia and the partner(s) will have access to Your Personal Information, and either Suforia or our partners may provide You with the sales or product promotion information. Each party will be responsible for managing their own use of the Personal Information collected for the joint sale or product promotion. We recommend You review the privacy policies of these partners to address any questions You have regarding their handling of Your information.

Improve Products, Services, and Experiences. Suforia may use Your Personal Information to evaluate and improve our products, services, marketing, and customer relationships.

Communicate with You about a Conference or Event. We or our partners may communicate with You about a conference or event hosted or co-sponsored by Suforia or one of our partners. This may include information about the event’s content, logistics, payment, updates, and any additional meetings, special demonstrations or other customer facilitation that we may provide related to Your event registration. After the event, Suforia may contact You about the event and related products and services, and may share information about Your attendance with Your company. Where legally permitted, Suforia will also allow designated partners or conference sponsors to send You up to two communications related to Your event attendance. Please note that our partners or conference sponsors may directly request Your Personal Information at their conference booths or presentations. You should review their privacy policies to learn how they use Personal Information.

Obtain Third Party Services. We also share Personal Information and Other Information with third parties who provide services to Suforia, such as credit card processing services, order fulfillment, analytics, event / campaign management, website management, information technology and related infrastructure provision, customer service, e-mail delivery, auditing, and other similar services. When Suforia shares Personal Information with third party service providers, we require that they use Your Personal Information and Other Information only for the purpose of providing services to us and subject to terms consistent with this Policy.

Protect our Employees, Sites, Facilities, and Operations. Suforia may disclose Your Personal Information as we believe to be necessary or appropriate to protect the health and safety of our employees and visitors, our physical and online operations, our property, rights, and privacy, and/or that of our affiliates, You or others. If You visit our offices, You may be photographed or videotaped as part of maintaining the security of our facilities. Facility security photography will be treated as sensitive information and will only be used for security and investigation purposes.

Comply with Legal Requirements and Corporate Transactions. Suforia may disclose Your Personal Information as we believe to be necessary or appropriate: (a) under applicable law, including laws outside Your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside Your country of residence, for national security and/or law enforcement purposes; (d) to enforce our terms and conditions; and (e) to allow us to pursue available remedies or limit the damages that we may sustain. Additionally, in the event of a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings), we may transfer the Personal Information we have collected to the relevant third party. Some of the Personal Information and Other Information uses specified above are not mandatory and may be controlled by You.

Other Information

We may use, transfer, and disclose Other Information we collect for any purpose, except where applicable law requires otherwise. If we are required to treat Other Information as Personal Information under applicable law, then we will only use it in the same way that we are permitted to use and disclose Personal Information.

How We Collect Information

Suforia and our third party service providers may collect both Personal Information and Other Information from a variety of sources that generally fall into three categories:

• Direct Interactions: From Your use of and interaction with us such as account creation, submission of registrations and forms, or sales inquiries and transactions.
• Publicly Available Data / Data from Third Parties: Data from Automated Interactions on non-Suforia websites, or other data You may have made publicly available, such as social media posts, or data provided by third party sources, such as marketing opt-in lists, or data aggregators.
• Automated Interactions: From the use of technologies such as electronic communication protocols, cookies, embedded URLs or pixels, or widgets, buttons and tools. Although Suforia’s use of Automated Interactions may change over time as technology evolves, the following descriptions are designed to provide You with additional detail about Suforia’s current approach to information collected from Automated Interactions.

Electronic Communications Protocols: As is true when You visit most websites and apps, Suforia may automatically receive information from You as part of the communication connection itself, which often consists of network routing information (where You came from), equipment information (browser type or device type), Your IP address (which may identify Your general geographic location or company), and date and time. Suforia may also automatically receive and record information when each Suforia webpage was visited and how much time was spent on the page, how often You access the website or third party websites, performance data, aggregate usage, or general geo-location data.

Cookies: Suforia’s server will query Your browser to see if there are “cookies” previously set by us. A cookie is a small piece of information sent by a Web server to store on a Web browser so it can later be read back from that browser. Cookies may collect information, including a unique identifier, user preferences, profile information, membership information, and general usage and volume statistical information. Cookies may also be used to collect individualized website use data, provide electronic personalization, or conduct and measure the effectiveness of advertising in accordance with this Policy. Some cookies may remain on users’ computers after they leave the website. While the majority are set to expire within 1-24 months of Your last visit to the website that set the cookie, others may not expire because of their nature, like cookies that remember opt-out preferences.

Your browser may provide You with information and control over cookies. You can set Your browser to alert You when a cookie is being used, and accept or reject the cookie. You can also set Your browser to refuse all cookies or accept only cookies returned to the originating servers. Users can generally disable the cookie feature on their browser without affecting their ability to use the site, except in some cases where cookies are used as an essential security feature necessary for transaction completion. Cookies, however, are important to the proper functioning of a site, and disabling them may degrade Your experience and interfere with website features and customizations.

Suforia has engaged one or more third party service providers to track and analyze both individualized usage and volume statistical information from interactions with third party websites. The service provider(s) may set cookies on behalf of Suforia. Suforia also uses other third party cookies to provide advertising and personalization services in accordance with this Policy, and to track the performance of Suforia advertisements and Suforia e-mails.

Flash Cookies: We may use Flash cookies, also known as “local shared objects,” where Flash technology is used. Flash cookies are used to remember the site’s settings to personalize the look and feel of the site. Like normal cookies, Flash cookies are represented as small files on Your computer.

Embedded URLs: Suforia may use a tracking technique that employs embedded URLs with or without cookies. Embedded URLs allow limited information to follow You as You navigate, but are not associated with Personal Information and are not used beyond the session.

Embedded Pixels and Similar Technologies: Suforia and its service providers may use embedded pixel technologies for the purposes of identifying unique user visits (as opposed to aggregate hits) and for advertising purposes. In addition, embedded pixels or other technologies may be used in e-mails and our online display advertising to provide information on when the e-mail or ad was opened to track marketing campaign responsiveness; information collected using these technologies may be associated with the recipient’s e-mail address.

Widgets, Buttons, and Tools: Our services may include widgets, which are interactive mini-programs that run on our site to provide specific services from another company (e.g., links to bookmarked sites), along with buttons or other tools that link to other companies’ services (e.g., a “Like” button or third party map). The widget, button or tool may collect and automatically send Personal Information, such as Your e-mail address, or Other Information (such as Your browser information, or IP address), to a third party. Cookies may also be set or used by the widgets, buttons or tools to enable them to function properly or for other purposes, which may include advertising. Information collected or used by a widget, button or tool, including cookie settings and preferences, is governed by the privacy policy of the company that created it.

Physical Location: We may collect and share the physical location of Your device for purposes consistent with this Policy, such as to provide You with personalized location-based services or content. In some instances, You may be permitted to allow or deny such use of Your device’s location, but if You choose to deny such use, we may not be able to provide You with the applicable personalized services or content.

Registration and Privacy Choices

A list of Your current Privacy Choices is listed

Registration Suforia allows You to establish an online registration profile for marketing communications at Suforia.com. You may use the profile to customize and control Your preferences for receiving electronic information, including opting into (or out of) communities, newsletters and general interest areas.

E-mail Marketing Suforia enables You to opt out of marketing communications. You may opt out of e-mail marketing by modifying Your online profile as described above or by using our general unsubscribe automated link that is included in Suforia marketing e-mails. You can find details on how to automatically unsubscribe from e-mail communications, as well as how to submit requests to opt-out from phone and postal marketing,

Cookies and Do Not Track. Suforia enables You to opt out of cookies that are not required to enable core site functionality. Suforia uses its cookies preferences tool to process Internet advertising and tracking preferences, but does not respond any other Do Not Track signals. Please remember that if You delete Your cookies, or use a different browser or computer, You will need to set Your cookies preferences again.

Mobile Application. Suforia’s mobile applications may send push notifications directly to Your mobile device for the purposes specified in this Policy. You may opt-out of receiving such push notifications and location-based services on Your mobile device at any time by editing the notification and location settings on Your mobile device.

Third Party Permission-Based Lists. On occasion, Suforia may use third-party lists to send communications about Suforia products and services. These lists, which are maintained by third parties, include users eligible under applicable law to receive e-mails from other companies such as Suforia. When we use such lists, the communications will include mechanisms to opt out of receiving Suforia marketing communications.

Information-Sharing Choices. There are limitations to opting out of sharing with third parties in the case of: (1) joint sales or joint events; (2) where the customer has requested follow-up which involves Suforia partners; (3) where third parties are required to accomplish the transaction or perform the service; and (4) where required by law.

Access, Correction, and Profile Updates

You may request to review, correct, update, suppress, or otherwise modify any of Your Personal Information that You have previously provided to us. In Your request, please make clear what Personal Information You would like to have changed, whether You would like to have Your Personal Information that You have provided to us suppressed from our database or otherwise let us know what limitations You would like to put on our use of Your Personal Information that You have provided to us. While the majority of questions and issues related to access can be handled quickly, complex requests may take more research and time. In such cases, issues will be addressed, or You will be contacted regarding the nature of the problem and appropriate next steps, within thirty days. Please email info@suforia.com to change or delete any information that we may have collected.  We will get back to you within 30 days with an update.

Retention and Deletion

Suforia will retain Your Personal Information for as long as Your account is active; as needed to provide You products or services; as needed for the purposes outlined in this Policy or at the time of collection; as necessary to comply with our legal obligations (e.g., to honor opt-outs), resolve disputes, and enforce our agreements; or to the extent permitted by law.

At the end of the retention period, Suforia will delete Your Personal Information in a manner designed to ensure that it cannot be reconstructed or read.

Advertising

Suforia uses third parties to administer Suforia advertisements on third party website and other mediums. Other Information, such as user community or implied or inferred interests, may be used in the selection of advertising to make sure that it has relevance to the user. Some ads may contain embedded pixels that may write and read cookies or return session connection information that allows advertisers to better determine how many individual users have interacted with the ad.

Suforia may also use advertising technologies and participate in advertising technology networks that collect Other Information from Suforia and non-Suforia websites, as well as from other sources, to show You Suforia-related advertisements on Suforia’s own and third-party websites. These advertisements may be tailored to Your perceived interests using retargeting and behavioral advertising technologies, a set of practices collectively referred to as “Interest Based Advertising” in this Policy. Any retargeted or behavioral advertisements served to Your browser will contain information on or near it that informs You about the advertising technology partner and how to opt-out of viewing such advertisements.

Cookie-based tools that allow You to opt-out of Interest Based Advertising prevent Suforia and other participating advertising technology companies from serving interest-related ads to You on behalf of Suforia. They will only work on the Internet browser on which they are deposited, and they will only function only if Your browser is set to accept third-party cookies. These cookie-based opt-out tools may not be as reliable where (e.g., certain mobile devices and operating systems) cookies are sometimes automatically disabled or removed. If You delete cookies, change browsers, computers or use another operating system, You will need to opt-out again.

Security

The security of Your Personal Information is very important to Suforia. We use physical, electronic, and administrative safeguards that are designed to protect Your Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction.

In addition, Suforia uses standard security protocols and mechanisms to exchange the transmission of sensitive data such as credit card details. When You enter sensitive Personal Information such as Your credit card number on our site, we encrypt it using secure socket layer (SSL) technology.

In the event that Your Personal Information is acquired, or is reasonably believed to have been acquired, by an unauthorized person and applicable law requires notification, Suforia will notify You by e-mail or mail. Suforia will give You notice promptly, consistent with the reasonable needs of law enforcement and/or Suforia to determine the scope of the breach and to investigate and restore the integrity of the data system.

Sensitive Information

We ask that You not send us, and You not share any sensitive Personal Information (e.g., government-issued or financial account numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, genetic, or biometric data, criminal background or trade union membership).

Children’s Privacy

As a company focused on serving the needs of businesses, Suforia’s services are not directed to minors and Suforia does not promote or market its services to minors, except as part of specific educational outreach programs with parental permission.

Contact Us

Suforia has appointed a Chief Privacy Officer. If You believe Your Personal Information has been used in a way that is not consistent with this Policy or Your specified preferences, or if You have further questions related to this policy, please contact the Chief Privacy Officer:

Chief Privacy Officer

Suforia Corporation
325 S. Biscayne Blvd, Suite 2823

Miami, Florida 33131

Policy Updates

We may update this Policy from time to time. In the event we make material changes that reduce Your rights or Suforia’s obligations under this Policy, we will post a prominent notice in this section of this Policy notifying users when it is updated.

Suforia Services Privacy Policy

Scope

This policy covers the privacy practices that Suforia Corporation and its subsidiaries and affiliates (“Suforia” or “we”) employ when providing support, consulting, Cloud or other services (the “services”) to its customers (“You” or “Your”). Suforia established this privacy policy in order to clarify that the use of information to which it may be provided access in order to provide services is more limited.

Customer Information and Services Data

Customer Information is information that we may collect from Your use of the Suforia Web sites and Your interactions with us offline.

Services Data is data that resides on Suforia, customer or third-party systems to which Suforia is provided access to perform services (including Cloud environments as well as test, development and production environments that may be accessed to perform Suforia consulting and support services). Suforia treats services data according to the terms of this policy, and treats services data as confidential in accordance with the terms of Your order for services.

Other Information Suforia may also collect other information about the customer and some employees, for example through its web sites, as part of that interaction. All of that information is customer information.

Having contracted with Suforia for Cloud or other services, the customer provides Suforia access to its production, development or test environment, which may include personal information about its employees, customers, partners or suppliers (collectively “end users”).

How Suforia Collects and Uses Services Data

Below are the conditions under which Suforia may access, collect and/or use services data.

To Provide Services and to Fix Issues. Services data may be accessed and used to perform services under Your order for support, consulting, Cloud or other services and to confirm Your compliance with the terms of Your order. This may include testing and applying new product or system versions, patches, updates and upgrades; monitoring and testing system use and performance; and resolving bugs and other issues You have reported to Suforia. Any copies of services data created for these purposes are only maintained for time periods relevant to those purposes.

As a Result of Legal Requirements. Suforia may be required to retain or provide access to services data to comply with legally mandated reporting, disclosure or other legal process requirements.

Suforia may transfer and access services data globally as required for the purposes specified above. If Suforia hires subcontractors to assist in providing services, their access to services data will be consistent with the terms of Your order for services and this services privacy policy. Suforia is responsible for its subcontractors’ compliance with the terms of this policy and Your order.

Suforia does not use services data except as stated above or in Your order. Suforia may process services data, but does not control Your collection or use practices for services data. If You provide any services data to Suforia, You are responsible for providing any notices and/or obtaining any consents necessary for Suforia to access, use, retain and transfer services data as specified in this policy and Your order.

Access Controls

Suforia’s access to services data is based on job role/responsibility. You have access to the services data used by Your end users; end users should direct any requests related to their personal information to You.

Security and Breach Notification

Suforia is committed to the security of Your services data, and has in place physical, administrative and technical measures designed to prevent unauthorized access to that information. Suforia security policies cover the management of security for both its internal operations as well as the services. These policies, which are aligned with the ISO/IEC 27001:2013 standard, govern all areas of security applicable to services and apply to all Suforia employees. Suforia’s Support, Consulting and Cloud lines of business have developed detailed statements of security practices that apply to many of their service offerings, which are available for review at Your request.

Suforia is also committed to reducing risks of human error, theft, fraud, and misuse of Suforia facilities. Suforia’s efforts include making personnel aware of security policies and training employees to implement security policies. Suforia employees are required to maintain the confidentiality of services data. Employees’ obligations include written confidentiality agreements, regular training on information protection, and compliance with company policies concerning protection of confidential information.

Suforia promptly evaluates and responds to incidents that create suspicions of unauthorized handling of services data. Suforia and its legal team are informed of such incidents and, depending on the nature of the activity, define escalation paths and response teams to address the incidents. If Suforia determines that Your services data has been misappropriated (including by a Suforia employee) or otherwise wrongly acquired by a third party, Suforia will promptly report such misappropriation or acquisition to You.

Suforia Marketing Cloud & Suforia Data Cloud Privacy Policy

Introduction

It is important to Suforia that consumers have greater knowledge and control over information related to them that Suforia makes available to its Suforia Marketing Cloud and Suforia Data Cloud marketing services customers (“Cloud services”). This privacy policy is designed to provide consumers (“You” or “Your”) with tools to help understand and control the collection and use of that information.

Scope

This policy applies to Suforia’s handling of third-party information about You to provide Cloud services (“Marketing Information”). “Third-party” information is information that Suforia receives from third parties and uses to provide Cloud services in accordance with this privacy policy. This may include information that does not directly identify You and as well as information that does. The section of this privacy policy entitled “Types of Information Collected” describes the different types of information.

This policy does not apply to a Cloud customer’s own collection and use of Your information (known as “first party” information) to conduct marketing activities, including when they do so using Suforia products or services. For example, a Suforia customer may use the Suforia Marketing Cloud or other Cloud services to collect and manage only the data they themselves (or their agents) have collected or purchased, otherwise known as “first-party” information. This first-party information is collected, shared and used subject to the individual privacy policy of the Suforia customer that collected it, and therefore is not covered by this policy; please consult that company if You have any questions about its use of Your information. Please note however, that if You use the opt-out tool described in this policy, Suforia will opt You out of first-party collection and use of Your information facilitated by Cloud services for interest-based advertising, in addition to opting You out of the third party collection described later in this policy.

Types of Information Collected

Marketing Information may include both offline and online information. Offline Marketing Information originates from sources such as brick-and-mortar or online retail stores, grocery stores and their associated loyalty cards, catalog orders and catalog address lists (“Offline Marketing Information”).

Offline Marketing Information in the Cloud that directly identifies a particular individual may include:

• Name and physical address, email addresses, and telephone numbers
• Behavioral or demographic attributes, when tied to personal identifiers
• Transactional data based on past purchase behavior, when tied to personal identifiers
• Company data such as the name, size and location of the consumer’s company and the consumer’s role within the company
• Data from marketing opt-in lists, consumer surveys, or publicly available information

Online Marketing Information is collected based on Internet-based activity and does not directly identify You (“Online Marketing Information”). Online Marketing Information in the Cloud that does not directly identify a particular individual may include:

• Unique IDs such as a cookie placed on a computer, mobile or device IDs
• Internet Protocol address (“IP address”) and information derived from IP address such as geographic location
• Information about a device such as information contained in HTTP Headers (defined below) or other internet transfer protocol signals, browser or device type and version, operating system, user-agent strings and information about or from the presence or use of “apps” on mobile devices, screen resolution, and the consumer’s preferred language
• De-identified personal information (such as email addresses that are de-identified so as to be non-identifiable to the recipient of such information)
• Demographic information such as a consumer’s gender, age, and income range, when not tied to personal identifiers
• Behavioral data of consumers’ computer or device usage on websites or apps, such as advertisements clicked, websites and content areas, date and time of activities
• The web search a consumer used to locate and navigate to a website
• Latitude/Longitude data (“Lat/Long data”), Google Earth coordinates, etc.

How Information is Collected

Suforia may receive Marketing Information from third parties, such as our customers, data providers and data partners (“Data Sources”). Suforia allows our Cloud Data Sources to send us Marketing Information that they have collected from both online and offline sources. This may include information from customer lists, website membership, or other information created from a third-party’s own technology (such as proprietary modeling or matching technology of other companies).

Online Marketing Information is collected from Your interactions on Your computer or device including data contained in standard HTTP headers or HTML, collected by Cookies, or specific site interaction like clicks and other online behavior able to be determined through JavaScript and Pixel Tags.

“Cookies” are small text files that contain a string of characters and uniquely identify a browser. They are sent to a computer by website operators or third parties. Most browsers are initially configured to accept cookies by default. You may, however, be able to change Your browser settings to cause Your browser to refuse third-party cookies or to indicate when a third-party cookie is being sent. Check Your browser’s “Help” files to learn more about handling cookies.

“HTML” is the language used to write webpages. HTML may include “Pixel Tags” or small strings of code contained in HTML that provide a method for delivering a graphic image on a webpage, email, or other electronic document. Pixel tags allow the operator of the webpage or other document, or a third party who serves the pixel tag, to set, read, and modify cookies on, and to transfer other data to, the browser used to view the webpage or other document. Pixel tags may also be used to obtain information about the computer being used to view that webpage or other document, including the IP address of the computer that the tag is sent to, the time it was sent, the consumer’s operating system and browser type, and other similar information.

“HTTP Headers” are information that is transmitted whenever a webpage is viewed, and contain technical information required for communication between a browsing device and a website server. Other electronic communication protocols (such as those used for email) also use headers to transmit information. Our Cloud customers may transmit information through HTTP (or other electronic communication protocol) headers to Suforia or otherwise direct Suforia to retrieve such information from consumers’ interaction with the customer’s website. This may include information about the device browser, the requested webpage, server and other information the customer knows about the consumer, its computer or device (such as a carrier or device identifier).

How Suforia Uses Marketing Information

Cloud customers and partners use Profiles and Interest Segments (each defined below) for marketing campaigns to try to make the content and ads that consumers receive more relevant. Profiles are based on offline or online interactions with the consumer that have been collected by Suforia’s Data Sources to infer interests. When we receive Offline Marketing Information that identifies a consumer, we remove the direct identifiers, such as name, address, telephone number, and email address, prior to using it for online interest-based advertising.

We may prepare reports and metrics based on Marketing Information that provide our customers with the number of consumers using aggregated data on consumers’ activity on the websites. We may also prepare aggregate reports for our customers that measure the effectiveness of their marketing campaigns. The reports and metrics provided to our customers do not include any Marketing Information that directly identifies a consumer.

Offline Marketing Information may be used by our customers for offline direct mail campaigns. Suforia may supplement a customer’s marketing list or provide a customer with potential prospective consumers to assist the customer with offline direct marketing.

We may also use Marketing Information for billing, auditing, research and development purposes, for our internal operational purposes, and to create aggregate statistics for market research or analytics services. Aggregated statistics do not include any information that directly identifies a consumer.

How Suforia Creates Cookie IDs and Other Identifiers

Suforia creates Profiles using various methods and technologies. Suforia creates offline Profiles and Interest Segments at the household level and/or individual level by using past purchase behavior, demographic data, and behavioral attributes. Suforia creates online Profiles through the use of cookies, cross-device/cross-context technology (explained below), or other unique identifiers provided to us by our customers (such as mobile advertising IDs).

Suforia associates each Cookie used for interest-based advertising that we set on a consumer’s web browser with a unique identifier (“Cookie ID”). When our Data Sources transmit information about that web browser to us, or otherwise direct Suforia to collect information from the interaction between that web browser and a webpage, we use the Cookie ID to store the information into a Profile with the same Cookie ID.

Other Identifiers. Suforia may create a statistical ID (“Stat ID”) for a user or a group of users using the user agent string and IP address. Creating a stat ID involves computing and then assigning a probabilistic identifier to a device or a group of devices based on information contained in the header. Multiple users may share a Stat ID or one user may have multiple Stat IDs. Data Sources may create or collect other unique identifiers and provide those to Suforia. These may include IDs intended for marketing use (such as mobile advertising IDs), hashed email, or proprietary identifiers created by the Data Sources. Suforia may create connections between these and other identifiers.

Cross-Device/Cross-Context Technology

Suforia may also link Profiles using cross-device/cross-context technology. This technology is designed to enable Suforia and its customers to connect a consumer’s Interest Segments across the various devices or contexts where the consumer is browsing digital content. For example, a single consumer might use multiple browsers on a single device, or use various devices (such as desktops, smartphones, and tablets), which can result in a consumer having multiple Profiles across these various contexts and devices. Cross-device/cross-context technology may be used to connect these various Profiles and the corresponding Interest Data from the different contexts and devices.

Suforia analyzes this data to determine if the devices or contexts are likely to be related to a single consumer. When a probable connection is found, Suforia creates links between the Profile IDs from the different devices/contexts using a reference table to link these devices or contexts. Suforia customers can then use linked Interest Data when serving interest-based advertising and other content across the consumer’s devices/contexts.

Disclosure of Marketing Information

We disclose Marketing Information to our Cloud customers to facilitate our customers’ use of the Cloud services for executing offline and online marketing campaigns. Our customers may use third-party service providers, acting on their behalf, to create and display advertising or other content that reflects a Profile’s membership in an Interest Segment. When Suforia shares Your Marketing Information with Cloud customers, we require them to use Marketing Information consistent with this Policy and to maintain the confidentiality of that information.

We may also share Marketing Information with third-party service providers in order for those service providers to perform business functions for Suforia or on behalf of Suforia customers. When Suforia shares Your Marketing Information with third party service providers, we require them to use Marketing Information only for the purpose of providing services to us and to implement security controls to maintain the confidentiality of that information.

Suforia may also use or disclose Marketing Information as we believe to be necessary or appropriate: (a) under applicable law, including laws outside Your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside Your country of residence, for national security and/or law enforcement purposes; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, You or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

Additionally, in the event of a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings), we may transfer Marketing Information to the relevant third party.

Retention of Marketing Information

Suforia sets Online Marketing Information collected for interest-based advertising to expire within 180 days from the date it is collected. On an occasional basis and in accordance with applicable law, Suforia may permit some Cloud customers to retain Marketing Information for up to 36 months for limited purposes such as seasonal or cyclical interest-based advertising campaigns or internal analytics and model development; such customers are required to delete this Marketing Information at the end of the agreed time period.

Suforia may also retain Offline Marketing Information and other statistical data related to the performance, operation and use of Cloud services for more than 180 days for security and operations management, statistical analyses, service improvement, and research and development.

Accessing Marketing Information

Suforia maintains a Cloud Registry which allows You to view the type of third-party online Interest Segments in the Suforia Marketplace that is applicable to the device that views the Registry. Within the Registry, You may remove individual interest segments at Your sole discretion. Please note that the Interest Segments You see within the Registry are information from the Profile associated with the specific browser, computer or device that You are using to visit the Registry. You may see different segments when viewing the Registry from a different browser, computer or device.

You may request to review, correct, update, suppress, or otherwise modify Your Offline Marketing Information, or object to the use or processing of such Offline Marketing Information by us via written request. Suforia will provide You with a copy of the Offline Marketing Information in our databases, including a list of the Interest Segments that we have associated with You. You may request to receive this information by sending a written request, along with a copy of government-issued identification to verify Your identity, to:

Chief Privacy Officer

Suforia Corporation
325 S. Biscayne Blvd, Suite 2823

Miami, Florida 33131

Opting-Out

As described above, Suforia uses third party Offline and Online Marketing Information to provide Cloud services to our customers. We also provide consumers the ability to opt out of Suforia’s use of that information.

Online Marketing Information Opt-Out. Suforia offers multiple ways for You to opt out of third-party collection and use of Your Marketing Information for online interest-based advertising. Opting out does not mean You will stop seeing online advertisements, but the advertisements You do see will not be influenced by Marketing Information collected using the Cloud. If Your browser accepts cookies, You can opt out directly from the Cloud’s third-party interest based advertising by downloading Suforia’s Cloud opt-out cookie. This Opt-out Cookie, when deposited on Your browser, will prevent the Cloud from creating Interest Segments based on information collected from that browser.

Note: The opt-out tools are currently Cookie-based and prevent Suforia from using Marketing Information for interest-based advertising on the browser on which they are installed. As a result, the opt out will only function if Your browser is set to accept third-party Cookies and may not function where Cookies are sometimes automatically disabled or removed (e.g., certain mobile devices and operating systems). If You delete Cookies, change Your browser settings, switch browsers or computers, or use another operating system, You will need to opt out again. Suforia does not use persistent, unique identifiers to revive a previously opted-out profile or deleted Cookie.

Also note: The Cloud may interact with third parties who engage in interest-based advertising in conjunction with certain Cloud services. Suforia encourages You to use the NAI, DAA, and EDAA opt-out tools if You are interested in opting out of this sort of activity.

Cross-Device/Cross-Context Opt-Out. When You opt out of interest-based advertising above and Suforia has used cross-device/cross-context technology to link that profile to other devices or contexts, Suforia will break the connections from the opted-out profile to those other devices or contexts. If You wish to opt out of interest-based advertising based on Your other devices or contexts, You should exercise one of the opt-out options discussed above using each of the devices/contexts (including each browser) that You use.

Mobile Opt-Out. The Cloud allows customers to use Marketing Information collected from mobile devices for interest-based advertising. While the opt-out methods described above often work for mobile web browsing, they are Cookie-based and are therefore less reliable in mobile “app” environments that may not accept Cookies. As an alternative, Suforia suggests You download AppChoices App provided by the Digital Advertising Alliance (DAA). This app allows consumers to exercise opt-out control for specific companies, including Suforia, and provides a more reliable opt-out signal when You are in a mobile app.

Offline Marketing Information Opt-out. Suforia honors Your choice to opt out of the use of Offline Marketing Information for offline direct mail campaigns or online interest-based advertising. To process Your request to opt out, we require Your name, address and email address. Your request will take effect within 30 days. You may still receive marketing due to marketing campaigns already underway; however, You will be opted out of all future marketing campaigns.

If You would like to opt out of all direct mail marketing to Your home address, You may visit the Direct Marketing Association website for information on how to reduce direct mail marketing to Your home address.

Do Not Track. Suforia does not uniformly process do-not-track signals from browsers. However, You may prevent Suforia from collecting Interest Segments using Cookies on a browser by blocking third-party Cookies in that browser. If You block third-party Cookies from being set on Your browser, You may not be able to enjoy some features or functionality of, and You may see the same content and advertisements repeatedly on, some websites.

Suforia may add additional opt-out tools over time as they become available.

Suforia’s Commitment to Privacy Standards

Industry Involvement. Suforia is a member of, and adheres to the self-regulatory principles of, the Direct Marketing Association (DMA), Direct Marketing Association UK (DMA UK), Network Advertising Initiative (NAI), Interactive Advertising Bureau (IAB), and Digital Advertising Alliance (DAA). As a member of these organizations, Suforia works with industry-leading companies to address important privacy and consumer protection issues in offline direct marketing and online advertising.

The NAI has created a compliance program that incorporates attestation reviews, a consumer complaint process, sanctions and annual reporting to help ensure that member companies keep their promises to You and abide by the NAI’s Self-Regulatory Code of Conduct. The Digital Advertising Alliance (DAA), Digital Advertising Alliance of Canada (DAAC), and European Digital Advertising Alliance (EDAA) provide self-regulatory Principles for Online Behavioral Advertising. 

Data Sources. Suforia requires our Data Sources to comply with laws applicable to their collection, use and sharing of Marketing Information, and to maintain their own privacy policies that disclose their practices as required by applicable laws. Suforia permits these companies to link directly to this privacy policy. Suforia also mandates that these companies obtain Your consent as required by applicable law, including consents required to collect, use, and share Your information.

Sensitive Data. Suforia is aware of the sensitivity of certain types of data. We do not create any online Interest Segments that reflect third-party Marketing Information that we consider sensitive. While the types of Marketing Information considered sensitive may vary among consumers, we presently treat online Marketing Information as sensitive if it includes precise health information; certain aspects of a consumer’s personal life or financial situation; or interest in “adult” products or services. We do not allow our Marketing Information to be used for employment, credit, healthcare, or insurance eligibility purposes. Our customers who collect their own data (first-party data), including those who choose to share their data with other third parties, may have their own standards of what they consider sensitive; however, Suforia requires all such customers to comply with laws applicable to sensitive information.

Children. We do not intentionally collect Marketing Information from, and do not tailor any services to, children under 18 years of age. We prohibit our Data Sources from providing Suforia with information from sites directed to children under the age of 18 or from consumers whose age these companies know to be under the age of 18.

Security

The security of Marketing Information is very important to Suforia. We use physical, technical, and administrative safeguards that are designed to protect Marketing Information from loss, misuse and unauthorized access, disclosure, alteration and destruction.

In the event that Suforia determines that Marketing Information identifying You and stored in the Cloud is acquired, or is reasonably believed to have been acquired, by an unauthorized person and applicable law requires notification, Suforia will, consistent with the reasonable needs of law enforcement and subject to applicable law, notify the applicable Data Source who provided Suforia with the information so that it may notify You.

Email and Profile Information

To customize and control Your preferences for receiving electronic information, including opting into (or out of) Suforia communities, newsletters and general interest areas through Your Suforia profile, You may opt out of Suforia’s email marketing by modifying Your online profile as described above or by using our general unsubscribe automated link that is included in Suforia marketing emails.

You can also find details on how to automatically unsubscribe from email communications, as well as how to submit requests to opt-out from phone and postal marketing, on ourwebsite www.suforia.com.

Cookie Preferences on Suforia websites

Suforia enables You to opt out of cookies that are not required to enable core site functionality. Suforia uses its cookies preferences tool to processes Internet advertising and tracking preferences, but does not process any other Do Not Track signals. Once You have set Your cookie preferences, Suforia will follow the specific choices You made there. Please remember that if You delete Your cookies, or use a different browser or computer, You will need to set Your cookies preferences again.

Interest Based Advertising (IBA) Enabled by Suforia Data Cloud

The Cloud facilitates the collection and use of data by our customers in connection with interest-based advertising.

Online Marketing Information Opt-Out. If Your browser accepts cookies, You can opt out directly from the Cloud’s third-party interest based advertising by downloading Suforia’s Cloud opt-out cookie. This Opt-out Cookie, when deposited on Your browser, will prevent the Cloud from creating Interest Segments based on information collected from that browser.

Offline Marketing Information Opt-out. The Cloud honors Your choice to opt out of the use of Offline Marketing Information for offline direct mail campaigns or online interest-based advertising.

Procedure for Making Claims of Copyright Infringement

Suforia respects the intellectual property rights of others, and we ask our individuals using Suforia Web sites to do the same. If You believe that Your copyrighted work has been copied and is accessible on a Suforia Web site in a way that constitutes copyright infringement, please send a Notice to our Copyright Agent providing the following information:

• The electronic or physical signature of the owner of the copyright or the person authorized to act on the owner’s behalf
• A description of the copyrighted work that You claim has been infringed and a description of the infringing activity
• A description of where the material that You claim is infringing is located, such as the URL where it is posted
• Your name, address, telephone number, and email address
• A statement by You that You have a good faith belief that the disputed use of the material is not authorized by the copyright owner, its agent, or the law
• A statement by You, made under penalty of perjury, that the above information in Your Notice is accurate and that You are the copyright owner or are authorized to act on the copyright owner’s behalf

Suforia’s Copyright Agent for Notice of claims of copyright infringement can be reached as follows:

Chief Privacy Officer

Suforia Corporation
325 S. Biscayne Blvd, Suite 2823

Miami, Florida 33131

Reporting Piracy of Suforia Products

If You believe that Suforia software or documentation is being copied, sold or distributed without licenses or permission from Suforia, please contact the Legal Department at www.suforia.com.

Use of Suforia Screenshots

Suforia’s software programs are copyrighted materials owned by Suforia. Screenshots constituting an image of an individual screen display from any Suforia software, application or service are protected by copyright. If You want to use more than ten (10) screenshots in a published piece, such as a book or white paper, You will require a formal permission letter from Suforia. We may approve Your request if the screenshot content does not constitute more than 25% of the content of Your work.

If You want to use ten (10) or fewer screenshots in a published piece, You may do so provided that You agree and adhere to the following terms:

1. This permission constitutes a fully revocable, nonexclusive license and is not a transfer of ownership, title or any other right or interest in Suforia’s screenshots. Suforia may terminate permission at any time by notifying You of the termination of permission for Your particular use. Suforia may revise or withdraw this general permission at any time without notice.
2. Your use may not directly or indirectly state or imply Suforia sponsorship, affiliation or endorsement of Your product, service, or published piece.
3. Screenshots must be reproduced in their entirety and You may not alter screenshots in any way except to proportionally resize them. All added commentary and analysis relating to Suforia screenshots must be clearly attributable to You and not to Suforia.
4. This permission does not apply to any Suforia screenshots that are from beta products or other products that are subject to non-disclosure obligations or that have not yet been commercially released.
5. Suforia screenshots may not be incorporated into: comparative advertising; obscene, pornographic or sexually explicit materials; or materials which are, in Suforia’s sole opinion, disparaging or defamatory of Suforia, its products, or any other person or entity.
6. Suforia expressly disclaims all warranties of any kind, whether express or implied, including, but not limited to, the implied warranties of merchantability, fitness for a particular purpose and non-infringement in connection with Your use of Suforia screenshots. Your use of Suforia screenshots is at Your own discretion and risk.

Third Party Usage Guidelines for Suforia Trademarks

Suforia’s trademarks and service marks (“Suforia trademarks”) are valuable assets that Suforia needs to protect. We ask that You help us by properly using and crediting Suforia trademarks in accordance with these guidelines. For information about proper use of Suforia logos, logotypes, signatures, and design marks, please review the Third Party Usage Guidelines for Suforia Logos.

Permissible Use

You may generally use Suforia trademarks to refer to the associated Suforia products or services. For instance, an authorized reseller can note in its advertisements that it is selling the Suforia application server. Similarly, a Suforia customer may issue a press release stating that it has implemented Suforia software.

Relationship of Products or Services

You may indicate the relationship of Your products or services to Suforia products or services by using accurate, descriptive tag lines in which “Suforia” is related in connection with Your product or service name. Within text or body copy, such tag lines may appear in the same type as Your product or service name. On product, packaging, advertising and other collateral where Your product or service name is displayed apart from body copy, make sure that the tag line appears in significantly smaller type than Your name. You should also distinguish the tag line from Your mark by using a different font or color.

Open Source Software

Most open source licenses do not grant, and many exclude, a license of trademark rights. Do not assume You can use the name of a source code base in the name of Your distribution developed from that code base. Without a license or permission, You may not incorporate Suforia trademarks in the name of Your distribution or other products that incorporate open source elements. Truthful statements incorporating a trademark are generally allowed, but You should check the terms of the license for the original source code or any posted trademark guidelines for the project.

User Groups

Suforia generally permits use of its marks in group names that clarify the relationship between Suforia and the group and do not create confusion about the source of products. This applies only to user groups that are not formally doing business as commercial entities. If You are administering a user group that includes an Suforia trademark in its name, do not claim any trademark rights in the name or attempt to register the name or Your logo with a trademark office, and do not register the name as a trade name or business name, or conduct any business under the name.

Prohibited Use

You may not use Suforia trademarks in a manner which could cause confusion as to Suforia sponsorship, affiliation or endorsement. Take particular care not to use Suforia marks as set out below.

Company, Product or Service Names

Do not use Suforia trademarks or potentially confusing variations as all or part of Your company, product or service names. If You wish to note the relationship of Your products or services to Suforia products or services, please use an appropriate tag line.

Logos
For more information regarding use of Suforia logos, please review the Third Party Usage Guidelines for Suforia Logos.

Trade Dress

You must not imitate Suforia trade dress, type style or logos. For instance, do not copy Suforia packaging for use with Your product or display Your product name in the distinctive logotype associated with the Suforia logo.

Domain Names

Do not use Suforia trademarks or potentially confusing variations in Your Internet domain name. This helps prevent Internet users from being confused as to whether You or Suforia is the source of the Web site.

Trademark Symbols and Credit Lines

Proper trademark attribution through trademark symbols and credit lines helps makes the public aware of our trademarks, and helps prevent them from becoming generic terms. Credit lines also help clarify that they belong to Suforia. Accordingly, Suforia would appreciate You attributing ownership of Suforia trademarks to Suforia Corporation by using trademark symbols (™ or SM or ®) and credit lines as detailed below.

Trademark Symbols

Use the ® symbol with the most prominent appearance of the “Suforia” mark on products, packaging, manuals, advertisements, promotional materials and Web pages (for example, in the headline of an advertisement), and the first use of the mark in text or body copy. This includes situations where “Suforia” is a part of a product or service name.

Credit Line

All products, packaging, manuals, advertisements, promotional materials and Web pages bearing Suforia trademarks should include the following trademark credit line:

“Suforia is a registered trademark of Suforia and/or its affiliates. Other names may be trademarks of their respective owners.”

The credit line may appear anywhere on the collateral, but typically is displayed on a copyright page, the back of a package or at the end of a document or web page.

Third Party Usage Guidelines for Suforia Logos

Suforia’s logos, logotypes, signatures and design marks (“Suforia logos”) are valuable assets that Suforia needs to protect. Accordingly, we ask that You follow these guidelines with respect to Suforia logos. Remember that You are generally not able to use Suforia logos unless You are specifically licensed or authorized to use them.

Proper Use

Third parties expressly licensed or authorized to use Suforia logos must not alter or modify them in any way. Make sure to use Suforia approved artwork and refer to the appropriate identity guidelines provided by Suforia. Use must comply with the terms and conditions of Your license or Suforia’s authorization.