Privacy Policy

Overview

Who we are

We are Sonobi, Inc., an independent technology company serving both media brands/publishers and advertisers/agencies. We are a Delaware corporation, having an address at 444 W New England Avenue, Suite 215 Winter Park, FL 32789. All references in this policy to “Sonobi“, “our“, “us” or “we” refer to Sonobi, Inc..  All references in this policy to “our website”, are a reference to the website owned by Sonobi at www.sonobi.com and our media brand’s/publisher’s website.

Our values and what this policy is for

We value your privacy and want to be accountable and fair to you as well as transparent with you in the way that we collect and use your personal information.  We also want you to know your rights in relation to your information.

In line with these values, this privacy policy tells you what to expect when we collect and use personal information about you.  We have tried to make it easy for you to navigate so you can find the information that is most relevant to you and our relationship with you.

We are always looking to improve the information we provide to our customers and contacts so if you have any feedback on this privacy policy, let us know by emailing us at privacy@sonobi.com.

Who this policy applies to  

This policy applies to:

1. Personnel at media brands/publishers and advertisers/agencies that we work with or other third parties to which we provide services Click here.

2. Visitors to our website Click here.

3. People who contact us with enquiries Click here.

4. Our suppliers and employees of our suppliers Click here.

5. End users who are served with advertising (where Sonobi acts as data processor for advertisers and publishers) Click here.

Depending on our relationship, we will collect and use your information in different ways.  Please click on the links above to find out the information that we collect about you and how we use this information.

What this policy contains

This privacy policy describes the following important topics related to your information (you can click on the links to find out more):

1. How we obtain your personal information Click here.

2. Collection of your personal information and how we use it Click here.

3. Our legal basis for using your personal information Click here.

4. How and why we share your personal information Click here.

5. How long we store your personal information Click here.

6. Your rights Click here.

7. Marketing Click here.

8. Where we may transfer your personal information Click here.

9. Risks and how we keep your personal information secure Click here.

10. California residents Click here.

11. Children Click here.

12. Links to other websites Click here.

13. Changes to this privacy policy Click here.

14. Further questions and how to make a complaint Click here.

Your rights to object

You have various rights Section 6 in respect of our use of your personal information.  Two of the fundamental rights to be aware of are:

1. You may ask us to stop using your personal information for direct marketing purposes.  If you exercise this right, we will stop using your personal information for this purpose.
2. You may ask us to consider any valid objections which you have to our use of your personal information, where we process your personal information on the basis of our, or another person’s, legitimate interest.

What you need to do and your confirmation to us:

Please read this privacy policy carefully to understand how we handle your personal information. By engaging with us in the ways set out in this privacy policy, you confirm that you have read and understood the entirety of this privacy policy, as it applies to you.

Privacy Policy Details

1. How we obtain your personal information

Voluntarily

You may provide us with your personal information voluntarily.  However, we may also receive information about you from third parties such our media brands/publishers, advertisers/agencies, partners, suppliers or via websites which you visit, which we refer to as “third-party sources” or “suppliers” throughout this policy.

Via online forms

You may give us personal information about yourself by using the online forms provided on our website or by contacting us by phone, email or other means. This includes, for example, where you provide your personal information to us in order to receive information or services from us. If you are a supplier, you may also give us personal information about you when you are offering or providing services to us.

2. Collection of your personal information and how we use it  

Please go to the subsection(s) below that best describes our relationship with you to find out the information that we collect about you and how we use this information.  We refer to this as “personal information” throughout this policy.

Personnel at media brands/publishers and advertisers/agencies that we work with or other third parties to which we provide services

What personal information we collect about you. We, or third parties on our behalf, may collect and use any of the following information about you: your name; your postal address; your email address; your telephone number; online account authentication details; and any other information provided when you correspond with us.

How we use your personal information. We will collect, use and store the personal information listed above for the following reasons:

• To provide you with our services;
• To deal with any enquiries or issues you have about our services that you request from us;
• To provide support for any faults or failures in our service or technologies;
• To send you certain communications (including by email or post) about our services such as service announcements and administrative messages (for example, setting out changes to our terms and conditions and keeping you informed about our fees and charges);
• To carry out statistical analysis and market research relating to our services; and
• If you have consented or if it is in our legitimate interests, for business development and marketing purposes, to contact you (including by email or post) with information about our services which either you requested, or which we feel will be of interest to you (including newsletters).

Source of personal information.  We often receive personal information directly from you. However, we may also obtain it from other third-party sources.

Information we need to provide services to you. We need certain types of personal information so that we can provide services to the business that you represent. We also need certain types of personal information in order to perform contractual and other legal obligations that we have to such business. If you do not provide us with such personal information, or if you ask us to delete it, you may no longer be able to access our services.

Visitors to our website

What personal information we collect about you. We, or third parties on our behalf, may collect and use any of the following information about you: your name; your email address; information provided when you correspond with us; any updates to information provided to us; and personal information we collect about you or that we obtain from our third party sources.

We also automatically create and record the following information when you visit our website:

• Technical information. This includes: the Internet protocol (IP) address used to connect your computer to the internet address; the device ID; the website address and country from which you access information; the requested files; the browser type and version; the browser plug-in types and versions; the operating system; and the platform. We use this personal information to administer our website, to measure the efficiency of our systems and to undertake an analysis on the locations from which people access our web pages;
• Information about your visit and your behavior on our website (for example, the pages that you click on).  This may include the website you visit before and after visiting our website (including date and time), time and length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, traffic data, location data, weblogs and other communication data and information provided when requesting further service or downloads; and
• Cookie information. Some pages on our client websites use our cookies, which are small files placed on your internet browser when you visit our website. We use cookies in order to offer you a more tailored advertising experience.

Where cookies are used, you may block these at any time. To do so, you can activate the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies), you may not be able to access all or parts of our clients’ websites or to use all the functionality provided through their websites.

For detailed information on the cookies we use and the purposes for which we use them, please refer to our cookies policy here Cookies Policy.

How we use your personal information. We will collect, use and store the personal information listed above for the following reasons:

• To allow you to access and use our website;
• To receive enquiries from you through the website about our services;
• For improvement and maintenance of our website and to provide technical support for our website;
• To ensure the security of our website;
• To recognize you when you return to our website, to store information about your preferences, and to allow us to customize the website according to your individual interests; and
• To evaluate your visit to the website and prepare reports or compile statistics to understand the type of people who use our website, how they use our website and to make our website more intuitive. Such details will be anonymised as far as reasonably possible and you will not be identifiable from the information collected.

Please read the remainder of section 2 for more details about how we use your personal information.

People who contact us with enquiries

What personal information we collect about you. We, or third parties on our behalf, may collect and use any of the following information about you: your name; your email address; information provided when you correspond with us; and any updates to information provided to us.

How we use your personal information. We will collect, use and store the personal information listed above to deal with any enquiries or issues you have about our business and services, including any questions you may have about how we collect, store and use your personal information, or any requests made by you for a copy of the information we hold about you.  We may process your personal information for these purposes where it is in our legitimate interests for client services purposes.

Please read the remainder of section 2 for more details about how we use your personal information.

Our suppliers and employees of our suppliers

What personal information we collect about you. We, or third parties on our behalf, may collect and use any of the following information about you: your name; work contact information (phone number, postal address, mailing address, email address); your job title; your date of birth; information provided when you correspond with us; any updates to information provided to us; and personal information we collect about you from third party sources such as LinkedIn.

How we use your personal information. We will collect, use and store the personal information listed above for the following reasons: to enable us to receive and manage services from you (including supplier due diligence, payment and expense reporting and financial audits); and for background checks required by law.

Please read the remainder of section 2 for more details about how we use your personal information.

Source of personal information.  We may receive some of your personal information from third party sources, such as your employer or your employer’s company website. We may also collect this personal information from publicly-available sources, such as LinkedIn.

Additional reasons for collecting, using and storing your personal information

Whatever our relationship with you is, we may also collect, use and store your personal information for the following additional reasons:

To deal with any enquiries or issues you have about how we collect, store and use your personal information, or any requests made by you for a copy of the information we hold about you.  If we do not have a contract with you, we may process your personal information for these purposes where it is in our legitimate interests for customer services purposes;

For internal corporate reporting, business administration, ensuring adequate insurance coverage for our business, ensuring the security of company facilities, research, and development, and to identify and implement business efficiencies.  We may process your personal information for these purposes where it is in our legitimate interests to do so;

To comply with any procedures, laws, and regulations which apply to us – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others to comply, as well as where we are legally required to do so;

To establish, exercise or defend our legal rights – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others, as well as where we are legally required to do so.

Further Processing

We will not use your personal information in any way that is incompatible with the purposes set out in section 2.  Please contact us at privacy@sonobi.com for further information on the analysis we will undertake to establish if a new use of your personal information is compatible with these purposes.

Sonobi as data processor for advertisers and publishers

Please note that we act as a data processor for both (A) advertisers, who may act through agencies, and (B) media brands and publisher websites where ads are displayed.

What personal information we collect about you. In our capacity as data processor, we or third parties on our behalf, may collect and use the following information about you:

• Technical information collected when you use the website of media brands/publishers that we provide services to. This includes: the Internet protocol (IP) address used to connect your device to the internet address; your device ID; the website address and country from which you access information; the files requested; browser type and version; browser plug-in types and versions; user agent; operating system; platform; the website you visit before and after visiting our media brand’s/publisher’s website (including date and time), time and length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, traffic data, location data, weblogs and other communication data, information provided when requesting further service or downloads;
• Information obtain from media brand/publisher websites. We obtain information such as your email address and a publisher issued identifier. This information will be stored temporarily on our servers during the processing of such information and will be permanently deleted once the processing is complete;
• Information collected by or through third-party advertising companies. We may share information about your activity on our media brand’s/publisher’s website with third parties for the purpose of tailoring, analysing, managing, reporting, and optimizing advertising. These third parties may use cookies, pixel tags (also called web beacons or clear gifs), and/or other technologies to collect such information for such purposes. Pixel tags enable us, and these third-party advertisers, to recognize a browser’s cookie when a browser visits the site on which the pixel tag is located in order to learn which advertisement brings a user to a given site. In addition, we may receive information from advertisers and/or their service providers such as advertising identifiers, IP addresses, and post-conversion data. If you wish to opt out of third-party interest-based advertising, please visit www.networkadvertising.org for details on how to do so. We also receive information about consumers from third parties to enable targeted advertising on the website(s) and application(s) that we support. The collection and use of that data is governed by the privacy policy and legal terms of the data collector and the website using the data; it is not governed by Sonobi; and
• Cookie information. The websites of media brands/publishers we work for might use our cookies, which are small files placed on your internet browser when you visit our website. We use cookies in order to offer you a more tailored advertising experience.  You may block these cookies at any time. To do so, you can activate the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies), you may not be able to access all or parts of our clients’ websites or to use all the functionality provided through their websites.

How we use your personal information. In our capacity as data processor, we may use the personal information listed above for the following reasons:

• To assist with the serving of digital ads to you which are tailored to you;
• To match multiple devices associated with the same publisher identifier as devices belonging to the same user or household. Where we are able to make such a match, we may use this information to deliver targeted advertisements across multiple devices on behalf of our customers;
• To limit the number of times that you see a digital advertisement;
• To measure the effectiveness of digital advertising campaigns; and
• For any other purposes that our advertisers/agencies or media brands/publishers (as appropriate) instruct in relation to the services that we provide to them.

We are not in charge of how your data is used. As we act as a data processor, we are not ultimately in charge of how your data is used, and we act on the instructions of the relevant data controller. In order to exercise any of your rights as a data subject in relation to the personal data referred to in the subsection “Sonobi as data processor for advertisers and publishers”, please contact the relevant advertiser/agency or media brand/publisher.

3. Legal basis for use of your personal information

Legal bases

We consider that the legal bases for using your personal information as set out in this privacy policy are as follows:

To perform our obligations. Our use of your personal information is necessary to perform our obligations under any contract with you (for example, to comply with the terms of use of our website which you accept by browsing our website); or

To comply with our legal obligations. Our use of your personal information is necessary for complying with our legal obligations (for example, for tax regulation purposes); or

For our legitimate interests. Where neither (a) nor (b) apply, use of your personal information is necessary for our legitimate interests or the legitimate interests of others. Our legitimate interests are to:

• Run, grow and develop our business;
• Provide our services to clients, make and receive payment and provide client services;
• Target you with advertising content that is relevant to you;
• Obtain and share data in order to get a better sense of your interests, to help inform advertising that we serve to you;
• Operate our website;
• Select appropriately skilled and qualified suppliers;
• Marketing, market research and business development; and
• For internal administrative purposes.

We have carried out a balancing test and we believe that we have a legitimate business interest to use and share your personal data (in compliance with this privacy policy and subject to your various rights as set out in this privacy policy) and that our legitimate interest is not detrimental to you.

If we rely on our (or another person’s) legitimate interests for using your personal information in the future, we will undertake a balancing test to ensure that our (or the other person’s) legitimate interests are not outweighed by your interests or fundamental rights and freedoms which require protection of the personal information.  You can ask us for information on this balancing test by emailing us at privacy@sonobi.com.

For marketing purposes

We may process your personal information in some cases for marketing purposes on the basis of your consent (which you may withdraw at any time after giving it, as described below).

Withdrawing your consent

If we rely on your consent for us to use your personal information in a particular way, but you later change your mind, you may withdraw your consent by contacting us at privacy@sonobi.com and we will stop collecting and using your personal information.

4. How and why we share your personal information with others

Legitimate interests

We may share your personal information with our group companies where it is in our legitimate interests to do so for internal administrative purposes – for example, ensuring consistent and coherent delivery of our services to our clients, corporate strategy, compliance, auditing and monitoring, research and development and quality assurance.    

Sharing with third parties

We will share your personal information with the following third parties or categories of third parties:

• Media brands/publishers to which we provide our services, or prospective media brands/publishers;
• Advertisers/agencies to which we provide our services, or advertisers/agencies;
• Our affiliates, agents and business partners (in aggregated form);
• Our other service providers and subcontractors, including but not limited to data hosting providers, data storage providers, payment processors, suppliers of technical and support services and insurers;
• Companies that assist us in our marketing, advertising, and promotional activities;
• Analytics and search engine providers that assist us in the improvement and optimization of our website; and
• Our parent company, subsidiaries, joint ventures or other companies under common control (for aggregation, analysis, and benchmarking purposes).

We will always ensure that any third parties with whom we share your personal information are subject to privacy and security obligations consistent with this privacy policy and applicable laws.

Disclosing to third parties

We will also disclose your personal information to third parties:

• Where it is in our legitimate interests to do so to run, grow and develop our business. More specifically: if we sell or buy any business or assets, we may disclose your personal information to the prospective seller or buyer of such business or assets; or if substantially all of Sonobi’s or any of its affiliates’ assets are acquired by a third party, in which case personal information held by Sonobi will be one of the transferred assets;
• If we are under a duty to disclose or share your personal information in order to comply with any legal obligation, any lawful request from government or law enforcement officials and as may be required to meet national security or law enforcement requirements or prevent illegal activity;
• In order to enforce or apply our terms and conditions or any other agreement, or to respond to any claims, to protect our rights or the rights of a third party, to protect the safety of any person or to prevent any illegal activity; or
• To protect the rights, property, or safety of Sonobi, our staff, our clients or other persons. This may include exchanging personal information with other organizations for the purposes of fraud protection and credit risk reduction.

Disclosing for reporting

We may also disclose and use anonymized, aggregated reporting and statistics about users of our website or our goods and services for the purpose of internal reporting or reporting to other third parties, and for our marketing and promotion purposes.

Third party consent

With the exception of the cases expressly detailed above, we will never share, sell or rent any of your personal information to any third party without notifying you and, where necessary, obtaining your consent. If you have given your consent for us to use your personal information in a particular way, but later change your mind, you should contact us and we will stop doing so.

5. How long we store your personal information

We keep your personal information for no longer than necessary for the purposes for which the personal information is processed.  The length of time we retain personal information for depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights. Usually, we keep personal data for a period of 4 years. Where the personal data is used for ad targeting purposes and is based on cookies, we will retain your personal information in a form that identifies you only for no more than 30 days (unless we reasonably need it for the purposes of archiving in the public interest, journalism, literature and art, scientific or historical research and statistical analysis, and subject to the protection of this Privacy Policy). After such time periods have expired, we may either delete your personal information or retain it in a form such that it does not identify you personally.

6. Your rights

Rights in relation to your personal information

You have certain rights in relation to your personal information. If you would like further information in relation to these or would like to exercise any of them, please contact us via email at privacy@sonobi.com at any time. You have the following rights:

Right of access.  You have a right of access to any personal information we hold about you.  You can ask us for a copy of your personal information; confirmation whether your personal information is being used by us; details about how and why it is being used; and details of what safeguards are in place if we transfer your information outside of the European Economic Area (“EEA”).

Right to update your information.  You have a right to request an update to any of your personal information which is out of date or incorrect.

Right delete your information.  You have a right to ask us to delete any personal information which we are holding about you in certain specific circumstances.  You can ask us for further information on these specific circumstances by contacting us at privacy@sonobi.com.

We will pass your request onto other recipients of your personal information unless that is impossible or involves disproportionate effort.  You can ask us who the recipients are by contacting us at the email address above.

Right to restrict use of your information. You have a right to ask us to restrict the way that we process your personal information in certain specific circumstances.  You can ask us for further information on these specific circumstances by contacting us at privacy@sonobi.com.

Right to stop marketing. You have a right to ask us to stop using your personal information for direct-marketing purposes. If you exercise this right, we will stop using your personal information for this purpose.

Right to data portability. You have a right to ask us to provide your personal information to a third party provider of services.

This right only applies where we use your personal information on the basis of your consent or performance of a contract, and where our use of your information is carried out by automated means.

Right to object.  You have a right to ask us to consider any valid objections which you have to our use of your personal information where we process your personal information on the basis of our or another person’s legitimate interest.

Our response to your requests

We will consider all such requests and provide our response within a reasonable period (and in any event within one month of your request, unless we notify you that we are entitled to a longer period allowed by applicable law). Please note, however, that certain personal information may be exempt from such requests in certain circumstances – for example if we need to keep using the information to comply with our own legal obligations or to establish, exercise or defend legal claims.

Exceptions

If an exception applies, we will tell you this when responding to your request.  We may request you provide us with information necessary to confirm your identity before responding to any request you make.

7. Marketing

• We may collect and use your personal information for undertaking marketing by email, telephone and post.
• We may send you certain marketing communications (including electronic marketing communications to existing customers) if it is in our legitimate interests to do so for marketing and business development purposes.
• However, we will always obtain your consent to direct marketing communications where we are required to do so by law and if we intend to disclose your personal information to any third party for such marketing.
• If you wish to stop receiving marketing communications, you can contact us by email at privacy@sonobi.com or click on the ‘unsubscribe’ link at the bottom of any Sonobi marketing email.

8. Where we may transfer your personal information

Where your data is used, stored, or accessed

Your personal information will be used, stored and/or accessed from our servers located in the U.S.A. If you are located outside of the U.S.A., please be aware that any information provided to us, including personal information, will be transferred from your country of origin to the U.S.A..

Transfer to a non-EEA members supplier, client, or partner

Where any personal information about you is transferred to a non-EEA members supplier, client or partner, we will take appropriate measures to ensure that the recipient protects your personal information adequately in accordance with this privacy policy.  These measures may include the following cases permitted in Articles 45 and 46 of the General Data Protection Regulation:

• In the case of US based entities, entering into European Commission approved standard contractual arrangements with them, or ensuring they have signed up to the EU-US Privacy Shield (see further https://www.privacyshield.gov/welcome); or
• In the case of entities based in other countries outside the EEA, entering into European Commission approved standard contractual arrangements with them.

Privacy Shield Framework

Sonobi complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from the European Union member countries (including Iceland, Liechtenstein and Norway) and Switzerland to the United States respectively. Sonobi has certified that it adheres to the Privacy Shield principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, Recourse, Enforcement and Liability (the “Privacy Shield Principles”). With regard to the Principle of Accountability for Onward Transfer, for example, Sonobi remains liable if our agent processes such personal information in a manner inconsistent with the Privacy Shield Principles, unless we prove that we are not responsible for the event giving rise to the damage. If there is a conflict between this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit www.privacyshield.gov.

Sonobi is subject to the investigatory and enforcement powers of the Federal Trade Commission. In compliance with the EU-U.S. and the Swiss-U.S. Privacy Shield Principles, Sonobi commits to resolve complaints about your privacy and our collection or use of your personal information. European Union or Swiss individuals with inquiries or complaints regarding this Privacy Policy should first contact Sonobi at privacy@sonobi.com.

Sonobi is further committed to refer unresolved privacy complaints under the EU-U.S. and the Swiss-U.S. Privacy Shield Principles to BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by Sonobi, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint. If these processes do not result in a resolution, you may also contact your local data protection authority, the U.S. Department of Commerce, and/or the Federal Trade Commission for assistance. If your complaint still remains unresolved, then you have the right to invoke binding arbitration by the Privacy Shield Panel upon written notice to Sonobi at privacy@sonobi.com. Pursuant to the Privacy Shield, Sonobi Inc remains liable for the transfer of personal data to third parties acting as our agents unless we can prove we were not a party to the events giving rise to the damages.

Further details

Further details on the steps we take to protect your personal information, in these cases is available from us on request by contacting us by email at privacy@sonobi.com at any time.

9. Risks and how we keep your personal information secure

Loss, theft, or misuse

The main risk of our processing of your personal information is if it is lost, stolen or misused.  This could lead to your personal information being in the hands of someone else who may use it fraudulently or publicize information that you would prefer to keep private. For this reason, Sonobi is committed to protecting your personal information from loss, theft and misuse.  We take all reasonable precautions to safeguard the confidentiality of your personal information, including through use of appropriate organisational and technical measures.

Transfer

Your personal information will be transferred over the internet.  Although we make every effort to protect the personal information which you provide to us, the transmission of information over the internet is not completely secure. As such, you acknowledge and accept that we cannot guarantee the security of your personal information transmitted to our website and that any such transmission is at your own risk. Once we have received your personal information, we will use strict procedures and security features to prevent unauthorized access to it.

Passwords

Where we have given you (or where you have chosen) a password which enables you to access your online account, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

10. California Residents

Opting out of third-party sharing

Under California Civil Code Section 1798.83, California residents who have an established business relationship with Sonobi may choose to opt out of our sharing your Personal Information with third parties for direct marketing purposes. If you are a California resident and (a) you wish to opt out; or (b) you wish to request certain information regarding our disclosure of your Personal Information to third parties for the direct marketing purposes, please send an e-mail to privacy@sonobi.com or write to us at:

Sonobi, Inc.

915 Broadway, Suite 1802

New York, NY 10010

Other no-tracking mechanisms

In addition, Sonobi does not monitor, recognize, or honor any opt-out or do not track mechanisms, including general web browser “Do Not Track” settings and/or signals.

11. Children

We do not knowingly collect personal information from children under the age of 13 through the website. If you are under 13, please do not give us any personal information. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children to never provide personal information through the Website without their permission. If you have reason to believe that a child under the age of 13 has provided personal information to us, please contact us, and we will endeavor to delete that information from our databases.

12. Links to other websites

Our website may contain hyperlinks to websites that are not operated by us. These hyperlinks are provided for your reference and convenience only and do not imply any endorsement of the activities of such third-party websites or any association with their operators. This privacy policy only applies to the personal information that we collect or which we receive from third party sources, and we cannot be responsible for personal information about you that is collected and stored by third parties. Third party websites have their own terms and conditions and privacy policies, and you should read these carefully before you submit any personal information to these websites. We do not endorse, or otherwise accept, any responsibility or liability for the content of such third party websites or third party terms and conditions or policies.

13. Changes to our privacy policy

We may update our privacy policy from time to time. Any changes we make to our privacy policy in the future will be posted on this page and, whenever appropriate, emailed or sent to you by post. Please check back frequently for any updates or changes to our privacy policy.

14. Further questions and how to make a complaint

Queries for Sonobi

If you have any queries or complaints about our collection, use or storage of your personal information, or if you wish to exercise any of your rights in relation to your personal information, please contact privacy@sonobi.com. We will investigate and attempt to resolve any such complaint or dispute regarding the use or disclosure of your personal information.

Formal complaints

You may also make a complaint to the Information Commissioner’s Office, or the data protection regulator in the country where you usually live or work, or where an alleged infringement of the General Data Protection Regulation has taken place.  Alternatively, you may seek a remedy through the courts if you believe your rights have been breached.

The practices described in this privacy policy statement are current as of Sep. 2018.