Sona Labs (“Sona” or “we”) provides its business customers with a customer data platform and advanced marketing attribution tools. This Privacy Policy (“Privacy Policy” or “Policy”) explains our practices regarding the collection, use, and disclosure of information that we receive through our website located at www.sona.com (the “Site”) and our communications with you (collectively, the “Services”). This Privacy Policy does not apply to any third-party websites, services, or applications, even if they are accessible through our Services.
Scope of the Privacy Policy
This Privacy Policy applies to all users of our Services including without limitation, site visitors, account holders, free trial customers, paying customers, and recipients of communications from us (all such users of the Services are collectively referred to herein as “Customers” or “You”). This Privacy Policy does not apply to any of the information that our customers may collect, process, or provide in the course of using our Services (“Customer Data”). Our customers’ respective privacy policies govern their collection and use of Customer Data. Our processing of Customer Data is governed by the contracts that we have in place with our customers, not this Privacy Policy.
Information Collected Automatically
Information Sent by Your Device: We collect certain information that your mobile device, laptop, or other hardware device sends when you use our Services, including but not limited to IP address, user agent information, network and connectivity information, device identifiers, advertising identifiers, language preferences, user settings, software and operating system names and versions, hardware models, as well as other information about your use of our Services.
Location Information: When you use our Services, we may collect and store information about your location by converting your IP address into a rough geo-location or by requesting precise location through your browser settings.
Information Collected Using Cookies and Other Web Technologies: Like many website owners and operators, we (and our partners who assist us with marketing, analytics, Customer research, advertising, and Customer support) may utilize automated data collection tools such as cookies, web beacons, and pixel tags to collect certain information from Customers of our Services. These tools are used for a variety of purposes, including but not limited to user authentication, account security, delivery and measuring of advertising, analyzing site traffic and trends, and fraud prevention. Cookies are small text files that are placed on your device by a web server when you access our Services. We may use both session cookies and persistent cookies to identify that you’ve logged in to the Services and to tell us how and when you interact with our Services. You have choices related to whether you want to accept (see the section below entitled "Your Choices"). Please note, however, that if you don’t accept cookies, you may not be able to access all portions or features of the Services. Web beacons (also known as web bugs, pixel tags, or clear GIFs) are tiny graphics with a unique identifier that may be included on our Services for several purposes, including delivering or communicating with cookies, to track and measure the performance of our Services, to monitor how many visitors view our Services, and to monitor the effectiveness of our advertising. Unlike cookies, which are stored on the device, Web beacons are typically embedded invisibly on web pages (or in an email). Note when we use the defined term “Cookies” in this Privacy Policy, we are referring collectively to cookies, pixel tags, web beacons, and similar tracking technologies. Our use of Cookies falls into the following general categories:
Necessary Cookies: We use this type of Cookie to run our site, and to identify and prevent security risks. For instance, we may use these cookies to store your session information to prevent others from changing your password without your username and password.
Performance Cookies: We use this type of Cookie to collect information about how you use our site, monitor site performance, and improve our site performance, our services, and your experience. For example, we can use these Cookies to learn more about which features are the most popular with our Customers and which ones might need some tweaks.
Preference Cookies: We use this type of Cookie to remember your settings and preferences, and to improve your experience on our site. For instance, we may use these Cookies to remember your language preferences.
Marketing Cookies: We use this type of Cookie to deliver advertisements, to make them more relevant and meaningful, and to track the efficiency of our advertising campaigns, both within and outside of our Services.
Interaction Data: We also collect information relating to the actions that you perform while logged into your accoun
Information From Third Parties
We may also obtain information about Customers from third parties, including but not limited to affiliates, joint marketing partners, lead providers, fraud and risk mitigation vendors, and identify verification services.
How We Use the Information
Our primary goals in collecting information are to (i) provide and improve our Services, (ii) customize content and the Services for you, (iii) administer your use of the Services (including your account, if you are an account holder), and (iv) enable you to enjoy and easily navigate our Services. We will use your Personal Data for the following purposes:
Providing our Services, including communicating with you, and providing customer support in relation to the Services;
Resolving disputes, responding to inquiries, collecting and processing payments fees (as applicable) and troubleshooting problems;
Collecting and processing payment;
Managing our everyday business needs, including, but not limited to the following activities: auditing, administration of the Services, forum management, fulfillment, analytics, fraud prevention, identify verification, and enforcement of our Terms and Conditions, or complying with applicable laws or regulations;
Customizing your experience and otherwise measuring and improving our content and Services;
Sending you relevant emails and communications (including keeping you informed about our products, offerings, and any promotional offers) that might be of interest to you. (In the event that we use your Personal Data to market to you, you will be able to opt-out of such uses);
Enforcing our agreements, terms, conditions, and policies, and sending you notices and alerts;
Better understanding our Customers’ interests, behaviors, and demographics;
Short-term, transient use, such as contextual customization of ads;
Auditing relating to interactions, transactions and other compliance activities; and
Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity.
We may use Personal Data and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, and de-identified information about the device from which you access our Services.
We may also use your information for any other purpose disclosed to you at the time we collect or receive your information, or otherwise with your consent.
Information We Share with Third Parties
We may share information you provide us, including your Personal Data, with third parties, in the types of scenarios, and for the types of reasons described in this section.
Services Providers and Business Partners: We may engage third-party service providers to help us administer, provide, and improve the Services, including but not limited to the following types of partners: third-party financial services companies, web hosting providers, cloud hosting providers, fraud detection services, identity verification services, fulfillment service providers, and customer support partners. These third-party service providers will have access to your Personal Data for the purpose of performing services on our behalf. For example, we may share your Personal Data with a cloud hosting provider (for example, Amazon Web Services) as part of our utilization of their hosting services.
At Your Request: We may share information about you with third parties in the event that you request we do so, for example, with other Customers or groups of Customers if you request that or if, for instance, you use a feature that performs that type of sharing function. Similarly we may share information about you with companies offering complimentary services, promotions, or offers through our Site or our Services, if you request, or consent, that we share your information.
Other Third Parties: We may share de-identified or aggregated data we collect from the use of the Services, including but not limited to de-identified or aggregated: transaction information, location information, information about the computer or device from which you access the Services, market trends, and other analysis that we create based on the information we receive from you and other Customers.
Our Subsidiaries and Affiliates: We share information with our corporate subsidiaries and affiliates, including parent and holding companies, for our administrative purposes, including activities such as IT management, auditing and compliance, and for them to provide services to you or support and supplement the Services we provide.
With Your Consent: There may be other circumstances where we will notify you of information that we seek to share with a third party not listed here, and will do so with your consent
Information Shared with Web Analytics Services Providers: We may use some or all of the following analytics services:
Google: We use Google Analytics, a service provided by Google, Inc. (“Google”), to gather information about how Customers engage with our Site and Services. For more information about Google Analytics, please visit this page. You can opt out of Google’s collection and processing of data generated by your use of the Services by going here. Segment: We may use a service provided by Segment, Inc. (“Segment”) to provide us with analytics data regarding Customers’ interactions with our Site and Services. You may opt-out of Segment’s automatic retention of data that is collected while using the Services by visiting this page. To track opt-outs, Segment uses a persistent opt-out cookie placed on your device. Please note that if you get a new computer, install a new browser, erase or otherwise alter the browser’s cookie file (including upgrading certain browsers), you may delete the Segment opt-out cookie. Information Disclosed in Connection with Business Transactions: If we are acquired by a third party as a result of a transaction such as a merger, acquisition, or asset sale, or if our assets are acquired by a third party in the event we go out of business or enter bankruptcy, some or all of our assets, including your Personal Data, may be disclosed or transferred to a third party acquirer in connection with the transaction.
Information Disclosed for Our Protection and the Protection of Others: We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. We may disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to: (i) respond to claims or legal process (including subpoenas); (ii) protect our property, rights and safety and the property, rights and safety of a third party or the public in general; and (iii) stop any activity that we consider illegal, unethical or legally actionable activity.
With Advertising Partners and Social Media. Your Personal Data may be shared with certain advertising partners who conduct or assist us with marketing, as well as advertising and social media partners who we allow to place cookies (or similar technology) in our Services as necessary to their provision of various services, including but not limited to ad attribution, ad placement, audience measurement, social sharing, and site analytics.
The Security of Your Information
We take reasonable administrative, physical, and electronic measures designed to protect the information that we collect from or about you (including your Personal Data) from unauthorized access, use or disclosure. When you enter sensitive information on our forms, we encrypt this data using SSL or other technologies. Please be aware, however, that no method of transmitting information over the internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail or by sending an email to you.
We need to retain the information you provide us in order to provide our Services, and we retain such information for as long as you maintain your account, at a minimum. We also retain certain relevant information, including transaction, location, device, and usage information, for as long as it is required to do so, in connection with regulatory, tax, insurance, legal, administrative, and other requirements. You may request deletion of your account at any time as provided above. Following such a request, we will delete the information that it is not necessary to retain. In certain circumstances, we may be unable to delete your account, such as if there is an outstanding credit or debt on your account or an unresolved dispute, ongoing investigation (e.g. for fraud or misuse), or we believe that we may be required to retain your account for legal, regulatory, or accounting reasons. Upon resolution of the issue preventing deletion, we will delete your account as described above. We may also retain certain information if necessary for our legitimate business interests, such as fraud prevention and enhancing Customers' safety and security. For example, if we shut down a Customer's account because of security or fraud incidents, we may retain certain information about that account to prevent that Customer from opening a new account in the future.
Processing Information in the United States
We are headquartered in the United States and may use service providers that operate in other countries. Your Personal Data may be transferred to, and maintained on, computers located outside of your state, province, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. We strive to safeguard your information consistent with the requirements of applicable laws by taking reasonable administrative, physical, and electronic measures designed to protect the information that we collect from or about you from unauthorized access, use, or disclosure. However, no security measures are failsafe and we cannot guarantee the security of your personal information.
Cookie Preferences Management
Notwithstanding anything else in this Privacy Policy, we and our marketing partners may use IP address, browser information, and your device information obtained by us when you visit our Site, utilize our Services, or open messages sent by us, in conjunction with third-party web cookies, pixels, or similar technologies, enabling us to obtain personal data about you (such as your name, contact details, location, and employer) held by third parties. To learn more, see the section above entitled “Information That We Collect” of this Privacy Policy. To opt out of the specific data collection and sharing practices described in this provision, please contact us using the contact information set forth in the section entitled “Privacy Questions” of this Privacy Policy.
Information We Collect (CCPA Required Disclosure)
As we address throughout this Privacy Policy, we collect Personal Data for a range of purposes, though primarily to allow us to provide and improve our Services. In the last 12 months, we have collected the following types of Personal Data about our Customers. In some cases the data is provided directly by Customers. In other cases it was provided by third parties, or obtained through Customer interaction with our Services.
Identifiers, such as your name, email address, IP address, username, or other similar identifiers. We primarily use these identifiers to create your account, maintain security of our Services, and communicate with you.
Customer records information, such as telephone number, bank account number, credit card number, or debit card number. We primarily use these types of information to facilitate transactions and payments and to communicate with our Customers. (This category under CCPA overlaps with other categories.)
Commercial information, such as payment history and purchase history. We primarily use this type of information to keep track of Customer transactions and for internal business and financial record keeping.
Internet or other electronic network activity information, such as session logs, search history, and information about your interaction with a website, application, or advertisement. We primarily use this type of information to help understand how our Services are performing, as well as to improve our own understanding of our Services.
Geolocation information, such as your IP address, which provides a rough approximation of location. We use this data primarily to understand where Customers are accessing the Services, and in some cases to provide more relevant advertising.
Professional or employment-related information, such as the name of your employer. We use this information in order to know the names and types of businesses that utilize our Services.
Information Sharing (CCPA Disclosure)
In the past 12 months, we’ve disclosed the above categories of information for business purposes, or at your direction, with our service providers, affiliates, and other third parties. For instance, we share Personal Data about our Customers with our data hosting and storage providers. For more details please refer to the section above entitled "Information That We Share with Third Parties." We have agreements with our service providers that limit their ability to use your information and require them to ensure its confidentiality.
Privacy Notice for European and Brazilian Customers
We are providing this supplemental privacy notice to European data subjects (including Customers in the EEA, UK, and Switzerland), pursuant to European data protection laws including the General Data Protection Regulation (“GDPR”) and Brazilian data subjects, pursuant to Brazilian data protection laws including the General Personal Data Protection law (“LGPD”). Sona Labs is the controller of your Personal Data. This means that Sona Labs is responsible for how your Personal Data is handled. And, we encourage you to review the remainder of this section to understand the bases upon which we process Personal Data as well as the rights afforded to you.
Processing Purpose
Legal Purpose
To operate our Services:
Processing is necessary to perform the contract governing our provision of our Services or to take steps that you request prior to signing up for the Services. If we have not entered into a contract with you, we process your Personal Data based on our legitimate interest in providing the Services you access and request.
For research and development, marketing purposes, compliance, fraud prevention and safety:
These activities constitute our legitimate interests. We do not use your Personal Data for these activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
For research and development, marketing purposes, compliance, fraud prevention and safety:
These activities constitute our legitimate interests. We do not use your Personal Data for these activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
To comply with the law:
Processing is necessary to comply with our legal obligations.
With your consent:
Processing is based on your consent. Where we rely on your consent you have the right to withdraw it any time in the manner indicated when you consent or in the Services.
