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Sovrin Foundation Website Privacy Policy
Last modified December 6th, 2018
This Privacy Policy explains how the Sovrin Foundation 86 N University Ave, Suite 110, Provo, UT 84601 (“Sovrin,” “we” or “us”) collects, uses, and discloses information (as hereinafter defined) from visitors to any Sovrin website that posts a link to this Privacy Policy (each, a “Website” and collectively, the “Websites”). By using our Websites and providing information to us, you agree to the terms and conditions of this Privacy Policy.
References to your information and personal data under this Privacy Policy only apply to that personal data and information we collect about you during your visit to the Websites. We also wish to clarify with you that the Sovrin Foundation may from time to time offer products and services governed by their own privacy policies. With regard to these products and services please refer to the applicable, governing privacy policies for information regarding how your information is used by Sovrin, if at all.

Contact Information
If you have any questions or concerns about this Privacy Policy, please let us know by contacting us at:
info at sovrin.org
Please note, that if you contact us to assist you, for your security and ours, we may require that you authenticate your identity before fulfilling your request.

Information We Collect
We may gather the information which you directly provide including but not limited to:
name;
email address;
home or business address;
username and password associated with your account;
phone number and other contact details; and
other details about you that you voluntarily provide.

Other Information We Collect Automatically
Our Websites collect certain information automatically about you and your use of our Website (collectively “Other Information”). This Other Information includes:
Device IDs, IP addresses or other unique device identifiers;
Advertising identifiers; and
Information collected via the use of cookies, web beacons and other technologies, including ad data.

Cookies and other Tracking Mechanisms
We and our service providers use cookies and other tracking mechanisms, to track information about your use of our Websites. We or our service providers may combine this information with other information we have received about you.
Cookies. A cookie is a text-only string of information that a website transfers to the cookie file of the browser on a computer’s hard disk so that it can remember the user. A cookie will typically contain the name of the domain from which the cookie has come, the ‘lifetime’ of the cookie, and a value, usually a randomly generated unique number. This helps us to provide you with a good experience when you browse our Websites and to improve our Websites, products and services. We predominantly use cookies for the following purposes:
Where they are essential to make our Websites work.
To compile statistics that help us to understand how users use our Websites and to help us improve the structure of our Websites.
Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies, which are embedded invisibly on web pages. We or our service providers may use clear GIFs (also known as web beacons, web bugs or pixel tags) in connection with our Websites to track the activities of visitors to our Websites, help us manage content, and compile statistics about usage of our Websites. We or our service providers may also use clear GIFs in HTML e-mails to our users, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded.

Google Analytics
We use a tool called “Google Analytics” to collect information about use of our Website. For more information on opting out of being tracked by Google Analytics, visit (https://) tools.google.com/dlpage/gaoptout.
How We Use Information
We use your information to:
Deliver our Websites to you;
Respond to your inquiries;
Communicate with you about our business, products, and services, including through newsletters and other similar materials;
Send you promotional materials and updates about our business, products, and services;
Assess the effectiveness of our marketing efforts;
Analyze and improve the functionality of our Websites;
Improve our products, services, and business;
Prevent, detect, or investigate security concerns, including fraud;
Comply with applicable laws, regulations, or industry requirements; and
Fulfill any other purpose that you have requested or consented to.

How We Share Information
We share your information with third parties in the following circumstances:
If you give us consent or permission to share the information;
To those third parties who perform functions on our behalf, including support service providers, such as Websites hosting, email and postal delivery, product and service delivery, analytics services, or other functions;
With our affiliates and subsidiaries;
In accordance with a business transaction. If we engage in a merger, acquisition, bankruptcy, dissolution, reorganization, other business transaction, we may share information subject to confidentiality arrangements;
To prevent, detect, or investigate security concerns, including fraud;
To protect and defend our operations, rights, privacy, safety or property, or that of its subsidiaries, affiliates, officers, employees, contractors, agents and/or partners;
To comply with applicable laws, regulations, or industry requirements; and
With law enforcement if required by law or in order to prevent fraud or other potential wrongdoing.
We do not share your personal data with third parties for their direct marketing purposes.

Your Data Subject Rights
In May 2018, a new data privacy law known as the EU General Data Protection Regulation (or the “GDPR”) became effective. To the extent the GDPR applies to you and subject to the conditions and exceptions set forth in the applicable law, you have the following rights with regard to our processing of your personal data:
Right to access, correct and delete your Personal Data: You have the right to request access to a copy of your personal data and to request correction of any inaccurate personal data about you. You furthermore have the right to request deletion of personal data we hold about you.
Right to withdraw consent: In the event your personal data is processed on the basis of your consent, you have the right to withdraw consent at any time by sending an email to info at sovrin.org specifying your request, without affecting the lawfulness of processing based on consent before its withdrawal.
Data portability: To the extent that we process your personal data based on consent or fulfillment of a contract and that personal data is processed by automatic means, you have the right to receive all such personal data that you have provided to us in a structured, commonly used and machine-readable format, and also to require us to transmit it to another data controller where this is technically feasible.
Right to restrict personal data use: You have the right to restrict our use of your personal data where (i) you contest the accuracy of the personal data; (ii) the use is unlawful but you do not want us to erase the personal data; (iii) we no longer need the personal data for the relevant purposes, but you require it for the establishment, exercise or defense of legal claims; or (iv) you have objected to our personal data use justified on our legitimate interests pending verification as to whether we have indeed compelling interests to continue the relevant personal data use.
Right to object: To the extent that we are relying on our legitimate interests to use your personal data, You have the right to object to such use, and we must stop such processing unless we can either demonstrate compelling legitimate grounds for the use that override your interests, rights and freedoms or where we need to process the personal data for the establishment, exercise or defense of legal claims.

How Long We Keep Your Personal Data
We retain your personal data for as long as necessary for the purposes for which it was collected and as otherwise required by law.
How to Exercise Your Rights
In order to exercise the rights stated above, please email info at sovrin.org.
Right to Complain to Supervisory Authority
If you believe that we are processing your personal data in an incorrect or unlawful manner, please contact us at info at sovrin.org. For those located in the European Union, you may also have a right to file a complaint with a Supervisory Authority.
Do-Not-Track
Currently, our systems do not recognize browser “do-not-track” requests.
Security
We have implemented administrative, technical, and physical security measures designed to protect against the loss, misuse and/or alteration of your information. No data storage or transmission plan is without risk. We cannot guarantee the security of your personal data transmitted to our Websites. Any transmission of personal data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Websites.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Websites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Leaving Our Websites Or Linking To Third Parties
When you leave our Websites and go to another application or linked site, we are not responsible for the content or availability of that linked site or application. Please be advised that we do not represent either the third party, or you, if you enter into a transaction on the third-party site or provide the third party personal data. Further, the privacy and security policies of the application or linked site may differ from those practiced by us. We are not responsible for the practices of any third parties, including those who have a link on our Websites or with whom we have a link on their site or application.
Changes
We reserve the right to change or revise this Privacy Policy at any time to reflect changes in the law or our data collection and use practices. New updates to the Privacy Policy will be posted to this Website so that you are aware of what information we collect, how we use it, and under what circumstances we disclose it. Privacy policy changes will apply to the information collected from the date we post our revised privacy policy, as well as to existing information we hold. The date the privacy policy was last revised is identified at the top of the page. Your continued use of this Websites after we make changes is deemed to be acceptance of those changes.
YOU CONSENT TO ANY AND ALL INFORMATION YOU PROVIDE AND SUBMIT VIA THE WEBSITES BEING SENT TO THE UNITED STATES OF AMERICA AND OTHER COUNTRIES THAT MAY BE OUTSIDE YOUR HOME COUNTRY OF RESIDENCE. YOU ARE INFORMED THAT THESE COUNTRIES PRESENTLY MAY NOT HAVE AN ADEQUATE LEVEL OF PERSONAL DATA PROTECTION AS DETERMINED BY THE EUROPEAN COMMISSION’S ADEQUACY DECISION ON OCTOBER 6, 2015 (Case C-362/14) AND ARTICULATED IN THE EUROPEAN UNION’S GENERAL DATA PROTECTION REGULATION AND HAVE NOT RECEIVED A SIMILAR DESIGNATION OF ADEQUACY BY ANY OTHER FOREIGN DATA PROTECTION AUTHORITY. YOU AGREE TO THE TRANSFER OF YOUR INFORMATION TO THESE COUNTRIES, TO BE USED IN ACCORDANCE WITH THIS PRIVACY POLICY.