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PRIVACY

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ShareThis takes privacy seriously.  This Privacy Notice sets out what data we
collect, how we collect it, why we process it, who we may share it with and,
where the data we collect is personal data, your rights with respect to such
personal data. ShareThis may change this Notice from time to time by updating
this page. You should check this page from time to time to ensure that you are
up to date with any changes.       

ShareThis is committed to processing information in accordance with applicable
laws (including where applicable the European Union’s General Data Protection
Regulation (“GDPR”) and the California Consumer Privacy Act (“CCPA”) and as
described in this Privacy Notice. For specific information about how ShareThis
adheres to the GDPR and your rights as an EEA data subject please click here.
For information about how ShareThis adheres to the CCPA, please click here.

To access information for Publishers, please visit the Publisher Information
page here.

To access Publisher Terms of Use, please click here.

Last Updated on: April 5, 2022

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Opt-Out of Data Collection and Sharing



ABOUT SHARETHIS AND ITS TOOLS

ShareThis provides website operators (“Publishers”) with customizable social
sharing tools, which makes sharing online content simple. Any user of a website
can easily share anything on the web with their friends on social sites, such as
Facebook, Twitter, Email, Digg, Reddit and more through using one of our tools
on that website (“ShareThis Icon”).

ShareThis also collects data about internet users and how they interact with
content, websites and adverts which enables ShareThis and our Publishers,
advertisers, customers and data partners to facilitate the delivery of relevant,
targeted advertising online to these groups. We also carry out analytics and
provide insights to understand internet users’ behaviour and improve the
effectiveness of online content and advertising, based on such browsing,
sharing, and what is considered to be the profile of that group.    

We do this by using technology such as cookies and pixels (including pixels and
cookies for our customers) (“ShareThis Publisher Applications”) to gather
information regarding the browsing and sharing activities of internet users,
both on websites that use our ShareThis Icon and other websites which have our
technology installed on them. We also receive data from others who operate in
the data analytics and advertising industries. We analyse and aggregate the data
we collect to create groups of data (called audience segments) based on defined
criteria.  For example, we segment into groups internet users who we believe
have similar characteristics, interests, needs or behavioral patterns. Where we
are able to infer that two or more browsers or devices are the same user or
household, we may use that information to bolster our audience segments.

Targeted advertising has the aim of displaying advertising which is more likely
to be of interest to internet users, based on aing has the aim of displaying
advertising which is more likely to be of interest to internet users, based on
analyses of their recent browsing and sharing activities and interactions with
the website and adverts. It is also sometimes referred to as interest-based
advertising or online behavioural advertising. For more information on this type
of advertising, click here.


CONTENTS

I. Data Collection and Use

II. The GDPR and Your Rights as an EU or UK Data Subject

III. The LGPD and Your Rights as a Brazil Data Subject

IV. The CCPA and Your Rights as California Data Subject

V. Data Sharing or Disclosure, Recipients of Your Data

VI. Commitments to Privacy Standards

VII. User Choices and Opt-out Rights



I. Data Collection and Use

In order to offer our products and services, we collect and use data relating to
the websites you visit to display personalized advertisements, provide
analytics, and data modeling based on social sharing, by us or third parties.
This data is pseudonymous in that it may not be used directly by ShareThis to
identify an actual person. This data does enable our systems to recognize your
computer, device and/or browser over time.

In many places, this data is considered personal data as it relates to an
identified or identifiable natural person.

We do not intentionally collect contact information such as your name, postal
address, phone number, email address, credit card information, or anything else
that can allow us or our customers to contact you directly as part of our
products and services. We may collect such information if you are one of our
Publishers or if you have a business relationship with ShareThis.

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We have set out below the categories of data we process and why we process each
category of data.

 1. Usage Data and Profile Information



1.1 Usage Data

We collect information about how internet users browse the internet and interact
with online content and advertisements through our ShareThis Icon, the ShareThis
Publisher Applications and user interactions with advertisements on the
internet. We call this “Usage Data”.

Usage Data includes:

 * The unique IDs of the cookie(s) placed on your web browser (example:
   37d387ca-f68a-11e5-b87d-0e58954c72b1) and/or a hashed version of an email
   address which help us recognize your browser or device over time.
 * Information about the user’s browser and device
 * User agent string
 * Webpages viewed (including the URL addresses of such pages and search
   parameters, which may include search terms and key words) and the previous
   web pages that referred the user to that webpage 
 * Time when webpages are viewed
 * Search queries from which users are directed to a webpage
 * Navigation from page to page
 * Time spent on each webpage
 * Interactions with the webpage, including items clicked or selected and
   content highlighted or copied
 * Ads viewed or displayed to the user and the user’s interactions with those
   ads
 * Shares of content including what content is shared and where – for example,
   the relevant social media site (e.g., Twitter, Facebook)
 * Geographic information such as country, city, state or postal code.
 * IP addresses
 * Device IDs

Although the Usage Data listed above is not used by ShareThis to directly
identify an actual person, it is considered to be personal data in many places.

1.2 Profile Information

We receive information about the content of the websites that you visit and
information about the audience of those websites to enable us to infer and
create groups of users who have similar characteristics, interests or behavioral
patterns. We combine the Usage Data with data we receive from third party
advertisers, analytics vendors and data partners to create categories of data
that are helpful to advertisers seeking to deliver a more personalized
advertising experience. For example, if a user regularly views or shares content
about shopping for a car, our systems may infer that this user may be interested
in purchasing an automobile.  This practice is sometimes referred to as interest
based advertising, and a segment titled “interested in automobile” is sometimes
referred to as an audience segment or a “profile.” When we group this data into
profiles, we refer to it as “Profile Information”.

We can infer this Profile Information (by reference to browser identifiers, not
actual names) using the information we obtain from third parties about the
likely content and characteristics of the users and audiences of the websites
which are visited. For example, users of a particular website may have an
interest in cars and typically be within a certain age or income range. Where we
are able to infer that two or more browsers or devices are the same user or
household, we may use that information to bolster our Profile Information.

The characteristics by which we group users relate to age ranges, income ranges,
education, gender, ethnicity and family composition, on the basis of the typical
audience of websites they visit and content viewed.

In certain cases where Publishers that we work with utilize the “Google
Analytics By ShareThis WordPress” plug-in on their websites, ShareThis uses a
Google Analytics feature currently known as Google Analytics Demographics, in
order to better understand the audience demographics of those Publisher
websites, and to provide insights about those demographics to the Publishers
that own or operate those websites. Where Google Analytics Demographics is
enabled, certain Usage Data and Profile Information will be shared with Google
so that we may provide demographic reporting features to those Publishers. To
learn more about Google Analytics’ privacy practices, please click here. To
opt-out of Google Analytics by installing the Google Analytics Opt-out Browser
Add-on, please click here, or you may also visit the NAI consumer choice page.

If you would like to see a list of the types of Profile Information used by
ShareThis, including any Profile Information that is health or political in
nature (U.S. only), please click here. ShareThis does not create Profile
Information based upon visits to adult entertainment websites.

1.3 How we obtain Usage Data and Profile Information

We collect Usage Data when your device visits our website, uses or interacts
with our services (including sharing content with the ShareThis Icon), when your
device visits Publishers’ websites that use ShareThis Publisher Applications,
and when your device views or clicks advertisements that we serve or are served
on our behalf.  We do so by using cookies placed on your browser, pixel tags,
and HTTP headers (or other communication protocols) and the use of hashed email
address..

Our use of Cookies and other Tracking Technologies

Web Environment: (desktop, tablet, and smartphone browsers)

ShareThis uses browser cookies to “tag” visitors on the websites that use
ShareThis Publisher Applications. These users are given a technical identifier,
such as C62414AY9324FB5671069928026P0067.

This browser cookie tracks the user’s browsing data. Pixel tags are then used to
transfer this browsing data to ShareThis and our customers and data partners.

Cookies: Small text files that contain a string of characters and uniquely
identify a browser. Cookies are installed on a browser by the publisher of a
website as well by third parties who do not operate the website but whose
JavaScript and/or pixel tags (described below) are found on the website.
ShareThis cookies and cookies of our customers are installed in user browsers by
the ShareThis Publisher Applications which are on Publishers’ websites. Many
browsers are initially set up to accept cookies. However, you may be able to
change your browser settings to refuse or otherwise restrict cookies. Check your
browser’s “Help” files to learn more about handling cookies on your browser. 

CookieDurationPurpose_stid1 yearShareThis cookie ID._stidv10 yearsShareThis
cookie ID version.wordpress_test_cookieSessionShareThis cookie, tests if we have
access to cookies.pubconsent13 monthsShareThis cookie set to indicate user has
made a declaration about GDPR data collection for IAB TCF v1 format.st_optout10
yearsShareThis cookie set to indicate that user has opted out from data
collection._ga2 yearsGoogle Analytics cookie used by ShareThis to distinguish
users._gat1 dayGoogle Analytics cookie used by ShareThis to distinguish
users._gid1 dayGoogle Analytics cookie used by ShareThis to distinguish
users.visopt_s3 monthsVWO cookie to see the number of times the browser was
closed and reopened._vis_opt_test_cookieSessionVWO session cookie to see if the
cookies are enabled on the browser of the user or not. Helps in tracking the
number of browser sessions of a visitor._vwo_uuid_v21 yearVWO cookie calculates
uniques traffic on a website.intercom-id-fe2c9dmj10 monthsIntercom: Anonymous
visitor identifier cookie for site visitors.intercom-session-fe2c9dmj7
monthsIntercom: Identifer for each unique browser session. Session cookie is
refreshed on each successful logged-in ping, extending it to 1 week from that
moment. User can access their conversations and have data communicated on logged
out pages for 1 week, as long as the session isn’t intentionally terminated with
‘Intercom (’shutdown’), which usually happens on
logout.pxcelBcnLcySessionsShareThis Tag Management System cookie to track
latency on reporting beacon.pxcelAcc3PC1 dayShareThis Tag Management System
cookie to check whether third party cookies are accepted by the browser. This is
only set if there is no incoming cookie in the request.pxcelPage_c010
and/or
pxcelPage_c010_B
and/or
pxcelPage_c010_C
and/or
pxcelPage_c010_D1 yearShareThis Tag Management System cookie to track status of
pixel rotation loading. ShareThis uses a different cookie for different groups
of sites within the ShareThis network.usprivacyn/aShareThis reads if the
usprivacy cookie is present in the publisher domain.fpestid13 monthsFpestid is a
ShareThis cookie ID set in the domain of the website operator.

Pixel tags: These are small blocks of code on a webpage which read and place
cookies. When you visit a webpage, ShareThis’ pixel will see if your browser has
a ShareThis cookie installed on it. If it doesn’t, the pixel will install the
cookie. If it does, the pixel will “read” the cookie and will send us
information such as the time you viewed a webpage, the type of browser used and
your IP address. This is how we learn about your interests and enable our
customers to deliver targeted advertising to you.

HTTP headers: These are transmitted whenever a webpage is viewed, and contain
technical information required to connect your browser to the webpage. This
information may include information about the browser and the requested webpage.
ShareThis collects this information.

Hashed emails: Hashing an email is a cryptographic function. Hashing is a way of
encrypting a piece of data, like an email address, into a hexadecimal string. By
doing this, each email address becomes an unrecognizable jumble of numbers and
letters. This technique doesn’t allow us to send you an email message or to
identify who you are. However, it does allow us to recognize your browser or
device in the same way that cookies help us to recognize your browser or device.
ShareThis may obtain hashed emails from our advertising partners to help provide
our products and services. We may also receive and hash emails you provide to
our Publishers. 

Other Environments: (Mobile applications)

To serve ads in mobile applications identifiers may be used, such as Google
Advertising ID or Apple IDFA, depending on the operating system of your mobile
device. The advertiser identifier identifies your device but not you directly
and can be reset by you. See your device manufacturer for more information or
visit NAI Mobile opt-out page
at https://www.networkadvertising.org/mobile-choice/.

Linking Environments: (browsers and mobile apps used)

To serve you personalized advertisements and provide a seamless online
experience, third party data partners that we work with may link your
identifiers on the different environments you use. We may enable the linking of
our Usage Data through cookie syncing. We do not use plain text information that
may be used by ShareThis to identify you such as your name or address to operate
the linking. Our data partners may use exact linking methods by leveraging the
pseudonymous data collected through our technology such as advertising partner
identifiers.

You can manage cookies, change consents or opt out of personalized ads using the
mechanisms described in ‘User Choices’.

1.4 How we use Usage Data and Profile Information

We use Usage Data and Profile Information to enable the delivery of targeted
advertising, to provide analytics, and for data modeling using cookies or
similar tracking technologies described above. In the US, ShareThis creates
modeled segments based off of demographic attributes for certain sensitive
health conditions. ShareThis believes it is important to help pharmaceutical
companies advertise treatments to help provide solutions for those looking to
learn more about a given condition. This may include the individual with the
ailment, family members, or medical professionals who are conducting online
research on the condition. 

In addition, we may license portions of this data to our partners for their use
for targeted advertising, analytics and modeling. Where allowed by law, our
customers may use this data for other uses such as addressing fraud, enhancing
their security efforts or understanding macro investment trends.

Our customers who we share your data with may use this information to generate
their own Profile Information. They may independently gain other demographical
information about you through their own cookies or web beacons and combine it
with the data we provide to them. While we require our customers to avoid
merging data received from ShareThis with identifiable personal data such as a
clear email address (i.e., in violation of the NAI Code of Conduct), the use of
cookies and pixel tags by these third-party advertisers, publishers, and ad
networks are subject to their own privacy policies.  Please refer to the
‘Recipients of Your Data’ section of this Privacy Notice for more information
about who we disclose your data to.

 2. Children

ShareThis does not intentionally collect data from children and does not tailor
any Profile Information to enable targeting of children under 16 years of age.
If you are a parent or guardian and believe we may be processing data of
children you are responsible for, please see the section on User Choices and
Rights, or contact us directly.

 3. Emails from Users with ShareThis Icon

When you share to email with the ShareThis Icon, you choose how to connect to
email from your device. We will only know what content you shared, and that you
did so by means of email. We do not receive any information about the email
itself, for example, your email address, the email address of the recipient or
the content of your email. We are not responsible for the information shared by
users via the ShareThis Publisher Applications.

 4. Account Information

“Account Information” means the information which Publishers and representatives
of Publishers provide when they register for an account with us and when they
use their account.

Many of our services can be used without registering with us. However if you are
a Publisher, or represent a Publisher, and want to use some of our enhanced
features, you will need to register with us.

If you choose to register with us, you must be and you affirm that you are 16
years of age or older. We do not sell or share registration information with
third parties for direct marketing purposes.

 5. Business contacts data

We may process your personal data if you are or your employer has a business
relationship with us. You could be a customer, supplier, or a prospect (e.g. a
Publisher, a data provider, a social media platform, an agency, an advertiser
etc.). The personal data we hold about you refers to your professional life
(name, email address, billing address, office address, phone numbers, title,
company you work for). We would have collected that information from exchanging
emails or business cards, meeting at industry meetings or client sessions etc.
We may process that data for a number of legitimate business purposes,
including: a) to communicate with you within the context of our business
relationship; b) to provide our products or services; c) for billing and
invoicing purposes; and d) for sales, marketing and product promotional purposes
((e.g., uploading emails into LinkedIn and similar platforms to advertise new
services to current and prospective customers).

This data may also be processed for the purposes set out in the section ‘General
purposes which apply to all data.’

 6. Employee and Job Applicants’ data

If you are an employee of ShareThis, or you apply for a role with ShareThis, in
the US or in Europe, please refer to our HR Policy for information about how we
process your data. These can be obtained from our HR department
at HR@ShareThis.com.  

 7. Data Collected on ShareThis.com

This section sets out how we process data of visitors of our corporate
website (ShareThis.com), apart from any ‘Usage Data and Profile Information’ and
the ‘Account Information’ which relates only to Publishers who register with us.

When you visit our website, you may choose to provide information to us
voluntarily if you interact with ShareThis.com in certain ways, such as by
applying for employment with ShareThis, or using one of our contact forms. This
information is used only for the reasons for which it was collected, such as
responding to your communication, and it is not shared with third parties other
than trusted service providers who are contractually required to only use such
data to fulfill the purpose for which it was collected.

We use cookies and similar tracking technologies to collect data automatically
when you visit ShareThis.com and use that information to help administer the
website, to remember your preferences, to conduct website analytics and for
security and fraud prevention purposes.  

This Privacy Notice does not apply to the privacy practices of other websites or
of third parties who collect information on ShareThis.com. We encourage you to
visit the applicable policies of those third parties, or visit www.aboutads.info
to learn more about interest-based advertising and to see your opt-out choices
from other participating companies that may be collecting and using data on
ShareThis.com.

 8. General purposes which apply to all data

There are a number of “general” reasons that ShareThis may process data on our
systems. Many of them are required by applicable law and/or to help us ensure
that the Internet remains a safe space. Some of them enable us to promote and
grow our business. If you’d like additional information, please email
privacy@sharethis.com. 

We may also process data for the following purposes: a) as required by
applicable law; b) to cooperate with competent legal authorities such as data
protection regulators, the police and the FBI; c) to enforce our terms and
conditions, including by obtaining advice and conducting legal proceedings; d)
to protect our operations, property and interests, and those of third parties;
e)  to sell and promote the sale of our business and/or assets.

Finally, ShareThis may transfer information to a successor entity in connection
with a corporate merger, consolidation, sale of assets, bankruptcy, or other
corporate change. If ShareThis is involved in a merger, acquisition, or sale of
all or a portion of its assets, you will be notified via email and/or a
prominent notice on our website of any change in ownership or uses of your
information, as well as any choices you may have regarding your information.




II. The GDPR and Your Rights as an EU or UK Data Subject

If you are located in the European Economic Area (EEA), the General Data
Protection Regulation (GDPR) applies to our processing of personal data. If you
are located in the United Kingdom, then the Data Protection Act 2018 applies to
our processing of personal data. These laws each grant those located
respectively in the EEA and the UK a set of clear privacy rights and imposes
responsibilities on ShareThis as we process the personal data of data subjects
located in those places. The ShareThis privacy policy outlines how and why
ShareThis processes personal data. This section is designed to provide more
information on how ShareThis adheres to the GDPR and the Data Protection Act
2018 and your rights as a data subject located in the UK or the EEA.

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Definition of Personal Data

Both the GDPR and UK Data Protection Act define personal data broadly. As such,
where Usage Data and/or Profile Information relates to an individual in the EEA
or UK we treat it as personal data. Similarly, nearly all of the data collected
from EEA and UK data subjects in the context of our normal business operations
is likely to be considered personal data. This includes: a) data collected via
visits to ShareThis.com; b) data collected from Customers, Publishers and
business partners; and c) data collected from employees and prospective
employees.

Special Categories of Personal Data

ShareThis does not collect nor process any special categories of personal data
with respect to UK or EEA data subjects, and we do not create Profile
Information of audience segments of such consumers based on special categories
of personal data (i.e. data revealing racial or ethnic origin, political
opinions, religious or philosophical beliefs, or trade union membership, genetic
data, biometric data, data concerning health, or data concerning a natural
person’s sex life or sexual orientation).

Legal Basis for Processing

Both the UK Data Protection Act and GDPR requires entities seeking to process
personal data to have a valid legal basis for doing so. The legal basis utilized
by ShareThis include: a) consent; b) legitimate interest (i.e., where we believe
that our need to process the data and/or the value we deliver by processing such
data is not outweighed by the rights of the data subject); c) where necessary
for the performance of a contract; and d) where processing is necessary to
comply with our legal obligations. We will endeavor to outline our legal basis
for the most common types of processing conducted by ShareThis.

Cookie and Similar Tracking Technologies – We endeavor to obtain consent for our
placement of cookies, pixels and similar tracking technologies as required under
the ePrivacy Directive as implemented throughout the EEA. As ShareThis does not
have direct relationships with Internet users in many cases, we ask Publishers
and other partners to obtain a consent on our behalf as described below.  Where
we directly place cookies (e.g., via ShareThis.com) we directly obtain the
consent from data subjects we’ve identified as being from the EEA or other place
where consent is required.

Usage Data and Profile Information – While we obtain a consent for our placement
of cookies as described above, ShareThis processes Usage Data and Profile
Information under our legitimate interest. For purposes of clarity, where this
data is utilized for analytics, targeted advertising, measurement or reporting,
we also process it via legitimate interest. To offer additional transparency, we
endeavor to mention some of these use cases in the consents obtained for cookies
and pixels.

Website Data – We collect personal data via ShareThis.com. Where that data is
provided to ShareThis (e.g., via completing an online form), we consider it
either Account Data and/or data collected pursuant to a Business Relationship
which are described below. Where we place cookies via the website, we use
consent. Where data is collected automatically (e.g., log files containing IP
addresses), we process such data via our legitimate interest and in order to
maintain the website and help us to a better job of personalizing the website to
the interests of visitors.

Account Data and Business Relationships – We require some Publishers to setup an
Account with ShareThis. Similarly, we maintain accounts containing personal data
with most of the vendors who provide services to ShareThis, our Customers, our
employees and our business partners. If you are an employee of one of those
entities, ShareThis may have your personal data including your name, your work
email or your work telephone number. For data subjects located in the EEA or UK,
we process this data under the legal basis of contractual necessity. In other
words, we need to process this data in order to honor the terms of the contract
between ShareThis and the Publisher, Customer, vendor, Etc. This includes
maintaining an account and login credentials, billing and payment purposes,
communicating with the other party, and fulfilling requests. Where we are
seeking to market additional products and services to these entities, we will do
so via legitimate interest unless applicable law dictates that we use consent
(e.g., for email marketing).

General Purposes – There are a number of instances where ShareThis processes
personal data which are distinct from the descriptions provided above. For
example:

Legal and Regulatory Compliance – Like most companies, ShareThis will process
data in order to comply with law, cooperate with requests from competent legal
authorities such as the police, and to pay taxes. The legal basis for this type
of processing is necessary for ShareThis to meet our legal and regulatory
obligations.

Enforcement of legal obligations – To enforce our terms and conditions, protect
of our intellectual property and/or the rights of third parties, ShareThis
processes personal data in these instances via our legitimate interest. This may
include obtaining advice and conducting legal proceedings.

Sell and Promote our Business – ShareThis may choose to conduct, evaluate and/or
promote the sale of our business via our legitimate interest.

Aggregated Data – Where we aggregate data and remove digital identifiers (e.g.,
cookie IDs), we may use this data for internal research, marketing, and
statistical analysis purposes.

Data Controller

ShareThis is generally a Controller of data with respect to the data processed
as described above. Where the GDPR or UK Data Protection Act applies to Usage
Data and Profile Information and we share this data with our Customers, our
Customers are independent controllers in relation to their processing of such
data and they process it in accordance with their own privacy policies.
ShareThis is also the controller of the data it collects via ShareThis.com.

Data Processors

ShareThis also has a number of agents and service providers who operate as
processors of data on ShareThis’ behalf. This agents and service providers are
only able to use the data as specifically directed by ShareThis and only to
provide the services requested by us. They are also contractually obligated to
process the data securely and under confidentiality obligations.

UK and EU Data Subject Rights

Where the GDPR or UK Data Protection Act applies, such data subjects have
certain rights, including: a) The right to be informed about the types of data
being processed and the legal basis for processing; b) the right to access and
see the data being processed; c) the right of rectification, to make corrections
to data subject to processing; d) the right to erase data; e) the right to
restrict processing of data; f) the right of data portability; g) the right to
object to the processing of data and f) the right not to be subject to automated
decision-making. Some of these rights apply only in certain circumstances and
depend on the legal basis relied upon to process the data. As an example, the
right to object applies to processing which is carried out because it is
necessary for our legitimate interests and only if we cannot demonstrate
compelling legitimate grounds which outweigh your rights, interests and
freedoms. The same right does not apply to processing which is necessary for us
to comply with our legal obligations or to perform a contract with you. Given
that both the UK Data Protection Act and the GDPR defines personal data broadly,
these rights may extend to the personal data we place into cookies or similar
tracking technologies.

Where processing is based on your consent, in accordance with the GDPR and UK
Data Protection Act (as applicable), you may withdraw that consent at any time,
although any processing previously carried out will still be legal. In order to
exercise your data subjects’ rights or if you have any questions about these
rights, you can write to us at privacy@sharethis.com. We will endeavor to
respond to any requests to exercise your rights within one month from when they
are made, although this period may be extended in some cases in which case we
will inform you before the expiration of the one month period.

You also have the right to submit complaints to the supervisory authority in
your jurisdiction. A list of supervisory authorities in the EEA can be found
here: https://edpb.europa.eu/about-edpb/board/members_en. 

How ShareThis interacts with our Publishers on GDPR and UK Data Protection
compliance

If you are in the European Economic Area, you may be familiar with websites
asking you to consent to the use of cookies and similar technologies. If you are
in the UK, you may see similar consent notices which pertain to the UK Data
Protection Act. Where the ShareThis Applications are used to process personal
data from data subjects in places where a notice and/or consent is required, our
Publishers are required to notify you about the use of the ShareThis
Applications, mention ShareThis as a third party who processes your personal
data and ask you to consent to such processing as well as the placement of
cookies.

Cross-border transfers of EU or UK personal data

We generally process data in the United States. When we share data, we provide
data to companies globally. In each case, we have safeguards in place which
allow those transfers to happen in a way that ensures data is handled in
accordance with the applicable law. 

When we transfer personal data outside the EEA or UK, unless the recipient or
location to which the data is transferred has been approved by the appropriate
authorities as providing an adequate level of protection for personal data, we
put in place measures to ensure that the transfer complies with the applicable
data protection law and that the personal data which is transferred is
appropriately safeguarded.

When we enter into business relationships which involves the transfer of EU
personal data to the United States, we put in place reasonable transfer
mechanisms such as the EU standard contractual clauses with the recipient. More
information about international data transfers under the GDPR can be found
at https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_en. 
If requested, we may make available a copy of such safeguards, as required by
the GDPR.

Data Protection Officer and Representative

ShareThis has appointed a data protection officer to supervise our personal data
processing-related activities, and to respond to requests as required.  Our DPO
can be contacted as follows: Vincent Potier (ShareThis DPO): dpo@sharethis.com 

ShareThis’ representative in the EU is: ShareThis UK Limited of 10 John Street,
London WC1N 2EB, UK.      




III. The LGPD and Your Rights as a Brazil Data Subject

If you are located in Brazil, then the Brazilian General Law for the Protection
of Personal Data (LGPD) applies to our processing of personal data. The LGPD
grants those located Brazil a set of clear privacy rights and imposes
responsibilities on ShareThis as we process the personal data of data subjects
located in Brazil. The ShareThis privacy policy outlines how and why ShareThis
processes personal data. This section is designed to provide more information on
how ShareThis adheres to the LGPD and your rights as a data subject located in
Brazil.

--------------------------------------------------------------------------------

Definition of Personal Data

Like the GDPR, the LGPD defines personal data broadly. As such, where Usage Data
and/or Profile Information relates to an individual in the Brazil, we treat it
as personal data. Similarly, nearly all of the data collected from EEA and UK
data subjects in the context of our normal business operations is likely to be
considered personal data. This includes: a) data collected via visits to
ShareThis.com; b) data collected from Customers, Publishers and business
partners; and c) data collected from employees and prospective employees, as
applicable.

Special Categories of Personal Data
ShareThis does not collect nor process any special categories of personal data
with respect to data subjects in Brazil.


Legal Basis for Processing
The LGPD entities seeking to process personal data to have a valid legal basis
for doing so. The legal basis utilized by ShareThis include: a) consent; b)
legitimate interest (i.e., where we believe that our need to process the data
and/or the value we deliver by processing such data is not outweighed by the
rights of the data subject); c) where necessary for the performance of a
contract; and d) where processing is necessary to comply with our legal
obligations.

Brazil and Data Subject Rights
Where the LGPD applies, such data subjects have certain rights, including: a)
The right to be informed about the types of data being processed and the legal
basis for processing; b) the right to access and see the data being processed;
c) the right of rectification, to make corrections to data subject to
processing; d) the right to erase data; e) the right to restrict processing of
data; f) the right of data portability; g) the right to object to the processing
of data and f) the right not to be subject to automated decision-making. Some of
these rights apply only in certain circumstances and depend on the legal basis
relied upon to process the data. If you are located in Brazil and have questions
about how ShareThis implements these rights, please email us at
privacy@sharethis.com.




IV. The CCPA and Your Rights as California Data Subject

--------------------------------------------------------------------------------

Starting January 1, 2020, the California Consumer Privacy Act (CCPA) provides
additional privacy protections for California data subjects and users,
including:

 * the right to see what data we have about you, your computer or device (i.e.,
   the right to know),
 * the right to delete the data we have about you, your computer or device
   (i.e., the right to delete), and
 * the right to opt-out of the sale of data about you, your computer or device
   to certain third parties (i.e., the right to opt-out from sales of your
   information).

The CCPA defines personal information broadly. And as such, almost all of the
information we collect is considered personal information under the CCPA.
California data subjects may send an email to privacy@sharethis.com to exercise
those rights of visit our data subject access page at CCPA GDPR Data Subject
Access Request. California data subjects may also call us on our toll free CCPA
privacy hotline at 1-800-272-1765.

We do not treat users that exercise any of the above rights differently.
However, we may not be able to honor a right if doing so would violate
applicable law. ShareThis does not sell data collected via our website or the
data we use to operate our business. However, we transfer personal information
collected via the ShareThis Publisher Applications to third parties and as such
are considered to have sold data over the past twelve months under California
law, including any of the Usage Data, Profile Information and/or audience
segments.

Your California Data Subject Access and Deletion Rights

The California Consumer Privacy Act (CCPA) provides certain rights to California
consumers – including the right to know the personal information that we may
have about you, and the right to delete that information.  ShareThis is
committed to transparency, and we want California consumers to have access to
personal information that we may have about them and/or the devices that they
may use to access the Internet.  We generally ask only for the minimum
information necessary to help us process a subject access or deletion request
and will keep information pertaining to your request for up to two years. If you
are a customer of ShareThis with a login and password to the ShareThis platform,
we ask that you first direct your request to the person or persons at your
organization that administers the relationship with ShareThis.

If you’d like to make a CCPA access or deletion request, please send an email
to privacy@sharethis.com. California data subjects may also call us on our toll
free CCPA privacy hotline at 1-800-272-1765.

If you make a subject access request as set out in this policy, you are entitled
to see and delete the personal information that we have about you including any
digital identifiers such as cookie IDs and mobile advertising IDs that ShareThis
may store. We will confirm your request within 10 days and make a good faith
attempt to fulfill your request within 45 days.

Under the CCPA, your request to see the personal information that we have about
you may include: (1) specific pieces of personal information that we may have
about you; (2) categories of personal information we have collected about you;
(3) categories of sources from which the personal information is collected; (4)
categories of personal information that we sold or disclosed for a business
purpose about you; (5) categories of third parties to whom the personal
information was sold or disclosed for a business purpose under the CCPA; and (6)
the business or commercial purpose for collecting or selling personal
information. Most of this information is described at least generally in our
privacy policy.

Verifying Data Subject Access and Deletion Requests

We may take steps to verify your request and may require you to demonstrate or
attest via affidavit that you own or control the computer or device from which
you are making such requests – particularly where you are seeking access to or
deletion of pseudonymous personal information such as digital identifiers.

We will fulfill requests we are able to verify so long as we are not prohibited
from doing so by applicable law and/or the information is not essential to us
for billing, fraud prevention or security purposes. We will share our reason(s)
for denying your request in the event that we are unable to fulfill your
request. If we are unable to fulfil your deletion request, we may invite you to
make a request to opt-out at our privacy policy.

Access and Deletion Requests made via Authorized Agents

You may make an access or deletion request via an authorized agent by having
such agent follow the process below. Please note that we will request any
authorized agent demonstrate that they have been authorized by you to make a
request on your behalf. And we will verify your request and/or require you to
complete an affidavit as described above. We request that any authorized agent
provide us with contact details such as an email address and phone number so
that we may ensure a timely response to the consumer.

CCPA Metrics for 2020
Pursuant to CCPA Regulation 999.317(g), ShareThis informs you of the following
metrics:
a. The number of CCPA requests to know that ShareThis received, complied with
whole or part and denied in 2020: 9, 8, 1.
b. the number of CCPA requests to delete that ShareThis received, complied with
whole or part and denied in 2020: 57, 57 and 0
c. The number of CCPA requests to opt-out that ShareThis received via our email
form, complied with whole or part and denied in 2020: 1, 1 and 0.
d. The median number of days within which ShareThis substantively responded to
requests to know, requests to delete and requests to opt-out: 10, 8, and 6
e. The number of opt-out requests we received via the ShareThis opt-out page or
industry opt-out pages worldwide in 2020 was 18,887,357 and all resulted in the
real-time placement of an opt-out cookie by ShareThis as described in this
privacy policy.




V. Data Sharing or Disclosure, Recipients of Your Data

--------------------------------------------------------------------------------

We share Usage Data, Profile Information and/or audience segments for marketing
and advertising purposes with:

 * Advertisers;
 * Publishers;
 * Advertising agencies and agency trading desks which operate technology
   platforms designed to deliver ads on websites and other forms of digital
   media;
 * Agency trading desks;
 * Data management platform which help advertisers and publishers organize data
   about Internet users;
 * Investment firms and financial institutions seeking to better understand how
   consumers use the Internet;
 * Device graph service providers who link different online identifiers to a
   single user;
 * Advertising technology providers which hep automate the. delivery of
   advertisements on websites and. other forms of digital media;
 * Research companies seeking to better understand consumer perceptions;
 * Data brokers and other data partners.

(all, our “Customers”) for the purposes listed in the section ‘Data Collection
and Use.’

Where the GDPR applies to Usage Data and Profile Information and we share this
data with our Customers, our Customers are independent controllers in relation
to their processing of such data and they process it in accordance with their
own privacy policies.

Customers may share the data which they process with other third parties who are
not mentioned in this Privacy Notice, in accordance with their own privacy
policies.   As an example, they may use third party service providers to display
advertising or other content on their behalf. 

Please review some of our Customer’s privacy policies for more information:

LiveRamp: https://liveramp.com/privacy/
AppNexus: https://www.appnexus.com/platform-privacy-policy
Eyeota : https://www.eyeota.com/privacy-policy
Oracle: https://www.oracle.com/legal/privacy/privacy-policy.html
Lotame: https://www.lotame.com/about-lotame/privacy/
Nielsen: https://www.nielsen.com/ssa/en/legal/privacy-policy/
Retargetly: https://retargetly.com/privacy-policy
1plusX: https://www.1plusx.com/privacy-policy/
AptivIO: https://aptiv.io/privacy-policy
Dunn & Bradstreet: https://www.dnb.com/ca-en/utility-pages/privacy-policy.html

2. Other third party agents and service providers

We share the data described in this Privacy Notice trusted agents with data
storage and processing facilities such as Amazon Web Services who are required
under contract to only process data according to our written instructions and we
require them to use data only for the purposes of providing services to us and
to implement security controls and to maintain the confidentiality of that
information. Here are the categories of service providers utilized by ShareThis:

 * Cloud data storage providers such as Amazon Web Services;
 * Customer billing systems providers;
 * Email service providers offering tools to send emails on our behalf;
 * Website analytics providers such as Google analytics;
 * Customer relationship management software providers;
 * Vendors assisting us with legally required audits;
 * Third-party computer programmers helping ensure our systems are operating
   properly;
 * Job ticket support vendors helping us record issues and debug; and
 * Security vendors.

3. Data Retention

We have defined retention policies for different types of personal data. We only
retain data for as long as necessary for the purpose for which we process it and
only as long as it remains relevant, unless we need to retain it because we are
required to do so by law, to defend and exercise claims, or for regulatory
reasons.

3.1 Usage Data, Profile Information and Data Collected via ShareThis.com

We retain Usage Data and Profile Information for up to 13 months from the date
of collection for targeted advertising, and for up to 36 months for insights and
analytics. We also retain data collected via ShareThis.com for up to 36 months
for analytics and to ensure that our website functions properly.

We may aggregate and anonymise data so that it can no longer be linked to a
device or individual, therefore it ceases to be personal data, and we may retain
this data for longer periods.

3.2 Account Information

We retain Account Information for as long as you have an active account with us.
If you have not logged into any of our services with your username and password
for a period of 14 consecutive months, we may deem your account as being
inactive and delete your Account Information. This could result in the loss of
data you may have saved and we do not accept liability for such deletion.

You always have the option to cancel your account with us at any time. Simply
sign into the site and click on the My Account at the top of the page. Click on
Edit Profile and then select Deactivate Account and follow the instructions. You
may also request to have your Account Information removed by submitting a
request to privacy@sharethis.com.

4. Data Security

The security of your information is a high priority to ShareThis. We have
implemented industry-standard security measures.

While no transmission of data over the Internet is guaranteed to be completely
secure, we strive to protect your data. It may be possible for third parties not
under the control of ShareThis to unlawfully intercept or access transmissions
of private communications. ShareThis cannot ensure or warrant the security of
information you transmit to us.




VI. Commitments to Privacy Standards

ShareThis promotes transparency and control for users as members of various
self-regulatory programs. ShareThis also participates in and has certified its
compliance with the EU-US and Swiss U.S. Privacy Shield Frameworks.

--------------------------------------------------------------------------------

ShareThis is a member of the following self-regulatory programs:

Network Advertising Initiative (NAI):

ShareThis adheres to the NAI Code of Conduct.  NAI offers an online web opt-out
platform to allow consumers to express their choices and provides general
information related to privacy and Interest Based Advertising.

The Digital Advertising Alliance (DAA):

ShareThis adheres to the Digital Advertising Alliance Self-Regulatory Principles
for Online Behavioral Advertising.  The DAA opt-out platform offers the consumer
a choice page to opt out from advertising services, and general information
related to privacy.

European Interactive Digital Advertising Alliance (EDAA):

ShareThis adheres to the European Interactive Digital Advertising Alliance’s
(“EDAA”) principles.  The EDAA opt-out platform offers consumers in the European
Union a choice page to opt out from advertising services, and general
information related to privacy.

GDPR and Swiss Privacy Shield:

ShareThis, Inc. is committed to protecting data and enabling individual privacy
rights in every location we do business. Therefore, we comply with the GDPR and
the EU-US and Swiss-US Privacy Shield Frameworks.

In accordance with the GDPR, which is designed to empower and protect the data
privacy rights of EU individuals, ShareThis makes available user consent tools
(ShareThis is a registered CMP with the IAB Transparency and Consent Framework),
as well as facilitating user data rights outlined throughout this notice.




VII. User Choices and Opt-out Rights

If you do not want to receive advertisements based on Usage Data and Profile
Information collected by ShareThis on your current browser, you can change and
manage your preferences in relation to the collection and processing of Usage
Data and Profile Information by clicking the ShareThis opt-out button available
on this privacy policy. When data subjects opt-out, ShareThis will stop
transferring data about their browser or device to third parties but does not
otherwise treat those users differently.

If you do not want to receive ads based on Usage Data collected by ShareThis
whatever device or browser used, you must opt-out from our services for each
device and each internet web browser. 

Opt-Out of Data Collection and Sharing

Click below to “Limit Ad-Tracking” function on mobile devices:

Instructions by Google for most Androids: Google Play Help

Instructions by Apple for iOS version 6 and above: Apple Support Center

--------------------------------------------------------------------------------

Furthermore:

This process does not mean you will stop seeing advertisements, but that the
advertisements you do see will not be influenced by the Usage Data collected and
Profile Information used by ShareThis. 

If you have any questions about your opt-out rights, you can write to us
at privacy@sharethis.com.

Browser environment: (desktop, tablet, and smartphone browsers)

When you change your consents or opt out, an opt-out cookie will be set on your
browser. We must maintain the opt-out cookie on your browser in order to
recognize you as having opted out from our service. The ShareThis opt-out cookie
is like any other cookie; therefore, if you clear that cookie from your browser,
use a different internet browser, or use a new computer to access the internet
you must go through the process again.

You can also opt out by visiting the following links.

Network Advertising Initiative (“NAI”) Opt-Out Platform

Digital Advertising Alliance (“DAA”) Opt-Out Platform

European Interactive Digital Advertising Alliance (“EDAA”) Opt-Out Platform

The Ghostery browser extension is also a good tool to see a list of all
third-party cookies on each website you visit and allows you to selectively opt
out.

Note:

The opt-out tools above are currently cookie-based ie they set a cookie on your
browser which tells us that you have opted out. This means that the opt-out will
only function if your browser is set to accept third party cookies. If your
browser is set to automatically reject cookies or if you remove all cookies from
your browser, the opt-out mechanism will not work since we would not see an
opt-out cookie on your browser.

Also keep in mind that cookies are browser based, therefore if you change
browsers, operating systems or computers you would need to opt out again.

Mobile environment:

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 interest-based advertising cookies.

Instead, you can typically opt out at the mobile platform level by the “limit ad
tracking” function within the settings, as described below. Though we do not
collect data from mobile apps for interest-based advertising, we or third
parties we work with may use such data collected by others in delivering
interest-based ads.

Most Android Users:

To use the “opt-out of interest-based advertising” option, follow the
instructions provided by Google here: Google Play Help.

Please note that this is a device setting and will disable interest-based ads
from all providers, and not just for ShareThis.

iOS users: (version 6 and above)

To use the “Limit Ad-Tracking” option, follow the instructions provided by Apple
here: Apple Support Center.

Please note that this is a device setting and will disable interest-based ads
from all providers, and not just for ShareThis.

Do Not Track:

You may also stop the collection of your Usage Data by using the do-not-track
function of your browser. ShareThis recognizes these do-not-track signals from
your browser. As required by law, or where we are able to ascertain that such
signals are enacted by you and not set by default by your browser, we will
consider them to be an indication that you have opted out.

Onward Transfer/Privacy Shield:

ShareThis complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S.
Privacy Shield Frameworks as set forth by the U.S. Department of Commerce
regarding the collection, use, and retention of personal information transferred
from the European Union and the United Kingdom and/or Switzerland to the United
States in reliance on Privacy Shield. The Privacy Shield is administered by the
US Department of Commerce regarding the collection, use, and retention of
personal information from European Union member countries as well as Switzerland
and the United Kingdom. ShareThis has certified that it adheres to the Privacy
Shield Principles of Notice, Choice, Accountability for Onward Transfer,
Security, Data Integrity and Purpose Limitation, Access, and Recourse,
Enforcement and Liability. If there is any conflict between the policies in this
privacy notice 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 https://www.privacyshield.gov.

In the context of an onward transfer, ShareThis is responsible for the
processing of personal data it receives under the Privacy Shield and
subsequently transfers to a third party acting as an agent on its behalf.
ShareThis shall remain liable under the Privacy Shield principles if its agent
processes such personal data in a manner inconsistent with the Privacy Shield
principles, unless the ShareThis proves that it is not responsible for the event
giving rise to the damage.

In compliance with the EU-US and Swiss-US Privacy Shield Principles, ShareThis
commits to resolve complaints about your privacy and our collecting or use of
your personal information. European Union, UK, or Swiss individuals with
inquiries or complaints regarding this privacy notice should first contact
ShareThis directly at privacy@sharethis.com. We will respond to your complaint
within 30 days of receipt.

We have further committed to refer unresolved privacy complaints under the EU-US
and Swiss-US 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
acknowledgement of your complaint, or if your complaint is not satisfactorily
addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more
information and to file a complaint.

For residual disputes that cannot be resolved by the methods above, under
limited circumstances, a binding arbitration option may be available before a
Privacy Shield Panel. To find out more about the Privacy Shield’s binding
arbitration scheme, please
see: https://www.privacyshield.gov/article?id=ANNEX-I-introduction.

The Federal Trade Commission has investigation and enforcement authority over
our compliance with the Privacy Shield. 

If you believe we have not respected your rights or otherwise not handled data
correctly, then we encourage you to contact us directly and we will do
everything possible to help.

However, where you still have a complaint, then you have the right to raise the
matter with the Supervisory Authority (or data protection agency) in your
country for resolution.





CONTACT INFORMATION

ShareThis, Inc.
3000 El Camino Real
5 Palo Alto Square, Suite 150
Palo Alto, CA 94306, USA
privacy@sharethis.com

We have appointed a data protection officer to supervise our personal data
processing-related activities, and to respond to requests as required. Our DPO
can be contacted as follows:

Vincent Potier (ShareThis DPO): dpo@sharethis.com



ShareThis’ representative in the UK is: ShareThis UK Limited of 10 John Street,
LondonWC1N 2EB, UK



VeraSafe has been appointed as ShareThis’s representative in the European Union
for data protection matters, pursuant to Article 27 of the General
Data Protection Regulation of the European Union. If you are in the European
Economic Area, VeraSafe can be contacted in addition
to representative@sharethis.com, only on matters related to the processing of
personal data. To make such an inquiry, please contact VeraSafe using this
contact form:
https://verasafe.com/public-resources/contact-data-protection-representative or
via telephone at: +420 228 881 031.




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WE CARE ABOUT YOUR PRIVACY

ShareThis
Vendors
Manage Settings
Vendors


SHARETHIS SETTINGS


PURPOSES

WE AND OUR PARTNERS CAN:

Store and/or access information on a device

Create a personalised ads profile

Create a personalised content profile

Select personalised content

Apply market research to generate audience insights


WE HAVE A LEGITIMATE INTEREST FOR THESE PURPOSES:

 * Develop and improve products


VENDOR SETTINGS


PURPOSES

VENDORS CAN:

Store and/or access information on a device

Select basic ads

Create a personalised ads profile

Select personalised ads

Create a personalised content profile

Select personalised content

Measure ad performance

Measure content performance

Apply market research to generate audience insights

Develop and improve products



SPECIAL PURPOSES

VENDORS CAN:

 * Ensure security, prevent fraud, and debug
 * Technically deliver ads or content


FEATURES

VENDORS CAN:

 * Match and combine offline data sources
 * Link different devices
 * Receive and use automatically-sent device characteristics for identification


SPECIAL FEATURES

VENDORS CAN:

Use precise geolocation data

Actively scan device characteristics for identification


Some partners do not ask for your consent to process your data, instead, they
rely on their legitimate business interest. Personal data processed includes but
is not limited to cookies, IP addresses, and URLs visited. View our list of
partners to see the purposes they believe they have a legitimate interest for
and object to legitimate interests on a per vendor basis. Manage your settings
and object to purposes as a legitimate interest in general.

You can change your settings at any time, including by withdrawing your consent,
by clicking on the cog icon in the bottom right hand corner.

Manage Settings
Vendors
Accept All
Reject All
Save & Exit