=================================================================== --- 20220201_rev01 +++ 20220401_rev01 @@ -1,50 +1,63 @@ -Privacy (2021) - -**Please click the following links to read our Privacy Policy in other languages:** **[Confidentialité](https://pcdn.sharethis.com/wp-content/uploads/2021/11/ShareThis-Privacy-Policy-11.2.21_FR.pdf) (Français), [Privacidad](https://pcdn.sharethis.com/wp-content/uploads/2021/11/ShareThis-Privacy-Policy-11.2.21_ES.pdf) (Español), [Privacy](https://pcdn.sharethis.com/wp-content/uploads/2021/11/ShareThis-Privacy-Policy-11.2.21_IT.pdf) (Italiano), [Privacidade](https://pcdn.sharethis.com/wp-content/uploads/2021/11/ShareThis-Privacy-Policy-11.2.21_PT.pdf) (Português), [Datenschutz](https://pcdn.sharethis.com/wp-content/uploads/2021/11/ShareThis-Privacy-Policy-11.2.21_DE.pdf) (Deutsche), [プライバシー](https://pcdn.sharethis.com/wp-content/uploads/2021/11/ShareThis-Privacy-Policy-11.2.21_JA.pdf) (日本語), [Privasi](https://pcdn.sharethis.com/wp-content/uploads/2022/01/ShareThis-Privacy-Policy-Indonesian-1.20.22.pdf) (Bahasa Indonesia), [Privasi](https://pcdn.sharethis.com/wp-content/uploads/2022/01/ShareThis-Privacy-Policy-Malay-1.20.22.pdf) (Melayu), [Pagkapribado](https://pcdn.sharethis.com/wp-content/uploads/2022/01/ShareThis-Privacy-Policy-Tagalog-1.20.22.pdf) (Tagalog), [गोपनीयता](https://pcdn.sharethis.com/wp-content/uploads/2022/01/ShareThis-Privacy-Policy-Hindi-1.20.22.pdf) (हिन्दी), ([سياسة الخصوصية](https://pcdn.sharethis.com/wp-content/uploads/2022/01/ShareThis-Privacy-Policy-Arabic-1.20.22.pdf) (عربى.** - -### **Updated November 2, 2021** - 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**](https://www.sharethis.com/publisher/)**.** -To access Publisher Terms of Use please click [here](https://sharethis.com/publisher-terms-of-use/). -### About ShareThis and its Tools +To access Publisher Terms of Use, please click [**here**](https://sharethis.com/publisher-terms-of-use/). +Last Updated on: March 23, 2022 + +- * * + 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 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](http://www.networkadvertising.org/understanding-online-advertising). +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](http://www.networkadvertising.org/understanding-online-advertising). -### Data Collection and Use +## 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. -Additional Information +- * * 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. **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. +- 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 @@ -81,168 +94,126 @@ 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. -

Cookie	Duration	Purpose
_stid	1 year	ShareThis cookie ID
_stidv	1 year	ShareThis cookie ID version
wordpress_test_cookie	Session	ShareThis cookie, tests if we have access to cookies
pubconsent	13 months	ShareThis cookie set to indicate user has made a declaration about GDPR data collection for IAB TCF v1 format
st_optout	10 years	ShareThis cookie set to indicate that user has opted out from data collection
_ga	2 years	Google Analytics cookie used by ShareThis to distinguish users
_gat	1 day	Google Analytics cookie used by ShareThis to throttle request rate
_gid	1 day	Google Analytics cookie used by ShareThis to distinguish users
visopt_s	3 months	VWO cookie to see the number of times the browser was closed and reopened
_vis_opt_test_cookie	Session	VWO 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_v2	1 Year	VWO cookie calculates uniques traffic on a website
intercom-id-fe2c9dmj	10 months	Intercom: Anonymous visitor identifier cookie for site visitors
intercom-session-fe2c9dmj	7 days	Intercom: 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.
pxcelBcnLcy	session	ShareThis Tag Management System cookie to track latency on reporting beacon.
pxcelAcc3PC	1 day	ShareThis 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_D	1 year	ShareThis 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.
usprivacy	n/a	ShareThis reads if the usprivacy cookie is present in the publisher domain
fpestid	13 months	Fpestid is a ShareThis cookie ID set in the domain of the website operator

+| Cookie | Duration | Purpose | +| --- | --- | --- | +| \_stid | 1 year | ShareThis cookie ID. | +| \_stidv | 10 years | ShareThis cookie ID version. | +| wordpress\_test\_cookie | Session | ShareThis cookie, tests if we have access to cookies. | +| pubconsent | 13 months | ShareThis cookie set to indicate user has made a declaration about GDPR data collection for IAB TCF v1 format. | +| st\_optout | 10 years | ShareThis cookie set to indicate that user has opted out from data collection. | +| \_ga | 2 years | Google Analytics cookie used by ShareThis to distinguish users. | +| \_gat | 1 day | Google Analytics cookie used by ShareThis to distinguish users. | +| \_gid | 1 day | Google Analytics cookie used by ShareThis to distinguish users. | +| visopt\_s | 3 months | VWO cookie to see the number of times the browser was closed and reopened. | +| \_vis\_opt\_test\_cookie | Session | VWO 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\_v2 | 1 year | VWO cookie calculates uniques traffic on a website. | +| intercom-id-fe2c9dmj | 10 months | Intercom: Anonymous visitor identifier cookie for site visitors. | +| intercom-session-fe2c9dmj | 7 months | Intercom: 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. | +| pxcelBcnLcy | Sessions | ShareThis Tag Management System cookie to track latency on reporting beacon. | +| pxcelAcc3PC | 1 day | ShareThis 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\_D | 1 year | ShareThis 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. | +| usprivacy | n/a | ShareThis reads if the usprivacy cookie is present in the publisher domain. | +| fpestid | 13 months | Fpestid 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/](https://www.networkadvertising.org/mobile-choice). -**Linking Environments**: (browsers and mobile apps used) +**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'](). +You can manage cookies, change consents or opt out of personalized ads using the mechanisms described in '[User Choices'](https://sharethis.com/privacy/). **1.4 How we use Usage Data and Profile Information** 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. 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** +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** +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** +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** +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.']() +This data may also be processed for the purposes set out in the section '[General purposes which apply to all data.'](https://sharethis.com/privacy/) -**6\. Employee and Job Applicants' 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](mailto:HR@ShareThis.com). -**7\. Data Collected on 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. +This section sets out how we process data of _visitors of our corporate website_ (ShareThis.com), apart from any ['Usage Data and Profile Information'](https://sharethis.com/privacy/) and the ['Account Information'](https://sharethis.com/privacy/) 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. 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** +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. -### The GDPR and Your Rights as an EU or UK Data Subject +III. **The LGPD and Your Rights as a Brazil 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. - -Additional Information - -**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](mailto: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](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](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](mailto:dpo@sharethis.com) - -ShareThis' representative in the EU is: ShareThis UK Limited of 10 John Street, London WC1N 2EB, UK. - -### 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. -Additional information +- * * **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. -Additional Information +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). @@ -275,32 +246,30 @@ 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. -### Data Sharing or Disclosure, Recipients of Your Data +V. **Data Sharing or Disclosure, Recipients of Your Data** -Additional Information +- * * -**1.Our Customers** - We share Usage Data, Profile Information and/or audience segments for marketing and advertising purposes with: -1. Advertisers; -2. Publishers; -3. Advertising agencies and agency trading desks which operate technology platforms designed to deliver ads on websites and other forms of digital media; -4. Agency trading desks; -5. Data management platform which help advertisers and publishers organize data about Internet users; -6. Investment firms and financial institutions seeking to better understand how consumers use the Internet; -7. Device graph service providers who link different online identifiers to a single user; -8. Advertising technology providers which hep automate the. delivery of advertisements on websites and. other forms of digital media; -9. Research companies seeking to better understand consumer perceptions; -10. Data brokers and other data partners. +- 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]().' +(all, our "**Customers**") for the purposes listed in the section ['Data Collection and Use](https://sharethis.com/privacy/).' 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: @@ -349,49 +318,43 @@ **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. -### Commitments to Privacy Standards +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. -Additional Information +- * * ShareThis is a member of the following self-regulatory programs: -**Network Advertising Initiative (NAI):** - -ShareThis adheres to the [NAI Code of Conduct](http://www.networkadvertising.org/sites/default/files/nai_code2018.pdf). NAI offers an online [web opt-out platform](http://www.networkadvertising.org/choices/) to allow consumers to express their choices and provides general information related to privacy and [Interest Based Advertising](http://www.networkadvertising.org/understanding-online-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](http://www.aboutads.info/choices/) offers the consumer a choice page to opt out from advertising services, and general information related to privacy. -**EDAA:** - **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. -### User Choices and Opt-out Rights +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. **Click below to "Limit Ad-Tracking" function on mobile devices:** Instructions by Google for most Androids: [Google Play Help](https://support.google.com/googleplay/answer/3405269) Instructions by Apple for iOS version 6 and above: [Apple Support Center](https://support.apple.com/en-us/HT202074) -Additional Information +- * * 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](mailto:privacy@sharethis.com). @@ -453,18 +416,30 @@ 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. -**Last Updated: November 2, 2021** +## **Contact Information** -**Contact** ShareThis, Inc. 3000 El Camino Real 5 Palo Alto Square, Suite 150 Palo Alto, CA 94306, USA -[privacy@sharethis.com](mailto:privacy@sharethis.com) +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](mailto:dpo@sharethis.com) -ShareThis' representative in the EU is: ShareThis UK Limited of 10 John Street, London WC1N 2EB, UK +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. + +## **Opt-out confirmed** + +Now, we can't sell your data. + +**Close** + +Back to contents

ShareThis Privacy Notice

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