Privacy Policy

SponsorCloud LLC (“SponsorCloud”) is committed to the privacy of your information. This Privacy Policy is meant to help you understand the information we collect, why we collect it, and how you can manage it. This Privacy Policy applies to our website available at https://www.sponsorcloud.io/, including any related or connected websites owned by SponsorCloud (the “Site”) and any related products, services, or communications (collectively the “Services”). The terms “you,” “yours,” or similar expressions refers to users of this Site and our Services, as well as any other individuals whose information we collect and process through the Site and Services. The terms “we,” “us,” “our” or similar expressions refer to SponsorCloud and their agents, subsidiaries, affiliates, officers, employees, and partners.  

This Privacy Policy does not extend to anyone whose personal information is not under our control or management, including data that is collected by other websites that you may visit before or after this Site, and which are not governed by this Privacy Policy. We are not responsible for the data protection or privacy policies of any other websites and accept no responsibility or liability for those policies. Please carefully check the policies of other websites and services you use before you visit or submit personal information.

If you choose to use our Site or Services, then you agree to the collection and use of information in relation to this Privacy Policy. The information that we collect is used for providing and improving the Site or Services. We will not use or share your information with anyone except as described in this Privacy Policy.

This Privacy Policy is incorporated into and subject to the Terms of Service (“Terms of Service”) (available at https://www.sponsorcloud.io/terms-of-service). Each time that you access or use the Site or Services, you acknowledge that you have read, understand and agree to be bound by the Terms of Service and this Privacy Policy. If you do not agree to the Terms of Service and this Privacy Policy, you must discontinue using our Site and Services.

A. Important Definitions

Personal Information:  We consider some, but not all, of the information you or an Authorized User provides us to be “Personal Information.” We define Personal Information as information about you that is personally identifiable to you, such as your contact information (e.g., name, address, e-mail address, or telephone number), financial transactional information (e.g., bank account numbers, etc.) and any other non-public information that is associated with such information (collectively, “Personal Information”).  It does not include aggregate information where your identity has been removed, deidentified, or made anonymous. We will not rent or sell your Personal Information to third parties without your explicit consent.  

Customer:  A Customer is as defined in the Terms of Service and includes you, your agents and affiliates if any, and any other person accessing your SponsorCloud Account.

Authorized User:  An Authorized User is as defined in the Terms of Service and includes an investor, employee, or any authorized user you agree to provide access to the Site and Services as authorized by your subscription level on your Account to use the Services.

B. Information We Collect

1. Information We Collect and Receive: In order for you to use our Site and Services, we need to collect and process certain types of information. Depending on your use of our Site and Services, this may include:

• Information you provide to us by completing forms on our Site: For example, your name, contact and address information, and any other information you may provide in the forms on our Site;
• Information you provide to us by contacting us: Any personal information you may provide to us when you e-mail or call us, such as name, phone number, employer, and any other details you provide in your communications. SponsorCloud may also request your contact information for the purposes of having someone contact you for additional information, or in response to your request for information from us;
• Transaction information when you purchase Services from us: For example, if you make purchases with your credit card, we may use your credit card information for shipping, billing, and credit card validation purposes;
• Information to support delivery of our Services: For example, we may require your address to deliver Services and other materials to you that were requested by you;
• Login information, such as username and password, that you may use in connection with our Services;
• Information about your activity through our Services, including your device information, such as your IP address, the type of device or browser you use, and your actions on the Site.
• Information stored as part of any software as a service or other Services, such as customer information, investment information, and other data provided as part of your use of the Services.

We will only use Personal Information to provide you with information, products, or services you have requested, or for other purposes set out in this Privacy Policy. Personal Information does not include aggregate information from which individual identities have been removed.

2. Information from Children: SponsorCloud does not knowingly solicit or collect any personal information from anyone under 13 years of age, and children under 18 are not permitted to register for or use our Site or Services, including by subscribing to receive information from SponsorCloud. Parents can contact our customer service department to access, change, or delete the personal information that has been submitted by a child. If we become aware that a child under the age of 18 has provided us with personal information, we will delete it.

Cookies and Tracers 

We may use cookies and similar technologies (e.g., web beacons, pixels, ad tags, and device identifiers) to recognize you and/or your device(s) on, off and across the Site and different Services and devices. A cookie is a small file that is placed onto your device (e.g., computer, smartphone, or other electronic device) that stores information when you visit a website.  

Do Not Track is a privacy preference that users can set in their web browsers.  When a user turns on the Do Not Track signal, the browser sends a message to websites requesting them not to track the user.  PLEASE BE AWARE that our website currently does not recognize or respond to “Do Not Track” signals.

SponsorCloud uses cookies and related technologies on our Site to help us recognize your device as a repeat visitor, and enable certain website features and functionalities. Some of this data will be aggregated or statistical, which means that we will not be able to identify you individually. 

Types of Cookies

The cookies we place on your device fall into one of the following categories:

• Strictly necessary cookies: these cookies are essential for you to be able to navigate our Site and use its features. Without these cookies, the services you have asked for could not be provided.

• Performance cookies: these cookies collect information about how you use our Site, for example, which pages you go to most often. These cookies do not collect personally identifiable information about you. All information collected by these cookies is aggregated and anonymous, and is only used to improve how our Site works.
• Functionality cookies: these cookies allow our Site to remember the choices you make (such as your user name, language, last action and search preferences) and provide enhanced, more personal features. The information collected by these cookies is anonymous and cannot track your browsing activity on other websites.
• Marketing cookies: also known as advertising cookies, these cookies are used to deliver advertisements more relevant to you and your interests. They are also used to limit the number of times you see an advertisement on our Site and help measure the effectiveness of the advertising campaign. This is sometimes referred to as online behavioral advertising. In some cases, our partners may use cookies to provide us with information about your interactions with their services. These cookies remember that you have visited a website, and this information is shared with other organizations such as advertisers. Those third-party cookies would be subject to the third-party service’s policies.

Consent to Use Cookies

The first time you visit our Site, a cookie notice is displayed describing our use of cookies, and linking to this Cookie Policy. As described in that notice, if you use this Site and/or Service after this notification has been displayed to you, we will assume that you consent to our use of cookies for the purposes described in this policy.

Controlling Cookies

Your browser may give you the ability to control some types of cookies. If you do not want to accept the kinds of cookies you can control, you can change your browser settings so that certain types of cookies are not accepted.

If you turn off any cookies, please be aware that you may lose some of the functionality of this Site. For more information about cookies and how to disable them please check one or more of the following resources: http://www.allaboutcookies.org/ or https://ico.org.uk/for-the-public/online/cookies/.

Cookies We Use

The table below explains the cookies we use on our website and the purposes for which they are used:

__stripe_mid

Stores Stripe Merchant ID. Helps map Customer payments to SyndicationPro account.

Persistent

Session + 1 year

__stripe_sid

Stores Stripe Subscription ID. Helps ensure only Customers with a valid subscription can access our Software.

Persistent

Session + 30 mins

_gat_tracker1

Used to track general statistics such as pageviews, time spent on page, etc.,

Session

Session + 1 min

_ga

Used to track general statistics such as pageviews, time spent on page, etc.,

Persistent

Session + 2 year

_gid

Used to track general statistics such as pageviews, time spent on page, etc.,

Persistent

Session + 1 day

CookieConsent

Stores User's cookie consent information.

Persistent

Session + 1 year

Google Analytics

We may use Google Analytics on our Site.  A Deal Sponsor may also use Google Analytics on their specific URL that we assign to their Account.  

Google Analytics is a website analysis service. Website analysis refers to the collection, recording and analysis of data regarding the behavior of visitors to the website. A website analysis service records e.g. data showing from which website a data subject has come to a website (so-called referrer), which subpages of the website were accessed or how often and how long a subpage was viewed. Website analysis is used mainly for the optimization of a website and for a cost-benefit analysis of Internet adverting.

Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA, is the operator of the Google Analytics component.

Google Analytics uses cookies. The information about your use of our website generated by the Google Analytics cookie is normally transmitted to a Google server in the USA and stored there. Google might disclose these personal data collected via the technical procedure to third parties.

You may prevent the storage of cookies by setting your browser software accordingly, but you might then not be able to fully use all functions of our website.

You may furthermore prevent the disclosure of the data generated by the cookie which refer to the use of the website (including your IP address) to Google as well as the processing of these data by Google by downloading and installing the browser plug-in available under the following link: https://tools.google.com/dlpage/gaoptout?hl=en.  This browser add-on notifies Google Analytics via JavaScript that no data or information about website visitors may be transmitted to Google Analytics.

Additional information and the applicable privacy policy of Google may be downloaded from https://policies.google.com/privacy?hl=en and from  https://marketingplatform.google.com/about/analytics/terms/us/. 

Google Analytics is explained in more detail under this link: https://marketingplatform.google.com/about/.

How We Use Information

SponsorCloud may use the Personal Information we collect for the following purposes:

1. To allow you to log into and access your Account and communicate with you about your Account or transactions;
2. To deliver our Services;
3. To provide customer service and our support services, or respond to any requests you make;
4. To process any financial transactions you make on our Site;
5. To facilitate SponsorCloud’s development, design, marketing or quality improvement of the Site and to improve our general business purposes.
6. To keep your information secure such as by monitoring for security irregularities, and to be able to verify your identity and contact information;
7. To alert you about product updates, special offers, updated information and other news and services from SponsorCloud;
8. To ensure our Site and Services are relevant to you and your interests;
9. To help us create and publish content most relevant to you; and
10. To contact you in response to any communications or requests submitted by you.
11. To detect, investigate and prevent activities that may violate our policies or be illegal.
12. To review whether it is responsive to a subpoena or other legal request we have received.

How Information May Be Shared

SponsorCloud will never sell or rent any of your Personal Information, and we will never share your Personal Information publicly without your consent. However, we may share any and all of your information in the following instances:

• Third-Party Business Vendors:  From time to time, SponsorCloud may engage other trusted third-party companies and individuals to perform functions such as sending postal mail and e-mail, removing repetitive information from customer lists, analyzing data, providing marketing assistance, providing search results and links (including paid listings and links), and providing customer service. Such companies shall only use your Personal Information for those purposes required to perform their functions and only when you consent to SponsorCloud sharing your Personal Information with such companies so they can perform their functions. For example, we may store the information described in Section B(1) above with a third-party data storage service to support delivery of our Services, and to respond to customer service requests. Whenever we share data with third-party services, we require that they use your information only for the purposes we’ve authorized, and only pursuant to contractual obligations requiring such third parties to maintain the privacy and security of your Personal Information.
  

Law Enforcement:  We may also disclose Personal Information when it is reasonably necessary to conduct our business, in connection with the sale of a business, to enforce our Terms of Use or rules, to ensure the safety and security of our guests and third parties, or to protect our rights and property and the rights and property of our guests and third parties, and to comply with the law, law enforcement, or other legal request.

• Directed By You:  We may share your Personal Information when you direct us to share your information with third-party sites or platforms.  The following are the third-party sites or platforms that we may share your Personal Information upon your consent:

• Parallel Markets Inc.:  Information is shared for investors accreditation verification purposes.
• Dwolla, Inc.:  Information is shared to facilitate ACH transactions.
• Lob.com, Inc.:  Information is shared to allow for check deliveries.

Please note that once we share your information with another company, the other company’s privacy practices will govern their use of the information. 

6. Protection of your Personal Information

We take the security of your personal information seriously and follow industry-standard practices to protect the data we collect and process. SponsorCloud has therefore put in place commercially reasonable physical, electronic, and managerial procedures to safeguard and secure the personal information that SponsorCloud collects. Access to personal information will be restricted to our authorized personnel who require the information in order to perform their duties properly. In addition, access will be limited to only that information that is strictly necessary for the performance of those duties.

Remember, the safety and security of your information also depends on you. You must take precautions to protect the security of any personally identifiable information that you may transmit over any public or untrusted network by using encryption and other techniques to prevent unauthorized persons from intercepting or receiving any personally identifiable information. You are responsible for the security of your information when using unencrypted, open access, public or otherwise unsecured networks. No method of transmission over the internet or electronic storage is completely secure, so SponsorCloud cannot guarantee its absolute security.

In the event you disclose any of your personal information in a public forum, the information in that disclosure will be treated as public, we will not take any steps to protect, secure, or delete that disclosure, and you should not have any expectation of privacy or confidentiality with regards to that disclosure.

7. Data Transfers

Because SponsorCloud is a US-based company, your information may be collected and processed in the United States. Additionally, as part of the products and services offered to you through our Site, the information which we collect about you may be transferred to, and stored in, one or more countries other than where you currently reside. For example, this may occur if any of our servers or third-party service providers are located in a country other than yours. These countries may have different data protection laws that are similar to your current residence. However, if we transfer your information in this way, we will put in place appropriate protection through written agreements to make sure your personal data remains adequately protected and is treated in line with this Privacy Policy.

8. How You Control Your Information

You may modify, change, or correct your Personal Information in the same manner in which you originally provided it to us.

If you want to delete your Account, we are sorry to lose your business, and we hope that you will give us the opportunity to discuss any issues or concerns that you have had regarding our service. To delete your account, please contact us at support@sponsorcloud.io. Once we receive your request, we will then take steps to delete your Personal Information within a commercially reasonable time. We may retain some information for our own backup, archival, record or audit purposes and as otherwise required by law, however, we will only retain the information for those purposes. Please note that we will only be able to delete your Personal Information that is within our control, and we will not be able delete your Personal Information that we had previously shared with others in accordance with this privacy policy.

9. E-mail Notifications

We try to keep e-mail communications to a minimum, and give you the ability to opt out of any marketing communications we send. For example, we may send you e-mail relating to the Products or Services that we offer. You may also elect to receive certain marketing e-mail communications, in accordance with your preferences, and from which you may opt out at any time. You can always opt out of receiving e-mail information or mobile device notifications from SponsorCloud (other than certain required communications informing you of the completion of a purchase, user registration, correction of user data, or change of password), by adjusting your user preferences in your account profile if you are a registered user, or by sending us an e-mail at support@sponsorcloud.io stating your request. If we have sent you a promotional e-mail or mobile device notification, you may send us a return e-mail or mobile device communication asking to be omitted from future e-mail or mobile device distributions. This opt out does not apply to information provided to SponsorCloud as a result of a purchase of the Products or Services, product service experience, or other transactions.

10. Retention

We will continue to store and process your information until the earlier of (i) your request that we delete your Personal Information in accordance with the procedures set forth in this Privacy Policy; (ii) your Personal Information is no longer required to fulfill the identified purpose for which it was collected; or (iii) we decide to delete your Personal Information for reasons such as because your failure to use our Service for a prolonged period of time (as determined in our sole discretion) or another business reason makes it desirable for us to delete your information.

The length of time for which we will retain your Personal Information will depend on the purposes for which we need to retain it. This is a case-by-case determination that depends on things like the nature of the data, why it is collected, why it is processed, and any relevant legal or operational retention needs. For example, we may retain your data for as long as you maintain an account on our Site so that we may process and deliver your orders. We may continue to retain your Personal Information to meet any legal requirements or to defend or exercise our legal rights. We review our retention periods for personal information on a regular basis. When the relevant processing activity has been completed, we may destroy your data, or alternatively anonymize the data in such a way that you are not personally identifiable, either directly or indirectly.

11. Basis for Processing – European Union Residents

Data protection law in Europe requires a “lawful basis” for collecting and retaining personal information from residents of the European Economic Area. Our lawful bases include:

• Performing the contract we have with you: In certain circumstances, we need your personal data to comply with our contractual obligation to deliver our Products and Services, and assist with any questions you may have.
• Consent: we may ask your consent to process your personal information in some situations.
• Legal compliance: Sometimes the law says we need to collect and use your data.
• Legitimate interests: This is a term in data protection law that allows us to process your personal information if we have a fair reason to use your data, and only if we do so in ways which do not hurt your interests and rights. We sometimes require your data to pursue our legitimate interests in running our business, including for delivering our Products and Services, fraud prevention, quality assurance, and marketing purposes, as long as our use of your data does not materially impact your rights, freedom, or interests. This allows us to improve and develop the quality of the online experience we offer all our users

12. What are Your Data Protection Rights?

Subject to certain conditions data protection laws give you various rights with respect to our use of your personal data.  To exercise your rights set forth in this section, please contact us at support@sponsorcloud.io.  Subject to our authentication of your identity, we will act on your request promptly and in accordance with applicable laws.

Economic European Area / United Kingdom

If you are in the Economic European Area (EEA) or the United Kingdom (UK), you have the following rights:

Right to Withdraw Consent and Stop Our Use of Your Personal Information: If you have consented for SponsorCloud to use your personal information for a specific purpose or purposes, you may contact us to instruct us that you withdraw your consent that we use your personal information for that purpose or those purposes.  Note however, this will not affect any processing or use of your personal information that took place before you withdrew your consent. 

Right to Access and Port Your Personal Information:  You may contact us to receive a copy of your personal information and it shall be provided in a structured, commonly used and machine-readable format, which you may then port elsewhere for your purposes.

Right to Correct or Change Your Personal Information: If your personal information has changed or you discover our records of your personal information is otherwise incorrect, you may contact us to change your personal information accordingly.

Right to Be Forgotten: If you do not wish for SponsorCloud to have your personal information anymore, you may contact us to instruct us to delete your personal information from our records.  We will delete your personal information from our database.  Note, however, if you have communicated to us through e-mail or other channels, we may incidentally have portions of your personal information within our internal archives of such communications, however, we will not use such Personal Information for any purpose inconsistent with your right to be forgotten or the record-keeping purposes of the archive.  We may also preserve your personal information if we are required to do so by law, however, we will not use such Personal Information for any purpose inconsistent with your right to be forgotten or such legal obligation. 

Right to Review Decision-Making: If you question why you have received a communication or other material from SponsorCloud, you may contact us to learn what about your personal information led us to send you the communication or other material.  You have the right to object to a decision based solely on automated processing, including profiling, which produces legal effects concerning or affecting you.

Right to Restriction of Processing:  If any of the following conditions apply, you have the right to request a restriction on the processing of your data: (1) accuracy of the data is contested; (2)the processing is unlawful and you oppose erasure of the data; (3) the controller no longer needs your personal data for processing but legal claims require data not to be erased; and (4) you object to the processing of your personal information in accordance with Article 21(1) of the GDPR.

Right to Object:  You have the right to object to the processing of personal data concerning yourself in accordance with Article 21 of the GDPR and that do not fall under any exception.

California

In accordance with the obligations under the California Consumer Privacy Act (“CCPA”) and the California Privacy Rights Act (“CPRA”), we set forth the following additional notices and policies with respect to the residents of California who use the Service.

Categories of Personal Information

The following are categories of Personal Information collected from consumers, the categories of sources from which the information was collected, and the business purpose for which the information was collected and disclosed within the last twelve (12) months. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract.  Note that SponsorCloud DOES NOT SELL Your Personal Information.

Category

Collected

Categories of Sources of Personal Information From Which We May Collect

Category of Third-Party Recipients Which We May Share Personal Information

Business Purpose Disclosures

Identifiers (such as real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, e-mail address, account name, driver's license number, passport number, or other similar identifiers.)

YES

• You (e.g. forms or profiles you complete on the Site.)
• Indirectly/automatically collected by Mighty Networks through the use of the Site.

NONE

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code §1798.80(e)) 

NO

NONE

NONE

Protected classification characteristics under California or federal law

NO

NONE

NONE

Commercial information 

NO

NONE

NONE

Biometric information 

NO

NONE

NONE

Internet or other similar network activity 

YES

• Indirectly/automatically collected by Mighty Networks through the use of the Site 

NONE

Geolocation data 

NO

NONE

NONE

Sensory data 

NO

NONE

NONE

Professional or employment-related information 

NO

NONE

NONE

Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) 

NO

NONE

NONE

Inferences drawn from other personal information 

NO

NONE

NONE

Government Identifiers

NO

NONE

NONE

Complete account access credentials

NO

NONE

NONE

Precise geolocation

NO

NONE

NONE

Racial or ethnic origin

NO

NONE

NONE

Religious or philosophical beliefs

NO

NONE

NONE

Union membership

NO

NONE

NONE

Genetic data

NO

NONE

NONE

Mail, e-mail, or text messages contents

YES

• You (e.g. mail, e-mails or text messages you may send to us).

NONE

Unique identifying biometric information

NO

NONE

NONE

Health, sex life, or sexual orientation information

NO

NONE

NONE

California Residents Rights

Right to Know/Access Personal Information:  California residents have the right to request access to categories of Personal Information collected about you within the last 12 months and information regarding the source of that information, the business or commercial purposes for which we collect it, and the third parties and service providers with whom we share it.  If we sold or disclosed your Personal Information for a business purpose, then California residents have the right to two separate lists disclosing (1) the sales, identifying the personal information categories that each category of recipient purchased, and (2) disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained. Lastly, California residents have the right to specific piece of personal information we collected, or a data portability request.

Right to Request Deletion of Personal Information:  Subject to certain exceptions under Cal. Civ. Code §1798.105(c) and (d), California residents have the right to, at no charge, request deletion of their Personal Information that we have collected about them and to have such Personal Information deleted, except where an exemption applies.  We will delete or deidentify personal information not subject to an exception from our records and will direct our service providers to take similar action.

Right to Opt Out of Sale of Personal Information:  Under the CCPA, California residents have the right to opt-out of our sale of their Personal Information.  SponsorCloud does NOT SELL any personal information to another business or a third party for monetary or other valuable consideration.  

Right to Non-discrimination:  The CCPA prohibits discrimination against California residents for exercising their rights under the CCPA.  Unless permitted by the CCPA, we will not (a) deny you goods or services, (b) charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties, (c) provide you a different level or quality of goods or services, or (d) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services. 

How to Submit a Request to Exercise Your Rights

You may submit a request to exercise your rights as listed above by contacting us in any of the following manners:

• Submit a written request to support@sponsorcloud.io.
• Call us at (346) 766-2236.

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information.  (See Authorized Agent section below).  You may also make a request as an Authorized Agent to know or delete on behalf of your child by following the same instructions listed above.

Any request received from a California resident will be responded to as required by law.  You may only submit a request to know twice within a 12 month period.  

Persons with disabilities may obtain this notice in alternative format upon request by contacting us at support@sponsorcloud.io.

Verification Procedures

In order to process a request to exercise a California residents’ rights, we must verify your request.  We do this by asking you to provide personal identifiers we can match against information we may have collected from you previously; and by confirming your request using the e-mail or telephone account stated in the request.

Authorized Agent

California Residents may authorize another individual or a business registered with the California Secretary of State, called an authorized agent, to make requests on your behalf.  We require that you and the individual complete affidavits in order to verify the identity of the authorized agent and confirm that you have authorized them to act on your behalf. 

Response Timing

We will confirm receipt of your request within 10 business days.  If you do not receive a confirmation with the 10-day timeframe, please contact us at support@sponsorcloud.io.  We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.  We will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance, specifically by e-mail.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Financial Incentives

A business may offer financial incentives for the collection and use of California residents' personal information, provided it is not unjust, unreasonable, coercive or usurious, and is made available in compliance with applicable transparency, informed consent, and opt-out requirements.  California residents may not be included in such incentives without their prior informed opt-in consent.  SponsorCloud DOES NOT offer any rewards programs, incentives or price differences for the collection or sharing of data at this time.  

California Do Not Track Disclosure

Do Not Track is a privacy preference that users can set in their web browsers.  When a user turns on the Do Not Track signal, the browser sends a message to websites requesting them not to track the user.  At this time, we do not respond to Do Not Track browser settings or signals.

California’s Shine the Light Law

California Civil Code Section 1798.83 permits customers of SponsorCloud who are California residents to request certain information regarding and/or opt-out of our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please write to us at support@sponsorcloud.io.

Colorado

In accordance with the obligations under the Colorado Privacy Act (“CPA”), SponsorCloud only collects data on a business-to-business basis, for commercial purposes. We only collect data to provide a product or service you specifically requested. We DO NOT SELL your information. If you would like to access, delete, receive a copy of the personal data, limit the use of your personal data, or opt out of the sale of personal data (should SponsorCloud start selling data), as defined by the CPA, please contact us at support@sponsorcloud.io. Subject to our authentication of your identity, we will act on your request promptly.  If SponsorCloud denies your request, we will advise you of the reason for the refusal.

Virginia

In accordance with the obligations under the Virginia Consumer Data Protection Act (“VACDPA”), SponsorCloud only collects protected information in a commercial context.  We DO NOT SELL your information. If you would like to access, delete, receive a copy of the personal data, limit the use of your personal data, or opt out of the sale of personal data (should SponsorCloud start selling data), as defined by the VACDPA, please contact us at support@sponsorcloud.io. Subject to our authentication of your identity, we will act on your request promptly.  If SponsorCloud denies your request, we will advise you of the reason for the refusal.

Canada

In accordance with the obligations under the Personal Information Protection and Electronic Documents Act (“PIPEDA”), we set forth the following additional notices and polices with respect to the residents of Canada who use the Service.

Your Rights to Your Personal Information

• The right to withdraw your consent (where our processing activity is based on your consent);
• The right to be provided with details about what personal data we hold about you and whether your personal data has been transferred to a third-party, and to be provided with a copy of your personal data;
• The right to opt into and to stop receiving marketing communication; and
• The right to require us to update any inaccuracies in the personal data we hold.  In order to assist us with this, please keep your account information up to date;

To exercise any of your rights set forth in this section, please contact us at support@sponsorcloud.io.  Subject to our authentication of your identity, we will act on your request promptly.  If SponsorCloud denies your request, we will advise you of the reason for the refusal.

If you are not satisfied with how we have addressed your complaint or concerns, you can also contact your appropriate data privacy regulator.  If you are located in Canada, your appropriate data privacy regulator may be the Office of the Privacy Commissioner of Canada or a local provincial privacy regulator.

Note: Publicly available information is defined under SOR/2001-7.  This includes information such as any personal information including the name, title, address and telephone number of an individual that appears in a professional or business directory, listing or notice, that is available to the public, where the collection, use and disclosure of the personal information relate directly to the purpose for which the information appears in the directory, listing or notice.  (For full definition see SOR/2001-7).

An organization may collect, use and disclose publicly available Personal Information without the knowledge or consent of the individual.

13. Choice of Law

The laws of the State of Utah shall govern any dispute, including those disputes arising from SponsorCloud’s use of Personal Information or otherwise relating to privacy, as specified in the Terms of Service. [https://www.sponsorcloud.io/terms-of-service] This Policy does not create rights enforceable by third parties.

14. Questions, Comments, or Complaints

If you have questions or comments about this Privacy Policy, or if you are not completely satisfied with this Privacy Policy or its application by us, we invite you to convey your concerns or suggestions to us at support@sponsorcloud.io. If you have an applicable disability, you may also contact us at the above e-mail address to request access to this Privacy Policy an alternative format. We will reply as quickly as possible and inform you of the steps, if any, that have been or will be taken in order to address your concern or implement the suggestion.

15. Updates and Changes to this Privacy Policy

We may update this Policy from time to time. If we do, we’ll let you know about any material changes, either by notifying you on the Site or by sending you an e-mail. If you keep using our Site, Products, or Services after a change, that means you accept this Policy. Where the changes require opting in pursuant to law, you will be provided with the option to opt-in in the notification process.

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