Website Privacy Policy

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Last updated: January 2023

SOURCEPOINT TECHNOLOGIES, INC. WEBSITE PRIVACY POLICY

1. Introduction

This website privacy policy (“Policy”) describes the processing of Personal Data by Sourcepoint Technologies, Inc. (“Sourcepoint”, “we”, “us”, “our”) in connection with the use of our website www.sourcepoint.com (“Website”). This Policy does not cover Personal Data that we process on behalf of our customers when you visit the websites or mobile applications of companies that use our consent management or anti ad block services. That information can be found in our Sourcepoint Services Privacy Notice. 

This Policy describes: 

• Who we are (Section 2),
• The types of Personal Data that we process and the purposes for which we process Personal Data (Section 3),
• How we use Cookies on the Website (Section 4),
• With whom we may share your Personal Data (Section 5),
• Which security measures we have implemented (Section 6),
• Further information for EU Users (Section 7)
• Further information for Users in California and Virginia (Section 8)
• How you can contact us (Section 9)

We may amend this Policy from time to time by uploading a replacement Policy to the Website. 

2. Who We Are

Sourcepoint Technologies, Inc. is a Delaware company. You can contact us by writing to our corporate mailing address in 228 Park Avenue South, #87903, New York, NY 10003-1502, United States or using our contact form under https://sourcepoint.com/connect-page/.

3. Processing Of Your Personal Data

“Personal Data” means any information relating to an identified or identifiable natural person or that may be considered “personal data” or “personal information” under applicable privacy or data protection laws. This may include your name, address, email address, or phone number, but can also include IP address, browser type, or previously visited websites.

3.1 Types of Personal Data and Purpose for Processing 

In connection with your use of the Website, we process the following Personal Data:

3.2. Legal bases for processing and retention of Personal Data

In addition to the information provided in section 3.1 (“Processing Of Your Personal Data”), please find details on the legal bases for the processing your Personal Data (applicable for EU users) and on retention periods below:

4. How We Use Cookies

The Website uses cookies and similar technologies, such as pixels or beacons (“Cookies”). These Cookies are used to make it easier for you to use the Website during future visits, authenticate you, remember your preferences, monitor and analyze traffic on our Website, personalize the content of the Website for you, measure ad and content performance, and create personalized content profiles. Please read more about the Cookies we use on the Website in our Cookie preferences, which is accessed in the GDPR Privacy Settings at the bottom of the page. You can always (when first visiting our Website and on every visit thereafter) accept or decline the use of the Cookies on our Website in the GDPR Privacy Settings by (1) clicking on “Accept All” or “Reject All buttons” or (2) moving the switch next to the Cookies to “on” or “off” and clicking on “Save & Exit”. You can also modify your Cookie choices in your browser settings. If you decline the use of Cookies, we may not be able to provide certain functionalities to you.

5. Recipients Of Your Personal Data 

5.1 Service providers

We share information with vendors who assist us with providing the Website, for example with hosting the Website, sending newsletters, storing data in clouds, website tracking (cookies and similar technologies), and processing your job applications.  In some cases, we authorize these vendors to collect data on our behalf. We have carefully selected these service providers and concluded data processing agreements with them, if required by applicable data protection laws.

5.2 Transfers to third parties

We may disclose your Personal Data:

• To certain social media platforms to enable us to identify you and serve targeted Sourcepoint advertisements to you on such social media platforms. This may include your name, email address, company name and job title. 
• If required to do so by law or if we believe that such action is necessary to protect and defend the rights, property or personal safety of us or our employees, or of other users of the Website. We process your Personal Data for these purposes either to comply with legal obligations or based on our legitimate interests in safeguarding us and others;
• To potential purchasers or investors (and their advisers) on the sale of the whole or any related part of our business and/or assets. Depending on the transaction such transfers may be based on our legitimate interests to conclude the transaction or as disclosure is necessary for the performance of the contract between you and us. 

6. Security Measures

We employ security measures to protect your Personal Data from access by unauthorised persons and against unlawful processing, accidental loss, destruction and damage.

The transmission of information using Wi-Fi networks and cellular data networks may not be completely secure. Although we will use reasonable methods to protect your Personal Data, we cannot guarantee the security of data transmitted to us using the Website and any such transmission is made at your own risk.

7. Further information for EU Users

The following additional information and rights only apply to users who visit the Website from the EU/EEA.

7.1 Recipients outside the EU/EEA

Some of the recipients listed in section 5 may be located outside the European Union/the European Economic Area. In such cases, we use safeguard to establish an adequate data protection level in the third country, such as standard contractual clauses or binding corporate rules. You may ask to receive a copy of the safeguard by contacting us as described in the “Questions And Contact Details” section below.

7.2 Your Rights

You have the following rights in relation to the Personal Data we hold about you, given that the accordant preconditions are fulfilled:

• Right of access:
  • If you ask us, we will confirm whether we are processing your Personal data and, if so, provide you with a copy of that Personal Data (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.
• Right to rectification:
  • If the Personal Data we hold about you is inaccurate or incomplete, you are entitled to have it rectified or completed. If we have shared your Personal Data with others, we will let them know about the rectification where possible.
• Right to erasure:
  • You may ask us to delete or remove your Personal Data in some circumstances, such as where we no longer need it or you withdraw your consent (where applicable). If we have shared your Personal Data with others, we will let them know about the erasure where possible.
• Right to restrict processing:
  • You may ask us to restrict or ‘block’ the processing of your Personal Data in certain circumstances such as where you contest the accuracy of that Personal Data or object to us processing it (but not continuing to store it). We will tell you before we lift any restriction on processing. If we have shared your Personal Data with others, we will let them know about the restriction where possible.
• Right to data portability:
  • You have the right to obtain Personal Data you have provided to us, that we are processing based on your consent or because necessary to perform a contract with you, in a structured, commonly used and machine-readable format, and to reuse it elsewhere.
• Right to object:
  • You may ask us at any time to stop processing your Personal Data, and we will do so, if we are relying on our own or someone else’s legitimate interests to process your Personal Data, except if we can demonstrate compelling legal grounds for the; or processing your Personal Data for direct marketing.
• Rights in relation to automated decision-making and profiling:
  • You have the right not to be subject to a decision when it is based solely on automated processing, including profiling, and it produces a legal effect or similarly significantly affects you unless such profiling is necessary for entering into, or the performance of, a contract between you and us.
• Right to withdraw consent:
  • If we rely on your consent as our legal basis for processing your Personal Data, you have the right to withdraw that consent at any time.
• Right to lodge a complaint with the data protection authority:
  • If you have a concern about any aspect of our privacy practices, including the way we have handled your Personal Data, you can report it to the data protection authority that is authorized to hear those concerns.

EU users may exercise their rights by completing this form.

7.3 EU representative

Data subjects in the EU may also contact our office in Germany by writing to Sourcepoint GmbH, Friedrichstrasse. 68, 10117, Berlin, Germany.  

8. Further information for Users in California, Virginia, Colorado, or Connecticut

The following additional information and rights only apply to residents of California, Virginia, Colorado, or Connecticut who visit the Website.

8.1 Your Rights

Depending on where you reside, you may have the following rights in relation to the Personal Data we hold about you, given that the accordant preconditions are fulfilled:

• Right of disclosure:
  • If you ask us, we will confirm (no more than twice in a 12-month period) what (if any) Personal Data about you that we collect, use, disclose, share or sell during the preceding year. You may request the following information:
    Specific pieces of Personal Data that we have collected about you;
    Categories of Personal Data that we’ve collected about you;
    Categories of sources from which we collected Personal Data about you;
    Categories of Personal Data that we sold or disclosed for a business purpose about you;
    Categories of third parties to whom Personal Data about you was sold or disclosed for a business purpose; and
    Our business or commercial purpose for collecting or selling Personal Data about you.
• Right to correction:
  • If the Personal Data we hold about you is inaccurate or incomplete, you are entitled to have it corrected or completed. If we have shared your Personal Data with others, we will let them know about the rectification where possible.
• Right to deletion:
  • You may ask us to delete or remove your Personal Data in some circumstances. If we have shared your Personal Data with others, we will let them know about the deletion request where possible.
• Right to opt out of sharing / targeted advertising:
  • We do not consider that our disclosure of Personal Data to third parties constitutes a “Sale” of Personal Data under applicable U.S. data protection laws. However, you may ask us at any time to stop “sharing” your Personal Data with third party social media platforms for purposes of identifying you and serving targeted Sourcepoint advertisements to you on such social media platforms.
• Right of non-discrimination:
  • We will not discriminate against you for exercising any of the above rights.

California, Virginia, Colorado, and Connecticut users may exercise their rights by completing this form or by emailing us at [email protected]. 

Virginia residents may appeal the denial of a request by emailing us at [email protected]. 

9. Questions And Contact Details

If you have any questions about this Policy or our data processing practices, you can contact us using the contact details available at https://sourcepoint.com/connect-page/, by writing to Sourcepoint Technologies, Inc., 228 Park Avenue South, #87903, New York, NY 10003 -1502, USA, or, if you are located in the EU, to our German office named in section 7.3.

If you would like to review further information on Sourcepoint’s processing of Personal Data as a data processor or service provider in connection with the use of our services Dialogue Consent Management Platform and Anti Adblock, please visit our Privacy Notice – Sourcepoint Services.