SOPHIA SEARCH LIMITED PRIVACY AND SECURITY POLICY STATEMENT

Last Updated:  March 31, 2014

Sophia Search Limited and its affiliates (collectively, “Sophia”) takes your privacy very seriously and are committed to safeguarding your privacy pursuant to this policy.  The policy is designed to inform you about Sophia’s practices regarding the collection, use, and disclosure of any personal information on discoversophia.com and its sub-domains and related sites (the “Site”) and when you view or click on our embedded Ambient Commerce Unit (the “Unit”) when the Unit is embedded on the Site or a third party site.

PLEASE REVIEW THIS PRIVACY POLICY BEFORE USING THIS SITE.  IF YOU DO NOT AGREE WITH OUR PRIVACY POLICY, DO NOT USE THE SITE.  BY SUBMITTING ANY PERSONAL INFORMATION TO THE SITE, YOU AGREE TO BE BOUND BY THE TERMS OF THIS PRIVACY POLICY.

This privacy policy may be modified by Sophia at any time and at our discretion.  Notice of any such modifications shall be given by posting a revised version of this Privacy Policy on the Site.  Sophia suggests that you check this page frequently to review any changes, as continued use of the Unit and the Site constitutes your acceptance of any such modifications.

INFORMATION COLLECTED

When you view or click on the Unit and when you visit the Site, you send certain information to Sophia or its third party service providers, which may include without limitation your IP Address (as described in further detail below), your domain name, referring site addresses, the access date and time, and technical information such as user agent strings and browser and operating system types. In addition, for our advertisers who interact with Sophia through the Site, by submitting an insertion order to Sophia or by otherwise opening an account with Sophia, you may be required to send certain information to Sophia, such as your name, email address, telephone number, and banking or other financial information which Sophia will use to receive and process payments and as otherwise set forth herein.

COOKIES AND IP ADDRESSES

Sophia and our third party advertisers and partners may use cookies in connection with your use of the Site or the Unit. Sophia may use cookies on the Site in order to understand basic statistics, visitor patterns and overall trends regarding use of the Site.  Sophia’s third party advertisers and partners may use cookies to help create a more personalized experience and to recognize your use of the Unit and the Site.  A “cookie” is a small data file that can be stored on your computer to assist Sophia’s third party advertisers and partners in delivering a consistent and effective user experience to you.  Such cookies may include “session” cookies (short-term data files which help to recognize and identify a particular delivery of a website) as well as “persistent” cookies (longer-term data files which support additional functionality, including assisting websites to recognize you during multiple return views and visits).

An “IP Address” is a series of numbers assigned to your computer when you are connected to the Internet.  The communication protocols upon which the Internet operates cause Sophia to receive your IP Address every time you access and use the Unit and the Site.  Sophia may retain log files containing your IP Address.

USE OF INFORMATION

Sophia identifies the geographic location of the IP Address associated with each user that connects to a Unit in order to identify local retailers and present the user with related advertising. Except in aggregated, de-identified form, Sophia does not otherwise use personal information obtained via the Unit.

For personal or technical information Sophia may collect via the Site, Sophia may store, use and analyze that information to provide and improve its services and as otherwise set forth herein.

Sophia may disclose personal and technical information to third party service providers and to affiliates or related companies providing services to or on behalf of Sophia, in each case on the condition that they agree to treat your information in a manner substantially in accordance with this Privacy Policy.

Sophia may use your information aggregated with that of other users.  In such cases, any personal identifying information will be stripped and the aggregate data will be completely anonymous.  This aggregate data shows overall trends in the use of the Unit and the Site, and may be used by Sophia or third parties to improve the Unit and the Site or for marketing, research and other business purposes.

Except in the instances discussed in this Privacy Policy, Sophia will not disclose your information to unaffiliated third parties without your consent.

DISCLOSURE OF INFORMATION TO UNAFFILIATED THIRD PARTIES

Please note that we share customer information across Sophia-owned business entities and companies working on our behalf, but only as described above in “Use of Information”.

a.         Third-Party Service Providers and Suppliers

We will not share your personal information with third parties except in responding to your requests for products or services.  Sophia may contract with third-party service providers and suppliers to deliver complete products, services and customer solutions to our customers.  Suppliers and service providers are generally required to keep confidential the information received on behalf of Sophia and generally may not use it for any purpose other than to carry out the services they are performing for us.  These service providers may change or we may contract with additional service providers to better accommodate our customers.

b.         Law Enforcement

Sophia may disclose personal, technical, or other information when required by law to do so or as set forth below.  Such circumstances may include criminal or civil subpoenas, court orders, or requests by law enforcement personnel.  Sophia will only disclose information when it has a good-faith belief that such disclosure is necessary to comply with applicable laws and regulations, to prevent fraud or illegal activities from being conducted via the Unit and the Site, to protect Sophia’s property interests (including intellectual property), or to prevent imminent harm.  Such disclosure may be made to law enforcement officers, government agencies, other companies, lawyers, or agents.

c.         Change of Ownership

Should Sophia or any related entities merge with or be acquired by another business entity or some or all of their respective assets acquired, including their customer information, Sophia may share your personal information with such entities.

CHILDREN UNDER AGE 13

The Unit and the Site are not intended for use by children under 13 years of age, and Sophia does not intentionally or knowingly collect personal information from anyone under 13.  No one under the age of 13 is allowed to transmit information via the Unit or the Site.  If you are under 13, please do not attempt to transmit any personal information to us.  Do not assist anyone under 13 to transmit any personal information to us.  If we learn that we have received such information, we will remove and delete that information.  If you believe that Sophia may have received any personal information about a child under the age of 13, please contact us at the address at the end of this policy specifically identifying the information in question.

CHILDREN BETWEEN THE AGES OF 13 AND 18

We recommend that anyone between the age of 13 and 18 get permission from his or her parents or guardians before transmitting any personal information to or through the Unit or the Site.

SECURITY

Sophia takes appropriate measures to ensure the security of your information. However, Sophia cannot guarantee that third parties will not overcome any such measures and gain access to your information for unauthorized purposes.  By using the Unit or the Site, you accept the risk that compromise of and unauthorized access to your information is possible.  To the fullest extent permitted by law, Sophia disclaims any warranty or guarantee that your information will be protected from misuse, appropriation, alteration, or loss, and you accept the risk of any potential resulting liability.

LINKS TO OTHER SITES

You may encounter links to third-party websites when using the Unit or the Site.  These links may have been placed on the Unit or the Site by Sophia, by an advertiser, through the use of a third-party application, or in some other manner.  Sophia makes no guarantees regarding the content, reliability, correctness, or safety of any third-party website accessed through links appearing on the Unit or the Site.  Sophia does not control the content of these sites and does not supervise links posted by advertisers or applications.  Such sites may have different privacy policies or no privacy policy.  If you access any such links, you do so at your own risk.

CONTACT INFORMATION

If you have any concerns or questions regarding this Privacy Policy, Sophia can be contacted via email at privacy@discoversophia.com, or by postal mail at the following address:

Sophia Search Limited
Northern Ireland Science Park
The Innovation Centre
Queen’s Road
Queen’s Island
Belfast, BT3 9DT
Northern Ireland

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