Privacy Notice – Sourcepoint Services

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Last updated: August 2025

Privacy Notice – Sourcepoint Services (Sourcepoint as Processor / Service Provider when providing the following services: Dialogue Consent Management Platform; and Dialogue Universal Consent and Preferences; and Diagnose Mobile Compliance Monitoring). 

This privacy notice (“Privacy Notice”) describes the processing of personal data by Sourcepoint Technologies, Inc. (“Sourcepoint”) on behalf of Sourcepoint’s business customers (“Customers”) in connection with the use of the services Dialogue Consent Management Platform, Dialogue Universal Consent and Preferences, and Diagnose Mobile Compliance Monitoring services (“Services”). This Privacy Notice applies only to Sourcepoint’s collection and processing of personal data from visitors to our Customers’ websites and mobile apps (“Customer Sites”).

This Notice does not cover personal data that we process when you visit sourcepoint.com or log into our Services through sourcepoint.com That information can be found in our Website Privacy Policy.

1. Sourcepoint is a data processor with regard to the collection and processing of personal data from Customer Sites in connection with the Services

Sourcepoint only processes personal data of visitors to the Customer Sites (“End User Data”) based on the instructions of our Customers and on their behalf in connection with the Services. The Customers are the responsible entities for the processing of End User Data. From a data protection perspective, our Customers are “data controllers” or “businesses” and Sourcepoint is a “data processor” or “service provider”, depending on applicable data protection laws.

2. Sourcepoint’s Services

Sourcepoint provides certain privacy technology to its Customers for their use on the Customer Sites, which require the processing of End User Data by Sourcepoint as a data processor or service provider. These services are:

  • Dialogue CMP – our consent management platform, more information here,
  • Dialogue Universal Consent and Preferences – our marketing preferences and legal transaction management solution, more information here,
  • Diagnose – our compliance monitoring solution (mobile apps), more information here,

3. Processing of End User Data in connection with the Services

Sourcepoint processes the following categories of End User Data of Sourcepoint Customers in connection with the Services:

 

Service
 Categories of personal data processed
Dialogue Consent Management Platform

For the purpose of providing the consent management solution: IP address, Unique User ID, the consent text file of the individual end user concerning the relevant Customer Sites, information on the device and browser and operating system of the individual end user, and if provided by the Customer to Sourcepoint, an AuthID. Sourcepoint transfers the Unique User ID and consent text file to the third-party providers selected by Sourcepoint Customers in order to communicate End User consent selections.

 

For the purpose of providing reports on the use of the consent management solution by the Customer on Customer Sites: Unique User ID, information on the Customer Site, region, device, browser, operating system, relevant time period for the reports (e.g. week, month or quarter) and aggregated statistical information on the use of the consent management solution (total number of page views, unique users, and views who received a message, statistics on the individual end users’ consent decisions which may include “Accept All”, “Legitimate interests only”, “Reject all”, “No choices made”, “Previous accept all”, and “Other choices”).
Dialogue Universal Consent and Preferences

For the purpose of providing the preferences solution: Unique User ID, email address; and the preferences record of the End User (marketing preferences or information about legal policies or terms viewed or acknowledged by the End User).
Diagnose Compliance Monitoring (mobile apps only; our Diagnose solution for web does not collect or process End User Data)

For the purpose of creating aggregated reports on the presence and activity of third-party vendors on a Customer’s mobile app: timestamp (monitored to the millisecond but rounded to the day upon collection; domain of vendors who are present in the Customer mobile app during an End User session; unique session ID (assigned to a session, not a user, i.e., not used for the same user over multiple sessions); user consent or opt-out decisions during such session; and IP address (monitored and mapped to a geographical region, after which only the geographical region, not the IP address is stored).

Sourcepoint is a registered CMP (ID 6) with the IAB Europe Transparency & Consent Framework with respect to Sourcepoint’s Dialogue services. Sourcepoint attests to Sourcepoint’s participation in the IAB Europe Transparency & Consent Framework and compliance with the Policies and Specifications of the Transparency & Consent Framework.

4. Questions and contact details

If you have any questions regarding the processing of End User Data, would like to obtain further information (such as the purpose or legal basis of processing) or would like to claim any data subject rights in connection with the Services, please contact the Customer which is the owner of the website which has linked you to this Privacy Notice or review the Customer’s own privacy policy.

If you would like to review further information on the processing of personal data in connection with Sourcepoint’s own website, please visit our website privacy policy.

If you have any questions about this Privacy Notice or Sourcepoint’s data processing practices, you can contact us using the contact details available at https://www.sourcepoint.com/contact, by writing to Sourcepoint Technologies, Inc., 228 Park Avenue South, #87903, New York, NY 10003 -1502, USA, or to our German office at Sourcepoint GmbH, Friedrichstrasse. 68, 10117, Berlin, Germany.

Nothing in this policy contradicts the following statement: Sourcepoint does not utilize data collected through the domains privacy-mgmt.com and summerhamster.com in a third-party context (including IP addresses and user identifiers) for any purpose not directly related to managing consent preferences, including the use and sharing of such data to enable tracking of particular users or devices by other services.

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