Privacy Policy

SOURCEPOINT TECHNOLOGIES, INC. PRIVACY AND COOKIE POLICY

 

    1. Introduction

This Privacy and Cookie Policy (“Policy”) applies to your use of:

The websites of Sourcepoint Technologies, Inc. (“we”, “us”, “our”) www.sourcepoint.com, www.altpayservices.com and all underlying content pages (“Websites”); and

our services, including AltPay, that enable you to pay a publisher for the right to access and engage with content on publisher’s owned or controlled websites, apps, and other digital media properties of a publisher using the ad block software you have installed and are using in connection with such access (collectively, “Services”).

This Policy describes what data we collect when you use the Websites or the Services, why we collect it and what we do with it. It also explains the choices that you have with regard to how we use this data.

The Policy applies in addition to the Terms of Service (“Terms”) applicable to your use of the Services. The Terms are available at http://altpayservices.com/terms.html.

We may amend this Policy from time to time by uploading a replacement Policy to the Websites. We will inform you in advance of substantial changes to this Policy by e-mail or pop-up on our Websites.

 

    2. Data Controller

Sourcepoint Technologies, Inc. is the data controller for any personal data provided to us or otherwise collected by us. 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://www.sourcepoint.com/contact.

 

    3. Use Of Your Personal Data

We will process your personal data in the following ways:

Types Of Personal DataWhy Processed (Purpose)
Data relating to your use of the Websites and/or the Services, obtained through your Internet browser, such as your (anonymized) IP address (which is a number that is automatically assigned to your computer when you use the Internet and can be used to identify the location from which your computer is connecting to the Internet) and usage data (e.g. what pages you view, where you click, what operating system you use).To analyse, administer, support, improve and develop your access to and use of the Websites and the Services.
Information on your use of the Websites that is tracked via cookies.See section 4 on cookies and the link provided there for details.
Information that you provide on our career page (Name, email, phone number, if you were referred by your current Sourcepoint employee) and personal data relating to your job application that you provide us with via the Websites or in a job interview, This may include your name, contact details, academic curriculum, professional qualifications, professional experience, date of birth, gender,  photos and your LinkedIn profile, if you wish to include it in your application. Further, we process personal data in connection with the decision of your application. To evaluate your job application, to contact you  regarding your current application and to include you in our talent pool for future vacancies.
Name, email address, job categories and preferred location To send you job alerts that match your skills.
Depending on the Website: name, email address, access code (optional for Altpay), subject of your inquiry and possible messages provided by you in our general contact forms.To respond to your inquiry. 
Name, address, company and the message provided by you. To provide a demo of our Services to you. 
    3.1 In connection with your use of the Websites

In connection with your use of the Websites, we process the following personal data:

    3.2 In connection with marketing

In connection with marketing and news on our products, we process the following personal data:

Types Of Personal DataWhy Processed (Purpose)
Your email address and country code (based on your IP address) provided by you.To send you our newsletter with information on our new products as well as the latest industry news & information that is relevant for your area.
Your full name, email address, your company’s name and possible messages provided by you to be contacted by us to learn more about our technologies, e.g. Altpay or the CMP solution.To contact you to provide you with information regarding our technologies that you would like to learn about.
    3.3 In connection with our Altpay product

In connection with our Altpay product, we process the following personal data:

Types Of Personal DataWhy Processed (Purpose)
Your email address provided by you at the time you access the Services as well as your order, your contact and invoicing details such as price, name and address.
  • To enable us to provide you with access to the Services and invoice you.
  • To contact you regarding your access to the Services or to notify you of important changes to the Services.
  • To provide you with a list of access codes and your payment history for your AltPay purchases.
Your email address provided by you when you suggest a new website for our Altpay technology.To assess the suggested website and contact you in this regard.
Your email address and related information to your use of the Altpay Service.To send you marketing emails about products or services of Sourcepoint similar to the Services you subscribed to (see marketing above).
    4. How We Use Cookies

The Websites use cookies and similar technologies. These cookies are used to make it easier for you to use the Websites during future visits, monitor and analyse traffic on our Websites, personalise the content of the Websites for you, provide you with interest-based advertising, measure ad and content performance, and create personalized content profiles. Please read more about the cookies we use on the Websites in our Cookie preferences, which is accessed in the 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 used on our Websites in our Cookie preference information by moving the switch next to the cookies to “on” or “off”. 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 hosting the Websites, 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
    5.2.1 Payment processing

Where you elect to access the Altpay Services, our payment services provider Braintree Payments, a part of PayPal, Inc. (“Braintree”), will process payment information (including card number, security code associated with your card, expiry date) that you provide to Braintree in order to enable payment processing services that you request from us. To enable payment with Braintree, we will inform Braintree about your name and the invoice details. We will receive from Braintree only general information about your payment (e.g. method used, some digits of your credit card), but not your complete payment information.

    5.2.2 Legal requirements

Moreover, in processing your personal data, we may disclose your personal data:

  • 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 Websites and/or the Services. 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 stadium of 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 endeavours to protect your personal data, we cannot guarantee the security of data transmitted to us using the Websites and/or the Services 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 Websites from the EU/EEA.

    7.1 Legitimate Interests

“Legitimate interests” means the interests of our company in conducting and managing our business. For example, we may have a legitimate interest in processing personal data of our customers for direct marketing purposes and to analyse how the Websites and the Services are being used by you.

When we process your personal data for our legitimate interests, we make sure to consider and balance any potential impact on you and your rights under data protection laws. Our legitimate business interests do not automatically override your interests – we will not use your personal data for activities where our interests are overridden by the impact on you, unless we have your consent or those activities are otherwise required or permitted to by law.

You have the right to object to processing that is based on our legitimate interests. For more information on your rights, please see “Your Rights” section below.

    7.2 Legal bases for processing and retention of personal data

In addition to the information provided in sec. 3 (“Use Of Your Personal Data”), please find details on the legal bases for processing your personal data and on retention periods for your personal data below:

    7.2.1 Use of Websites
PurposeLegal Basis For Processing Retention period
To analyse, administer, support, improve and develop your access to and use of the Websites and the Services.It is in our legitimate interests (Article 6 (1) (f) GDPR) to analyse how the Websites and the Services are being used by you as a user of our services. This helps us improve the Websites and our services. For more information about what we mean by legitimate interests, and when we may process your data for our legitimate interests, please see “Legitimate Interests” section below.We retain your data for this purpose for 26 months after you have visited our Websites, and, where applicable, as required or permitted by statutory law.
Purposes related to cookies as explained in section 4 on cookies and the link provided there.See section 4 on cookies and the link provided there for details.See section 4 on cookies and the link provided there for details.
To evaluate your job application and to contact you regarding your current application and to include you in our talent pool for future vacancies:Processing of this data to evaluate your job application is necessary in preparation of the performance of a contract between you and us in connection with a possible employment (Article 6 (1) (b) GDPR). We process your data  to include you in our talent pool for future vacancies is only with your consent (Article 6 (1) (a) GDPR). You have the right to opt-out at any time. For more information on your rights, please see “Your Rights” section belowIf your application is successful, we retain the personal data for the duration of your employment with us, and beyond based on statutory retention periods. If we do not employ you we will delete your personal data when accordant time limits for legal actions have lapsed, unless you consented to be included in our talent pool. If you wish to be included in our talent pool, we store your personal data for 7 years after you have consented. 
To send you job alerts that match your skillsIf you subscribe to receiving job alerts via email from us, the processing is based on your consent (Article 6 (1) (a) GDPR). You have the right to opt-out from the job alerts at any time. For more information on your rights, please see “Your Rights” section below or the “unsubscribe” function in our job alert emails.We will process this personal data until you opt out/withdraw your consent, and, where applicable, as required or permitted by statutory law.
To respond to your inquiry. Processing of this data is necessary for the performance of a (quasi-) contract between you and us in connection with your inquiry (Article 6 (1) (b) GDPR).We retain this personal data for the time required to respond to your request and, where applicable, as required or permitted by statutory law.
To provide a demo of our Services to you. Processing of this personal data is necessary for the performance of a (quasi-) contract between you and us to provide the demo to you (Article 6 (1) (b) GDPR).We retain this personal data for the time required to provide the demo of our Services to you and, where applicable, as required or permitted by statutory law.

 

    7.2.2 Marketing
PurposeLegal Basis For Processing Retention period
To send you our newsletter with information on our new products as well as the latest industry news & information that is relevant for your area.If you subscribe to receive news via email from us, the processing is based on your consent (Article 6 (1) (a) GDPR). If you are already a customer who has purchased products or services from us, we also process your email address to offer similar products or services to you that may be of interest to you. Such processing is based on our legitimate interest to conduct direct marketing (Article 6 (1) (f) GDPR). You may always object to such processing. You have the right to opt-out from marketing at any time. For more information on your rights, please see “Your Rights” section below or the “unsubscribe” function in our marketing emails.We will process this personal data for as long as you show interest in our services and newsletters or until you opt out/withdraw your consent, and, where applicable, as required or permitted by statutory law.
To contact you to provide you with information regarding our technologies that you would like to learn about.Processing of this personal data is necessary for the performance of a (quasi-) contract between you and us in connection with your inquiry (Article 6 (1) (b) GDPR). We process your personal data to handle your inquiry and to provide you with the required information.We retain this personal data for the time required to respond to your request and, where applicable, as required or permitted by statutory law.
    7.2.3 Altpay product
PurposeLegal Basis For Processing (for EU users)Retention period
  • To enable us to provide you with access to the Services and invoice you.
  • To contact you regarding your access to the Services or to notify you of important changes to the Services.
  • To provide you with a list of access codes and your payment history for your AltPay purchases.
Processing of your email address is necessary for the performance of the contract between you and us in connection with the Services (Article 6 (1) (b). If you do not provide us with your email address, we will not be able to provide you with access to the Services and to contact you regarding your access or changes to the Services.We retain this personal data as long as you use our Services and, where applicable, as required or permitted by statutory law.
To assess the suggested website and contact you in this regard.It is in our legitimate interests (Article 6 (1) (f) GDPR) to learn about websites that could benefit from our Altpay technology as this helps us expanding our business.We retain this personal data for as long as required to evaluate your suggestion and, where applicable, as required or permitted by statutory law.
To send you marketing emails about products or services of Sourcepoint similar to the Services you subscribed to (see marketing section above).If you are already a customer who has purchased products or services from us, we also process your email address to offer similar products or services to you that may be of interest to you Such processing is based on our legitimate interest to conduct direct marketing (Article 6 (1) (f) GDPR). You may always object to such processing.You have the right to opt-out from marketing at any time. For more information on your rights, please see “Your Rights” section below or the “unsubscribe” function in our marketing emails.We will process this personal data for as long as you show interest in our services and newsletters or until you opt out and, where applicable, as required or permitted by statutory law.
    7.3 Recipients outside the EU/EEA

Some of the above (sec. 5) listed recipients may be located outside the European Union/the European Economic Area. In such cases, we use EU standard contractual clauses, or recipients that are Binding Corporate Rules certified as a safeguard to establish an adequate data protection level in the third country. You may ask to receive a copy of the safeguard by contacting us as described in the “Questions And Contact Details” section below.

    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 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 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 processing (for more information about what we mean by legitimate interests, and when we may process your data for our legitimate interests, please see “Legitimate Interests” section above); or processing your personal data for direct marketing. 
  • 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.

You may exercise your rights by contacting us as indicated under “Questions And Contact Details” section below.

    7.5 EU representative

Data subjects in the EU may also contact our office in Germany in Friedrichstrasse 68, 10117 Berlin, Germany.

    8. 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://www.sourcepoint.com/contact, 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 7.5.

Last updated: November 2020

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