PRIVACY POLICY

Effective Date: January 5, 2015 

Introduction

Welcome! You have arrived at www.sonavation.com, www.idkey.com and/or are otherwise interacting with our Service (defined below), which is owned and operated by Sonavation, Inc. (“Sonavation or “we,” “our” or “us”).

Sonavation respects the privacy rights of our online visitors and is committed to protecting the information collected about you.  To further this commitment, we have adopted this “Privacy Policy” to guide how we collect, store and use information that you provide to us.  This Privacy Policy governs your use of any online service location (e.g., web site or mobile app) that posts a link to this Privacy Policy (each a “Site”) as well as any interactive features, programs, widgets, or products that we own or control and that post a link to this Privacy Policy (collectively, the “Service”), regardless of how you access or use them, whether via personal computers, mobile devices or otherwise.

To the extent we provide you notice on our Service of different or additional privacy policies or practices (e.g., at the point of our collection), those additional terms shall govern such data collection and use.  Sonavation shall take reasonable steps to ensure that all Services covered by this Privacy Policy provide a link to this Privacy Policy.

In addition, please review the Service’s Terms of Service [LINK], which governs your use of the Service.  By using our Service, you consent to our Privacy Policy and Terms of Service and our collection, use and sharing of your information and data, and other activities, as described below. 

1.         What Information Does the Service Collect?

(a)           Information You Provide to Us

Personal Information and Demographic Information.  On the Service, we may ask you to provide us with certain categories of information such as: (1) personally identifiable information, which is information that identifies you personally, such as your first and last name, social security number, e-mail address, and home address (“Personal Information”); and (2) demographic information, such as information about your gender, income and communication preferences (“Demographic Information”).  We may collect this information through various forms and in various places on the Service, including account or device registration, contract us forms, or when you otherwise interact with the Service.  Generally, we will only collect Personal Information reasonably necessary to accomplish the purpose it is collected, and will retain it only as long as is reasonably necessary. To the extent we combine Demographic Information with your Personal Information we collect directly from you on the Service, we will treat the combined data as Personal Information under this Privacy Policy. 

(b)       Information Collected or Stored As You Access and Use the Service

In addition to any Personal Information or other information that you choose to submit to us via our Service, we and our third-party service providers may use a variety of technologies that automatically (or passively) store or collect certain information whenever you visit or interact with the Service (“Usage Information”).  We store and access Usage Information using a few technologies downloaded to your device. This happens whenever you interact with our Service. In our world, a “Device” may be your personal computer, browser, tablet, mobile phone, or Sonavation product.   This Usage Information may include: your IP address, UDID or other unique identifier (“Device Identifier”); your Device functionality (including browser, operating system, hardware, mobile network information); and the areas within our Service that you visit and your activities there, including remembering you and your preferences.

Tracking Technologies.  We may use various methods and technologies to automatically store or collect Usage Information (“Tracking Technologies”).  Tracking Technologies may set, change, alter or modify settings or configurations on your Device.

One of the ways we do this is through “cookies”. A cookie is a small files our Service gives your Device when it’s accessed. We use cookies to enable functionality, improve Service usage analytics, and market the Service. For example, a cookie allows us to keep you logged in during a session rather than asking for a password at every action. Another example is as a security measure to prevent fraudulent activity with your accounts. You can disable cookies on your Device, but parts of the Service may not be functional without them.

We and our vendors may also use tools like web beacons (“clear gifs”), scripts, and images to help manage site content and usage.

These technologies help us understand the performance and usefulness of content in the Service. We use these insights to improve the content, products or services offered through the Service.

Tracking Technologies used by our service providers are not covered by this policy. We don’t have control over them, but do screen to make sure they have acceptable policies before integrating.

TRACKING CONSENT

We get your consent to our storage and collection Tracking Technologies in a few ways:

  • Giving you transparent information in this Privacy Policy
  • Allowing you to choose to allow third parties access to your data
  • Giving you the opportunity to choose to disable cookies.

FYI: We are not required to get consent for Tracking Technology that’s strictly necessary to the Service. For example, using cookies as a way to improve security through fraud prevention.

“DO NOT TRACK”

Some third parties have ways (e.g. Browser do-not-track signals) for users to control how online services collect their information.  We don’t currently take any action based on these signals, however this may change in the future.

(c)        Information Third Parties Provide About You

We may, from time to time, supplement the information we collect directly from you on our Service with outside records from third parties for various purposes, including to verify your identity, to enhance our ability to serve you, to tailor our content to you and to offer you opportunities that may be of interest to you.  To the extent we combine information we receive from those sources with your Personal Information we collect on the Service, it will be treated as Personal Information and we will apply this Privacy Policy to such combined information, unless we have disclosed otherwise.

(d)       Interactions with Third-Party Services

Parts of the Service may include certain interactions with third-party websites or applications. This functionality may involve the third-party operator giving us certain information, including Personal Information. When you register with the Service for example, you may have an option to link your account to a third party account (e.g. Google) to help the registration, log in and transaction process, or otherwise. If we offer and you choose to use this functionality in our Service, the third-party may send your Personal Information to us. We will treat it as Personal Information under this Privacy Policy because we collect it as a result of you using our Service.

We may also provide third-party sites’ interfaces or links in the Service to help you send communications. For example, a share button for emailing links via the Service. These third parties may keep information used or provided in communications or other activities. These third parties’ practices are not subject to our Privacy Policy. Sonavation may not control or have access to your communications through these third parties.

When you use third party services, they are responsible for their practices. We can only vouch for our services and policies, and cannot be responsible for their practices. Be sure to review third-party policies before using their tools on our Service.

2.         How Do We Use the Information Collected?

Generally.  We may use your Personal Information, Demographic Information or Usage Information that we collect about you:  (1) to provide you with information or services or process transactions that you have requested or agreed to receive, including to send you electronic newsletters, or to provide you with special offers or promotional materials on behalf of us or third parties; (2) to enable you to participate in a variety of the Services’ features such as online entry sweepstakes, contests or other promotion, or our shopping-car functionality; (3) to process your registration with any of the Services, including verifying your information is active and valid; (4) to improve the Services or create new service offerings, to customize your experience on any of the Services, or to serve you specific content that is most relevant to you; (5) to contact you with regard to your use of any of the Services and, in our discretion, changes to the any of the Services  and/or any of the Services’ policies; (6) to register your product, including IDKEY; (7) to verify your identity; (8) to verify and authenticate transactions; (9) for internal business purposes; and (10) for purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy.

Contact Us.  When you contact us, we will use that information only for reasons connected with your request. Not all information submitted to the Service via a “contact us” form or other similar inquiry method may receive a response. 

3.         How and When Do We Share Information with Third Parties?

There are certain situations where we may share information we have collected about you with third parties. We do not share Personal Information collected through the Service with third parties for their direct marketing purposes. We may share non-Personal Information, such as aggregated user statistics, with third partiesWe may share non-Personal Information, such as aggregated user statistics and Usage Data, with third parties.

Sonavation may also disclose your information as follows:

(a)       When You Request Information From or Provide Information to Third Parties.  Our Service may present options to receive certain information or marketing from third parties. You may also have us send (or give access to) certain information to third parties. If you choose to do so your Personal Information and other information may be disclosed to those third parties. All information you disclose will be subject to the third-party privacy policies and practices.

(b)       Third Parties Providing Services on Our Behalf.  We may use third-party vendors to perform certain services on behalf of us or the Service, such as supplementing and confirming your identity, hosting the Service, designing and/or operating the Service’s features, tracking the Service’s activities and analytics, and enabling us to send you special offers or perform other administrative services.  We may provide these vendors with access to user information, including Device Identifiers and Personal Information, to carry out the services they are performing for you or for us.  Third-party analytics and other service providers may set and access their own Tracking Technologies on your Device and they may otherwise collect or have access to information about you, potentially including Personal Information, about you.  We are not responsible for those third party technologies or activities arising out of them.  However, some may offer you certain choices regarding their practices, and information we have been informed of regarding such choices is available at the end of this Privacy Policy.  We are not responsible for the effectiveness of or compliance with any third parties’ opt-out options.

(c)        To Deliver Social Content and Advertising.  We and others we work with (e.g., third party publishers, advertisers and advertising services providers) may use your Personal Information, Demographic Information and/or Usage Information we have collected in connection with the Service to target and deliver content and advertisements to you and other users, both on and off of our Service.  We may, from time to time, offer you options to manage this type of social sharing via your user settings, and we will, make reasonable good faith efforts to respect settings. 

(d)       To Protect the Rights of Sonavation and Others.  To the fullest extent permitted by applicable law, we may also disclose your information if we believe in good faith that doing so is necessary or appropriate to: (i) protect or defend the rights, safety or property of Sonavation or third parties (including through the enforcement of this Policy, our Terms of Service [LINK], and other applicable agreements and policies); or (ii) comply with legal and regulatory obligations (e.g., pursuant to law enforcement inquiries, subpoenas or court orders).

(e)       Affiliates and Business Transfer.  We may share your information, including your Device Identifiers and Personal Information, Demographic Information and Usage Information with our parent, subsidiaries and affiliates (“Affiliates”). We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the Service or applicable database; or (ii) in connection with a merger, consolidation, restructuring, bankruptcy, the sale of substantially all of our interests and/or assets or other corporate change, including, during the course of any due diligence process.

(f)        Sweepstakes, Contests and Promotions.  We may offer sweepstakes, contests, and other promotions (any, a “Promotion”) through the Service that may require registration.  By participating in a Promotion, you are agreeing to official rules that govern that Promotion, which may contain specific requirements of you, including, allowing the sponsor of the Promotion to use your name, voice and/or likeness in advertising or marketing associated with the Promotion.    

(g)       Your California Privacy Rights.  Under California law, California residents who have an established business relationship with Sonavation or one of its Affiliates may choose to opt out of Sonavation’s disclosure of personal information about them to third parties for direct marketing purposes.  Unless noted at the time of collection, our policy is not to disclose personal information collected online to a third party for direct marketing purposes without your approval.  If you choose to opt-out at any time after granting approval, please provide sufficient information for us to determine if this applies to you, attest to the fact that you are a California resident and provide a current California address for our response and email [privacy@sonavation.com ]or write to Sonavation at Sonavation, Inc. 3970 RCA Blvd. Suite 7003, Palm Beach Gardens, FL  33410, Attn: CA Privacy Rights. 

(h)       Your European Privacy Rights.  If you are a resident of Europe, including Switzerland, you may have the right to ask us not to process certain of your personal data (or provide it to third parties to process) for marketing purposes.  You can exercise your right, if applicable, to prevent such processing at any time by contacting us in the following ways:  Postal Mail: Sonavation, Inc. 3970 RCA Blvd. Suite 7003, Palm Beach Gardens, FL  33410, Attn: European Privacy Rights; By e-mail:  [privacy@sonavation.com.] 

4.         What About Information I Disclose Publicly Or To Others?

The Service may permit you to submit ideas, photographs, user profiles, writings, music, video, audio recordings, computer graphics, pictures, data, questions, comments, suggestions or other content, including Personal Information (collectively, “User Content”), such as on blogs and message boards.  Please think carefully before deciding what information you share, including Personal Information, in connection with your User Content.

5.         Do Third-Party Content, Links To Third-Party Sites, and/or Third-Party Apps Appear on the Service?

The Service may contain content that is supplied by a third party, and those third parties may collect Usage Information and your Device Identifier when pages from the Service are served to you.  In addition, when you are on the Service you may be directed to other services that are operated and controlled by third parties that we do not control.  We are not responsible for the data collection and privacy practices employed by any of these third parties or their services and they may be tracking you across multiple sites and may be sharing the results of that tracking with us and/or others.  For example, if you “click” on a link, the “click” may take you off the Service onto a different site.  These other sites may associate their Tracking Technologies with you, independently collect data about you, including Personal Information, and may or may not have their own published privacy policies.

We encourage you to note when you leave our Service and to review the third-party privacy policies of all third-party locations and exercise caution in connection with them.

6.         Are Ads Served On the Service?

The Service may use third parties such as network advertisers and ad exchanges to serve advertisements on the Service and may use third-party analytics and other service providers to evaluate and provide us and/or third parties with information about the use of the Service and viewing of ads and of our content.  Network advertisers are third parties that display advertisements, which may be based on your visits to the Service and other apps and sites you have visited.  Third-party ad serving enables us to target advertisements to you for products and services in which you might be interested.

Some may offer you certain choices regarding their practices, and information we have been informed of regarding such choices is available at the end of this Privacy Policy. While we may use a variety of companies to serve advertisements on the Service, you may wish to visit http://www.networkadvertising.org/optout_nonppii.asp, which provides information regarding this practice by Network Advertising Initiative (“NAI”) members, and your choices regarding having this information used by these companies, including the “opt-out” procedures of NAI members.  We are not responsible for effectiveness of, or compliance with, any third-parties’ opt-out options or programs.

7.         How Do I Change My Information and Communications Preferences?

We strive to keep your information accurate, but you are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of registration.  The Service may allow you to review, correct or update Personal Information you have provided through the Service’s registration forms or otherwise, and you may provide registration updates and changes by contacting us here. If so, we will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable (but we may retain prior information as business records).

With respect to our mobile and other applications (i.e., when we are the application publisher), you can prospectively stop all collection of information by the application by uninstalling the application.  You may use the standard uninstall process as may be available as part of your applicable Device or potentially via the appropriate application or app marketplace.

Please note that it is not always possible to completely remove or delete all of your information from our databases and that residual data may remain on backup media or for other reasons.  When you edit your Personal Information or change your preferences on the Service, information that you remove may persist internally for Sonavation’s administrative purposes.

If you have any questions about the Privacy Policy or practices described in it, you should contact us in the following ways: Postal Mail: Sonavation, Inc. 3970 RCA Blvd. Suite 7003, Palm Beach Gardens, FL  33410; By e-mail here.

8.         What About Transfer of Information to the United States?

Our Service is operated in the United States and intended for users located in the United States.  If you are located outside of the United States, please be aware that information we collect, including Personal Information, will be transferred to, and processed, stored and used in the United States.  The data protection laws in the United States may differ from those of the country in which you are located, and your Personal Information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States.  By using the Service or providing us with any information, you consent to the transfer to, and processing, usage, sharing and storage of your information, including Personal Information, in the United States as set forth in this Privacy Policy.

9.         What Should Parents Know About Children?

We understand the importance of protecting children’s privacy in the interactive world.  We are a general audience service and do not use the Service to knowingly collect personal information from children under the age of thirteen (13) that requires parental notice and consent under the Children’s Online Privacy Protection Act (“COPPA”) without such parental consent.  If you are a child under 13 years of age, you are not permitted to use the Service and should not send any information about yourself to us through the Service.

In the event that we become aware that we have collected personal information from any child, we will dispose of that information in accordance with COPPA and other applicable laws and regulations.  If you are a parent or guardian and you believe that your child under the age of 13 has provided us with personal information without COPPA-required consent, please contact us here.

10.       What About Security?

We endeavor to incorporate commercially reasonable safeguards to help protect and secure your Personal Information.  However, no data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information can be guaranteed to be 100% secure.

11.       What About Changes to the Privacy Policy?

We reserve the right to change this Privacy Policy at any time.  Any changes will be effective immediately upon the posting of the revised Privacy Policy and your use of our Service indicates your consent to the privacy policy posted at the time of use.  However, we will not use your previously collected Personal Information in a manner materially different than represented at the time it was collected without your consent.  If you have a subscription to a Service, material changes to the Privacy Policy will only become effective with respect to the aspect of that subscription Service at the end of the then current term unless you otherwise consent.  To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.

//End Privacy Policy//

The following third parties that collect information from you on or in connection with our Service have given us notice that you may obtain information on their policies and practices, and in some instances opt-out of certain of their activities, as follows:

Party

Service

For More Information

Use of Tracking Technologies

Privacy Choices

 

PLEASE NOTE:  We are not responsible for third-party policies or practices.  We try to keep this information current, and will add to and subtract from the chart above as appropriate, but it is provided as a courtesy and may not be current or accurate.  Please contact the applicable third parties regarding their privacy and data security policies and practices.