Effective date: January 20, 2023
All capitalized terms have their definition in Sova's Terms of Service, unless otherwise noted here.
|Section||What can you find there?|
|Who is responsible for the processing of your information||Subject to limited exceptions, Sova is the controller and entity responsible for the processing of your personal data in connection with the Website or Service.|
|What information Sova collects||Sova collects information directly from you for your registration, payment, transactions, and user profile. We also automatically collect from you your usage information, cookies, and device information, subject, where necessary, to your consent. Sova may also collect personal data from third parties. We only collect the minimum amount of personal data necessary from you, unless you choose to provide more.|
|How Sova uses your information||In this section, we describe the ways in which we use your information, including to provide you the Service, to communicate with you, for security and compliance purposes, and to improve our Website or Service or develop new features and functionality of our Website or Service. We also describe the legal basis upon which we process your information, where legally required.|
|How we share the information we collect||We may share your information with third parties under one of the following circumstances: with your consent, with our service providers, for security purposes, to comply with our legal obligations, or when there is a change of control or sale of corporate entities or business units. We do not sell your personal information and we do not host advertising on Sova.|
|Your choices regarding our processing of your personal data||We provide ways for you to access, alter, or delete your personal information.|
|How Sova secures your information||We take all measures reasonably necessary to protect the confidentiality, integrity, and availability of your personal data on Sova and to protect the resilience of our servers.|
|Communication preferences||We communicate with you by email. You can control the way we contact you in your account settings, or by contacting us.|
|Resolving complaints||In the unlikely event that we are unable to resolve a privacy concern quickly and thoroughly, we provide a path of dispute resolution.|
The data controller of your personal data is Individual Entrepreneur Kirill Shnurov.
In some cases, Sova is acting only on your behalf for the personal data we collect and process in connection with our Service (for example, for the personal data added to a knowledge base by the contributors to such knowledge base). In such cases, Sova will only process the data in order to provide the Service requested by you.
The personal data we collect depends on how you interact with us, the services you use, and the choices you make. We collect information about you from different sources and in various ways when you use our Service, including information you provide directly, information collected automatically, third-party data sources, and data we infer or generate from other data.
We collect personal data you provide to us. For example:
We collect information such as your first and last name, email address, and password during account creation.
If you make a purchase or other financial transaction, we collect credit card numbers, financial account information, and other payment details.
We collect any photographs, documents, or other files you upload to our Service; and if you send us email messages or other communications, we collect and retain those communications. For example, you may choose to give us more information for your Account profile, such as your full name, an avatar which may include a photograph, your biography, your location, your company, and a URL to a third-party website. Please note that your profile information may be visible to other Users of our Service.
When you visit or use our Service, we collect some information automatically. For example:
If you have a paid Account with us, or make a purchase or sale using our Service, we automatically collect certain information about your transactions on the Service, such as your full name, address, region, state, country, zip code, the date, time, and amount charged.
If you're accessing or using our Service, we may automatically collect information about how you use the Service, such as the pages you view, the referring site, your IP address and information about your device, session information, the date and time of each request, information contained in or relating to your contributions to individual knowledge bases, and telemetry data (i.e., information about how a specific feature or service is performing) regarding your use of other features and functionality of the Service.
As further described below, we automatically collect information from cookies (such as cookie ID and settings) in connection with our Service.
We may collect information about your device, such as its IP address, browser or client application information, language preference, operating system and application version, device type and ID, and device model and manufacturer.
In connection with certain features and depending on the functionality of the Service, we collect geolocation information such as through IP addresses or the location information you choose to provide in your Account profile.
We infer new information from other data we collect, including using automated means to generate information about your likely preferences or other characteristics (“inferences”). For example, we infer your general geographic location (such as city, state, and country) based on your IP address.
Other companies with whom you choose to engage. Sova may collect personal data about you from third parties. For example, this may happen if you sign up for training or to receive information about Sova from one of our vendors, partners, or affiliates. Sova does not purchase personal data from third-party data brokers.
Service Providers. We may also receive information from processors or service providers who process the data on our behalf, such as our payment processor who process payment and billing information in connection with our Service.
Co-branding/marketing partners. We may receive information from partners with which we offer co-branded services or engage in joint marketing activities.
Publicly available sources. We may also obtain information from publicly available sources.
When you are asked to provide personal data, you may decline. And you may use web browser or operating system controls to prevent certain types of automatic data collection. But if you choose not to provide or allow information that is necessary for certain services or features, those services or features may not be available or fully functional.
We may use your information to provide, administer, analyze, manage, and operate our Service. For example, we use your information for the following purposes:
We combine data we collect from different sources for these purposes and to give you a more seamless, consistent, and personalized experience.
We share personal data as described below, including with your consent or as necessary to complete your transactions or provide the services you have requested or authorized. In addition, we may share each of the categories of your personal data described above with the types of third parties described below for the following business purposes:
Your name will be displayed in pages changes history when you contribute to knowledge bases. In a public knowledge base changes history may be visible to anyone, that depends on a specific knowledge base permissions.
We share your personal data with third parties when you tell us to do so. Additionally, you may direct us through your actions on Sova to share your personal data.
We share your personal data with service providers who process the information on our behalf to provide or improve our Service. For example, our service providers may perform payment processing, customer support ticketing, network data transmission, web analytics, marketing operations, security, and other similar services. While Sova processes all personal data in the EU, our service providers may process data outside of the European Union or the United States. Such processing by service providers will be in compliance with applicable law including any relevant transfer mechanism.
We enable access to personal data across our subsidiaries, affiliates, and related companies, for example, where we share common data systems, when affiliates provide services on our behalf, or where access is needed to operate and provide the Service.
We will disclose personal data if we believe it is necessary to:
Sova may disclose personal data or other information we collect about you to law enforcement or other governmental agencies if required in response to a valid legal process.
Please note that some of the features on our Service include integrations, references, or links to services provided by third parties whose privacy practices differ from ours. If you provide personal data to any of those third parties, or allow us to share personal data with them, that data is governed by their privacy policies.
Finally, we may share de-identified information in accordance with applicable law.
We do not sell your personal data for monetary or other consideration as defined under California and Nevada state laws.
We provide choices about the personal data we collect about you. The choices you make will not apply to any personal data associated with an Organization under your Account.
Access, correction, and deletion. If you're a Sova user, you may access, update, alter, or delete your basic user profile information by editing your user profile. You can control the information we collect about you by limiting what information is in your profile, by keeping your information current, or by changing your cookie preferences.
If Sova processes personal data other than your profile information, such as information about you Sova receives from third parties, then you may, subject to applicable law, access, update, alter, delete, object to or restrict the processing of your personal data by contacting us.
We use your email address to communicate with you. For example, if you contact our Support team with a request, we respond to you via email.
Sova will send notification emails, for example, about changes in a knowledge bases you have access to, new features, requests for feedback, important policy changes, or to offer customer support. We may also send marketing emails, based on your choices and in accordance with applicable laws and regulations. There's an “unsubscribe” link located at the bottom of each of the marketing emails we send you.
Please note that you cannot opt out of receiving important communications from us, such as emails from our Support team or system emails.
If the processing of personal data about you is subject to European Union data protection law, you have certain rights with respect to that data:
You can request access to, and rectification or erasure of, personal data;
If any automated processing of personal data is based on your consent or a contract with you, you have a right to transfer or receive a copy of the personal data in a usable and portable format;
If the processing of personal data is based on your consent, you can withdraw consent at any time for future processing;
You can to object to, or obtain a restriction of, the processing of personal data under certain circumstances; and
For residents of France, you can send us specific instructions regarding the use of your data after your death.
To make such requests, please use the contact information at the bottom of this policy. When we are processing data on behalf of another party (i.e., where Sova is acting as a data processor) you should direct your request to that party. You also have the right to lodge a complaint with a supervisory authority, but we encourage you to first contact us with any questions or concerns.
We rely on different lawful bases for collecting and processing personal data about you, for example, with your consent and/or as necessary to provide the services you use, operate our business, meet our contractual and legal obligations, protect the security of our systems and our customers, or fulfill other legitimate interests.
For Marketing Pages, we may also use non-essential cookies to (i) gather information about users’ interests and online activities to personalize their experiences, including by making the ads, content, recommendations, and marketing seen or received more relevant and (ii) serve and measure the effectiveness of targeted advertising and other marketing efforts. If you disable the non-essential cookies on the Marketing Pages, the ads, content, and marketing you see may be less relevant.
Our emails to users may contain a pixel tag, which is a small, clear image that can tell us whether or not you have opened an email and what your IP address is. We use this pixel tag to make our email communications more effective and to make sure we are not sending you unwanted email.
The length of time a cookie will stay on your browser or device depends on whether it is a “persistent” or “session” cookie. Session cookies will only stay on your device until you stop browsing. Persistent cookies stay until they expire or are deleted. The expiration time or retention period applicable to persistent cookies depends on the purpose of the cookie collection and tool used. You may be able to delete cookie data as described here.
Cookies are small text files stored by your browser on your device. A cookie can later be read when your browser connects to a web server in the same domain that placed the cookie. The text in a cookie contains a string of numbers and letters that may uniquely identify your device and can contain other information as well. This allows the web server to recognize your browser over time, each time it connects to that web server.
Web beacons are electronic images (also called “single-pixel” or “clear GIFs”) that are contained within a website or email. When your browser opens a webpage or email that contains a web beacon, it automatically connects to the web server that hosts the image (typically operated by a third party). This allows that web server to log information about your device and to set and read its own cookies. In the same way, third-party content on our websites (such as embedded videos, plug-ins, or ads) results in your browser connecting to the third-party web server that hosts that content.
We may also use so-called “flash cookies” (also known as “Local Shared Objects” or “LSOs”) to collect and store information about your use of our Services. Flash cookies are commonly used for advertisements and videos.
We and/or our partners also share the information we collect or infer with third parties for these purposes.
The table below provides additional information about how we use different types of cookies:
|Required Cookies||Sova uses required cookies to perform essential website functions and to provide the services. For example, cookies are used to log you in, save your language preferences, provide a shopping cart experience, improve performance, route traffic between web servers, detect the size of your screen, determine page load times, improve user experience, and for audience measurement. These cookies are necessary for our websites to work.|
|Analytics||We allow third parties to use analytics cookies to understand how you use our websites so we can make them better. For example, cookies are used to gather information about the pages you visit and how many clicks you need to accomplish a task. We also use some analytics cookies to provide personalized advertising.|
|Social Media||Sova and third parties use social media cookies to show you ads and content based on your social media profiles and activity on Sova’s websites. This ensures that the ads and content you see on our websites and on social media will better reflect your interests. This also enables third parties to develop and improve their products, which they may use on websites that are not owned or operated by Sova.|
|Advertising||In addition, Sova and third parties use advertising cookies to show you new ads based on ads you've already seen. Cookies also track which ads you click or purchases you make after clicking an ad. This is done both for payment purposes and to show you ads that are more relevant to you. For example, cookies are used to detect when you click an ad and to show you ads based on your social media interests and website browsing history.|
You have several options to disable non-essential cookies:
Specifically on Sova Marketing Pages
Any Sova page that serves non-essential cookies will have a link in the page’s footer to cookie settings. You can express your preferences at any time by clicking on that linking and updating your settings.
Some users will also be able to manage non-essential cookies via a cookie consent banner, including the options to accept, manage, and reject all non-essential cookies.
Generally for all websites
You can control the cookies you encounter on the web using a variety of widely-available tools. For example:
These choices are specific to the browser you are using. If you access our Services from other devices or browsers, take these actions from those systems to ensure your choices apply to the data collected when you use those systems.
We retain personal data for as long as necessary to provide the services and fulfill the transactions you have requested, comply with our legal obligations, resolve disputes, enforce our agreements, and other legitimate and lawful business purposes. Because these needs can vary for different data types in the context of different services, actual retention periods can vary significantly based on criteria such as user expectations or consent, the sensitivity of the data, the availability of automated controls that enable users to delete data, and our legal or contractual obligations. For example, we may retain your personal data for longer periods, where necessary, subject to applicable law, for security purposes.
Sova takes reasonable measures necessary to protect your personal data from unauthorized access, alteration, or destruction; maintain data accuracy; and help ensure the appropriate use of your personal data. To help us protect personal data, we request that you use a strong password and never share your password with anyone or use the same password with other sites or accounts.
In addition, if your account has private knowledge bases, you control the access to that Content. Sova personnel does not access private knowledge base content except for
Sova processes personal data both inside and outside of the United States and relies on legal mechanisms such as Standard Contractual Clauses to lawfully transfer data from the European Economic Area, the United Kingdom, and Switzerland to the United States. You may request a copy of the Standard Contractual Clauses using the contact details provided in the section entitled “Contacting Sova” below.
If you have concerns about the way Sova is handling your personal data, please let us know immediately. We want to help. You may email us directly at (privacy [at] sova [dot] wiki) with the subject line "Privacy Concerns." We will respond promptly — within 45 days at the latest.
In the unlikely event that a dispute arises between you and Sova regarding our handling of your User Personal Information, we will do our best to resolve it. Additionally, if you are a resident of an EU member state, you have the right to file a complaint with your local supervisory authority, and you might have more options.
The California Consumer Privacy Act of 2018, (Cal. Civ. Code §1798.100 et seq., as amended, “CCPA”) gives California residents rights and control over their personal information. Individual Entrepreneur Kirill Shnurov ("Sova", "we") provides this statement to those residents ("you") in accordance with requirements under the CCPA to make certain disclosures about the collection and processing of their personal information. This is Sova’s California-specific description of consumers’ privacy rights under the CCPA.
|Category of personal information collected in last 12 months||Category of sources from which the personal information has been collected|
|Identifiers (such as real name, alias, postal address, unique personal identifier, online identifier Internet Protocol address, email address, account name, or other similar identifiers)||Information consumer provides directly or automatically through their interaction with our Service and/or Website or Sova's vendors, partners, or affiliates|
|Personal information described in Cal. Civ. Code §1798.80 (e) such as name, address, credit card or debit card number)||Information consumer may choose to provide directly, through service providers|
|Characteristics of protected classifications under California or federal law (such as gender)||Information consumer may choose to provide directly|
|Commercial information (such as about products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)||Information consumer provides directly or automatically through their interaction with our Services|
|Geolocation data (such as any information collected after giving users the opportunity to opt-in to location-based services, which rely upon a device’s precise location services. )||Information consumer provides automatically through their interaction with our Services|
|Audio, electronic, visual, or similar information such as content and files uploaded to the Service.||Information consumer may choose to provide directly|
|Professional or employment information||Information consumer may choose to provide directly|
|Inferences drawn from any of the information identified in this table to create a profile about a consumer reflecting the consumer’s preferences||Information consumer provides directly or automatically through their interaction with our Services|
Under the CCPA, a business that sells California residents' personal information to others: 1) must give notice to California residents before selling their personal information to others; and 2) must provide the right to opt out of the sale of their personal information.
Sova does not sell personal information, including personal information of anyone under 16 years old.
The CCPA provides California residents with certain rights related to their personal information. To submit a request based on these rights, please contact us via (privacy [at] sova [dot] wiki).
When receiving a request, we will verify that the individual making the request is the resident to whom the personal information subject to the request pertains. California residents may exercise their rights themselves or may use an authorized agent, designated in writing or through a power of attorney, to make requests on their behalf. If you use an authorized agent to submit a request, we may require that you provide us additional information demonstrating that the agent is acting on your behalf, and we may need you to verify your identity directly with us.
With respect to your personal information, California residents may exercise the rights described below.
You also have a right to request that we delete personal information under certain circumstances, subject to a number of exceptions.
You have a right to opt-out from future “sales” of personal information. Note that we do not “sell” personal information as defined by the CCPA and have not done so in the past 12 months.
You have a right to not be discriminated against for exercising your CCPA rights. We will not discriminate against you for exercising your CCPA rights.
You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights under the CCPA. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us.
Further, to provide or delete specific pieces of personal information we will need to verify your identity to the degree of certainty required by law. We will verify your request by asking you to submit the request from the email address associated with your account or requiring you to provide information necessary to verify your account.
Finally, you have a right to receive notice of our practices at or before collection of personal information.
Additionally, under California Civil Code section 1798.83, also known as the “Shine the Light” law, California residents who have provided personal information to a business with which the individual has established a business relationship for personal, family, or household purposes (“California Customers”) may request information about whether the business has disclosed personal information to any third parties for the third parties’ direct marketing purposes. Please be aware that we do not disclose personal information to any third parties for their direct marketing purposes as defined by this law.
California Customers may request further information about our compliance with this law by emailing (privacy [at] sova [dot] wiki). Please note that businesses are required to respond to one request per California Customer each year and may not be required to respond to requests made by means other than through the designated email address.
California residents under the age of 18 who are registered users of online sites, services, or applications have a right under California Business and Professions Code Section 22581 to remove, or request and obtain removal of, content or information they have publicly posted. To remove content or information you have publicly posted, please submit a Private Information Removal request. Alternatively, to request that we remove such content or information, please send a detailed description of the specific content or information you wish to have removed to Sova support. Please be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.
If you have any questions about our privacy practices with respect to California residents, please contact us via (privacy [at] sova [dot] wiki).