Privacy Policy
Effective Date: January 1, 2020
SBA Communications Corporation, including its subsidiaries and affiliates (collectively, "SBA," "we," or "us") is
committed to protecting your privacy and developing technology that gives you the most powerful and safe online
experience. This Privacy Policy (the "Privacy Policy") applies to the SBA Website and any other website that
links
to this Privacy Policy (the “Website” or “Site”). By using the SBA Website, you consent to the practices
described
in this statement. If you do not agree with the terms of this Privacy Policy, please refrain from using our
Site.
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Applicability
This Privacy Policy is a statement of how information about you is collected from the Website, used and potentially shared by SBA.
Specifically, this Privacy Policy will tell you:
- what Personal Information we collect on our Website;
- what are your choices as to your Personal Information;
- how we use your Personal Information and with whom we share it; and
- how we protect your Personal Information.
Personal Information is any information that directly and indirectly identifies an individual user or that could
be
reasonably linked to a particular person, computer, or device (“Personal Information”). This information
includes,
but is not limited to: (i) your name; (ii) mailing address; (iii) telephone number; (iv) financial account
information; (v) social security number; (vi) email address; and (vii) other, similar information.
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Changes
SBA reserves the right to amend this Privacy Policy at any time in its sole discretion. If we do, we will update
the
“effective date” at the top of this Privacy Policy and make sure to notify you about any material changes either
by
displaying a prominent notice on top of the SBA Website or emailing you directly. Changes, revisions or
deletions
with regard to this Privacy Policy shall be effective immediately upon their inclusion in, or deletion from,
this
Privacy Policy and the posting of the same in this Privacy Policy on the Website.
You are encouraged to revisit this Privacy Policy from time to time in order to review any changes that have been
made. Your continued access and use of the Website following the posting of any such changes shall
indicate your acceptance of the same.
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Purposes and Uses of Your Personal Information
We generally use your Personal Information for the following purposes:
- as required by law;
- as necessary for the performance of a contract with you, and our business partners in order to run our
Website;
- to handle contact and user support requests submitted via forms on our Website or email;
- to improve our services and the Website;
- to conduct marketing campaigns;
- to ensure security or our Website; and
- with your explicit and informed consent.
We will only use your Personal Information for the purposes for which it was originally collected. If we need to
use
your Personal Information for an unrelated purpose, we will notify you and we will explain the legal basis which
allows us to do so. Please note that we may process your Personal Information without your knowledge or consent
if
we believe that it is reasonably necessary to comply with applicable laws.
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Types of Personal Information Collected
We will only collect Personal Information about you that is adequate, relevant and limited to what is necessary.
SBA Account Setup. When you sign up for an account with us, we ask for and collect Personal
Information such as your name, valid email address, address, and phone number.
Website Forms. If you express an interest in receiving information about our services by using
any
of the forms on our Website, we will keep a record of our communications with you.
Communication Information. We keep your Personal Information associated with customer support
requests and inquiries to keep track who has handled your issue and whether and how it was resolved.
Automated Information. We automatically receive and record information from your browser about
devices you use to access our Website. This includes things like IP addresses, the type of browser and device
you
use, the webpage you visited before coming to our sites, and identifiers associated with your devices. We also
use
“cookies” and various other tracking technologies (e.g., cookies and beacons) to collect and store information
about
your use of our Website. We use these tools to ensure that you receive a personalized experience, and to keep
your
account safe. Please refer to the What Tracking Technologies We Use section of this Privacy Policy for more
information.
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Cookies and Other Tracking Technologies
We use common tracking technologies, such as log files, cookies, web beacons, and similar tools to automatically
collect information about you, which may contain Personal Information. This information is used to analyze how
our
Website is used, to guarantee security of our Website and to improve our services.
Log Files. Either directly, or through our hosting service provider, we may automatically
receive and record information from your Internet browser, including your IP address (the Internet address of
your
PC), your computer’s name, the type and version of your web browser, referrer addresses, where the computer is
routing from and other generally-accepted log information. We may also record page views (hit counts) and other
general statistical and tracking information that will be aggregated with information about other users in order
to
understand how our Website is being used, and for security and monitoring purposes.
Email Tracking. We may send emails that use a “click-through URL” linked to content on our
Website. When you click one of these URLs, you pass through our web server before arriving at a destination
webpage.
We track this click-through information to help determine interest in particular topics and measure the
effectiveness of our communications. If you prefer not to be tracked simply do not click text or graphic links
in
the email, or notify us in as set forth below (Changing or Removing Information; Opting Out).
Cookies. As mentioned above, SBA utilizes “cookies” to track and store information
about Website users. “Cookies” are alphanumeric
identifiers in the form of text files that are inserted and stored on your hard drive. Cookies track your
personal
preferences and activities. If you do not want cookies to be inserted into your hard drive, you can disable its
ability to accept and receive cookies through your web browser. However, keep in mind that if you disable your
hard
drive’s ability to accept and receive cookies, you may not be able to fully utilize all of the convenience and
additional features of the Website. SBA uses
cookies on its Website for the following
purposes:
to serve you better by remembering your user preferences; to improve our Website; to make our Website
function
properly; and to provide a secure browsing experience during your use of our Website.
We use the following types of cookies on our Website:
Strictly Necessary Cookies. These cookies are essential because they enable you to move around
our
Website and access its secure areas. Without these cookies, some functionalities on the Website will not work
properly. These cookies do not gather information about you for marketing purposes. This category of cookies is
essential for our Website to work and they cannot be disabled.
Functional Cookies. We use functional cookies to remember your choices so we can tailor our
Website
to provide you with enhanced features and personalized content. For example, these cookies can be used to
remember
your name or preferences on our Website. We do not use functional cookies to target you with online marketing.
While
these cookies can be disabled, this may result in less functionality during your use of our Website.
Performance or Analytic Cookies. These cookies collect anonymous passive information about how
you
use our Website, including webpages you visit, and links you click. We use the information collected by such
cookies
to improve and optimize our Website. We do not use these cookies to target you with online marketing. You can
disable these cookies.
Third-Party Cookies. These are cookies that are provided by third-party service providers and
belong
in one of the cookie categories described above. These third-party providers process your Personal Information
on
our behalf pursuant to our instructions and obligations consistent with this Privacy Policy.
Your Choices
Your browser may provide you with the option to refuse some or all browser cookies. You may also be able to
remove
cookies from your browser. You can exercise your preferences in relation to cookies served on our Site by taking
the
steps outlined below.
First-Party Cookies. You can use the browser with which you are viewing this Site to enable,
disable
or delete cookies. To do this, follow the instructions provided by your browser (usually located within the
“Help”,
“Tools” or “Edit” settings). Please note, if you set your browser to disable cookies, you may not be able to
access
secure areas of the Site. Also, if you disable cookies other parts of the Services may not work properly. You
can
find more information about how to change your browser cookie settings at http://www.allaboutcookies.org.
Third-Party Cookies. To opt-out of third-party advertising networks and similar entities that
use
advertising cookies go to http://www.aboutads.info/choices. Once
you
click the link you may choose to opt-out of such advertising from all participating advertising companies or
only
advertising provided by specific advertising entities. For more information about third-party advertising
networks
and similar entities that use these technologies, please see http://www.aboutads.info/consumers.
We do not control third parties’ collection or use of your information to serve interest-based advertising.
However,
these third parties may provide you with ways to choose not to have your information collected or used in this
way. In addition, most web browsers provide help pages relating to setting cookie preferences. More
information may be found for the following browsers here:
Do Not Track. Some Internet browsers, such as Internet Explorer, Firefox, and Safari,
include
the ability to transmit “Do Not Track” or “DNT” signals. Since uniform standards for “DNT" signals have not been
adopted, our Site does not currently process or respond to “DNT” signals.
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Sharing Personal Information with Third Parties
If we have collected Personal Information from you, we will not disclose your Personal Information to third
parties
without your express consent, except in the following circumstances:
Business Partners. We employ other companies to perform functions on our behalf, such as
maintaining the Website, collecting information, sending and responding to electronic mail and other functions
necessary to support SBA, the Website and the products and services that we offer. We will provide our business
partners with only that Personal Information necessary to perform their functions and instruct them not to use
your
information for any purpose inconsistent with this Privacy Policy. We require the companies we work with agree
contractually to comply with privacy laws and to maintain protections for Personal Information consistent with
this
Privacy Policy.
Questions of Harm. We may disclose your Personal Information on a case-by-case basis to
attorneys, private investigation organizations, or law enforcement agencies if we believe that you are: (i) in
risk
of harm from another; (ii) harming or interfering (or will harm or interfere) with others; or (iii) violating
(either intentionally or unintentionally) our Terms of Use or other legal obligations.
Within Our Corporate Organization. We may share your personal information
with our subsidiaries and affiliates in order to provide you with the Site or services and take actions based on
your request, as well as for the purpose of management and analysis. For example, we may share your
information with our subsidiaries and affiliated companies to administer our loyalty programs, process orders
and
requests, and expand and promote our Site and services.
Legal. We will reveal Personal Information about you to the extent we reasonably
believe
we are required to do so by law. If we receive legal process calling for the disclosure of your Personal
Information, we may attempt to notify you via the contact information you provided (if any) within a reasonable
time
before we respond to the request, unless such notification is not permitted. In addition, we may share your
Personal
Information with third parties as otherwise permitted by law in order, for example, to protect against fraud,
the
confidentiality or security of our business records or to comply with applicable legal requirements.
Transfer of Ownership. We shall be entitled to transfer Personal Information to a third
party
in connection with a sale or merger of a Website or a business unit. If we transfer your Personal Information,
we
will do so under this Privacy Policy, provided the acquiring third party has agreed to safeguard your Personal
Information with protections that in all material respects are the same as or more protective than those set out
in
this Privacy Policy.
Consent. We may disclose your personal information for any purpose with your consent.
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Changing or Removing Information; Opting Out
We give our users appropriate control over their Personal Information. You can contact us to change or update
discretionary information that you have previously submitted. See Contact Us section below for our contact
information.
If we send you bulletins, updates, surveys or other unsolicited communications that are marketing-related
materials,
we will provide you with the ability to decline – or “opt-out of” – receiving such communications. Instructions
for
opting-out will be provided if and when we determine to send you such a communication. Please understand that
you
will not be allowed to “opt-out of” formal notices concerning operation of this Website, and legal and other
related
notices concerning your relationship to the Site.
Finally, if you request, we will remove your name and all other Personal Information from our databases. Please
understand, however, that it may be impossible to remove this information completely, due to backups and records
of
deletions. In addition, please understand that, if you request deletion of your information, you will be unable
to
utilize associated features of the Website and any associated services. You may not remove de-identified,
anonymous,
or aggregate data from our databases.
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International Transfers
Your Personal Information may be stored and processed in any country where we have offices or servers or in which
we
engage service providers. Your Personal Information may be transferred to countries outside your country of
residence, including the United States, which may have different data protection and data processing laws than
those
in your country. Any such transfer shall take place only in accordance with and as permitted by the law of
your jurisdiction, but please be aware that the laws and practices relating to the protection of Personal
Information are likely to be different and in some cases may be weaker than those within your home jurisdiction.
Regardless, in all events, we shall apply the provisions of this Privacy Policy to your Personal Information
wherever it is located.
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Security of Your Personal Information
SBA utilizes commercially reasonable physical, administrative and technical safeguards to protect security of any
Personal Information submitted by you though our Website. One of such safeguards is HTTPS protocol that we use
to
ensure that your Personal Information is kept confidential.
Our security systems are structured to deter unauthorized access to Personal Information you provide to us.
Please
understand, though, that information processing activities can never be 100% secure. Due to the nature of
Internet
communications and evolving technologies, we cannot provide, and disclaim, assurance that the information you
provide us will remain free from loss, misuse, or alteration by third parties who, despite our efforts, obtain
unauthorized access.
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Retention
We will retain your Personal Information for as long as your account is active, or for the length of time needed
to
fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted
by
law. After retention periods expire, we delete your Personal Information or prevent any future use of it.
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Links to Third Party Sites
SBA Website may contain links to other websites. This Privacy Policy applies solely to our Website, and SBA makes no representations or
warranties about, nor is it responsible for, the privacy practices of other websites. When you enter a linked
website, SBA encourages you to read the privacy policy of that linked website, as its privacy policy may differ
substantially from that of the Website.
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Children’s Personal Information
We do not knowingly or intentionally collect Personal Information from minors. If you are under 18, you may use
our
Website only with your parent or guardian’s consent. Please contact us if you believe we have collected Personal
Information about a child without consent so we can take appropriate measures and delete it.
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California Privacy Rights
This section applies only to California residents. Pursuant to the California Consumer Privacy Act of 2018
(“CCPA”),
below is a summary of the “Personal Information” categories, as identified and defined by the CCPA (see
California
Civil Code section 1798.140 (o)), that we collect, the reason we collect your Personal Information, where we
obtain
the Personal Information, and the third parties with whom we may share your Personal Information.
We generally collect the following categories of Personal Information about your when you use our Site or
services:
- identifiers such as a name, address, unique personal identifier, email, phone number, your device’s IP
address,
software, and identification numbers associated with your devices;
- protected classifications, such as gender;
- commercial information such as records of products or services purchased, obtained, or considered by you;
- Internet or other electronic information regarding you browsing history, search history, the webpage visited
before you came to our Site, length of visit and number of page views, click-stream data, locale
preferences,
your mobile carrier, date and time stamps associated with transactions, and system configuration
information;
- audio recordings of your voice to the extent you call us, as permitted under applicable law;
- professional or employment-related information; and
- inferences about your preferences, characteristics, behavior and attitudes.
We generally do not collect protected classification information, such as gender, geolocation information,
biometric
information or education-related information. For more information about the Personal Information we collect and
how
we collect it, please refer to Sections 4 and 5, above.
We collect your Personal Information for the business purposes described in Section 3, above. The CCPA defines a
“business purpose” as the use of Personal Information for the business’s operational purposes, or other notified
purposes, provided the use of Personal Information is reasonably necessary and proportionate to achieve the
operational purpose for which the Personal Information was collected or another operational purpose that is
compatible with the context in which the Personal Information was collected.
The categories of third parties with whom we may share your Personal Information are listed in Section 6, above.
Privacy Rights
If you are a California resident, you have rights in relation to your Personal Information; however, your rights
are
subject to certain exceptions. For instance, we cannot disclose specific pieces of Personal Information if the
disclosure would create a substantial, articulable, and unreasonable risk to the security of the Personal
Information, your account with us or the security of our network systems.
- Right Against Discrimination - You have the right not to be discriminated against for
exercising any of the rights described in this section. We will not discriminate against you for exercising
your
right to know, delete or opt-out of sales.
- Right to Know - You have the right to request in writing: (i) a list of the categories of
Personal Information, such as name, address, email address, that a business has disclosed to third parties
during the immediately preceding calendar year for the third parties' direct marketing purposes, and (ii)
the
names and addresses of all such third parties. In addition, you have the right to request: (i) the
categories of
Personal Information we have collected about you, (ii) the categories of sources from which Personal
Information
is collected, (iii) the business or commercial purpose for the information collection, (iv) the categories
of
third parties with whom we have shared Personal Information, and (v) the specific pieces of Personal
Information
we hold about an individual. You have the right to request a copy of the specific Personal Information we
collected about you during the 12 months before your request.
- Right to Delete - You have the right to request us delete any Personal Information we have
collected from you or maintain about you, subject to certain exceptions.
To assert your right to know or your right to delete your Personal Information, please contact according to the
“Contact Us” section below. To verify your identity, we may ask you to verify Personal Information we already
have
on file for you. If we cannot verify your identity from the information we have on file, we may request
additional
information from you, which we will only use to verify your identity, and for security or fraud-prevention
purposes.
- Right to Opt-Out of Sales - You have a right to opt-out of any sales of your Personal
Information. We do not sell any Personal Information.
In addition, California Civil Code Section 1798.83 permits customers of SBA who are California residents to
request
certain information regarding our disclosure of Personal Information to third-parties for their direct marketing
purposes. To make such a request, please information@sbasite.com.
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Contact Us
We encourage you to provide us with feedback regarding this Privacy Policy. If you have questions, comments or
concerns regarding this Privacy Policy, please call us at 1.800.487.SITE or email us at information@sbasite.com.