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Personal Data Privacy Policy

1. Introduction

1.1 We are committed to safeguarding the privacy of our service users.

1.2 This policy applies where we are acting as a data processor with respect to the personal data of our service users; in other words, where we process personal data on behalf of another institution.

1.3 In this policy, “we”, “us” and “our” refer to Signal Vine, Inc.

2. How we use your personal data

In this Section 2 we have set out:

(a) the general categories of personal data that we may process;

(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;

(c) the purposes for which we may process personal data; and

(d) the legal bases of the processing.

2.1 We may process your information about you as provided by an organization contracted to use Signal Vine (“profile data“). The profile data may include your name, address, mobile phone number, gender, date of birth, interests, and hobbies, educational details and employment details. The profile data may be processed for the purposes of determining who receives a message from our platform and what the content of that message will be. The legal basis for this processing is consent and our legitimate interests, namely the performance of a contract between that providing organization and us.

2.2 We may process data about your use or interaction with our services (“usage data“). The usage data may include mobile carrier and device type, as well as information about the timing, frequency, and pattern of your service use. Usage data is obtained from SMS/MMS service providers when transporting messages between you and customers of our service. This usage data may be processed for the purposes of analyzing the use of the website and services. The legal basis for this processing is for ensuring that messages sent on our platform are delivered.

2.3 We may process your personal data that are provided in the course of the use of our services (“service data“). The service data may include message content, message delivery date and/or time and other relevant message metadata. The source of the service data is the interaction between you and one of our contracted organizations using the platform. The service data may be processed for the purposes of providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is the proper administration of our platform and business.

2.4 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

2.5 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

2.6 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

2.7 Please do not supply any other person’s personal data to us, unless there is legal basis and we prompt you to do so.

3. Providing your personal data to others

3.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.

3.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

3.3 We may disclose your personal data to one or more of those selected third party suppliers of SMS, MMS or RCS delivery services for the purpose of transmitting messages between you and a contracted customer. Each such third party will act as a data controller in relation to the data that we supply to it.

3.4 In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

4. Transfers of your personal data

In this Section 4, we provide information about the circumstances in which your personal data may be transferred to other countries.

4.1 We do not transfer data outside of the United States, except in situations where the mobile phone that a message is being delivered to is either temporarily or permanently outside of the United States.  In this case, only the Usage and Service Data is transferred.

4.2 We have offices and facilities in the United States. Transfers of data within the United States will be protected by appropriate safeguards.

4.3 The hosting facilities for our website are situated in the United States. Transfers of data within the United States will be protected by appropriate safeguards.

4.4 Our messaging providers are situated in The United States. Transfers to and from these providers will be protected by appropriate safeguards.

5. Retaining and deleting personal data

This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

5.1 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

5.2 It is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:

(a) the period of retention of all personal data will be determined based on the length of the contract between Signal Vine and the organization that is using the service to message you.

(b) all personal data will be removed from Signal Vine’s active databases within 30 days of the termination of an organization’s contract.

(c) all personal data will be removed from Signal Vine’s backup databases within 45 days of the termination of an organization’s contract.

5.3 Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

6. Amendments

6.1 We may update this policy from time to time by publishing a new version on our website.

6.2 You should check this page occasionally to ensure you are in agreement with any changes to this policy.

7. Your rights

In this Section 7, we have summarized the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

7.1 Your principal rights under data protection law are:

(a) the right to access;

(b) the right to rectification;

(c) the right to erasure;

(d) the right to restrict processing;

(e) the right to object to processing;

(f) the right to data portability;

(g) the right to complain to a supervisory authority; and

(h) the right to withdraw consent.

7.2 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.  You can get a copy of your personal data by emailing privacy@signalvine.com.

7.3 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

7.4 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

7.5 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

7.6 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

7.7 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

7.8 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

7.9 To the extent that the legal basis for our processing of your personal data is:

(a) consent; or

(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,

and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

7.10 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection.

7.11 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

7.12 You may exercise any of your rights in relation to your personal data by written notice to us in addition to the other methods specified in this Section 7.

8. Our details

8.1 Signal Vine, Inc. is a corporation organized and existing under and by virtue of the provisions of the General Corporation Law of the State of Delaware.

8.2 Our principal place of business is at 811 N. Royal St, Alexandria, VA 22314.

8.3 You can contact us:

(a) by post, using the postal address given above;

(b) by email at info@signalvine.com

(c) by phone at (703) 480-0278