The Signal Vine Enterprise Messaging Platform is used by organizations of all sizes to deploy and operate applications throughout the world. The Signal Vine platform allows our Customers to focus on designing and implementing high-impact projects and/or research studies, while Signal Vine provides communication infrastructure for deploying custom messaging algorithms. Signal Vine applies industry standard security practices and manages platform security so customers can focus on achieving their goals. Our platform is designed to protect Customers from threats by applying industry-standard security controls at every layer from physical to application and by isolating customer applications and data.
Signal Vine provides a reliable and secure solution for implementing text- message based interventions. The Customer accesses the Signal Vine Enterprise Messaging Platform (the `SMS Platform`) through a secure web portal, where they can design the texting intervention and track participant progress. The web application is hosted on a separate, secure application server. All servers can only be accessed using key-based authentication (a 2048-bit RSA key pair) and we employ access control policies to secure appropriate access and ensure that protected information and all data are protected. Signal Vine employs highly restrictive network access and a rigorous data backup protocol.
DATA CONFIDENTIALITY AND RETENTION
During the course of operating Service, Signal Vine collects and stores customer information that falls into the following classes: SMS logs, debugging logs, and message recipient data. Signal Vine protects these forms of customer data by maintaining strict isolation between the production environment and the development environments. Security policies are applied to ensure access to customer data is restricted to employees with a legitimate business need. Signal Vine performs regular backups of customer data and all backups are encrypted at rest using strong industry encryption techniques. Data generated by Customer in each program license is retained and remains available for access by Customer during the term of the license through the secure web portal. Upon termination of the license, Customer can access the data for 30 days, after which data will no longer be available to Customer. Upon requests to remove customer data, we can take action to remove the data on the live databases and can eventually phase out the data from our backups, subject to our company data retention policies.
When Signal Vine utilizes third-parties to deliver its services, customer data is subject to the security policies of these providers. Signal Vine operates its services in Amazon Web Services, a cloud-based infrastructure provider that provides its own security, availability, reliability, redundancy, and performance commitments. Text messaging capability is provided through Twilio, a cloud communications provider. Text messages sent and received through the Signal Vine system are maintained in Signal Vine’s account at Twilio as SMS logs and are subject to Twilio’s operating procedures, including its security practices of encryption and backup. For details, see Twilio’s and Amazon Web Service’s latest security policies, terms of service, and privacy policies. We will provide Customers with a copy of “Amazon Web Service: Overview of Security Processes” and Twilio’s “Security White Paper” upon request. We reserve the right to add and/or substitute third-party providers, in our sole discretion.
We may update this Security Overview over time. When we do, we will also revise the ‘last modified’ date at the bottom of this document. For material changes to this data security policy, we will notify you by placing a notice on the login page(s) of the Signal Vine Enterprise Messaging Platform or the home page of Signal Vine, or by sending you a notification directly.
Last modified: January 2017
WHAT TYPES OF PERSONAL INFORMATION DOES SIGNAL VINE GATHER?
We will use your information to communicate with you relating to Signal Vine and deliver the Service provided by Signal Vine. When you send email or other communications to us, we may retain those communications in order to process your inquiries, respond to your requests, and improve our services.
We collect information from you when you use the Site, when you subscribe to any of our newsletters or email alerts, register for the blog, sign up at a conference, fill out a form, upload information, or otherwise supply information
We may also automatically collect information regarding your interaction with, and use of, the Site. We may use a variety of methods to collect this information, including, but not limited to, cookies, pixel tags, Web beacons, embedded Web links and other commonly used information gathering tools (‘Automatic Data Collection Tools’). These Automatic Data Collection Tools collect certain standard information that your browser sends to us such as your browser type and language, access times, IP address, user-agent string and clickstream behavior.
Information may be collected by us or by our vendors who provide internet hosting for the Site and/or SMS transmission facilitation. We may combine information you give us with other information from Signal Vine sources, transactions and communications. We may also combine that information with data that is publicly available and data from third parties.
You will be solely responsible for maintaining the confidentiality and security of your account and password and for all activities that occur on or through your account, and you agree to immediately notify Signal Vine of any security breach of your account.
HOW DOES SIGNAL VINE USE PERSONAL INFORMATION IT RECEIVES FROM ME?
We use personal information to enable the Service provided through Signal Vine and as described in this privacy statement. We do not use or disclose your personal information except as described in this privacy statement. In support of these uses, we may use personal information to: allow you to participate in the Service provided by Signal Vine; to deliver the Service, which may require us to share some information with a third party or contractor we use to deliver the Service; and to provide you with important information about Signal Vine, including critical updates and notifications.
Signal Vine may use your personal information to:
Enable Your Use of the Site and Provide Assistance. We may use your information to communicate with you regarding the Service, your account information or other customer service matters; to respond to your questions and instructions; and to enhance, customize, and personalize your experiences and communications with us.
Operate, Improve and Analyze. We may use your information to operate, provide, improve and maintain the Service, including analyzing user behavior and trends; to send you administrative messages and other information about Signal Vine; to investigate or take action regarding violations or suspected violations of law or our terms; and/or to maintain the integrity of our network and address security issues.
Market and Promote. We may use your information to communicate with you about the Service and other products and services; administer surveys or other features; and display relevant marketing to you.
We may also access and/or disclose personal information if we believe such action is necessary to: (a) comply with the law or legal process served on us; (b) protect and defend our rights or property (including the enforcement of our agreements); or (c) act in urgent circumstances to protect the personal safety and welfare of Signal Vine users or members of the public. Personal information collected by Signal Vine is stored and processed in the United States, unless a customer is located in Canada, in which case personal information collected by Signal Vine may be stored and processed in Canada upon request.
Information collected from any source may be combined to improve the Service and enable more targeted, tailored communications. It may also be aggregated and made available without identifying you for research and analysis purposes, to ascertain trends, products, security/privacy patterns and research, internal record keeping and reporting, measuring and reporting learning, performance and other statistical information concerning any aspect of the Service and the Site.
WITH WHOM DOES SIGNAL VINE SHARE THE PERSONAL INFORMATION IT RECEIVES?
Information about our customers is an important part of our business, and we are committed to protecting the security of your personal information. We share customer information only as described below.
We may provide your information to our subsidiaries and affiliates (the ‘Signal Vine Companies’). Unless not permitted by applicable law, all companies within the Signal Vine Companies share information collected through the Site and may contact you directly.
We employ other companies (including our affiliates), including third party vendors, and individuals to perform functions on our behalf. Signal Vine works with support companies who assist with the administration of the Site, including, but not limited to, hosting the Site on their servers. These companies may have access to personal information needed to perform their functions. We only employ service companies that implement and maintain reasonable security measures to safeguard the confidentiality, security, and integrity of your personal information.
Other than as described above, you will receive notice when information about you might go to third parties and you will have an opportunity to choose not to share the information. We will not share your personal information for this purpose without your prior consent.
DATA RETENTION AND OPT-OUT
Information security is important to Signal Vine. We have established appropriate physical, electronic and managerial safeguards to protect the information we collect from you or about you. These safeguards are regularly reviewed to protect against unauthorized access, disclosure and improper use of your information, and to maintain the accuracy and integrity of that data. We use a variety of security measures, including encryption and authentication tools, to help protect your information. However, like other companies, Signal Vine cannot guarantee 100% the security or confidentiality of the information you provide to us. Consequently, while we endeavor to safeguard your Personal Information against unauthorized access and disclosure, we do not warrant or guarantee the absolute security of any Personal Information you transmit to, from or through the Site. In the event that we become aware of a security breach involving your Personal Information stored by or for us, we may notify you by posting such information to the Site or via email, to the extent available in connection with the Services. Please see our Security Overview for additional information regarding security.
Please note that some of the content we deliver to or receive from you through the Service, specifically that of email and text message, is unencrypted. And so, transmissions may be unknowingly and/or unintentionally intercepted by third parties. We do not maintain or have access to your device, phone, e- mail server, or networks outside of our domain and control; therefore, we bear no liability or responsibility for the security or control of content, email, text message, or otherwise, once delivered.
THIRD PARTY PRIVACY POLICIES
INTERNATIONAL USERS; STATE RESTRICTIONS
Notice to California residents about your California privacy rights: In addition to the other rights described in this policy, if you are a customer residing in California, you have the right to request information regarding the third parties with whom Signal Vine has shared customer personal information for direct marketing purposes during the past year. You have the right to submit a request to Signal Vine at its designated address and receive the following information within 30 days of its receipt of that request: (1) the types of personal information disclosed to third parties during the immediately preceding calendar year, (2) the names and addresses of third parties that received the personal information, and (3) if the nature of a third party’s business cannot be reasonably determined from the third party’s name, examples of its products or services. You are entitled to receive a copy of this information in a standardized format. Information provided will not be specific to you individually. All such requests must be in writing and sent to firstname.lastname@example.org.
Applicability to Children
Signal Vine, Inc. takes the privacy of children seriously. The Sites are not directed at children, we do not knowingly collect personal information from children under the age of 13 through the Site and we request that children under the age of 13 not download the Site or submit any personal information through the Site.
If we are advised in writing that we have inadvertently received or collected personal information from a child under 13 years of age without parental permission, we will remove such information from our database.
CHANGES TO POLICIES
Last Modified: January 2017
Signal Vine works with support companies who assist with the administration of the Site, including, but not limited to, hosting the Site on their servers. These companies may have access to personal information needed to perform their functions. We only employ service companies that implement and maintain reasonable security measures to safeguard the confidentiality, security, and integrity of your personal information.
Description of Service
THE SIGNAL VINE ENTERPRISE MESSAGING PLATFORM
The Signal Vine Enterprise Messaging Platform (the ‘SMS Platform’) is a platform used by organizations of all sizes to deploy and operate applications throughout the world. Our platform allows our customers to focus on designing and implementing high-impact projects or research studies while Signal Vine provides communication infrastructure for deploying custom messaging algorithms.
Your project will be launched at a custom site with a URL and login credentials that we will provide. The project site and all functionality will be maintained for the duration of your subscription or license to the SMS Platform. It is your responsibility to maintain the security of your login credentials. Security of your project site is very important. Please take appropriate precautions to protect your project and credentials, such as:
- logging out of the project site anytime you leave your computer after a session
- not writing down your username or password
Broadly, the project site allows you to:
- add participants
- define data and variables
- create messaging content, scheduling, and logic (limitations exist)
- automate delivery of messaging to participants
- view or export all logs and data
We will assign your project a 10-digit phone number for sending and receiving SMS and/or MMS. If you require a short code, there is a separate application process. This phone number will be exclusive to your project in most cases. We procure phone numbers from Twilio and the phone numbers are subject to their policies.
- Phone numbers expire upon the end of your subscription or license
- We recommend that you send a message at the end of your program to let recipients know that the phone number will no longer belong to you, and may change owners.
- If you want us to maintain your phone number between projects, or for extended periods, there will be an additional cost to be determined at the time of the extension.
TRAINING AND SUPPORT
We will provide training and project support on a limited, per-project basis. The number of hours support from the Signal Vine team is indicated on your Order Form.
You are responsible for the content and material of your SMS messages and modules.
You are responsible for obtaining appropriate consent from message participants who will receive your SMS content, and for abiding by all laws regarding SMS use and the use of the SMS Platform, the delivery or storage of any information involved in the SMS Platform, and transmission of electronic communications.
SMS has several limitations, due to the nature of the medium and the carriers involved:
- text messages are not encrypted
- while the majority of text messages are usually delivered, delivery is not guaranteed
- you cannot track delivery of text messages
- outgoing messages cannot exceed 160 characters per message, or they will be split into multiple parts
We provide you with the ability to download text message logs and data about your participants.
As part of our standard agreement, Signal Vine offers 30 days of access to program data and messages for no additional fee following the end of a program.
After those 30 days, customers can pay to have access to this information for additional time. Otherwise, Signal Vine holds this information for an additional 100 days, during which time customers can pay to regain access to this information.
Following that additional 100 days, Signal Vine deletes the numbers and data. At this point, the information will no longer be available to the customer.
CHANGES TO THIS DOCUMENT
We may update the Description of Service over time. When we do, we will also revise the ‘last modified’ date at the bottom of this document. For material changes to this Description of Service, we will notify you by placing a notice on the login page(s) of the Signal Vine Enterprise Messaging Platform or the home page of Signal Vine, or by sending you a notification directly.
Last modified: January 2017