Effective Date: March 5th, 2020
● information you provide when registering with Singuli or updating your Client Information, which may include name, image, physical address, email address, username and password for third-party services, telephone and/or mobile phone number;
● your financial information which you provide when paying for our Service, including credit card or debit card, or bank account information;
● information we obtain from Client Content Partners, Client Third Parties and other third-party services with which you use our Service and/or share information (e.g., if you utilize our Service to gather information from Shopify, we obtain from Shopify information including name, email address and zip code for your Shoppers);
● information you include or make available in Client Content;
● information you provide in connection with any support, product evaluation, dispute resolution and other communications with our Service and personnel;
● information regarding the geographic location where your computing device is located when interacting with our Service; and
● information regarding the computing device you use when interacting with our Service.
Content from Third-Party Services
When you enable the Singuli Service to access a third-party service, such as Client Content Partners or Client Third Parties, you specifically authorize our Service to take certain actions, such as ingest your Client Content on that service, process it using our proprietary algorithms to make it more useful to you, and, at your request, perform various actions with it. Our Service may also anticipate that certain information possessed by Client Third Parties is relevant to the certain forecasting or other modeling processes and obtain or update it for processing by the Service. We store that Client Content in our systems. We rely upon you to determine what information you provide to us, or enable us to access from Client Content Partners or Client Third Parties, and to ensure that you have all rights to enable us to receive and process such information in providing our Service; this is solely your legal responsibility. We also use Singuli Service Providers who may collect information from you that they share with us. (You may review their respective privacy policies to learn more about what they collect and share.)
Automatically Collected Information
We collect certain information automatically through our Service by means of various software tools, including cookies, tracking pixels and similar technologies. We have a legitimate interest in using this information to help us provide our Service to you, and to learn how our Service is used. Singuli automatically receives and records “traffic data” on our server logs from your computer, including your geographical location and Internet Protocol (“IP”) address, Singuli cookie information, and pages you request. Cookies are alphanumeric identifiers that we transfer to your computer through your web browser to enable our systems to recognize your browser, tell us how and when pages in our Site are visited and by how many people. Singuli cookies do not collect personal information, and do not combine information collected through cookies to obtain personal information.
We use your personal information for the following purposes:
● to establish your account with our Service, and to communicate with you regarding your account;
● to identify and authenticate your access to certain parts of our Site and Service that you are authorized to access;
● to establish authorization for our Service to access the Client Content Partners and Client Third Parties you request;
● to operate, improve and personalize our Service for you, including any collection and processing of payment for our Service;
● to protect our rights and/or our property and to ensure the technical functionality and security of our Service;
● to provide you information regarding our Service and other services or products, or redeem promotional offers (consistent with your communications preferences);
● to display in your user profile; and
● to contact you to detect, prevent and mitigate fraudulent or illegal activities, investigate or inform about any security issues, enforce our agreements with you or other applicable policies, and comply with our legal obligations.
We use the information and data obtained from Client Content Partners and Client Third Parties to fulfill your requests for data analysis, and otherwise operate the Service. Singuli also uses a limited number of Singuli Service Providers to assist us in providing the Service to you, including Infrastructure As a Service (“IaaS”) hosting and Software As a Service (“SaaS”) operations for systems monitoring, data queuing and statistical and scientific activities. These third parties may access, process or store personal information and certain Client Content in the course of providing these services, but we instruct them to only use such information pursuant to our instructions in performing the Service.
Information Obtained via Technical Tools
We use information obtained from your computing device(s), as well as information obtained from cookies, tracking pixels and similar technologies, to understand how you and other users use our Service, and to develop improvements to our Service. We may also use these technologies to help deliver promotional messages and advertisements for relevant products and services.
Our Service operates on computers owned and/or operated by Singuli and located in third-party data centers; these computers are located in the United States and other countries. We retain your information as long as it is necessary and relevant for the operation of our Service. Upon request, personal information from closed accounts will be deleted as soon as reasonably possibly after the account is closed or deactivated. Under certain circumstances we may retain information, including personal information, from closed accounts to prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigation, enforce our Terms of Service, comply with applicable legal data retention obligations and take other actions permitted by law. After it is no longer necessary for us to retain your personal information, we will dispose of it in a secure manner according to our data retention and deletion policies in effect at that time.
YOUR CHOICES AND RIGHT TO ACCESS INFORMATION
You determine what personal information to provide to us, and you may modify this information at any time by logging into your account via our Site. However, if your organization uses an Administrator to manage elements of our Service, that person may also have the ability to add, edit or delete certain personal information and other information relating to your usage of the Service. It is your responsibility to ensure that your information is correct in your profile, and we may rely upon that information being current. You consent to our using the then-current address(es) in your user profile to deliver notices and important messages.
We do not sell or rent your personal information to third parties for their marketing purposes without your explicit consent. We may contact you via email with Service-related announcements that we think may be beneficial to you, and special offers. We also may contact you with information about products and services from our business partners. You may opt out of such communications at any time by following the opt-out instructions in such communications or contacting us at firstname.lastname@example.org. You may not opt out of receiving what we consider to be essential Service-related messages, support services responses or other communications relating to inappropriate use of the Service or requests from third-parties to access information in your account. We may deliver those messages using any of your addresses in your profile, and may send messages to you within the Service. Please note that if you have agreed to receive marketing communications from any third-party service with which you are using Singuli, you must change your communication preferences with them directly.
We will honor any statutory right you might have to access, modify or erase your personal information. You can contact Singuli Client support at email@example.com to request access. Where you have a legal right to request access or request the modification or erasure of information, we can still withhold that access or decline to correct information in some cases in accordance with applicable law, but will give you reasons if we do so.
We exist to provide a valuable service to you, and not to obtain your personal information to sell or rent to third parties. In addition to actions you elect to take to enable us to share your credentials with Client Content Partners and Client Third Parties to integrate Singuli with such third-party service, the circumstances in which we disclose personal information are limited to the following:
● We have your explicit consent to share the information.
● We believe it is necessary to investigate potential violations of our Terms of Service, to enforce the Terms of Service, or where we believe it is necessary to investigate, prevent or take action regarding illegal activities, suspected fraud or potential threats against persons, property or the systems on which we operate the Service.
● We determine that the access, preservation or disclosure of information is required or permitted by law to protect the rights, property or personal safety of Singuli and users of the Service, or is required to comply with applicable laws, including compliance with warrants, court orders, subpoenas, legal process, or other lawful government requests (including in response to public authorities to meet national security or law enforcement requirements).
● We do so in connection with the sale or reorganization of all or part of our business, as permitted by applicable law.
In each of these circumstances, we try to minimize the amount of personal information we share to what is directly relevant and necessary to accomplish the specified purpose. As stated above, we do not disclose your personal information to third parties for their marketing purposes without your explicit consent.
While we use contractual and other measures to ensure protection of personal information, the laws and regulations relating to privacy and personal information protection in other jurisdictions may not be the same as, or similar to, your local privacy laws. The governments, courts, law enforcement or regulatory agencies in these other jurisdictions may be able to request disclosure of personal information through the laws of these countries. In an effort to respect your privacy, we will not otherwise disclose your personal information to law enforcement, other government officials, or other third parties without a subpoena, court order or substantially similar legal procedure, except when we believe in good faith that the disclosure of information is necessary to prevent imminent physical harm, financial loss or to report potentially illegal or fraudulent activity.
SECURING YOUR INFORMATION
Singuli is committed to protecting the security of your information and takes reasonable precautions to protect it. Your Singuli account information is protected by a password for your privacy and security. We protect your information in our systems using technical and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. Some of the safeguards we use are firewalls and data encryption, physical access controls to our data centers, and information access authorization controls. Only personnel who need personal information to perform a specific job are granted access to it. All Singuli personnel are provided regular privacy and security awareness training.
Singuli uses Transport Layer Security (“TLS”) to encrypt all data communication over Hypertext Transfer Protocol (“HTTP”), otherwise known as HTTP Secure (“HTTPS”). However, internet data transmissions cannot be guaranteed to be 100% secure, and we cannot ensure the security of information during its transmission between you and us. Accordingly, you acknowledge that when you transport such information, you do so at your own risk. Additionally, while Singuli uses commercially reasonable means to secure your information, we cannot guarantee that your personal information will not be improperly accessed, disclosed, or destroyed by breach of any of our safeguards.
If we learn of a system breach, we may attempt to notify you and provide information on protective steps, if available, through the email address that you have provided to us or by posting a notice on our Site and/or via our Service and other communication platforms. Depending on where you live, you may have a legal right to receive such notices in writing. Should we receive any third party request for information about your account that we believe we are compelled to comply with, we will provide you with notice of such request (unless legally prohibited from doing so).
There are just a few more pieces of important privacy information related to your use of our Service that we need to cover:
Information from Children
We do not knowingly collect personal information from children without parental consent. If we learn that we have inadvertently obtained information in violation of applicable laws prohibiting collection of information from children without such consent, we will promptly delete it.
Third Party Privacy Practices
CHANGES TO POLICY
YOUR CALIFORNIA PRIVACY RIGHTS
If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by Singuli to third parties for the third parties’ direct marketing purposes. To make such a request, please send an email to firstname.lastname@example.org or write to us at:
41 Flatbush Ave., Floors 1 & 2
Brooklyn, New York 11217
QUESTIONS OR CONCERNS
41 Flatbush Ave., Floors 1 & 2
Brooklyn, New York 11217