Privacy Policy

1. General Information – Our contact details as data controllers

In this Privacy Policy, SIGNAL OCEAN LTD, a private limited company organized and existing under the laws of England and Wales, whose registered office is at 83 Cambridge Street, Pimlico, SW1V 4PS, London, England (“SO UK”), also deemed to include its wholly-owned subsidiary SIGNAL OCEAN SINGLE MEMBER PRIVATE COMPANY, a single-member private company organized and existing under the laws of Greece, whose registered office is at 110 Vouliagmenis Avenue, Glyfada, 166 74, Greece (“SO GR”), states its practices regarding information that it collects from you or through your use of the website hosting the Platform, which is accessible via https://app.signalocean.com/ (“Website”), how that information may be used and with whom it may be shared (the “Privacy Policy”). User’s privacy is SO UK’s top priority. SO UK and/or SO GR may use Personal Information and/or Cookies, as defined below, for the purpose of making the Website and/or Platform available to you in accordance with the Agreement. The data controllers of your Personal Information are Signal Ocean Ltd of 83 Cambridge Street, Pimlico, SW1V 4PS, London, England, and Signal Ocean Single Member Private Company of 110 Vouliagmenis Avenue, Glyfada, 16674, Greece.

The Privacy Policy will be revised from time to time. SO UK will notify you of any revisions by posting the updated version of the Privacy Policy on the Website and/or the Platform. Revised terms become effective on the first date that you access or use the Website and/or Platform after the updated Privacy Policy has been posted. SO UK advises you to periodically check the Privacy Policy for any such modifications or revisions. In the case of any material changes to the Privacy Policy, we will also notify you via e-mail at the email address you have provided upon registration. You represent that you have read and understood the Privacy Policy.

The Website and/or Platform may include links to third-party websites or applications whose privacy policies may differ from ours. Any information that these third parties collect about you is governed by their respective privacy policies. We suggest that you contact those third parties directly in order to obtain information about their privacy policies.

Unless otherwise provided herein, defined terms shall have the meaning ascribed to them in the Terms of Use. The Terms of Use and the Privacy Policy constitute the entire agreement between you and SO UK (the “Agreement”). For the purposes of this Privacy Policy, “use” shall mean any operation or set of operations performed on information provided by you, such as collection, use, storage, forwarding and/or disclosure. “Process” shall be construed accordingly.

2. Type of Personal Information we collect

“Personal Information” refers to information that allows SO UK to identify you, directly or indirectly, in particular by reference to an identifier, in the course of your registering to, accessing and using the Website and/or Platform. You shall not provide any Personal Information about others unless you are authorized to do so. By submitting Personal Information about others, you represent and warrant that you are authorized to do so and that you have received authorization from the person about whom you provide Personal Information and, where required, that this person has consented to have all such Personal Information submitted in accordance with this Privacy Policy.

When accessing and using the Website and the Platform through a paid account Personal Information shall be provided by you for the purposes of registration to the Platform and account creation; it includes name, address, email, telephone number, company/employer, job title, job department, payment details. Failure to provide such Personal Information will result in your inability to register to, access, and use the Platform and its subsequent versions.

When accessing and using the Website and the Platform by using the free edition and features available without creating an account, you will be asked to sign in via Google Sing-In or LinkedIn Sing-In or e-mail Sign-In, you will therefore need to create or to have an existing Google or LinkedIn or e-mail account. When you click the Google Sign-In or LinkedIn Sign-In button or email Sign-In button, a screen will open showing what information from your Google/LinkedIn/email account we would like to have access to. In particular, we currently collect and process the following personal information about you:

(a) via Google Sign-In:

• Name

• Google ID

• Username

• Profile picture URL

• E-mail address

(b) via LinkedIn Sign-In:

• ID

• First name

• Last name

• Profile picture URL

(c) via e-mail Sign-In:

• Name

• E-mail address

By clicking ‘‘Allow’’, you provide us with your consent, to collect your information from Google/LinkedIn/e-mail account by using their application programming interfaces (APIs) and enable you to register to, access, and use the Platform. Failure to provide the above personal information will result in your inability to register to, access, and use the Platform and its subsequent versions.

SO UK may also collect Personal Information automatically through your use of the Website and/or the Platform, such as IP address, date and daytime of access request, time zone difference to Greenwich Mean Time (GMT), the specific site requested, HTTP-status code, amount of data transmitted, the website from which you visit the Website, browser type, operating system, and user interface, language, and version of the browser software. Please refer to the section on Cookies and similar technologies below for more information.

3. Purposes for which your Personal Information is processed

SO UK may use your Personal Information to:

1. Process your registration for the purposes of using the Platform,

2. Provide you with the services and products of the Platform, including but not limited to process payments, if applicable, and provide you with customer support,

3. Communicate with you with respect to the use of the Platform and/or our services and products,

4. Notify you of any modifications/revisions to the Platform’s Terms of Use, including but not limited to the present Privacy Policy,

5. Ensure compliance with our legal obligations,

6. Improve the quality of Signal’s collaborations and provision of services and our unimpeded and effective communication and interaction with you,

7. Establish, exercise, or support our legal claims,

8. Improve your interaction with the Platform and optimize your experience with it,

9. Request your participation in surveys related to the Platform, its services, and products,

10. Protect our network, devices, and programs for cyber-security (i.e. ensuring confidentiality, integrity and availability of the information, data from attacks or unauthorized access, etc.) and other risk management purposes,

11. For our respective business purposes, such as data analysis, usage analytics, audits, fraud monitoring and prevention, improvement of the Platform, development of new services, identification of usage trends, business development, research, etc. For these purposes, and in order to pursue our legitimate interests, we may de-identify and/or aggregate your personal information with other information,

12. For marketing and promotion purposes, in case you have provided us with your explicit consent to such processing.

We collect, use or share your personal information only when there is a valid legal basis allowing us to do so. Most commonly, the lawful bases we rely on for processing your personal information are:

• We have your consent. You are able to remove your consent at any time. You can do this, by contacting Dimitris Tsapoulis, at the following e-mail address: [email protected],

• We have a legitimate interest, namely for the purposes described under section 3 (d), (f), (g), (h), (i), (j), (k),

• We have a legal obligation.

SO UK and/or SO GR may retain your Personal Information for up to seven (7) years from the termination of your right to use the Platform and/or the Website, in accordance with the Terms of Use.

You acknowledge that SO UK and/or SO GR may use your Personal Information as set forth r in this Privacy Policy in order for you to be able to use the Platform and/or the Website. If you don’t wish your Personal Information to be used by SO UK and/or SO GR as described herein, you may send an email to SO UK (contact person: Dimitris Tsapoulis) at the following address [email protected]. Requests are dealt with within seven (7) business days. However, please note that any objection by you to SO UK’s processing of your Personal Information will not affect the lawfulness of the use of your Personal Information up to that time and will result in the termination of your right to use the Platform and/or Website, in accordance with the Terms of Use.

4. Sharing your data with third parties

SO UK does not generally share your Personal Information with any third parties. However, your Personal Information may be disclosed in the following circumstances:

• By SO UK to SO GR, for the uses described in the Privacy Policy. SO UK represents and warrants that SO GR is required to comply with the same limitations as SO UK regarding the use of Personal Information.

• By SO UK and/or SO GR to third-party service providers, who provide services to SO UK and/or SO GR such as website hosting, data analysis, usage analytics, business development, payment processing, functionality development and improvement, information technology, customer support, and related infrastructure provision, provided that such service providers have provided SO UK and/or SO GR with satisfactory assurances of their technical and organizational ability to provide appropriate and sufficient data protection, in accordance with applicable law.

• By SO UK and/or SO GR to third-party providers of products or services that you purchase through the Platform.

• By SO UK and/or SO GR to other users for the implementation of any functionality of the Platform.

• By you to anyone with whom you communicate through the Platform.

• By you on pages, features, or any services of the Platform to which you are able to post information and materials. Please note that any information you post or disclose through these services may be available to other users as well.

• By SO UK and/or SO GR to a third party in the event of a merger, sale or transfer of assets, joint venture, assignment, reorganization or bankruptcy or other similar proceedings.

• By SO UK and/or SO GR to comply with any applicable law, including laws outside of your country of residence or outside of the European Economic Area, to respond to requests from courts, public and/or judicial authorities, which may include such authorities outside of your country of residence or of the European Economic Area to take precautions against liability, to investigate and defend SO UK and/or SO GR against any third-party claims or allegations.

• By SO UK and/or SO GR to protect the rights, privacy, security, safety, integrity, or property of SO UK, SO GR, facilities, or equipment used to make the services available, Platform users or others, and to enforce the Agreement.

SO UK and/or SO GR may transfer to, store and use your Personal Information – for troubleshooting, customer support, usage tracking, and data storage purposes – in any country where SO UK’s and/or SO GR’s related companies, affiliates, or third-party service providers are based, even countries outside of the European Economic Area, and which may have lower levels of data protection from those applicable in the European Economic Area. SO UK and/or SO GR also take steps to protect Personal Information in the country in which it is stored, used, or to which it is transferred and to ensure that any such data storages, uses, and transfers are subject to adequate safeguards. To safeguard such transfers SO UK and/or SO GR use data protection clauses or other appropriate legal mechanisms to safeguard the transfer. If you require more details please contact [email protected].

5. How we secure and store your personal information

SO UK and SO GR have put in place appropriate technical, organizational, and other measures to protect your Personal Information from unauthorized or unlawful use and accidental loss or damage and to provide a level of data protection that meets the requirements of applicable law. Such measures also apply to entities directly or indirectly controlling, controlled by, or under common control with SO UK and/or SO GR. However, no data security measures are 100% secure. We cannot ensure or warrant the security of any information you transmit to us or store on the Platform, and you do so at your own risk. SO UK suggests that you create a strong password and that you periodically change it. Moreover, if you have any reason to believe that your interaction with SO UK and/or SO GR and/or the Platform and/or the Website is no longer secure, please immediately notify SO UK at the following address [email protected].

You acknowledge and agree that the employees of SO UK and SO GR may gain access to your Personal Information. SO UK and/or SO GR shall limit such access on a need-to-know basis. SO UK and/or SO GR shall take all reasonable steps to ensure that such employees are informed of the nature of the Personal Information and comply with the provisions of this Privacy Policy.

6. Your data protection rights

Under data protection law, you have the following rights:

• Your right to information/communication – You have the right to request and receive clear, transparent, and easily understandable information regarding the processing of your personal information.

• Your right of access - You have the right to ask us for copies of your personal information in a structured, commonly used, and machine-readable format.

• Your right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete the information you think is incomplete.

• Your right to erasure/deletion - You have the right to ask us to erase or delete your personal information in certain circumstances, and especially when it is no longer necessary for the purposes collected or when there is no legitimate reason for us to continue processing it. The right of deletion is not absolute, especially in cases when there is a particular legal obligation or other legitimate reason for Signal to retain your personal information.

• Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances.

• Your right to object to processing - You have the right to object to the processing of your personal information in certain circumstances.

• Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organization, or to you, in certain circumstances.

• Your right to revoke your consent – You have the right to revoke your consent at any time, without prejudice to the lawfulness of the consent-based processing prior to its revocation, via e-mail to: [email protected].

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you, starting on the date of your submission request.

Please contact us at [email protected] if you wish to make a request.

7. How to complain

If you have any concerns about our use of your personal information, you can make a complaint to us at [email protected].

You can also complain to the relevant competent Data Protection Authority if you are unhappy with how we have used your personal information.

In particular, for complaints regarding the use of your personal information by the SO UK, you can contact ICO to the following contact details: (a) The ICO’s address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, (b) Helpline number: 0303 123 1113, (c) ICO website: https://www.ico.org.uk.

For complaints regarding the use of your personal information by the SO GR, you can contact the Hellenic Data Protection Authority at the following contact details: (a) Address: 1-3 Kifissias, 11523, Athens, (b) Telephone: +30 210 6475600 (c) Fax: +30 210 6475628 (d) E-mail: [email protected].

8. Cookies and similar technologies

The Platform and the Website collect information about the use of the Platform and/or the Website. Such information may be collected:

(a)   through your browser or device;

(b)   through cookies and similar technologies (such as beacons, pixels and tags); cookies contain a small amount of information downloaded to your computer or other device by the server of a website, page or advertisement, which allow the originating website, page or advertisement to recognize your computer or other device on subsequent visits; the Platform and the Website use both session-based cookies (which last only while your browser is open) and persistent cookies (enabling authentication, as well as other Platform features, for each time you log on to the Website and/or the Platform), as well as third-party cookies, such as Google Analytics, subject to the respective service provider’s policies; you may opt-out of third-party cookies on that provider’s respective website; although most browsers accept cookies by default, you are able to set yours to alert you when cookies are being used, as well as to accept or reject cookies; you may also opt-out of all or certain cookies used by the Website and/or the Platform, but please note that such opting-out may significantly disrupt your use of the Website and/or Platform and that you may even lose the ability to access the Website and/or Platform; cookies can be either associated with your account and Personal Information or used to perform analytics and personalization, among other things; the following types of cookies are used by the Platform and the Website:

• strictly necessary/essential cookies (i.e. cookies that are necessary in order to enable you to browse the Website and use the Platform and its features, such as accessing secure areas of the Platform),

• authentication and functionality cookies (i.e. cookies that are used to store login information, as well as to provide personalized services),

• performance and analytics cookies (i.e. cookies that are used to collect information about the use of the Website and/or the Platform, as well as for improvement and research of features and services of the Platform),

• security cookies (i.e. cookies that are used for the detection of malware and support of Website and/or Platform security),

• preference cookies (i.e. cookies that are used for the provision of customized services and features),

• marketing cookies (i.e. cookies that are used for launching and monitoring of marketing campaigns, delivering customized advertising).

(c)   through your use of the Platform and/or the Website (including but not limited to date and length of visit, location data, traffic data, etc.);

(d)   from you on a voluntary basis, such as information about your geographic and/or commercial preferences; and/or

(e)   by aggregating Personal Information, where such information does not personally identify you (collectively, “Electronic Tools”).

SO UK, SO GR, and their third-party service providers may use information collected through the Electronic Tools for any purpose, such as enhancement of navigation, functionality of the Platform, monitoring and analyzing the effectiveness of the Website and/or the Platform, as well as aggregating usage metrics, except where SO UK and/or SO GR are required to do otherwise under applicable law.

If SO UK and/or SO GR combine information collected through Electronic Tools with Personal Information, it/they will treat the combined information as Personal Information.

9. Cookie Details

In the table below we provide detailed information about all Cookies that are stored in your device during your visit/browsing to our Website. By accepting cookies on the Website, you consent and accept the use/storage of Cookies on your device for the purposes that are listed in the table below.

10. Disabling Cookies

You can disable Cookies by accessing the Cookies Control Panel of our Website or by changing the relevant settings in your browser. Note that the site may not operate correctly if all cookies are disabled.

Choose your browser and click the appropriate link to get further information on how to disable and delete Cookies:

Google: https://support.google.com/accounts/answer/61416?hl=en.

Mozilla: https://support.mozilla.org/en-US/kb/delete-cookies-remove-info-websites-stored.

Microsoft: https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies#ie=ie-11.

Opera: https://www.opera.com/help/tutorials/security/privacy/.

Safari: https://support.apple.com/en-us/HT201265.

For other browsers that are not in the list, please contact the program provider or alternatively check the help function of the browser.

11. Information about Cookies

For more information about cookies, how to use them as well as how they apply to the use of your personal information, please visit www.aboutcookies.org.

12. Other information that we collect

IP address is a unique number used by devices to identify and consult each other on a computer network using the Internet Protocol Standard. The IP address is a number that is assigned to your device (PC, tablet, smartphone) each time you access the internet to communicate with other devices. The IP address can also be recognized by your internet provider.

During your visit, the Website records the IP for security reasons and for preventing malicious actions. In addition, IP addresses are collected in order to analyze the website’s performance and optimize it by offering a more user-friendly and functional experience to you.

This information is necessary for the proper operation of the website and the user cannot deactivate them.