In this Privacy Policy, SIGNAL OCEAN LTD, a private limited company organised 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 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.
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 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.
Personal Information
“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. 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.
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), 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 browser software. Please refer to the section on Cookies and similar technologies below for more information.
SO UK may use your Personal Information to:
Process your registration for the purposes of using the Platform.
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.
Improve your interaction with the Platform;
Notify you of any changes to the Website and/or the Platform.
Communicate with you with respect to the Platform’s and/or SO UK’s services and products.
Enforce the Agreement.
Send you marketing communication, unless you have requested by written notice that your Personal Information not be used for the purposes of direct marketing.
Request your participation in surveys related to the Platform, its services and products and administer such surveys.
For SO UK’s and/or SO GR’s respective business purposes, such as data analysis, usage analytics, audits, fraud monitoring and prevention, development of new products and services, improvement of products and services of the Platform, identification of usage trends, business development, research etc. For these purposes, SO UK and/or SO GR may de-identify, and/or aggregate with other information, your Personal Information.
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 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.
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 that any such data storages, uses and transfers are subject to adequate safeguards.
You acknowledge that SO UK and/or SO GR may use your Personal Information as provided for 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 support@thesignalgroup.com. 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.
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 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 support@thesignalgroup.com.
You may review, rectify, modify, update, delete any of your Personal Information by sending an e-mail to support@thesignalgroup.com. You may also object to the use of any Personal Information for certain purposes in accordance with applicable law (for example, you have a right to object to your Personal Information being used for direct marketing purposes as well as certain rights to object to being profiled). You may also request from SO UK to provide you with your Personal Information in a structured, commonly used and machine-readable format and to transmit such Information to a third party pursuant to your instructions. In case you believe that your Personal Information as used by SO UK and/or SO GR is inaccurate, or that the use of your Personal Information is unlawful, or that SO UK no longer needs the Personal Information you submitted to it for the purposes designated, you may also request the restriction of use by SO UK and/or SO GR and or their third-party service providers until the incident is investigated and resolved.
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 that person has consented to having all such Personal Information submitted in accordance with this Privacy Policy.
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.
You may contact Dimitris Tsapoulis at the following address support@thesignalgroup.com for any questions about the Privacy Policy or any complaints or objections about the way your Personal Information has been processed by SO UK and/or SO GR. You may lodge a complaint with any supervisory authority if you believe that the use of your Personal Information by SO UK and/or SO GR infringes upon any applicable law.
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.
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:
(i) through your browser or device;
(ii) 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 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).
(iii) 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.);
(iv) from you on a voluntary basis, such as information about your geographic and/or commercial preferences; and/or
(v) 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.