Privacy Policy for SYGNAL

sygnal.ai (SYGNAL) and its corresponding services are wholly owned and operated by Sanostro AG, Zug, Switzerland.

Privacy is of utmost importance to SYGNAL. It is our policy to respect the confidentiality of information and the privacy of individuals. The data we protect are the "Personal Data" which is any information relating to an identified or identifiable natural person, sometimes called a data subject, and have made protecting the privacy and the confidentiality of Personal Data a fundamental component of the way we do business. We are also bound by principles contained in the EU General Data Protection Regulation (GDPR).

In this Policy, "Services" means the SYGNAL website, any feature provided by us via the website or any local application (mobile, desktop, or otherwise).

This Policy will be reviewed from time to time to take into account changes to our operations practices and, further, to make sure it remains appropriate to any changes in the law, technology, and the business environment. You should check this page from time to time to ensure that you are happy with any changes. Any information held will be governed by our most current Policy.

If you do not agree with this Privacy Policy in general or any part of it, you should not use the Services.

This Policy was last updated on January 16, 2024.

Information we collect from you

Information you provide us:

• When you register for SYGNAL’s Services we may collect the following personal data from you: email address, your first name, and your family name.
• If you contact us, we may keep a record of that correspondence.
• For payment services, we may collect additional information such as your billing address, your country of origin, and the name of the organization for whom you work.We DO NOT store your personal payment details. Such information may be collected and stored at the time of payment by our third-party payment service provider (Stripe Inc.) who is authorized to collect and store such data with full PCI & GDPR compliance.Stripe may collect personal data including payment method information (such as credit or debit card number, or bank account information), the purchase amount, date of purchase, and payment method. Different payment methods may require the collection of different categories of information. You may learn more about Stripe’s data collection policy here.

Information we collect automatically:

When you sign-up for or use the SYGNAL Services we may automatically collect the information as follows:

• Log information: We may log technical information about your use of the Services, including your browser type and version, sign-up time, last access time, initial Internet Protocol (IP) address, and last used Internet Protocol address.
• Device information: We may collect information about the mobile device you use to access our Services including the hardware model, operating system and version, unique device identifiers, and mobile network. If accessing our services from a desktop or notebook computer, we may collect information about your hardware model, operating system and version, unique device identifiers, and ISP.
• Usage Data: We may also collect information on the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers, and other diagnostic data.

Information we collect from other sources:

We also receive information from other sources and combine that information with information we collect through our Services. For instance:

• Referral ID: Should you have been referred to SYGNAL’s Services by a third party, we may collect a referral key/id which is used to identify the source of your first visit to Sanostro’s website and Services.
• Marketing data: Should you have arrived on SYGNAL’s platform via an online campaign, such as a banner advertisement or Google Search campaign: we may collect data that includes the campaign ID, referral network, advertisement ID, and creative asset ID.
• Cookies: Our Website uses “cookies” to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our Website. Cookies are files with a small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your computer's hard drive. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service. You can view our full Cookie Policy here.

Information generated by using our services:

As you use SYGNAL’s Services you will generate information which is directly associated with your account and use of the Services:

• Watchlist data: which includes signals and instruments you are actively following.
• Subscription information: signals, instruments, and packages to which you have subscribed to or purchased using SYGNAL’s Services, including the date of purchase, date of expiry, the price paid, and subscription type.

How we use your personal information

How we use the personal information you provided us

The personal information you provided us is used for the purposes as follows: authentication, operational management, customer support, payment services, and communication.

• Authentication: information collected at signup which allows you to access the SYGNAL platform (i.e. log into our website or mobile app), as well as for communicating with our customer support. For this purpose, we collect your email address. You may also be asked to provide a password, however, your password remains encrypted in our system and cannot be viewed by anyone.
• Payment Services: information that you provide us in order for us to legally process all monetary transactions. For this, our Payment Service Provider may require you to provide additional information such as a billing or personal address, mobile phone number, country of residence, postal code, etc. in order to legally and securely process your payments.
• Customer support: in order to answer any questions you may have regarding our Services, we will use any or all of the information at our disposal in order to accurately meet your support needs. This includes information you provided as well as automatically collected information and information generated by your use of our Services.
• Communication: you may provide us with your email address and unique device ID to which you may opt-in to receive content provided by SYGNAL.Please note: we distinguish between two forms of communication:

1. Transactional communication.Transactional communication cover receipts for a transaction initiated by you via our Services (i.e. a change in a signal to which you have subscribed, or a receipt for automated subscription payment).
2. Marketing communication. Marketing communication covers all communications initiated by SYGNAL for the purposes of marketing our Services. You will have the option to opt-out of marketing communications at any time by clicking on the “unsubscribe” button or by disabling notifications.

How we use information we collect automatically

When you use our Services, we may automatically collect information from you for the following purposes: user experience, bug tracking, communication, compliance, and fraud prevention.

• Log information: This information is used to help resolve technical issues, and is also taken into account for identifying potential fraudulent activity and to protect your account (i.e. a sudden IP address change).
• Device Information: This information allows our technical team to ensure that the Services work accurately on your device. This information is also used to identify potential fraudulent activity and to protect your account.
• Usage data: we use third-party event tracking software (Google Analytics & Google Tag Manager) to track all usage of our platform. Usage data allows us to identify and log technical errors, and to optimize our services for better ease of use. This information is anonymized and is not tied to any particular individual.

We will process your Personal Data legally and fairly and not use it outside the purposes of which we have informed you. So far as we are able we shall ensure that all of your Personal Data is accurate and up to date.

Disclosure of personal data

We may share your information with selected recipients to perform functions on our behalf. All such third parties will be contractually bound to protect data in compliance with our Policy. The categories of recipients include:

• Companies within the SYGNAL corporate family (Sanostro AG), in order to provide the Services to you.
• Mobile messaging services, like Twilio or WhatsApp, both located in the United States, or Telegram located in Germany to provide mobile messaging or automated notifications.
• Email providers, like Mailchimp, located in the United States, or Elastic Email, located in Canada, provide email services.
• Cloud service providers, like Infomaniak, located in Switzerland, to store certain personal data and for disaster recovery services, as well as for the performance of any contract we enter into with you.
• Payment service providers, like Stripe Inc., located in the United States, or our banks, located in Switzerland, who may require additional information to authenticate a transaction initiated by you.

We also may share personal information with a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of SYGNAL’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which Personal Data held by SYGNAL is among the assets transferred.

If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms & Conditions and other agreements; or to protect the rights, property, or safety of SYGNAL, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Except where we are required by law to disclose Personal Data or are exempted from, released from, or not subject to any legal requirement concerning the disclosure of Personal Data, we will require any person to whom we provide your Personal Data to agree to comply with our Privacy Policy in force at that time or requirements substantially similar to such policy. We will make reasonable commercial efforts to ensure that they comply with such policy or requirements, however, where not expressly prohibited by law, we will have no liability to you if any person fails to do so.

Legal basis for processing

We process Personal Information about you as a data controller as described in this section, where such processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. Our legitimate interests typically include: improving, maintaining, providing, and enhancing our technology, products and services; ensuring the security of the Services, website, and mobile apps; and for our marketing activities.

Security of your personal data

We protect Personal Data with appropriate physical, technological and organizational safeguards and security measures. Your Personal Data comes to us via the internet which chooses its own routes and means whereby information is conveyed from location to location. As such we cannot give any warranty or assurance that the means where information is conveyed to us are safe, reliable, or have integrity. We audit our procedures and security measures regularly to ensure they are being properly administered and remain effective and appropriate. Every member of SYGNAL is committed to our privacy policies and procedures to safeguard Personal Data. Our site has security measures in place to protect against the loss, misuse, and unauthorized alteration of the information under our control. More specifically, our server uses SSL (Secure Sockets Layer) security protection by encrypting your Personal Data to prevent individuals from reading these Data as they travel over the Internet.

Storage of personal data

All information you provide to us is stored on secure servers in Switzerland with ISO 14001 and ISO 50001 certified providers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password, which enables you to access certain parts of our website or mobile application, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

The privacy and confidentiality of your personal information are of fundamental importance to us. We take all appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure, or destruction of data and personal information.

We restrict access to personal information to employees, contractors, and agents in order to operate, develop, or improve our services.

Transfer of personal data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those from your jurisdiction.

If you are located outside Switzerland and choose to provide information to us, please note that we transfer the data, including Personal Data, to Switzerland and process it there.

When making a payment for our Services, your payment information will be collected and processed by our Payment Service Provider, Stripe Inc., located in the United States of America. Stripe Inc. is certified under the EU-U.S. and the Swiss-U.S. Privacy Shield Framework and adheres to the Privacy Shield Principles in connection with personal data transfers from the EEA, the UK, and Switzerland.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

SYGNAL will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Children's policy

Our Service does not address anyone under the age of 18 ("Children").

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

Your rights

You may have the following data protection rights:

• To access, correct, update, or request deletion of your Personal Information. SYGNAL takes reasonable steps to ensure that the data we collect is reliable for its intended use, accurate, complete, and up to date. You may contact us directly at any time about accessing, correcting, updating, or deleting your Personal Information, or altering your data, by emailing us at operations@sygnal.ai. We will consider your request in accordance with applicable laws.
• In addition, if you are a resident of the EEA, you can object to the processing of your Personal Information, ask us to restrict processing of your Personal Information, or request portability of your Personal Information - meaning that you can obtain a copy of your data in a commonly used electronic format so that you can manage and move it. Again, you can exercise these rights by emailing us at operations@sygnal.ai.
• You have the right to complain to a data protection authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority. Contact details for data protection authorities in the EEA are available here.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. We may ask you to verify your identity in order to help us respond efficiently to your request. Any access request after the first such request by you may be subject to a reasonable fee to meet our costs in providing you with details of the information we hold about you.

Acceptance

By using the Services, you signify your agreement to this Policy. SYGNAL reserves the right to change this Policy at any time. If we make any material changes to this Policy the revised Policy will be posted here, so that you are always aware of what information we collect, how we use it, and under what circumstances we disclose it. Please check this page frequently to see any updates or changes to this Policy.

Questions and complaints

Any questions about this policy, the collection, use, and disclosure of Personal Data by SYGNAL or access to your Personal Data which is required by law (or would be so subject had the storage in question taken place in a relevant EU member state if the case may be but not otherwise) to be disclosed should be directed to operations@sygnal.ai.

In the event that you wish to make a complaint about how we process your personal data, please contact us in the first instance at operations@sygnal.ai and we will endeavor to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with the data protection supervisory authority in the country in which you live or work where you think we have infringed data protection laws.

Questions, comments, and requests regarding this privacy policy are welcome and should be addressed to the Sanostro team, which can be reached at operations@sygnal.ai.