Privacy Policy



Last updated January 31, 2020

Thank you for
choosing to be part of our community at Sigmoidal LLC

("

Company

",
"we", "us", "our"). We are committed to
protecting your personal information and your right to privacy. If you have any questions or
concerns about this privacy notice, or our practices with regards to your personal information,
please contact us at [email protected]

When you

visit our website https://sigmoidal.io (the
"Website"),

and more generally, use any of our services (the "Services",
which include the 

Website

), we appreciate
that you are trusting us with your personal information. We take your privacy very seriously. In
this privacy notice, we seek to explain to you in the clearest way possible what information we
collect, how we use it and what rights you have in relation to it. We hope you take some time to
read through it carefully, as it is important. If there are any terms in this privacy notice that
you do not agree with, please discontinue use of our Services immediately.

This privacy notice applies
to all information collected through our Services (which, as described above, includes
our 

Website

), as well as, any
related services, sales, marketing or events.

Please read this
privacy notice carefully as it will help you understand what we do with the information
that we collect.


TABLE OF
CONTENTS


1. WHAT INFORMATION DO WE
COLLECT?

2. HOW DO WE USE YOUR INFORMATION?

3. WILL YOUR INFORMATION BE SHARED WITH
ANYONE?

4. DO WE USE COOKIES AND OTHER TRACKING
TECHNOLOGIES?

5. HOW LONG DO WE KEEP YOUR
INFORMATION?

6. HOW DO WE KEEP YOUR INFORMATION SAFE?

7. DO WE COLLECT INFORMATION FROM
MINORS?

8. WHAT ARE YOUR PRIVACY
RIGHTS?

9. CONTROLS FOR DO-NOT-TRACK FEATURES
10. DO CALIFORNIA RESIDENTS HAVE SPECIFIC
PRIVACY RIGHTS?

11. DO WE MAKE UPDATES TO THIS
NOTICE?

12. HOW CAN YOU CONTACT US ABOUT THIS
NOTICE?

13. HOW CAN YOU REVIEW, UPDATE OR DELETE THE DATA WE COLLECT FROM
YOU?


1. WHAT
INFORMATION DO WE COLLECT?


Personal information you disclose to
us


In
Short: 
 We collect
personal information that you provide to
us.


We collect
personal information that you voluntarily provide to us when you

express an interest in obtaining information
about us or our products and Services, when you participate in activities on the
Website

 or otherwise when you contact
us.

The personal
information that we collect depends on the context of your interactions with us and the
Website

, the choices you make and the products and features you use. The personal
information we collect may include the following:

Personal Information Provided by You. We collect

names; 

email addresses; 

job titles; 

contact preferences; 
and other similar information.

All personal
information that you provide to us must be true, complete and accurate, and you must notify us
of any changes to such personal information.


Information automatically
collected


In
Short: 
 Some
information — such as your Internet Protocol (IP) address and/or browser and
device characteristics — is collected automatically when you visit our
Website

.

We
automatically collect certain information when you visit, use or navigate the
Website

. This information does not reveal your specific identity (like your name or
contact information) but may include device and usage information, such as your IP address,
browser and device characteristics, operating system, language preferences, referring URLs,
device name, country, location, information about how and when you use our
Website

and other technical information. This information is primarily needed to
maintain the security and operation of our
Website

, and for our internal analytics and reporting purposes.

Like many
businesses, we also collect information through cookies and similar technologies.

The information
we collect includes:

  • Log and
    Usage Data.
    Log and usage data is service-related, diagnostic, usage and
    performance information our servers automatically collect when you access or use our
    Website

    and which we record in log files.
    Depending on how you interact with us, this log data may include your IP address, device
    information, browser type and settings and information about your activity in the
    Website

     (such as the date/time stamps
    associated with your usage, pages and files viewed, searches and other actions you take such
    as which features you use), device event information (such as system activity, error reports
    (sometimes called 'crash dumps') and hardware settings).

  • Device
    Data.
    We collect device data such as information about your computer, phone, tablet
    or other device you use to access the
    Website

    . Depending on the device used, this device data may include information
    such as your IP address (or proxy server), device and application identification numbers,
    location, browser type, hardware model Internet service provider and/or mobile carrier,
    operating system and system configuration information.

  • Location Data. We collect location data such as
    information about your device's location, which can be either precise or imprecise. How much
    information we collect depends on the type and settings of the device you use to access the
    Website

    . For example, we may use GPS and other
    technologies to collect geolocation data that tells us your current location (based on your
    IP address). You can opt out of allowing us to collect this information either by refusing
    access to the information or by disabling your Location setting on your device. Note
    however, if you choose to opt out, you may not be able to use certain aspects of the
    Services.

2. HOW DO WE
USE YOUR INFORMATION?


In Short:  We
process your information for purposes based on legitimate business
interests, the fulfillment of our contract with you, compliance with our
legal obligations, and/or your
consent.


We use personal
information collected via our
Website

for a variety of business purposes described below. We process your personal
information for these purposes in reliance on our legitimate business interests, in order to
enter into or perform a contract with you, with your consent, and/or for compliance with our
legal obligations. We indicate the specific processing grounds we rely on next to each purpose
listed below.

We use the
information we collect or receive:

  • To send administrative information
    to you. 
    We may use your personal information to send
    you product, service and new feature information and/or information
    about changes to our terms, conditions, and policies.

  • To protect our
    Services. 
    We may use your information as part of our
    efforts to keep our
    Website

    safe and
    secure (for example, for fraud monitoring and prevention).

  • To enforce our terms, conditions
    and policies for business purposes, to comply with legal and
    regulatory requirements or in connection with our contract.

  • To respond to legal requests
    and prevent harm. 
    If we receive a subpoena or
    other legal request, we may need to inspect the data we hold to
    determine how to respond.

  • To send you marketing and
    promotional communications.
    We and/or our third-party
    marketing partners may use the personal information you send to us for
    our marketing purposes, if this is in accordance with your marketing
    preferences. For example, when expressing an interest in obtaining
    information about us or our
    Website

    ,
    subscribing to marketing or otherwise contacting us, we will collect
    personal information from you. You can opt-out of our marketing emails
    at any time (see the "WHAT ARE YOUR PRIVACY
    RIGHTS
    " below).

  • Deliver targeted advertising to
    you.
     We may
    use your information to develop and display personalized content and
    advertising (and work with third parties who do so) tailored to your
    interests and/or location and to measure its effectiveness.

3. WILL YOUR INFORMATION
BE SHARED WITH
ANYONE?


In
Short:
  We only share information with
your consent, to comply with laws, to provide you with services, to
protect your rights, or to fulfill business
obligations.


We may process or share your data that we
hold based on the following legal basis:

  • Consent: We may
    process your data if you have given us specific consent to use your
    personal information for a specific purpose.

  • Legitimate Interests:
    We may process your data when it is reasonably necessary to achieve
    our legitimate business interests.

  • Performance of a
    Contract:
    Where we have entered into a contract with
    you, we may process your personal information to fulfill the terms
    of our contract.

  • Legal Obligations: We
    may disclose your information where we are legally required to do so
    in order to comply with applicable law, governmental requests, a
    judicial proceeding, court order, or legal process, such as in
    response to a court order or a subpoena (including in response to
    public authorities to meet national security or law enforcement
    requirements).

  • Vital Interests: We
    may disclose your information where we believe it is necessary to
    investigate, prevent, or take action regarding potential violations
    of our policies, suspected fraud, situations involving potential
    threats to the safety of any person and illegal activities, or as
    evidence in litigation in which we are involved.

More specifically, we may need to process
your data or share your personal information in the following
situations:

  • Business Transfers.
    We may share or transfer your information in connection with, or
    during negotiations of, any merger, sale of company assets,
    financing, or acquisition of all or a portion of our business to
    another company.

4.
DO WE USE COOKIES AND OTHER
TRACKING
TECHNOLOGIES?


In
Short: 
 We
may use cookies and other tracking
technologies to collect and store your
information.


We may use cookies
and similar tracking technologies (like web
beacons and pixels) to access or store
information. Specific information about how we
use such technologies and how you can refuse
certain cookies is set out in our Cookie
Notice
.

5.
HOW LONG DO WE KEEP YOUR
INFORMATION?


In
Short: 
 We
keep your information for as long as
necessary to fulfill the purposes outlined
in this privacy notice unless otherwise
required by law.


We will only keep
your personal information for as long as it is
necessary for the purposes set out in this
privacy notice, unless a longer retention period
is required or permitted by law (such as tax,
accounting or other legal requirements). No
purpose in this notice will require us keeping
your personal information for longer than

1 year

.

When we have no
ongoing legitimate business need to process your
personal information, we will either delete or
anonymize such information, or, if this is not
possible (for example, because your personal
information has been stored in backup archives),
then we will securely store your personal
information and isolate it from any further
processing until deletion is possible.

6.
HOW DO WE KEEP YOUR INFORMATION
SAFE?


In
Short: 
 We
aim to protect your personal information
through a system of organizational and
technical security
measures.


We have
implemented appropriate technical and
organizational security measures designed to
protect the security of any personal information
we process. However, despite our safeguards and
efforts to secure your information, no
electronic transmission over the Internet or
information storage technology can be guaranteed
to be 100% secure, so we cannot promise or
guarantee that hackers, cybercriminals, or other
unauthorized third parties will not be able to
defeat our security, and improperly collect,
access, steal, or modify your information.
Although we will do our best to protect your
personal information, transmission of personal
information to and from our

Website

is at your own risk. You should only access the

Website

within a secure environment.

7.
DO WE COLLECT INFORMATION FROM
MINORS?


In
Short:
  We do not
knowingly collect data from or market to
children under 18 years of
age.


We do not
knowingly solicit data from or market to
children under 18 years of age. By using the

Website

,
you represent that you are at least 18 or that
you are the parent or guardian of such a minor
and consent to such minor dependent’s use of the

Website

.
If we learn that personal information from users
less than 18 years of age has been collected, we
will deactivate the account and take reasonable
measures to promptly delete such data from our
records. If you become aware of any data we may
have collected from children under age 18,
please contact us at

[email protected]

.

8.
WHAT ARE YOUR PRIVACY
RIGHTS?


In
Short:
 

In
some regions, such as the European Economic
Area, you have rights that allow you greater
access to and control over your personal
information.

You
may review, change, or terminate your
account at any time.

In some regions
(like the European Economic Area), you have
certain rights under applicable data protection
laws. These may include the right (i) to request
access and obtain a copy of your personal
information, (ii) to request rectification or
erasure; (iii) to restrict the processing of
your personal information; and (iv) if
applicable, to data portability. In certain
circumstances, you may also have the right to
object to the processing of your personal
information. To make such a request, please use
the contact
details
provided
below. We will consider and act upon any request
in accordance with applicable data protection
laws.

If we are relying
on your consent to process your personal
information, you have the right to withdraw your
consent at any time. Please note however that
this will not affect the lawfulness of the
processing before its withdrawal, nor will it
affect the processing of your personal
information conducted in reliance on lawful
processing grounds other than consent.

 
If you are a
resident in the European Economic Area and you
believe we are unlawfully processing your
personal information, you also have the right to
complain to your local data protection
supervisory authority. You can find their
contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you are a
resident in Switzerland, the contact details for
the data protection authorities are available
here: https://www.edoeb.admin.ch/edoeb/en/home.html.

Cookies and
similar technologies:
Most Web
browsers are set to accept cookies by default. If
you prefer, you can usually choose to set your
browser to remove cookies and to reject cookies. If
you choose to remove cookies or reject cookies, this
could affect certain features or services of our

Website

.
To opt-out of interest-based advertising by
advertisers on our

Website

visit http://www.aboutads.info/choices/.

9.
CONTROLS FOR DO-NOT-TRACK
FEATURES


Most web browsers and
some mobile operating systems and mobile
applications include a Do-Not-Track ("DNT") feature
or setting you can activate to signal your privacy
preference not to have data about your online
browsing activities monitored and collected. At this
stage no uniform technology standard for recognizing
and implementing DNT signals has been finalized. As
such, we do not currently respond to DNT browser
signals or any other mechanism that automatically
communicates your choice not to be tracked online.
If a standard for online tracking is adopted that we
must follow in the future, we will inform you about
that practice in a revised version of this privacy
notice. 

10. DO
CALIFORNIA RESIDENTS HAVE SPECIFIC
PRIVACY
RIGHTS?


In
Short: 
 Yes, if
you are a resident of California, you are
granted specific rights regarding access to your
personal information.


California Civil Code
Section 1798.83, also known as the "Shine The Light"
law, permits our users who are California residents
to request and obtain from us, once a year and free
of charge, information about categories of personal
information (if any) we disclosed to third parties
for direct marketing purposes and the names and
addresses of all third parties with which we shared
personal information in the immediately preceding
calendar year. If you are a California resident and
would like to make such a request, please submit
your request in writing to us using the contact
information provided below.

If you are under 18
years of age, reside in California, and have a
registered account with

the Website

,
you have the right to request removal of unwanted
data that you publicly post on the

Website

.
To request removal of such data, please contact us
using the contact information provided below, and
include the email address associated with your
account and a statement that you reside in
California. We will make sure the data is not
publicly displayed on the

Website

,
but please be aware that the data may not be
completely or comprehensively removed from all our
systems (e.g. backups, etc.).


CCPA
Privacy Notice


The
California Code of Regulations
defines a "resident"
as:

(1) every individual
who is in the State of California for other than a
temporary or transitory purpose
and
(2) every individual
who is domiciled in the State of California who is
outside the State of California for a temporary or
transitory purpose

All other individuals
are defined as "non-residents."

If this definition of
"resident" applies to you, we must adhere to certain
rights and obligations regarding your personal
information.

What
categories of personal information do we
collect?


We have collected the
following categories of personal information in the
past twelve (12) months:


Category


Examples


Collected

A.
Identifiers
Contact
details, such as real name, alias,
postal address, telephone or mobile
contact number, unique personal
identifier, online identifier,
Internet Protocol address, email
address and account
name

NO

B.
Personal information categories
listed in the California Customer
Records statute
Name,
contact information, education,
employment, employment history and
financial
information

YES
C.
Protected classification
characteristics under California or
federal law
Gender
and date of
birth

NO

D.
Commercial
information
Transaction
information, purchase history,
financial details and payment
information

NO

E.
Biometric
information
Fingerprints
and voiceprints

NO

F.
Internet or other similar network
activity
Browsing
history, search history, online
behavior, interest data, and
interactions with our and other
websites, applications, systems and
advertisements

NO

G.
Geolocation
data
Device
location

NO

H.
Audio, electronic, visual, thermal,
olfactory, or similar
information
Images
and audio, video or call recordings
created in connection with our
business
activities

NO

I.
Professional or employment-related
information
Business
contact details in order to provide
you our services at a business
level, job title as well as work
history and professional
qualifications if you apply for a
job with us

YES

J.
Education
Information
Student
records and directory
information

NO

K.
Inferences drawn from other personal
information
Inferences
drawn from any of the collected
personal information listed above to
create a profile or summary about,
for example, an individual’s
preferences and
characteristics

NO

We may also collect
other personal information outside of these
categories instances where you interact with us
in-person, online, or by phone or mail in the
context of:

  • Receiving help
    through our customer support
    channels;

  • Participation in
    customer surveys or contests;
    and

  • Facilitation in
    the delivery of our Services and to respond to
    your inquiries.

How do we use
and share your personal
information?

More
information about our data collection and
sharing practices can be found in this
privacy notice

.

You may
contact us

by email
at 

[email protected],

or by referring to the
contact details at the bottom of this
document.

If you are
using an authorized agent to exercise your
right to opt-out we may deny a request if
the authorized agent does not submit proof
that they have been validly authorized to
act on your behalf.

Will
your information be shared with anyone
else?


We may
disclose your personal information with our
service providers pursuant to a written
contract between us and each service
provider. Each service provider is a
for-profit entity that processes the
information on our behalf.

We may use
your personal information for our own
business purposes, such as for undertaking
internal research for technological
development and demonstration. This is not
considered to be "selling" of your personal
data.

Sigmoidal LLC
 has not
disclosed or sold any personal information
to third parties for a business or
commercial purpose in the preceding 12
months.
Sigmoidal
LLC
will not sell
personal information in the future belonging
to website visitors, users and other
consumers.

Your
rights with respect to your personal
data


Right to
request deletion of the data - Request
to delete


You can ask
for the deletion of your personal
information. If you ask us to delete your
personal information, we will respect your
request and delete your personal
information, subject to certain exceptions
provided by law, such as (but not limited
to) the exercise by another consumer of his
or her right to free speech, our compliance
requirements resulting from a legal
obligation or any processing that may be
required to protect against illegal
activities.

Right to be
informed - Request to
know


Depending on
the circumstances, you have a right to
know:

  • whether we
    collect and use your personal
    information;

  • the
    categories of personal information that
    we collect;

  • the
    purposes for which the collected
    personal information is used;

  • whether we
    sell your personal information to third
    parties;

  • the
    categories of personal information that
    we sold or disclosed for a business
    purpose;

  • the
    categories of third parties to whom the
    personal information was sold or
    disclosed for a business purpose;
    and

  • the
    business or commercial purpose for
    collecting or selling personal
    information.

In accordance
with applicable law, we are not obligated to
provide or delete consumer information that
is de-identified in response to a consumer
request or to re-identify individual data to
verify a consumer
request.

Right to
Non-Discrimination for the Exercise of a
Consumer’s Privacy
Rights


We will not
discriminate against you if you exercise
your privacy rights.

Verification
process


Upon receiving
your request, we will need to verify your
identity to determine you are the same
person about whom we have the information in
our system. These verification efforts
require us to ask you to provide information
so that we can match it with information you
have previously provided us. For instance,
depending on the type of request you submit,
we may ask you to provide certain
information so that we can match the
information you provide with the information
we already have on file, or we may contact
you through a communication method (e.g.
phone or email) that you have previously
provided to us. We may also use other
verification methods as the circumstances
dictate.

We will only
use personal information provided in your
request to verify your identity or authority
to make the request. To the extent possible,
we will avoid requesting additional
information from you for the purposes of
verification. If, however, if we cannot
verify your identity from the information
already maintained by us, we may request
that you provide additional information for
the purposes of verifying your identity, and
for security or fraud-prevention purposes.
We will delete such additionally provided
information as soon as we finish verifying
you.

Other
privacy rights

  • you may
    object to the processing of your
    personal data

  • you may
    request correction of your personal data
    if it is incorrect or no longer
    relevant, or ask to restrict the
    processing of the data

  • you can
    designate an authorized agent to make a
    request under the CCPA on your behalf.
    We may deny a request from an authorized
    agent that does not submit proof that
    they have been validly authorized to act
    on your behalf in accordance with the
    CCPA.

  • you may
    request to opt-out from future selling
    of your personal information to third
    parties. Upon receiving a request to
    opt-out, we will act upon the request as
    soon as feasibly possible, but no later
    than 15 days from the date of the
    request submission.

To exercise
these rights, you can contact
us 

by email at
[email protected],

or by referring to the
contact details at the bottom of this document. If
you have a complaint about how we handle your data,
we would like to hear from you.

11.
DO WE MAKE UPDATES TO THIS
NOTICE?
     


In
Short: 
Yes, we will
update this notice as necessary to stay
compliant with relevant
laws.


We may update
this privacy notice from time to time. The
updated version will be indicated by an
updated "Revised" date and the updated
version will be effective as soon as it is
accessible. If we make material changes to
this privacy notice, we may notify you
either by prominently posting a notice of
such changes or by directly sending you a
notification. We encourage you to review
this privacy notice frequently to be
informed of how we are protecting your
information.

12.
HOW CAN YOU CONTACT US ABOUT
THIS
NOTICE?
     

If you have
questions or comments about this notice, you
may

contact our Data
Protection Officer (DPO),
Mariusz
Kierski
, by email at

[email protected]
, by
phone at
+1-347-779-2050,

or by post to:

Sigmoidal LLC

Mariusz
Kierski

757 Third Avenue,
20th Floor

New York

, NY

10017

United States

13.
HOW CAN YOU REVIEW, UPDATE,
OR DELETE THE DATA WE
COLLECT FROM
YOU?
     

Based on the
applicable laws of your country, you may
have the right to request access to the
personal information we collect from you,
change that information, or delete it in
some circumstances. To request to review,
update, or delete your personal information,
please
visit: [email protected]

. We will respond
to your request within 30 days.

[email protected]
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