SENDERSYSTEMS LIMITED (“SignalHire”, “we”, “us”, or “our”) operates the business known as SignalHire, which provides services, defined below, which include through the website www.signalhire.com (“Site”). We reserve the right to make changes to this Policy at any given time. If you want to make sure that you are up to date with the latest changes, please be sure to check back periodically.
A About us. SignalHire offers various services and tools designed specifically for recruiters, marketers, and HR specialists who are seeking to make contact with business professionals for employment or marketing purposes, or to obtain industry, market or competitor analysis. SignalHire offers these Services through its Site, or through other tools, to its Users, including access to its contacts search engine tool. The main purpose of this is to provide accurate contact information when Users are seeking to communicate B2B with professionals. Our Prospects Database contains information related to Professional Individuals, and has been curated and indexed from publicly available sources across the internet. Any reference to any of these services of ours, and to our Site, is collectively referred to as our “Services” in this Policy.
B Protection of minors. We do not solicit or target persons under 18 years of age. We do not knowingly collect any information relating to children under the age of 18. If we discover that a child under 18 has provided us with personal information, or we have otherwise came into possession of personal information of a child, we will promptly delete such personal information from our systems.
This Policy applies to any visitor to our Site, any User of our Services, or any Professional Individuals.
‘Site Visitor’ means you, if you are not considered a User, but are any other person who is accessing or otherwise making use of our Services, including this Site (including a Professional Individual). If you are a Professional Individual (as defined in this Policy) and you visit our Site for any reason (for example to view any Professional Profile or our contact information page), the provisions throughout this policy related to Site Visitors are deemed to also apply to you in that context.
B. UNDERSTANDING APPLICABLE PRIVACY LAWS
Notwithstanding our compliance with GDPR, for any person resident outside of Europe, we do comply with the following other named laws and regulations if a User or Professional Individual is resident (a) in the UK, we comply with the UK’s Data Protection Act 2018 and the UK’s Retained GDPR, or (b) in California, USA, we comply with the California Consumer Privacy Act (as amended by the 2020 legislation, if applicable to you) or (c) in Virginia, USA, we comply with the Virginia Consumer Data Protection Act (Va. Code Ann. §§ 59.1-575 to 59.1-585)
C. LAWFUL BASIS FOR PROCESSING PERSONAL DATA
Under certain Data Laws that may apply to our processing of personal data belonging to Users or Professional Individuals, we require a lawful basis for processing that personal data.
For Site Visitors and Users (meaning customers or those who use our services such as job applicants), our lawful basis for processing Personal Data is ‘contract’, meaning for the purposes of performing a contract to provide the Services to you, or for taking steps prior to entering into a contract. Where this is not appropriate, we obtain the relevant consents from you and consent is the lawful basis. Where neither contract nor consent is appropriate, legitimate interests is the lawful basis.
For Professional Individuals, the lawful basis for processing personal data belonging to that Professional Individual is ‘legitimate interests’.
A. How we obtain your data. We may collect personal data about you if you are a Professional Individual from either public sources or third parties, or when you contact us. In either case the career information we obtain about you may include your name, location, work experience, education history (including language skills), phone number, email address, links to your social media profile(s) and any avatar or other such profile or photo.
B. Public information. We may collect personal data about you through publicly available information sources on the web, much like a search engine, we index this information and make it available to our Users through the Prospect Database, and we display parts of this information in Professional Profiles on our Site. Given the vast amount of information indexable from the internet and public sources it may not always be possible to trace the exact source of your information.
C. From third parties. We may collect personal data about you through other Users, Site Visitors or other third parties who may share your personal data with us, or who may use our or third party tools such as browser extensions or plugins to share you personal data with us through the Services.
D. When you contact us. If you contact us in any manner we will keep any information you provide to us including records of correspondence, and you should be aware that we monitor and may record telephone calls and written correspondence for training and security purposes.
E. Visits to our Site or use of Services. If you visit our Site for any reason (see other sections in this Policy related to Site Visitors).
A. How we obtain information about you. We collect information about you if you are a Site Visitor, or User, directly from you, from third parties, and automatically through your use of our Services. We may combine information collected from or about you from these various sources. You have choices about the data we collect. When you are asked to provide personal data, you may decline. But if you choose not to provide data that is necessary to provide a product or feature, you may not be able to use that product or feature. The data we collect depends on the context of your interactions with us and our Services, the choices you make, including your privacy choices, and the products and features of our Services that you use or otherwise access.
B. We collect information from you when you sign up to our Services
C. We collect data when you communicate with us
D. We collect data when you are active on our Site or using our Services
If you’re just browsing our Site, editing or otherwise using your account, making any financial transactions on our Site, or otherwise making any use of our Services we will collect different data as you do it, some of which may be considered personal data:
E. Information We Collect Automatically Through Our Services.
We automatically collect information about you through your use of our Services, including, without limitation:
F. Information We Collect About Users from Third Parties.
We also collect information about you from third parties. For example, if you sign up to, or log into our Services using a third-party platform (e.g., Facebook, Google, or LinkedIn), then we may collect the following information:
We process data, including information about you if you are a Professional Individual in the following ways for legitimate purposes (in addition to any use if you become a Site Visitor or User, see Section 8):
A. Providing and Improving the Services.
We use the information we collect about you:
B. Communications (see Section 10 for more details)
We use the information we collect about you:
C. Research and Analytics.
We use the information we collect about you:
D. Protecting Rights and Interests
We use the information we collect about you:
E. Legal Compliance.
We use the information we collect about you to comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; to respond to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request, whether formal or informal, from law enforcement or a governmental authority.
F. Use of non-personal information
We use aggregate information about Users, Site Visitors and Professional Individuals, and non-personal information that we collect:
A. Disclosing information.
We may disclose your information (meaning personal information and User Content, and any other information whether personal or not), as described to you in this Policy and any applicable supplemental privacy statements applicable depending on your location and Data Laws.
B. Additional sharing of data relating to Professional Individuals.
In addition to the remainder of this section 9, for Professional Individuals, we may share information about you within our Prospects Database and/or Professional Profiles, meaning that the information obtained about you may be shared with Users for the purposes of us delivering the Services to them.
C. Sharing with our affiliates.
D. Sharing to third party service providers
We may disclose your information to our vendors, service providers, agents, or others who perform functions on our behalf. For example, we may disclose your information to third-party service providers to process payments on our behalf.
E. Sharing for corporate activity purposes
We may disclose your information to another entity in connection with, including during negotiations of, an acquisition or merger, sale or transfer of a business unit or assets, bankruptcy proceeding, or as part of any other similar business transfer to a buyer or prospective buyer of our business, our professional advisers, such as our lawyers or compliance advisors, or accountants, where it is necessary for them to advise and to any other persons if we are under a duty to disclose or share your information in order to comply with any legal obligation.
F. Sharing for protection of rights and interests
G. Sharing for legal or regulatory compliance
We may be required by law e.g. through potential or actual litigation, court order, public or governmental authorities, or rules and regulations within or out with your country of residence to disclose all or part of your information to third parties. We may also deem it necessary to make such a disclosure in the event of an issue of national security, law enforcement or other such similar situations as we deem necessary including, for example, allegations of alleged infringement of copyright, trade marks or other third parties’ rights by users or any criminal activity, whether formal or informal, from law enforcement or a government official or regulatory body.
H. Sharing of aggregate and anonymised information
We may disclose aggregate, anonymous, or de-identified information about users for marketing, advertising, research, compliance, or other purposes.
A. Marketing to our Users.
We may share your information with our affiliates or third parties to develop and deliver targeted advertising to you of our or third-party products and services, or to help us to prepare marketing reports. We may send you information about our or our affiliates’ products and services, news and offers, and selected third party products and services that we think may be of interest to you. We may do this by contacting you through your email address or mobile phone number that you have provided. Any communication received from us, as consented to by you, will clearly state that it is being sent by us. You have the option to opt-out of our marketing communications at any time (see below).
B. Third party marketing to Users.
If you have consented to receive marketing communications from third parties your data may be passed on to such third parties as we enter into data sharing agreements with, from time to time, for marketing and analytical reporting purposes. We cannot be held liable for the content of the third party’s communications or products/services they are promoting. If you have provided this consent, but change your mind, you can opt-out at any time (see below). Please be advised that you will also require to contact the individual third parties who have been marketing to you if you wish to stop receiving their communications directly.
C. Opting Opt from previously consented marketing.
If you, a User, or a person who has previously consented to receive marketing communications, have changed your mind about the marketing consent you have granted to us, you can follow the opt out procedures contained in any marketing email, or you can opt out by emailing us at firstname.lastname@example.org. Please be aware that it may take up to ten (10) business days for us to process opt-out requests.
D. Opt-out exceptions.
If you request to opt out of our marketing or communication emails, please be aware that opting out of marketing emails will not impact upon email communications you may continue to receive which are relevant to the administration of your account, or relative to any other Services you have requested to receive from us (unless those have been opted out of also), or which are required in order to communicate with you regarding any support, response, regulatory, legal or other permitted use as described in this Policy.
A. Third party marketing to you.
B. Communications from us.
We will only communicate with you if required to by law or regulation or to respond to any communication you instigate. If you want to exercise your right to remove your information from our Prospects Database or any Professional Profile, please complete our Opt Out Form here.
A. Retaining your data.
B. Storing your data.
Data Laws give users a number of rights which you are free to exercise at any time regarding any personal data that you have provided to us and we generally apply the rights afforded by the GDPR to all users, even if they are not resident in Europe. We will respond to requests to access or delete your personal data promptly and in any case within any time limits set by applicable Data Laws (if applicable to us in your case). We have summarised the rights here and how you can exercise them to ensure that we are reasonably and fairly processing your personal information in line with your rights, however you should obtain your own legal advice if you wish to rely on any legislative rights not covered here which you believe in good faith we have a duty to respond to. Subject to our own legitimate interests and any regulatory requirements placed upon us we will endeavour to meet requests made in exercising your rights.
B. Specific rights for residents of California, USA and Virginia, USA.
If you are a resident of California, USA or Virginia, USA, your attention is drawn to Section 14.
C. Verification may be needed.
We may require you to provide identification if you are exercising some of these rights, for cases where it is not immediately obvious that you are truly the person to whom the personal information relates, as we need to be certain before making any changes to someone’s personal information that it is your information (or you have that person’s authority to act for them). If identification documents are requested as part of the process, that document will only be collected, stored and processed by us for the sole purpose of confirming your identity in response to your request, and upon completing your request we will delete it.
D. Use of your email address.
We may need to communicate with you in response to your request, and we may require to update you on progress/confirm outcomes. We do this by email and when you complete the forms to contact us you will have the ability to consent to us using your email for this purpose. If you contact us by email, we assume that you are consenting to receiving a response from us by instigating the communication. Where any rights exercised by you result in you seeking to object to us processing your personal information or otherwise deleting your personal information, then in order to ensure we do not process any personal information of yours in future, we will retain your email address for the purpose of our opt out list only, and we will delete or anonymise all other information held.
E. Retaining other information.
Sometimes we need to keep a record of some data for security purposes (for example to assist law enforcement agencies with any criminal investigations or other regulatory authorities or dispute matters) or for payment processing (to prove to banks that we were authorised to take payments from you if you pay to use the services), even if you have requested removal of your data. Any such data retained will only be used for these limited purposes.
F. Important information about removal.
Removing your personal information from our Services will not necessarily mean that the original source of the personal information (other publicly available website materials not owned by us) will be removed, and we are only responsible for removing information within our control or possession, which is particularly important if you are a Professional Individual.
A. Right to access personal data we hold about you
What you can do. You can request a copy of the personal data that we hold about you.
How to make the request. Generally, to obtain a copy of your data, simply email email@example.com stating that you wish to request a copy of all personal data that we have about you, and you must include your name, email address and any relevant information to help us locate your information for example the URL Professional Profile if applicable.
The process. Upon receipt of your request and following verification of your identity if required by us to process your request, we will endeavour to provide the information that we are permitted to share (which may be redacted if it includes personal data or another person) to you within 14 to 30 days (or sooner if required by Data Laws). If you seek to make multiple requests within a short time period, we reserve the right to charge a nominal fee to cover the cost of our response to multiple access requests.
B. Right to amend/correct the data we hold on you
What you can do. We want to make sure our records are up to date and accurate, and in some countries Data Laws require us to allow you to correct or amend your personal data.
How to make the request. To request a correction or amendment to your personal data, simply email firstname.lastname@example.org stating that you wish to request a copy of all personal data that we have about you, and you must include your name, email address and any relevant information to help us locate your information for example the URL Professional Profile if applicable.
The process. Upon receipt of your request and following verification of your identity if required by us to process your request, we will review the changes you wish to make, and within a reasonable and practical time period (or earlier if required by Data Laws) our customer support team will ensure that your personal information held is corrected/updated/amended in line with your request, and they may inform you of this upon completion.
C. Objecting to processing of your personal data
It’s ok to change your mind about what personal data you are allowing us to use and keep and what you don’t want us to use or keep. We have to advise you however, that opting out of some personal data processing/storage may result in a loss of functionality of the Services and a reduced user experience.
What you can do. You can tell us at any time that you want us to stop processing your personal information, if (i) you are a Professional Individual and we are processing your personal information under a lawful basis within our Prospects Database/Professional Profiles and you do not wish for that to happen, or (ii) you are a User or Site Visitor, or any other person, who has previously consented to data processing but has now changed your mind and want to revoke any prior consent.
How to make the request
D. Your right to ask us to delete or destroy your personal information:
What you can do
E. Additional rights for residents of UK or EU only
(i) Right to be “be forgotten”. This right is for the erasure of your personal data, and is for residents of the UK and EU only. Please follow the process outlined at Section 13D (above). If you have any problems, please contact email@example.com
(ii) Right to data portability. This right allows you to receive personal information in a structured, commonly used, and machine-readable format and is for residents of the UK and EU only. Please email firstname.lastname@example.org with your name, email and any relevant additional information to enable us to process your request.
A. If you are a User, or Professional Individual, that is resident in California, USA or Virginia, USA, we have prepared this Notice to comply with the US Data Laws.
C. Categories of personal Information Collected. We collect identifiers
(‘Identifier Data’), internet or other electronic network activity information (‘E-Data’),
geolocation data (‘Location Data’) and Employment-related information (‘Employment Data’).
Please note that under Virginia state laws, personal data does not include information which is
publicly available. We do not collect sensitive personal information as defined by US Data Laws
E. Sources of the personal information collected. In addition to anything else stated within this Policy, the sources of personal information collected are:
H. Automated decision making/profiling/targeted advertising. We do not use automated decision making or profiling or targeted advertising.
I. Your rights depending on whether you live in California, USA or Virginia, USA:
D. Detailed cookie usage. We may use the following cookies with the functions and purposes explained here:
E. Do not track. Our Services do not currently respond to any web or mobile Do Not Track signals.
A. What we are doing. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Site/Services and any transmission is at your own risk. We take reasonable administrative, physical, and electronic measures designed to safeguard and protect your information from unauthorized access or disclosure. This includes using secure software and storing your information in encrypted form behind a firewall designed to block access from outside our network. Although we use commercially reasonable efforts to safeguard the privacy of your information, transmissions on the Internet cannot be made absolutely secure. Where any information is required to be disclosed to third party service providers to ensure the provision of Services to you, all such third parties are subject to strict agreements to ensure the continued safeguarding of your data as much as possible. We assume no responsibility or liability for disclosure of any of your information due to errors in transmission, unauthorized third-party access, or other causes beyond our reasonable control.
B. What you should do to protect yourself. You should take steps to protect against unauthorized access to your device and your User account by, among other things, choosing a robust password that nobody else knows or can easily guess and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.
A. LIMITATION OF LIABILITY. SOME JURISDICTIONS DO NOT ALLOW THE EXCLUSION OR LIMITATION OF CERTAIN DAMAGES, SO THE FOLLOWING LIMITATION AND EXCLUSIONS MAY NOT APPLY TO YOU AS A PERSON, A SITE VISITOR, A PROFESSIONAL INDIVIDUAL OR A USER OF OUR SERVICES. TO THE FULLEST EXTENT ALLOWED BY APPLICABLE LAW, UNDER NO CIRCUMSTANCES AND UNDER NO LEGAL THEORY (INCLUDING, WITHOUT LIMITATION, TORT, CONTRACT, STRICT LIABILITY, OR OTHERWISE) SHALL SENDERSYSTEMS LTD (OR ITS LICENSOR(S) OR SUPPLIER(S)) BE LIABLE TO YOU OR TO ANY OTHER PERSON FOR (A) ANY INDIRECT, SPECIAL, INCIDENTAL, OR CONSEQUENTIAL DAMAGES OF ANY KIND, INCLUDING DAMAGES FOR LOST PROFITS, LOSS OF GOODWILL, WORK STOPPAGE, ACCURACY OF RESULTS, OR COMPUTER FAILURE OR MALFUNCTION, OR (B) ANY AMOUNT, IN THE AGGREGATE, IN EXCESS OF THE GREATER OF (I) $100 OR (II) FOR USERS, THE AMOUNTS PAID BY YOU TO SENDERSYSTEMS LTD IN CONNECTION WITH THE SERVICES IN THE THREE (3) MONTH PERIOD PRECEDING THIS APPLICABLE CLAIM, OR (C) ANY MATTER BEYOND OUR REASONABLE CONTROL.
|Our company name:||SENDERSYSTEMS LIMITED|
Cornerstone Business Centre Suite 1, Level 2|
16th September Square
|Our support email:||email@example.com|
Should you have any reason to contact our Data Protection & Information Officer, they can be
contacted by writing to the above address, marked for their attention, or by emailing
Any communications to the DPIO which do not relate to data protection and privacy matters will not be responded to.
In accordance with GDPR, as we are established in Europe, we are not required to designate an EU Representative and all enquiries may be made to the Data Protection & Information Officer. However, in compliance with the UK Data Protection Act 2018, we are required to designate a UK Representative and we use a third party representative for this service which is Elpha Fox Privacy, 7 Bell Yard, London, WC2A 2JR
We hope that we will be able to directly resolve any complaint that you may have, however, if you are not happy with how we handle any complaint, depending on your place of residence, you may be able to raise a complaint at any time to your country’s national data protection authority.