Table of Contents
- CATEGORIES OF PERSONAL DATA WE COLLECT
- HOW DO WE COLLECT YOUR PERSONAL DATA
- HOW AND WHY WE USE YOUR PERSONAL DATA
- YOUR CONSENT
- HOW WE WILL KEEP YOUR DATA SECURE
- HOW LONG WE WILL KEEP YOUR PERSONAL DATA FOR?
- WHO HAS ACCESS TO YOUR PERSONAL DATA?
- DO WE TRANSFER YOUR PERSONAL DATA OUTSIDE OF THE EUROPE?
- WHAT RIGHTS DO YOU HAVE?
- DIRECT MARKETING
- PERSONAL DATA OF MINORS
- CONTACT US
We are committed to protecting your privacy. When you use our websites, we will collect certain information that can be used to identify you (“personal data”).
Signal is the “data controller” of the personal data we collect. This means that we determine the purposes and means of the processing, i.e. why and how of the processing. It also means we are responsible for responding to your questions and requests in relation to the personal data we hold about you.
2. CATEGORIES OF PERSONAL DATA WE COLLECT
We may collect the following types of personal data from you when you use our website:
- Contact details: this is information that allows us to contact you, such as your name, address, email addresses and social media handles/user names.
- Personal data in notifications you submit to us: if you submit information to us about our services through our website, for example, through Contact Us form, we will collect any personal data you include within your report.
- Records of your discussions with us: when you contact us using the contact options on the website (whether by email, an online form or through social media, such as through Twitter or on Facebook) or apps, we may keep a record of the information you provide when doing this.
- How you use our website: we collect information about the pages you look at and how you use them.
- Navigation data:
In the course of their normal operations, the information systems and software procedures used to make the website function collect some personal data whose transmission is implicit when using Internet communication protocols.
Such data includes: IP addresses, the type of browser used, the operating system, the domain name and the address of web sites from/to which access/exit was made, information about the pages visited by users within the site, the time of access, how long was spent on each page, an analysis of the internal path and other parameters relating to the operating system and IT environment of the user.
Such technical/IT data is gathered and utilised exclusively on an aggregate and anonymous basis and may be utilised to determine responsibility in case of alleged IT/electronic offences causing damage to the website.
This personal information does not directly identify you by name but could be used to identify that a specific computer or device has accessed to the website.
- Location information: your smartphone or computer’s IP address may tell us your approximate location when you connect to our website (this will usually be no more precise than a Country or city location).
When you provide us with your personal data through our online form, the form will identify which fields are “required” and which are not. The “required” fields are limited to the items which are essential for providing our services (e.g. email address when we provide information by email). If you do not fill in such fields essential to providing our services, we are unable to offer our services to you.
3. HOW DO WE COLLECT YOUR PERSONAL DATA
We will collect personal data from a number of sources. These include:
- Directly from you: for example, we will collect personal data directly from you when you set up an account with us, purchase services from us, complete forms we provide to you, make a notification about our services, contact us by email, or communicate with us directly in some other way (such as through social media).
- Our website: we will collect information we observe about the way you use our website.
4. HOW AND WHY WE USE YOUR PERSONAL DATA
We collect and use your personal data for the purposes below:
To improve your experience with us and on our website:
- Contact and communicate with you in relation to our business and services;
- Provide our services to you;
- Manage your account on our websites, and apps;
- In the course of investigating misuse of your account, fraud and debt collection;
- Identify you and authenticate your access rights access to our websites, systems and apps;
- To respond to your queries and provide you with information when you request it or when we believe our services may be of interest to you. If we intend to share electronic marketing with you, we will ask for your consent where required and you can opt out at any time;
- Invite you to provide feedback, participate in research, surveys or attend events;
- Personalise your experience when interacting with Signal;
- Perform analytics, market research and segmentation to understand your preferences, improve our services and our communications to you.
To manage and improve our business processes and operations:
- Manage the security of our network and information systems;
- Perform data analysis, audits and research to help us deliver and improve our digital platforms, content and Signal services;
- Monitor and analyse trends, usage and activity relating to our services to understand which parts of our services are of most interest and improve them accordingly;
- Prepare and perform management reporting and analysis, including analysis and measurement method.
- Perform online advertising;
- Conduct market research;
- Conduct direct marketing;
- Achieve other purposes.
To achieve other purposes, we use your personal data:
- To follow applicable laws and regulations;
- To inform you, when legally required, of changes to our terms, conditions, and policies;
- To investigate and take action against illegal or harmful user behaviour;
- To protect Signal’s essential interests or those of third parties.
We will only use your personal data when the law allows us to. Most commonly, we will rely on the lawful grounds listed below when we use your personal data.
- Consent: if you have consented to the collection and use of your personal data.
- Contract: if we need to use your personal data to perform a contract between us. For example, where we enter a contract with you to provide you with perform our services.
- Legal obligation: if we need to comply with a legal obligation.
- Legitimate interest: if our use of your personal data is for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. This includes carefully considered and specific purposes that enable us to enhance the services we provide, but which we believe also benefit our customers and ultimate consumers. It also includes the legitimate interest we have in assessing our services performance and safety and meeting our industry and regulatory obligations.
5. YOUR CONSENT
Under certain circumstances, where the legal basis for using your personal data is that you have provided your consent, you may withdraw your consent at any time. If you withdraw your consent, this will not make processing which we undertook before you withdrew your consent unlawful.
You can withdraw your consent by contacting us using the contact details listed below.
6. HOW WE WILL KEEP YOUR DATA SECURE
We have put in place appropriate security measures to prevent your personal data from being accidentally lost or used, accessed, altered or disclosed in an unauthorised way.
In addition, we limit access to your personal data by our employees. They will only use your personal data on our instructions and are required to keep your personal data confidential.
We have put in place procedures to deal with suspected data security breaches and will notify you and any applicable regulators of breaches in accordance with relevant legal requirements.
7. HOW LONG WE WILL KEEP YOUR PERSONAL DATA FOR?
In accordance with applicable data protection laws, we will process the data provided by you for the duration of the execution of the requested services and will retain it for a minimum period of time after the duration for the purpose of completing administrative activities including confirming whether we have received your payment for our services (if applicable) or appropriately handling your possible inquiries for a reasonable period of time, as well as for the time necessary to fulfil legal obligations. We store data for longer periods when it is required by law and for the time necessary to fulfil legal obligations.
If you have authorised the direct marketing activities described below in section 11 and the profiling activities described in section 12, the data collected will be retained for as long as the registration is active, and will be deleted after a minimum period of time for the purpose of completing our administrative activities.
8. WHO HAS ACCESS TO YOUR PERSONAL DATA?
We may share personal information with the following:
- Our staff – your personal data will be accessed by our staff but only where this is needed for their job role.
- Companies managing technical systems and services managed in the cloud and located outside the area of the European Union, as specified below.
9. DO WE TRANSFER YOUR PERSONAL DATA OUTSIDE OF THE EUROPE?
To ensure that your personal data is secure, we will only transfer your information to countries outside of Europe where we do so in accordance with the applicable data protection laws. This requires that one of the following conditions applies:
- the government body in charge of data protection of you has decided that the country provides an adequate level of protection for your personal data;
- the transfer is subject to a legally binding and enforceable commitment on the recipient to protect the personal data;
- the transfer is made subject to binding corporate rules; or
- the transfer is based on a derogation from the restrictions on transferring personal data outside of the EU.
We inform you that this transfer of personal data could be risky as the Court of Justice of the European Union considered that U.S. domestic law does not satisfy requirements that are essentially equivalent to those required under EU law, mainly because certain programmes enabling access by U.S. public authorities to personal data transferred from the EU to the U.S. for national security purposes.
10. WHAT RIGHTS DO YOU HAVE?
Under certain circumstances you have the right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate personal data we hold about you corrected.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. Please note that where personal data are processed for direct marketing purposes and profiling, to the extent that it is related to such direct marketing, you can object at any time to processing.
- Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you under certain circumstances, for example if you want us to restrict processing while the accuracy of the personal data is being established.
- Request that we transfer personal data that you have provided to us to you or another party.
- Request not to be subjected to automated decision-making. We will only use automated decision making and profiling for our online operations in limited circumstances.
You can exercise your rights by following this link: https://vectorinc.co.jp/en/privacy
We will immediately investigate any request you make and will respond to you within a month of your request. That period may be extended by us for a further two months where this is needed to help us respond properly (for example if the request is complicated for us to deal with and we need more time) but we will let you know the reasons for the delay.
If we decide to not take action on the request, we will inform you of the reasons for not taking action.
If you do not agree with a decision we make in relation to a rights request or believe that we are in breach of data protection laws in Europe, then you can lodge a complaint with a data protection regulator in Europe.
11. DIRECT MARKETING
We may contact you via electronic methods with information about our services. The processing of personal data for this purpose is based on your consent.
The provision of your data for the purposes referred to in this point is optional. The non-submittal of your data for these purposes and your lack of consent does not affect the conclusion of the contract or the provision of the services you have requested, but it makes it impossible to send you communications on new initiatives, offers or to improve our level of service to you.
When you use our website we may collect information about your use of the website through cookies.
A cookie is a small text file, which contains small amounts of information that passes to the device you are viewing the website on, through your web browser, so that the website can recognise and remember your device.
We may use profiling cookies or third-party cookies to carry out automatic processing aimed at analysing certain personal aspects such as your preferences, your habits, your purchases, your behaviour also in order to be able to send you information material and personalised offers selected according to your interests. Third-party cookies may be installed either directly by parties with whom we have concluded agreements, or by third parties with whom we have only indirect relationships through intermediaries.
The processing of personal data for this purpose has its legal basis in your consent.
The provision of your data for the purposes referred to in this point is optional. The non-submittal of your data for these purposes and your lack of consent will not prejudice the conclusion of the contract or the provision of the services you have requested, but it will make it impossible to send you communications or personalised information, suitable to your interests but possibly only generic and mass-market (if you have authorised to the processing referred to in the previous point Direct Marketing).
Please consult our Cookies Policy if you like to have more information.
13. PERSONAL DATA OF MINORS
We are offering our online services only to persons aged 18 years old or over. We will not consciously collect data from people under 18 years old without consent of their parent or legal guardians.
14. CONTACT US
SIGNAL, Inc. firstname.lastname@example.org
LAST UPDATED: [01/09/2021]