Singuli Privacy Policy

Effective Date: March 24th, 2023

This privacy policy (the “Privacy Policy”) governs how Singuli, Inc. (“Singuli”, “we”, “our” or “us”), obtains, stores, uses and discloses information, including personal information, in connection with the use of our website, https://singuli.co, and any other website that we operate (each, together with its sub-domains, content and services, a “Site”), and our data management service platform, APIs, interfaces, and other services provided by us in which a link to this Privacy Policy is displayed or incorporated by reference (together with our Site, collectively referred to herein as the “Service”). This Privacy Policy also applies to personal information we collect offline, such as information collected when you contact us for support.

This Privacy Policy does not apply to information we process as a data processor or service provider on behalf of our customers. We do not control how customers use information we process on their behalf, and you should consult with the applicable customer to understand how they use information they receive from us.

By accessing or using the Service, you acknowledge the applicability of this Privacy Policy. If you do not agree to this Privacy Policy, please do not access or use the Service. This Privacy Policy is incorporated by reference within the Terms of Service that you accept when you register to use our Service. If we use a capitalized term in this Privacy Policy without defining it, it shall have the meaning ascribed thereto in the Terms of Service.

Table of Contents

Information We Collect
How We Use Your Information
Disclosing Your Information
Our Legal Bases for Use of Your Information
Online Analytics and Tailored Advertising
Your Choices
Data Security
Data Retention
Do-Not-Track
Information from Children
Consent to Transfer
Third-Party Links and Services
Changes to this Privacy Policy
Questions or Concerns

1. Information We Collect

We collect data about you as described below when we provide our Service. Please note that we need certain types of information to provide the Service to you. If you do not provide us with such information, or if you ask us to delete that information, you may no longer be able to access or use certain aspects of the Service.

1. Information You Provide to Us Directly

We may collect information that you provide directly to us through:

• Your use of the Service;
• Your registration for the Service or when you provide or update your Client Information;
• Your communications with us, such as when you inquire about our Service or contact us for support;
• Your subscription to newsletters or updates; and
• Your in-person communications with us, such as through conferences or events.

The information you provide to us directly may concern you and others and may include, but is not limited to:

• Registration and Other Client Information: When registering for the Service or updating your Client Information, you may provide us with information including a name, address, email address, username, and password for third-party services, and telephone number.
• Financial Information: We may collect payment information for our Service, such as credit card, debit card, or financial account information.
• Transaction Information: We may collect information about transactions with you, such as purchases, purchase amount, and date of purchase.
• Business Information: We may collect general information about your employment or business, such as a business title, business phone, business email address, business product and service offerings, and other information you provide us when communicating with us.
• Communications: We may collect information in connection with any support, product evaluation, dispute resolution and other communications with our Service and personnel.

You are not required to provide us with such information, but certain features of the Service may not be accessible or available, absent the provision of the requested information.

2. Information We Collect From Third Parties

We may collect information about you or others through our affiliates or through non-affiliated parties. We may also collect information about you from other users. For example, users may provide us with information about colleagues or other prospective users of our Service.

We may combine information that we collect from you through the Service with information that we obtain from such other parties and information derived from other products or Service we provide.

3. Automatically-Collected Information

Device/Usage Information. We and our vendors, which include analytics companies such as Google Analytics, may use cookies, web beacons, and other tracking technologies to collect information about the computers or devices (including mobile devices) you use to access the Service. As described further below, we may collect and analyze information including but not limited to (a) browser type; (b) ISP or operating system; (c) domain name; (d) access time; (e) referring or exit pages; (f) page views; (g) IP address; (h) unique device identifiers (e.g. IDFA or Android ID); (i) version of our Service you’re using; and (j) the type of device that you use. We may also track when and how frequently you access or use the Service, including how you engage with or navigate our Site. We use this information (including the information collected by our vendors) for analytics (including to determine which portions of the Service are used most frequently and what our users like/do not like) and as otherwise described in this Privacy Policy.

Cookies and Other Electronic Technologies. We and our vendors may use cookies, clear GIFs, pixel tags, and other technologies that help us better understand user behavior, personalize preferences, perform research and analytics, and improve the Service. These technologies, for example, may allow us to tailor the Service to your needs, save your password in password-protected areas, track the pages you visit, help us manage content, and compile statistics about usage of our Service. We or our vendors also may use certain of these technologies in emails to our customers to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but your browser may allow you to modify your browser settings to decline cookies if you prefer. If you disable cookies, you may be prevented from taking full advantage of the Service, because the Service may not function properly. As we adopt additional technologies, we may also gather additional information through other methods.

Location Information. When you use the Service, we may collect general location information (such as general location inferred from an IP address).

2. How We Use Your Information

We process your information for the following purposes:

• To provide you with the Service, including to establish an account and to communicate with you regarding your account;
• To identify and authenticate your access to certain parts of our Service;
• To operate, improve, and personalize the Service;
• To process payment for the Service;
• To respond to your questions and inquiries, including to provide customer support and technical assistance;
• To communicate with you, including to send you emails about our products and services;
• To protect our rights and/or our property and to ensure the technical functionality and security of our Service;
• To conduct analysis and develop insights that enable us to operate, protect, make informed decisions and report on our business;
• To comply with our legal obligations or as permitted by law;
• To protect the safety and/or integrity of our users, employees, other parties, members of the public, and/or our Service;
• To investigate and prevent fraud;
• To enforce our legal terms or applicable policies; and
• To administer and troubleshoot the Service.

We may aggregate and/or de-identify information collected through the Service. We may use de-identified or aggregated data for any purpose, including without limitation for research and marketing purposes and may also disclose such data to other parties, including without limitation, advertisers, promotional partners, sponsors, event promoters, and/or others.

3. Disclosing Your Information

We may disclose the information we collect in the following circumstances:

Affiliates and Subsidiaries. We may disclose information to our affiliates and subsidiaries.

Vendors. We disclose your information to select vendors who perform services on our behalf. They provide a variety of services to us, including data storage, analytics, billing, payment processing, marketing, product content and features, customer service, data storage, security, fraud prevention, and legal services.

Safety and Protection of Singuli and Others. We may disclose certain information if we believe in good faith that doing so is necessary or appropriate to (i) protect or defend the rights, safety, or property of Singuli or other parties, including to defend or enforce our Privacy Policy, our Terms of Service, or any other contractual arrangement or (ii) respond to your requests for customer service; and/or (iii) protect the rights, property or personal safety of Singuli, its agents and affiliates, its employees, users and/or the public.

Legal Requirements. We may disclose certain information if we believe in good faith that doing so is necessary or appropriate to comply with any law enforcement, legal, or regulatory process, such as to respond to a warrant, subpoena, court order, or other applicable laws and regulations.

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

Consent/At Your Direction. We may disclose your information to nonaffiliated parties based on your consent to do so. For example, you may direct us to disclose information about you when you refer us or our Service to your colleagues or other acquaintances, or if you connect our Service with third-party services.

4. Our Legal Bases for Use of Your Information

Singuli is considered the “data controller” of the personal data we handle under this Privacy Policy. In other words, Singuli is responsible for deciding how to collect, use and disclose this data, subject to applicable law. The laws of some jurisdictions such as the laws of the European Economic Area and the United Kingdom require data controllers to tell you about the legal ground that they rely on for using or disclosing of your information. To the extent those laws apply, our legal grounds are as follows:

• Contractual Commitments: We may use or disclose information to honor our contractual commitments to you. For example, we will process your personal data to comply with our agreements with you, and to honor our commitments in any contracts that we have with you.
• With Your Consent: Where required by law, and in some other cases, we use or disclose information on the basis of your consent.
• Legitimate Interests: In many cases, we use or disclose information on the ground that it furthers our legitimate business interests in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals, such as customer service, certain promotional activities, analyzing and improving our business, providing security for the Service, preventing fraud, and managing legal issues.
• Legal Compliance: We need to use and disclose information in certain ways to comply with our legal obligations.

In addition to those rights described herein, you have the right to lodge a complaint with the relevant supervisory authority. However, we encourage you to contact us first, and we will do our best to resolve your concern.

5. Online Analytics and Tailored Advertising

1. Analytics

We may use third-party web analytics services on the Service, such as those of Google Analytics. These vendors use the sort of technology described in the “Automatically-Collected Information” section above to help us analyze how users use the Service, including by noting the third-party website from which you arrive. The information collected by such technology will be disclosed to or collected directly by these vendors, who use the information to evaluate your use of the Service. We also use Google Analytics for certain purposes related to advertising, as described in the following section. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-Out Browser Add-on.

2. Tailored Advertising

We may also allow third-party advertising networks to place cookies or other tracking technologies on your computer, mobile phone, or other device to collect information about your use of the Service in order to (i) inform, optimize, and serve marketing content based on past visits to the Service and other sites and (ii) report how our marketing content impressions and interactions with these marketing impressions are related to visits to our Service. We also allow other unaffiliated parties (e.g., ad networks and ad servers such as Google Analytics) to serve tailored marketing to you and to access their own cookies or other tracking technologies on your computer, mobile phone, or other device you use to access the Service. Those parties that use these technologies may offer you a way to opt out of targeted advertising as described below. You may receive tailored advertising on your computer through a web browser. Cookies may be associated with de-identified data linked to or derived from data you voluntarily have submitted to us (e.g., your email address) that we may disclose to a vendor in hashed, non-human-readable form.

If you are interested in more information about tailored advertising and how you can generally control cookies from being put on your computer to deliver tailored marketing, you may visit the Network Advertising Initiative’s (“NAI”) Consumer Opt-Out Link, the Digital Advertising Alliance’s (“DAA”) Consumer Opt-Out Link, and/or the European Interactive Digital Advertising Alliance to opt-out of receiving tailored advertising from companies that participate in those programs. To opt out of Google Analytics for Display Advertising or customize Google Display Network ads, you can visit the Google Ads Settings page. Please note that to the extent advertising technology is integrated into the Service, you may still receive advertising content even if you opt out of tailored advertising. In that case, the advertising content may not be tailored to your interests. Also, we do not control any of the above opt-out links and are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms. If your browsers are configured to reject cookies when you visit these opt-out pages, or you subsequently erase your cookies, use a different computer, or change web browsers, your opt-out may no longer be effective.

6. Your Choices

You have certain rights and choices with respect to your information such as:

• Personal Information: You have choices in what types of personal information to provide us, and you may modify some or all of this information by logging into your account via the Service. Please be advised if your organization uses an Administrator to manage elements of our Service, that person may also have the ability to add, edit or delete certain personal information and other information relating to your usage of the Service.
• Communication Preferences: We may contact you via email with Service-related announcements that we think may be beneficial to you, and special offers. We also may contact you with information about products and services from our business partners. You may opt out of such communications at any time by following the opt-out instructions in such communications or contacting us at support@singuli.co. You may not opt out of receiving what we consider to be essential Service-related messages, support services responses or other communications relating to inappropriate use of the Service or requests from third parties to access information in your account. Please note that if you have agreed to receive marketing communications from any third-party service with which you are using Singuli, you must change your communication preferences with them directly.

Your local law may provide you certain rights with respect to your personal information. Depending on your jurisdiction, you may request that we:

• provide access to and/or a copy of certain information we hold about you;
• prevent the processing of your information for direct-marketing purposes (including any direct marketing processing based on profiling);
• update information which is out of date or incorrect;
• delete certain information that we are holding about you;
• restrict the way that we process and disclose certain of your information;
• transfer your information to a third-party provider of services; and
• revoke your consent for the processing of your information.

Please note, however, that certain information may be exempt from such requests in some circumstances, which may include needing to continue processing your information for our legitimate interests or to comply with a legal obligation. We may request you provide us with information necessary to confirm your identity before responding to your request. To exercise any of these rights, please contact Singuli Client support at support@singuli.co.

7. Data Security

Singuli is committed to protecting the security of your information and takes reasonable precautions to protect it. Your Singuli account information is protected by a password for your privacy and security. We protect your information in our systems using technical and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. Some of the safeguards we use are firewalls and data encryption, physical access controls to our data centers, and information access authorization controls. However, no Internet or email transmission is ever fully secure or error free. Therefore, we do not promise and cannot guarantee the security of your personal data or communications.

8. Data Retention

We retain your information as long as it is necessary and relevant for the operation of our Service. Upon request, personal information from closed accounts will be deleted as soon as reasonably possibly after the account is closed or deactivated. Under certain circumstances we may retain information, including personal information, from closed accounts to prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigation, enforce our Terms of Service, comply with applicable legal data retention obligations, and take other actions permitted by law. After it is no longer necessary for us to retain your personal information, we will dispose of it in a secure manner according to our data retention and deletion policies in effect at that time. This may include aggregating or anonymizing the information.

9. Do-Not-Track

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We do not currently recognize or respond to browser-initiated DNT signals.

10. Information from Children

The Service is not designed for minors under 18. If we discover that an individual under 18 has provided us with personal information, we will close the account and delete the personal information to the extent required by the Children’s Online Privacy Protection Act or other applicable law. We may, where permitted by law, retain certain information internally for purposes described in this Privacy Policy.

11. Consent to Transfer

Our services are global and data may be stored and processed in the United States and other countries outside the United States which may have data protection laws that differ from the laws in your country. By using the Service, or providing us with any information, you consent to the collection, processing, maintenance, and transfer of such information in and to the United States and other applicable countries in which the privacy laws may not be as comprehensive as, or equivalent to, those in the country where you reside and/or are a citizen.

12. Third-Party Links and Services

This Privacy Policy addresses only the use, storage and disclosure of information we collect from you and in operating our Service. We do not control the data collection, storage, use or disclosure policies of Client Content Partners or Client Third Parties, so you must be aware of and comfortable with their privacy practices. We cannot guarantee the privacy or security of your information once you provide it to any third party and we encourage you to evaluate the privacy and security policies of any third party before entering into a transaction and choosing to share your information.

The Service may also contain links to third-party websites or services. We are not responsible for the content or practices of those websites or services. The collection, use, and disclosure of your information will be subject to the privacy policies of the third-party websites or services, and not this Privacy Policy. We urge you to read the privacy and security policies of these third parties.

13. Changes to this Privacy Policy

A variety of factors may require changes to this Privacy Policy, including the evolution of our Service and changes in laws applicable to us. We will update this Privacy Policy and may elect in some cases to send you a message alerting you to the change. By continuing to use the Service, you acknowledge the applicability of the updated Privacy Policy. If you disagree with any changes and do not wish your information to be subject to a revised Privacy Policy, you will need to close your account and stop using the Service.

14. Questions or Concerns

If you have questions or concerns about this Privacy Policy or information handling processes, you may contact us at the following addresses:

support@singuli.co

Singuli, Inc.
41 Flatbush Ave., Suite 1
Brooklyn, New York 11217