Last Modified: May 20, 2018
INFORMATION WE COLLECT
There are three types of information we collect:
Information from Organizations
Information You Choose to Give Us
When you use our Services, we collect the information you choose to share with us. For example:
Information We Get When You Use Our Services
When you use our services, certain information is automatically generated and stored about your visits. The type of information gathered this way includes things like
Location Based Services. The device you use to access the Service may provide your location to the Service. If you enable the location-based feature on your device, we will automatically receive information about your location when you use the Service. Your device may allow you to deactivate location-based services. If you deactivate location-based services, your device should no longer send information about your location to third parties, including Sigma; but be advised that if you turn off location-based services on your device, certain aspects of the Service may not be available to you.
Information We Received From Third Parties (other than Organizations).
If you log in to the Service using credentials associated with your account at third-party services such as Facebook, LinkedIn or Twitter (each, a “Third Party Service”), you allow Sigma to access certain information associated with your account with the Third Party Service. The information you allow us to access may vary according to the privacy settings you establish with the Third Party Service. We encourage you to review the privacy policies of any Third Party Services from which you access the Service.
HOW WE USE YOUR INFORMATION
Personal Data received from an Organization (“Organization Data”) will be used by Sigma in accordance with the Organization’s instructions and as required by applicable law. Sigma is a processor of Organization Data and the Organization is the controller. The Organization may, for example, use the Services to grant you a Merit, access, modify, export, share and remove Organization Data and otherwise apply its policies to the Services.
With your permission, Sigma uses information relating to Merits you have claimed and information we receive from you when you create an account and interact with the Service (“Your Sigma Data”) in order to provide you with an easily accessible place to track, access, and share documents relating to your Merits, to provide you with advertisements and other information which may be of interest to you and to offer you the most helpful Service. Sigma is a controller with regard to Your Sigma Data. Here are some of the ways we do that:
HOW WE SHARE YOUR INFORMATION
This section describes how Sigma may share and disclose information. Each Organization determines its own policies and practices for the sharing and disclosure of Organization Data and Sigma does not control how any Organization or third party chooses to share or disclose Organization Data.
OUR DATA RETENTION POLICY
Sigma will retain Organization Data in accordance with an Organization’s instructions, and as required by applicable law. Please Note: If you or an Organization asks us to delete Organization Data that data will be deleted from the Sigma Service as well. For more detail about our process should you wish to delete Organization data please contact us at firstname.lastname@example.org. Unless requested by you to delete Sigma Data, Sigma will retain Sigma Data as long as you have an account with us. Once you have deactivated your account, we will only keep your data for the period of time needed for Sigma to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements.
Account information. You can review, amend, correct, or delete your account information
The Service also provide tools for you to customize the information about yourself that is made accessible to others. Certain information about yourself, such as your full name, will always be visible to other users of the Service, and your decision to use the Service indicates your acceptance of these settings. You should review your privacy preferences regularly, to ensure that the settings match your preferences.
Promotional communications. You may opt out of receiving promotional communications from Sigma by following the instructions in those communications. If you opt out, we may still send you other kinds of communications, including those related to your current accounts or your use of the Service.
Advertisements. When you visit our Site, you may see advertisements which are relevant to your interests. If you do not wish to see any of these advertisements, please click here to adjust your privacy settings.
Sigma is committed to safeguarding the confidentiality of information that we collect about you. Please click here for more information about the precautions we take to protect your Personal Information.
YOUR CALIFORNIA PRIVACY RIGHTS
Under California Civil Code Section 1798.83, if you are a California resident and your business relationship with Sigma is primarily for personal, family or household purposes, you may request certain data regarding Sigma's disclosure, if any, of Personal Information to third parties for the third parties' direct marketing purposes. To make such a request, please send an e-mail message to email@example.com with "Request for California Privacy Information" in the subject line of your email. You may make such a request up to once per calendar year. If applicable, we will provide you, by e-mail, a list of the categories of Personal Information disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year, along with the third parties’ names and addresses. Please note that not all Personal Information sharing is covered by Section 1798.83’s requirements.
LINKS TO THIRD-PARTY SITES
NO USE BY MINORS
Our Service is intended for use by adults only. Sigma does not promote the Service to children, and does not intentionally collect any personally identifiable information from children under the age of thirteen (13). If you believe that a person under the age of thirteen (15) has disclosed personally identifiable information through the Service, please report this to us immediately by emailing us at firstname.lastname@example.org, with “Notice of Underage Person” in the subject line of your email, and we will remove such information from our files.
TRANSFER OF INFORMATION TO OTHER COUNTRIES
Sigma is based in the United States. Information that we have collected from or about you may be transferred to countries other than the one in which you reside, including the United States. By submitting your information to Sigma via the Service, you consent to such transfers and to the processing and storage of that information in various countries around the world, including countries other than the one in which you reside. If you are located outside of the United States and you choose to provide your information to us, you agree that we have the right to transfer your information to the United States, and process it there.
COMPLAINT, APPLICABLE LAW, and JURISDICTION
ADDITIONAL CLAUSES FOR USERS IN THE EUROPEAN UNION
If you’re a user in the European Union, you should know that Sigma is the controller of Your Sigma Data. Your country only allows us to use Personal Information contained in Your Sigma Data when certain conditions apply. These conditions are called “legal bases” and, at Sigma, we typically rely on one of three:
Your right to object.
You have the right to object to our use of your information. With many types of data, we’ve provided you with the ability to simply delete it if you don’t want us processing it anymore. For other types of data, we’ve given you the ability to stop the use of your data by disabling the feature altogether. You can do these things through the Service. If there are other types of information you don’t agree with us processing, you can contact us at email@example.com.
We may collect your Personal Information from, transfer it to, and store and process it in the United States and other countries outside of where you live. Whenever we share information of EU users outside the EU we make sure an adequate transfer mechanism is in place.
EU-US AND SWISS-US PRIVACY SHIELD
Sigma complies with the EU-U.S. Privacy Shield Framework Principles and the Swiss-U.S. Privacy Shield Framework Principles for Personal Information transferred to the United States from users in the EU and Switzerland. Under these Frameworks, we are subject to the Federal Trade Commission’s enforcement powers. To learn more about Privacy Shield and to view our certification, please click here.
If you have any questions or complaints about how we are complying with the Privacy Shield principles, please contact us at firstname.lastname@example.org. If we are unable to resolve the issue, we have committed to refer unresolved Privacy Shield complaints from EU and/or Swiss individuals to the BBB EU Privacy Shield, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not resolved your complaint, please click here. The services of the BBB EU Privacy Shield are provided at no cost to you.
In certain situation, you may have the right to invoke binding arbitration before a Privacy Shield Panel. To learn more about binding arbitration, see Annex I to the EU-U.S. Privacy Shield and Annex I to the Swiss-U.S. Privacy Shield.
As our mentioned above, we may sometimes share your Personal Information with third parties for processing on our behalf. We are responsible for this third-party processing if it violates the Privacy Shield principles, unless we can show that we were not responsible for the violation.
Note that we may be required to release EU Data in response to requests from public authorities, including to meet national security and law enforcement requirements.
Complaints? If you’re based in the EU, you can always file a complaint with the supervisory authority in your Member State. For example, if you’re based in the UK you can file a complaint with the Information Commissioner’s Office.
ADDITIONAL CLAUSES FOR AUSTRALIAN USERS
If you would like to access or correct the Personal Information which we hold about you, or you have a question or complaint about our use of your Personal Information please contact us at email@example.com. When contacting us please provide as much detail as possible in relation to your question, comment or complaint.
We will take any privacy complaint seriously and any complaint will be assessed with the aim of resolving any issue in a timely and efficient manner. We request that you cooperate with us during this process and provide us with any relevant information that we may need. If you are not satisfied with the outcome of our assessment of your complaint, you may wish to contact the Office of the Australian Information Commissioner.
DATA PROTECTION OFFICER
Our Data Protection Officer can be reached at firstname.lastname@example.org.