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TM SGNL - Privacy Poilcy

Updated: Mar 14, 2023

Privacy Policy

This privacy statement discloses the privacy practices for TM SGNL.

TM SGNL (“TM SGNL,” “we” or “us” or “our” ) is committed to protecting the privacy and security of your personally identifying information. We have prepared this Privacy Policy to explain how we collect, use, protect, and disclose your Personal Information (as defined below), usage data and message data when you use our marketing website located at TM (the “Site”), as well as when you use the TM SGNL Service which includes the TM SGNL mobile app, TM SGNL web interface, TM SGNL APIs, TM SGNL administrator tools and other products and services provided on the TM website (all of the foregoing, collectively, the “Service”).

By using the Service you consent to this Privacy Policy. By visiting the Site or using the Service, you accept the policies and practices described in this Policy, as such Policy may be amended from time to time. Each time you visit the Site or use the Service, you agree and expressly consent to our collection, use and disclosure of the information that you provide as described in this Policy. In any case, and with respect to any Google Account information, we will only use that information to access your Google Account when, and for the limited purposes for which, you have given us permission to do so. To be clear about the terminology we are using, when we use the phrase “Personal Information” in this Policy, we mean information about you that is personally identifiable, like your name, address, e-mail address, billing information, or phone number, as well as other non-public information that is associated with this personal information. When we use the phrase “Anonymous Information” in this Policy, we mean information that is not personally identifiable, or linked to your Personal Information such as aggregated information, general demographic information and IP addresses. Anonymous Information does not necessarily enable identification of individual persons.

· Collection and Use of Information

When you register for the TM SGNL Site and Service (web interface, mobile app, APIs and administration tools), we collect information that personally identifies you, such as your full name, mobile telephone number, e-mail address and other information that you provide to us or that you include in any TM SGNL profile or account (“Personal Information”). We also collect your contact lists and/or address book data that will be stored on our servers and will only be used to:

· notify you when your contacts become active on TM SGNL,

· indicate which of your contacts is already a TM SGNL user,

· correctly display the name of each contact as it appears in your address book when a message is received.

· to allow you to communicate with other users, we might share your contact information with other users.

In addition, we utilize a function that uses this data to synchronize your address book across your multiple devices.

We also utilize a function to collect media files and document attachments to our servers for archive or storage purposes in a retrievable format.

When you send or receive messages using our Service, as part of message delivery process, we temporarily process and store your messages, logging information, the recipients your contact data and other message related information. Note that we may share your Personal Information (e.g., name, e-mail address, telephone number) with other message recipients. Such sharing is done for message authentication and identity sharing with message recipients. After message is processed, and transmitted, we strive to delete message data. However we do not guarantee that all message data will be completely deleted and therefore any message data that you send is sent at your own risk. If your setting is configured to keep message data, we may keep it for display and management when you access our Service through the different components of the Service. We may also sync contact and application information with our server, to verify your ability to chat with other users of the application, the security level or other application settings. The copy of your address book (names and phones) is stored on a live database. Data that is deleted from your mobile device and/or the Service may still be stored in our servers for regulatory compliance or audit purposes. Data may have a “historical backup” which can be deleted at any time upon request by the user. Please note that only administrators can request and implement data deletion for company accounts. Your phone number, which will be verified via a text message that will be sent to you, will be used for identification purposes as your TM SGNL username. TM SGNL may interact with your phone’s SMS inbox, placing incoming messages in your inbox or reading the contents of the activation SMS sent to you by TM SGNL. If you choose to sync TM SGNL with your SMS/MMS messages, TM SGNL may also access other SMS/MMS information for encryption or server archiving purposes. We may even delete messages from your regular SMS/MMS message store. Other Usage Data We collect other usage data regarding how you access and use our Services, like the type of device you are using, and a device identifier, type of web browser, operating system, IP address used for access, ISP used for access, pages you viewed, duration of using our products, crash logs, and other information related to the use of our Services. We use this information to analyze trends. manage and administer the Service, troubleshoot problems, and to plan future enhancements and Service updates. Company Accounts & Administration Capabilities For some customers, as well as enterprise organizations, users’ message data and other personal information may be archived or stored in a retrievable format, as well as exported from our servers. In case your app is used as part of a company account, the company administrator may have access to messages on your phone. He can also control and configure settings related to the application on your device, as well as change SMS/MMS and other phone settings, and have rights and access to messages, settings and contacts including: the ability to deleted messages from your phone after a certain time, ability to wipe messages from your device, PIN enforcement for app usage, archiving of your phone messages on a remote server, access to your phone contacts and the ability to add and view contact on your device, setting other phone and message settings on your device and other Service components such as our web interface and Outlook plug-in. Your administrator may keep data, messages, and contacts that is deleted from your mobile device and/or the Service for regulatory compliance or audit purposes. If you are part of a company, we may sync and share your contact information with other members of the organization. Other Services In the event we make message boards and forums available to you (collectively, “Forums”), you will be solely responsible for the information and any other content you post on and through these Forums and should be aware that when you voluntarily disclose Personal Information (e.g., name, e-mail address, telephone number) on or through these Forums, such information is generally accessible to, and may be collected and used by, other users. This may result in unsolicited messages from third parties, and such messages are beyond our control. We do not exercise control over any users or Site visitors, and in no way are we responsible, nor do we have any liability whatsoever, for any collection or use of information you may disclose through the Forums. This Policy does not cover such disclosure of information. You are encouraged to exercise discretion when providing personal information about yourself in and through Forums. Please do not post any Personal Information on this Site that you expect to keep private. Cookies, Clear GIFs and Other Automatically Collected Data If you have permitted your computer to accept cookies, we may use cookies on the Site and the Service. Cookies are pieces of information that a website transfers to an individual’s hard drive for record-keeping purposes. Cookies make web-surfing easier by saving preferences and browsing patterns while you are at the Site. Cookies may be used to analyze the Site usage, improve content, customize the Site’s content and layout and for other customer service purposes. A cookie may enable us to relate your use of our Site to other information about you, including your Personal Information. All of these purposes serve to improve and personalize your experience on our Site. Most Web browsers can be set to inform you when a cookie has been sent to you and provide you with the opportunity to refuse that cookie. Additionally, if you have a Flash player installed on your computer, your Flash player can be set to reject or delete Flash cookies. However, refusing a cookie may, in some cases, preclude you from using, or negatively impact the display or function of, the Site or certain areas or features of the Site. We may use “clear GIFs” (aka “Web beacons” or “pixel tags”) or similar technologies, in the Site and/or in our communications with you to enable us to evaluate Site usage information about visitors to the Site, target campaigns, upgrade visitor information, and know whether you have visited a Web page or received a message. A clear GIF is typically a one-pixel, transparent image (although it can be a visible image as well), located on a web page or in an e-mail or other type of message, which is retrieved from a remote site on the Internet enabling the verification of an individual’s viewing or receipt of a Web page or message. A clear gif may enable us to relate your viewing or receipt of a Web page or message to other information about you, including your Personal Information. Our servers may automatically collect data about your Internet address when you visit the Site. This information, known as an Internet Protocol address, or IP Address, is a number that is automatically assigned to your computer by your Internet service provider whenever you are on the Internet. When you request pages from our Site, our servers may log your IP Address and, if applicable, your domain name. Your IP Address is used to help identify you and to gather demographic information about our members and users as a whole, but does not include personally identifiable information. Our server may also record the referring page that linked you to us (e.g., another web site or a search engine); the pages you visit on this Site; the web site you visit after this Site; the ads you see and/or click on; other information about the type of Web browser, computer, platform, related software and settings you are using; any search terms you have entered on this Site or a referral site; and other Web usage activity and data logged by our servers. We use this information for internal system administration, to help diagnose problems with our servers, and to administer our Service. Such information may also be used to gather demographic information, such as country of origin and Internet Service Provider. We will not link any Personal Information, including e-mail addresses, with aggregate data of our users. Any or all of these activities with regard to Site usage information may be performed on our behalf by our service providers, including, for example, our analytics vendor(s) and our e-mail management partner(s). Third-Party Sites and Privacy Practices You may arrive at our Site and/or download the TM SGNL App from another website. Users who wish to register for our service may register on-line or contact TM SGNL or one of our partners. All users’ information (including users who registered via a partner) is stored with TM and governed by our privacy policy. However, please understand that if you register with a partner they will have their own privacy policy and may use your information differently. Our Policy applies solely to Personal Information that is acquired on the Site or through your use of our Service, and/or your relationship with TM SGNL. We urge you to be careful when you enter any Personal Information online. We accept no responsibility or liability for these other websites. Analytics Collection TM SGNL uses Google Analytics and other analytics tools to help us anonymously track and report user/visitor behavior information and users’ standard log information to the Site and the TM SGNL App. This information (including but not limited to: IP address, data storage, maintenance services, database management, web analytics and information processing) helps us analyze and evaluate how the TM SGNL App and Site are used as part of our ongoing efforts to improve the Site and TM SGNL App’s features and services. No personally identifying data is included in this type of reporting. Google Analytics, and other analytics tools may have access to your information only for the purposes of performing these tasks and on behalf of TM SGNL and under obligation similar in those in this Privacy Policy. We will never (and will not allow any third party to) use the statistical analytics tool to track or to collect any Personal Information of visitors or users. Google will not associate your IP address with any other data held by Google. Neither we nor Google will link, or seek to link, an IP address with the identity of a device user. We will not associate any data gathered from this site with any Personally Identifiable Information from any source, unless you explicitly submit that information via a fill-in form on our website. If you do not want your information to be part of this statistical information gathering, you can disable Google Analytics using the application settings; visit the ‘More’ screen, tap settings, then disable Google Analytics Collect Data option. Log Management We may store log information for debugging or regulatory and compliances purposes.

· Sharing and Disclosure of Information

We do not rent, sell, or share any information about the user with any third-parties, except as specifically described herein. We may disclose your Personal Information if we believe such action is necessary to:

· comply with the law, or legal process served on us;

· protect and defend our rights or property (including the enforcement of our agreements); or

· act in urgent circumstances to protect the personal safety of users of our Service or members of the public.

In order to provide you with TM SGNL products you have requested, TM SGNL may sometimes, if necessary, share your Personal Information (excluding your address book and related information) and traffic data with trusted partner service providers and/or agents, for example: banking organizations or other providers of payment and analytical services, customer support, or hosting services. TM SGNL will always require these third parties to take appropriate organizational and technical measures to protect your personal data and traffic data and to observe the relevant legislation. TM SGNL will never share your address book information with any third party, except as may be required by law (see below). Third party companies, such as mobile providers, are used in order to send you an authentication SMS when you register with TM SGNL and for any message that is designated as an SMS/MMS message. In order to send you the SMS/MMS, we share with these third party companies your phone number and/or email address when delivering email messages. We may disclose information about you if we determine that for national security, law enforcement, or other issues of public importance that disclosure of information is necessary. We may from time to time ask you to provide information about your experiences which will be used to measure and improve quality. You are at no time under any obligation to provide any of such data. Any and all information which is voluntarily submitted in feedback forms on the Site or any survey that you accept to take part in is used for the purposes of reviewing this feedback and improving the TM SGNL software, products and websites. We may contact you to send you messages about faults and service issues. Furthermore, we reserve the right to use email, the TM SGNL software or SMS to notify you of any eventual claims related to your use of our software, websites and/or products, including without limitation claims of violation of third party rights. We may send you alerts via the TM SGNL software to notify you when someone has tried to contact you. We may also use the TM SGNL software to keep you up to date with news about our software and products that you have purchased and/or to inform you about other TM SGNL products and related information.

· Location Data

If you share a location in a chat, this location data is treated like other messages.

If you share your Live Location in any chat (or from Settings > People Nearby > Make Myself Visible), TM SGNL will use your data to display your location to those users with whom you are sharing it, even when the app is closed – for as long as you keep this optional features activated.

· GDPR Data Protection Agreement and EU‐U.S. Privacy Shield

TM SGNL has self-certified to the EU-U.S. Privacy Shield with respect to Customer Data and to the European Monetary System (EMS) General Data Protection Regulation (GDPR) Data Protection Agreement. For more information, see our GDPR Compliance Statement, Data Processing Agreement and Privacy Shield Notice.

· California Consumer Access and Deletion Rights

TM SGNL will support customers that would like more information about our use of Customer Account Data or Customer Usage Data, and you can contact our support and request us to :

· Provide you with details about the categories of personal information that we collect about you, including how we collect and share it;

· Provide you with information about the personal information we collect about you; and

· Delete the personal information we have about you.

· Children’s Privacy

TM SGNL websites and software clients are not intended for or designed to attract anyone under the age of 13 and we do not intentionally or knowingly collect Personal Information on our sites from anyone under the age of 13 (or older in some jurisdictions). We encourage parents to be involved in the online activities of their children to ensure that no information is collected from a child without parental permission.

· Security

We take reasonable precaution to protect Personal Information from misuse, loss and unauthorized access. Although we cannot guarantee that Personal Information will not be subject to unauthorized access, we have physical, electronic, and procedural safeguards in place to protect Personal Information. Personal Information is stored on our servers and protected by secured networks to which access is limited to a few authorized employees and personnel. All employees are made aware of our security procedures as part of our training process. We review our web security procedures on a monthly basis. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure.

· Business Transitions

In the event that we go through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of our assets, Personal Information will likely be among the assets transferred. As part of such a transaction the new entity will be required to commit to the same level of protection of your Personal Information as described in this Privacy Policy. If we cannot obtain such a commitment, we will not perform the business transition. We will post a notice on this Site of any such change in ownership or control of the Personal Information we may have prior to such transfer.

· Changes to Policy

From time to time, we may revise this Policy. We reserve the right to update or modify this Policy, or any other of our policies or practices, at any time with or without notice. However, we will not use your Personal Information in a way that is materially different than the uses described in this Policy without giving you an opportunity to opt-out of such differing uses. We will post the revised Policy on the Site, so that users can always be aware of what information we collect, how the information is used and under what circumstances such information may be disclosed. You agree to review the Policy periodically so that you are aware of any modifications. Your continued use of the Site indicates your assent to any changes and signifies your agreement to the terms of our Policy. If you do not agree with these terms, you should not use the Site, the TM SGNL App, or any other Service.

· Hosting of Site and Service

Please note that the Service and the Site are hosted in the United States and are intended for and directed to users in the United States. If you are an international user, please be advised that through your use of the Service or the Site, you expressly consent to your personal data being transferred to the United States and to the application of the United States federal laws and the laws of the State of Massachusetts (as applicable) to such transfer.

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