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Signal Digital, Inc. Platform Privacy Policy

This policy was last modified on and has an effective date of May 25, 2018.

Signal Digital, Inc. (“Signal” “we” or “us”), a digital marketing technology company, respects your privacy. The Signal Platform (“Platform”)  helps its clients collect, manage and distribute their data to better recognize, understand and market to their consumers. The purpose of this privacy policy is to help explain to our clients, consumers, and partners how we collect, use, and disclose such information through our Platform.

If you are a resident in the European Economic Area and want to find out more about your data protection rights, please see Data Subject Requests.

For information about how we collect, use, and disclose information from our clients and visitors to our websites, please see our Website Privacy Policy.

Our Platform is intended for use by our clients – and for the most part – we collect and process personal information through the Platform as a data processor on behalf of our clients (the client is the data controller). Please also note that in certain use cases this policy applies to the personal information we collect and process through the Platform as a data controller.

We are not responsible for the privacy or security practices of our clients, which may differ from those set forth in this policy. We require our clients to comply with all applicable laws and regulations and to provide you with notice of the collection of data as outlined in this policy. To understand how clients will use your personal information, please refer to the relevant privacy policies for those clients.

Quick Links

Our Platform
Information We Collect
How We Collect Usage Data
How We Use Your Information
How We Share Your Information
International Transfers
Your Privacy Choices & Opting Out
Data Retention
Additional Notice for EEA Residents
Data Subject Requests
Changes to this Platform Privacy Policy
How to Contact Us

Our Platform:

Our Platform helps clients collect, manage and distribute their data to better recognize, understand and market to their consumers.

The Signal Platform enables our clients to: 

  • Onboard and connect their offline data into the digital marketing and digital advertising ecosystem.
  • Link their offline and online data from digital applications such as websites, mobile apps, emails and digital advertising for better cross-channel measurement, advertising and marketing activities.
  • Recognize their users across multiple devices and platforms, to better understand their customers, and to engage their users with more relevant messages.
  • Distribute their data to their partners throughout the digital ecosystem.
    You can find out more about us and our Platform here.

Information We Collect:

In order to provide the Platform, our clients must configure the Platform to collect data from users of our clients’ websites, mobile applications, advertising impressions, email campaigns, retail stores and other sources (“Data Sources”) that use our Platform. Signal does not have any relationship, contractual or otherwise, with the users of the Data Sources, the client maintains these relationships.

The Platform deploys various cookies and similar tracking technologies (See How We Collect Usage Data) to automatically collect certain information about your device when you visit or interact with Data Sources that use our technology (“Usage Data”) as well as information about how you interact with ads. This includes your IP address and certain unique identifiers that may be considered personal information in certain jurisdictions, including the European Economic Area.

We collect this information by assigning a random unique identifier (“UID”) to your device the first time you interact with a Data Source that uses our technology. The UID is then used to establish linkages between you and other information the client and Platform may have about you.

The information we automatically collect includes:

  • Information about your device, such as the IP address and unique identifiers assigned to your device (e.g., iOS Identifier for Advertising (IDFA), Android Advertising ID (AAID or GAID).
  • Information about your online behavior, such as information about the activities or actions you take and content you view on Data Sources that use our technology, such as time spent on a web page, and whether you scroll or click on an ad or a web page, session start/ stop time, your referring website address, geo-location data, searches performed, and purchase history.
  • Information about ads served, viewed, or clicked on, such as the type of ad, where the ad was served, whether you clicked on it and the number of times you have seen the ad.

We do not collect any “sensitive” or “special categories of personal data” as defined under European data protection laws.

We may also enhance the Usage Data, with information collected from third parties, such as  other web-based and mobile networks, exchanges and websites (“Partners”) or our clients (for example, they may upload certain “offline” data into the Platform). In addition, the information we automatically collect may be associated with profile information that we infer about you. This information may include, for example, hashed identifiers derived from other information (such as email addresses), mobile device IDs, demographic or interest data, and content viewed or actions taken on a Data Source.

How We Collect Usage Data

We and/or our Partners use cookies and standard web technologies to collect Usage Data, including the following:

Cookies and Local Storage. Cookies and local storage are data files placed within a browser on a device when it is used to visit a website. Both cookies and local storage can be used to store device identifiers whenever you visit one of our client’s websites. Most browsers provide you with the ability to disable or decline cookies and local storage.
Web Beacons. Web Beacons are small graphic images or other web programming code called web beacons (also known as “1×1 GIFs” or “clear GIFs”) that are included in our clients’ websites or emails.

Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with a website. The code is temporarily downloaded onto your device from our web server, is active only while you are connected to the website, and is deactivated or deleted thereafter.

SDKs and APIs. SDKS and APIs are programming codes that collect information about your interactions with mobile apps and websites. This code is installed on a device, typically within our clients’ applications that you choose to download onto your mobile device.

How We Use Your Information

  • To provide the Platform to our Clients. Generally, we use the information we collect about you to help our clients to better understand their customers and prospective customers and help our clients better target and customize marketing, websites and content, and measure and optimize the performance of their marketing.
  • To build various inferenced data segments (“Data Segments”). We may use the information we collect to help our clients build Data Segments related to, for instance, the industry you are in or the type of content you appear to be interested in. We use these Data Segments to help our clients, understand their own customers. The Data Segments also may be associated with UIDs, cookies and/or mobile device advertising IDs.
  • To do “interest-based advertising”. We work with clients and Partners that use UIDs and associate them with cookies and/or other device identifiers such as hashed email addresses) to help them target ads to you that are based on your offline interests, transactions or demographic information. This is often known as “interest-based advertising.” You can find out more about this type of advertising at the DAA’s website, located at http://www.aboutads.info.
  • To do cross-device tracking. We (or Partners and clients we work with) may use the Usage Information – for example, IP addresses, hashed email addresses, and UIDs – to try to locate the same unique users across multiple browsers or devices (such as smartphones or tablets), or work with providers that do this, in order to enable our clients to better target ad campaigns to common sets of users. For instance, a brand may wish to target customers that it usually recognizes on web browsers through mobile apps.
  • To do “user matching”. We (or our Partners) may also use your information to sync cookies and other identifiers with other Partner and clients (“user matching”). For example, in addition to the UID’s a user may have been assigned in our system, we may also receive a list of UIDs our Partners or clients have assigned to a user. When we identify matches, we then let our clients and Partners know, in order to help them do any of the above, including enhancing their own data, to do interest based advertising or provide insights to other clients.
  • As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
  • To evaluate, operate or improve the Platform.

How We Share Your Information

  • Clients and Partners. We may share Usage Data that does not identify you personally but may identify your device with our clients, third parties chosen by our clients, and others for advertising purposes. We may also share Usage Data and information we derive from such data (such as inferred interests and preferences) with multiple clients and Partners.
  • Third Parties Providing Services on Our Behalf or on Behalf of Our Clients. Third parties who provide services to us or our clients may have access to information, including personal information, in order to perform services for us or on behalf of our clients. Examples include: assist with technical, operational, or hosting support, software and security services, or to enable other services that we offer.
  • Administrative and Legal Reasons. We may transfer and disclose information, including Usage Data, to third parties: (i) to respond to subpoenas or other legal processes or if in our opinion the disclosure is required by law; (ii) at the request of governmental authorities conducting an investigation; or (iii) to protect the safety, rights, property or security of any person or entity.
  • Business Transfers. We may disclose and transfer information, including Usage Data: (a) if we assign our rights regarding any of the information to a third party or (b) in connection with a corporate merger, consolidation, restructuring, sale of certain of Signal and/or its parent company ownership interests, assets, or both, bankruptcy or other corporate change, including, during the course of any due diligence process.

International Transfers

Signal is based in the United States. Therefore, we and our service providers may transfer your information to, or store or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction.

However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this privacy policy, such as requiring our third party service providers and Partners to protect the information in accordance with the European Commission’s Standard Contractual Clauses for the transfers of personal information. Further details can be provided upon request.

Your Privacy Choices & Opting Out

You may opt out of our interest-based advertising by following the instructions below for web browsers and mobile apps. Please note that web browsers and mobile apps operate using different identifiers. You must opt out separately in each web browser and for each computer or device that you would like to be opted-out on. Please note that it may take up to 7 days to process your opt-out request.

Opting out of interest based advertising from cookies

Web Browser Opt-Out. Signal is a member of the Network Advertising Initiative (“NAI”) and adheres to the NAI code of conduct. You may use the NAI opt out tool, which will allow you to opt out of seeing targeted ads through your web browser from NAI member companies. We also support the Self-Regulatory Principles for Online Behavioral Advertising as managed by the Digital Advertising Alliance (“DAA”). You can visit the DAA opt-out page here: https://www.aboutads.info/choices/. In addition, to opt-out of Signal’s use of information through your Web browser for targeted advertising purposes, please click here. Please note that we use cookies to implement your opt-out choice. If you delete our opt-out cookie(s), we will not be able to ensure that your information is no longer used to show ads that are targeted to your interests, unless you return to this page and opt-out again. If your browser is not configured to accept third-party cookies, then your opt-out preference cannot be stored.

Mobile App Opt Out. For mobile apps, you can typically limit ad tracking using the settings on your phone, tablet or other mobile device using the “Ads” menu, “Ad Tracking” setting, or similar setting on your device. Mobile device operating systems such as Apple iOS or Google Play Services provide mechanisms that allow users to opt out of the use of information about their usage of mobile apps to deliver targeted ads based on their interests. For more information, or to opt out using these mechanisms, consult your device settings (“Opt out of Interest-Based Ads” or “Opt out of Ads Personalization” on Android devices and “Limit Ad Tracking” on iOS devices). Please also see the NAI’s mobile opt-out instructions.
Please be aware that opting out does not mean that you will no longer receive targeted marketing messages in your mobile apps or Web browsers. You may still receive generic advertisements and you may see targeted advertisements based on information collected and used by entities other than us.

Location. Most mobile devices offer you the ability to stop the collection of location information at any time by changing the preferences on your device. You may also be able to stop the collection of location information by particular apps by adjusting the settings for individual apps or following the standard uninstall process to remove specific mobile apps from your device.
If you are a resident of the European Economic Area (EEA), you have some additional rights which are explained below in “Additional Notice for EEA Residents”.

Data Retention

We retain data for no longer than one year from when we last collect information about a user. Every time our technology collects new data about a user or a client uploads or changes a user record, this one-year counter begins again. We also retain data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Additional Notice for EEA Residents

If you are a resident of the EEA, you have certain rights and protections under the law regarding the processing of your personal data.
Legal Basis for Processing

If you are a resident of the EEA, we will only process your personal data:
When we have a legitimate interest in processing your personal data (e.g.,

  • we may process your personal data to help our clients reach you through more relevant ads, and to allow sites and services you use to provide free advertising-supported content);
    You have consented to the processing (e.g., you have clicked “I consent” on a website pop-up requesting that you allow our client to set cookies); or
    To comply with our legal or regulatory obligations.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “How to Contact Us” heading below.

Data Subject Requests

If you are a resident of the EEA, you have the right to access personal data we hold about you and to ask that your personal data be corrected, erased, or transferred. You may also have the right to object to, or request that we restrict, certain processing. If we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

To make any of these requests please email privacy@signal.co. We will respond as soon as practicable and no later than one month after receipt of your request.

Please note that because most of the information we store can only identify a particular browser or device, and cannot directly identify you personally, you may need to provide us with proof of identification so we can ensure that we accurately fulfill your request and do not infringe on the privacy rights of other individuals. We may deny or restrict fulfillment of your request in some cases, such as when your access to data places another individual’s privacy rights at risk, or the continued processing of your data is necessary to comply with a legal obligation. If so, we will notify you of the reason(s) for this denial.

Questions or Complaints

If you are a resident of the EEA and have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the data privacy authority where you reside. For contact details of your local Data Protection Authority, please see http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.

Changes to this Platform Privacy Policy

We may change this Platform Privacy Policy from time to time, in response to changing legal, technical or business developments. Such changes will be effective as soon as we post the revised policy on this Website, unless a different date is stated. You should review this policy regularly.

How to Contact Us

If you have questions or comments about this Policy, you can contact us at: privacy@signal.co or by post, using the contact details below:
Signal Digital Inc.
222 N. LaSalle St.
Suite 1600
Chicago IL
60601

To comply with our obligations under EU data protection legislation, we have appointed a Data Protection Officer (DPO). Our DPO is contactable at dpo@signal.co or by mail using the details provided above.


Signal Digital, Inc. Website Privacy Policy

This policy was posted and has an effective date of May 25, 2018.

Signal Digital, Inc. (“Signal”, “we” or “us”) takes privacy very seriously. This Website Privacy Policy explains how we collect, use and share personal information about you, and how you can exercise your privacy rights in connection with your use of our websites, features, and applications (collectively, our “Websites”). This Privacy Policy only applies to the data we collect through our Websites. If you are a consumer and would like to understand how Signal collects, uses, and discloses data through its technology, please review Signal’s Platform Privacy Policy.

Information we collect from applicants who apply for a job with Signal through our Websites or online applicant portals is available at our Recruitment Privacy Notice.

Quick Links

Information We Collect
Cookies and Similar Tracking Technologies
How We Use Your Information
Analytics Providers, Ad Servers, and Similar Third Parties
How We Share Your Information
Your Choices: Marketing Communications and Opting Out
Data Protection Rights
Residents of the European Economic Area and Data Subject Requests
Links to Other Sites and Interactions With Third-Party Services
Children
International Transfers
Security
Recruitment Privacy Notice
Changes to this Website Privacy Policy
How to Contact Us

Information We Collect

This Privacy Policy uses “Personal Information” to refer to information that identifies you as a specific individual, such as your name, mailing address, email address, phone number, or other information that identifies you as an actual person. In general, you can visit our Websites without providing us with any Personal Information. However, you may choose to submit Personal Information through our Websites, and we may request other information about you.

We may also collect information (including Personal Information) about you from third parties. For example, if you are on another website and you opt-in to receive information from Signal, that website will provide your contact and other information to us so that we may contact you as requested. We may supplement the information we collect directly with information we collect from third parties.

Social Features
The Website may offer social sharing features and other integrated tools (such as the Facebook “Share” button), which let you share actions you take on our Website with other services, and vice versa. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.

Information About Your Visit to Our Websites
We and our third-party service providers may automatically or passively collect certain information whenever you interact with our Websites (“Usage Information”). Usage Information may include the browser and operating system you are using, the URL or advertisement that referred you to our Websites, any search terms you entered into a search engine that led you to our Websites, the areas within our Websites that you visited, and the time of day you visited our Websites, among other information. Usage Information also includes the IP address of the network that you use to connect to the Website and unique identifiers for any computer, mobile phone, or other device used to access our Websites.

Cookies and Similar Tracking Technologies

We and our third-party service providers, including third-party advertisers and analytics providers, may use cookies or similar technologies to collect Usage Information when you visit our Websites. A “cookie” is a data file stored on your computer’s hard disk or similar device when you retrieve content from a Web server. Cookies may be used for a variety of purposes, e.g., to identify your device when you revisit our Websites, to recall your authentication information, or to store information related to your navigation throughout our Websites, or to enable certain features on our Websites. We may also employ software technology known as “web beacons” or “tracking tags” to help us keep track of what content on our Websites is effective and to serve relevant advertising to you. Web beacons are small graphics with a unique identifier that may be invisible to you, and which are used to track the online activity of Internet users. For further information about the types of cookies and other tracking technologies we use, please see our Cookie Notice.

How We Use Your Information

Generally, we collect, hold, and use information about you for the following purposes: to: (a) enable you to use our Websites, and to provide related user service, such as responding to your questions; (b) administer and develop our business relationship with you and the company you represent; (c) provide you with information, products, or services that you have requested or agreed to receive or that we otherwise believe will interest you; (d) tailor content, recommendations and offers we display to you, both on the Websites and elsewhere online, (e) conduct internal analyses, such as surveys and market research, to improve our Websites, our products and services, and for other internal business purposes; (f) process information you provide via our Websites, including verifying that your e-mail address is active and valid; (g) contact you with administrative communications; (h) for legal purposes, including using your information as we believe to be necessary or appropriate: (i) under applicable law, including laws outside your country of residence; (ii) to comply with subpoenas, warrants, or other legal process; (iii) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (iv) to enforce our terms and conditions; (v) to protect our operations or those of any of our affiliates; (vi) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (vii) carry out purposes as disclosed at the time you provide your information, with your consent, and as further described in this Website Privacy Policy.

Analytics Providers, Ad Servers, and Similar Third Parties

We work with network advertisers, ad agencies, analytics service providers and other vendors to provide us with information regarding traffic on our Websites, including pages viewed and the actions taken when visiting our Websites, to serve our advertisements on other websites, within mobile apps, and elsewhere online, and to provide us with information regarding the use of our Websites and the effectiveness of our advertisements. For example, if you view or click on an advertisement for Signal or one of our products, our service provider(s) may be able to tell us the advertisement that you clicked on and where you were viewing the advertisement. Our service providers may set and access their own tracking technologies on your device (including cookies and web beacons) and may otherwise collect or have access to information about you and your visits to and activity on the Websites, as well as on other websites or online services.

We use a variety of service providers to perform advertising services. Some of these companies are members of the Network Advertising Initiative (“NAI”) or the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. You may want to visit https://www.networkadvertising.org/managing/opt_out.asp, which provides information regarding targeted advertising and the “opt-out” procedures of NAI members. You may also want to visit or https://www.aboutads.info/choices/, which provides information regarding targeted advertising and offers an “opt-out” by participating companies in the DAA Self-Regulatory Program. Please note opting out through these mechanisms does not opt you out of being served advertising. You will continue to receive generic ads while online.

How We Share Your Information

We may disclose your personal information to the following categories of recipients:

  • to third party services providers and partners who provide data processing services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our Websites), or who otherwise process Personal information for purposes that are described in this Website Privacy Policy or notified to you when we collect your personal information;
  • to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person; or
  • to an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your Personal information only for the purposes disclosed in this Website Privacy Policy;
  • to any other person with your consent to the disclosure.

Your Choices: Marketing Communications and Opting Out

You may opt out of receiving promostional and marketing communications from us by emailing us at privacy@signal.co or by using the opt-out mechanism included in the commercial emails we send. Even if you opt out, we will still send you certain communications relating to your use of our Websites, service announcements, notices of changes to this Website Privacy Policy or our Terms of Use or similar administrative or transactional messages.

Data Protection Rights

You have the right to request access to the Personal Information we hold about you by emailing privacy@signal.co. In addition, at any time you can request that we modify, correct or delete your Personal Information that we hold about you if you believe it is inaccurate, incomplete, out-of-date, irrelevant or misleading by sending an email to us at privacy@signal.co.
We will respond as soon as practicable and no later than one month after receipt of your request. We may request proof of identification to verify your request. We may deny or restrict fulfillment of your request in some cases, such as when your access to data places another individual’s privacy rights at risk, or the continued processing of your data is necessary to comply with a legal obligation. If so, we will notify you of the reason(s) for this denial.

Residents of the European Economic Area

If you are a resident of the EEA, you have certain rights and protections under the law regarding the processing of your personal data.
Legal Basis for Processing:

  • To perform our obligations under a contract with you;
  • You have consented to the processing;
  • When we have a legitimate interest in processing your personal data (e.g., we may process your personal data to send you communications about products or features that may be of interest to you); or
    To comply with our legal or regulatory obligations.

Data Subject Requests

If you are resident in the EEA, the data controller of your personal information is Signal Digital, Inc. You have the right to access personal data we hold about you and to ask that your personal data be corrected, erased, or transferred. You may also have the right to object to, or request that we restrict, certain processing. To make any of these requests, please follow the instructions above or email privacy@signal.co.

Questions or Complaints

If you are a resident of the EEA and have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the data privacy authority where you reside. For contact details of your local Data Protection Authority, please see http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.

Links to Other Sites and Interactions With Third-Party Services

Our Websites may include third-party content or links to third-party sites that we do not control. These third parties’ practices regarding information collection, use, and sharing may be different than ours. We are not responsible for the privacy practices employed by any third party.

Children

Our Websites are not intended for use by anyone younger than the age of 13 and we do not knowingly collect Personal information from children younger than age 13. If we learn that we have in fact collected Personal information from a user younger than 13, we will delete it from our active databases.

International Transfers

Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective).

Specifically, our Website servers and our third party service providers and partners may operate in countries other than yours. However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Policy, such as use of the European Commission’s Standard Contractual Clauses in our third party contracts. If you are in the EEA, you are entitled to obtain a copy of these agreements by contacting us using the contact information below.

Australian Residents: You acknowledge and agree that when we disclose any Personal Information we have collected to a recipient outside of Australia then: (a) that information may go to a country that has different privacy laws than Australia (and which may not be comparable), and (b) it will be handled in accordance with the laws of that country, and not necessarily with Australian privacy law, and (c) that we may not take steps to ensure that the overseas recipient handles your Personal Information in accordance with Australian privacy. You consent to us disclosing your Personal Information to recipients located outside of Australia on that basis.

Security

We take commercially reasonable steps to help protect and secure the Personal Information that we hold about you (including from unauthorized access, modification and disclosure, and from other types of misuse, interference and loss). However, no data transmission over thSe Internet or wireless connection, or electronic storage of data, can be guaranteed to be completely secure. We cannot ensure or warrant the security of any information we collect via our Websites or the Internet.

Changes to this Website Privacy Policy

We may change this Website Privacy Policy from time to time in response to changing legal, technical or business developments. Such changes will be effective as soon as we post the revised policy on this Website, unless a different date is stated.

How to Contact Us

If you have questions or comments about this Policy, you can contact us at: privacy@signal.co or by post, using the contact details below:
Signal Digital Inc.
222 N. LaSalle St.
Suite 1600
Chicago IL
60601
To comply with our obligations under EU data protection legislation, we have appointed a Data Protection Officer (DPO). Our DPO is contactable at dpo@signal.co or by mail using the details provided above.

______________________________________________________________________________________________

Recruitment Privacy Notice

Signal Digital, Inc. (“Signal”, “the Company”, “we” or “us”) respect the privacy rights of individuals and are committed to handling personal information responsibly and in accordance with applicable law. This Notice sets out how we handle your personal information when you apply for a job or other role with us and the rights you have in connection with that information. The term “applicants” is used in this Notice to refer to anyone who applies for a job role, or who otherwise seeks to carry out work with or for us (whether on a permanent or non-permanent basis). If you are in any doubt, or have any comments or questions about this Notice, please contact us using the contact details set below.

Types of personal information we collect when you apply

Information that we collect automatically

You can visit the careers section of our website www.signal.co/careers (“Website”) and search for jobs without providing personal information. However, we do collect certain information automatically from your device when you visit our Website.  For further information, please see our Website Privacy Policy.

Personal information collected from you

The types of personal information we collect and process when you apply for a role with Signal includes (but is not limited to):

  • Identification data and contact details – including your name, address, email address, phone number and other contact information.
  • Employment history – such as previous employers and job titles/positions.
  • Background information – such as academic/professional qualifications, job qualifications, education, details included in your CV/résumé (which might include details of any memberships or interests constituting sensitive personal information), transcripts and employment references.
  • Details of your nominated referees (including their name, contact details, employer and job role).
  • Details of your immigration/visa status.
  • Previous applications/roles (information relating to previous applications you have made to the Company’s Group and/or any previous employment history with the Company’s Group).
  • Other information you voluntarily provide throughout the process, including through assessment centres / exercises and interviews.

As a general rule, during the recruitment process, we try not to collect or process any of the following: information that reveals your racial or ethnic origin, religious, political or philosophical beliefs or trade union membership; genetic data; biometric data for the purposes of unique identification; or information concerning your health or sexual orientation (“Sensitive Personal Information”), unless authorised by law or where necessary to comply with applicable laws.

However, in some circumstances, we may need to collect, or request on a voluntary disclosure basis, some Sensitive Personal Information for legitimate recruitment-related purposes: for example, information about your racial/ethnic origin, gender and disabilities for the purposes of equal opportunities monitoring, to comply with anti-discrimination laws and for government reporting obligations; or information about your physical or mental condition to consider accommodations for the recruitment process and/or subsequent job role. You may provide, on a voluntary basis, other Sensitive Personal Information during the recruitment process.

Personal information collected from other sources

  • References provided by referees.
  • Other background information provided or confirmed by academic institutions and training or certification providers.
  • Information provided by background checking agencies and other external database holders (for example credit reference agencies and professional / other sanctions registries).
  • Information provided by recruitment or executive search agencies.
  • Information collected from publicly available sources, including any social media platforms you use or other information available online.

(in each case, where permissible and in accordance with applicable law).

Purposes for processing personal information
We collect and use this personal information primarily for recruitment purposes – in particular, to determine your qualifications for employment and to reach a hiring decision. This includes assessing your skills, qualifications and background for a particular role, verifying your information, carrying our reference checks or background checks (where applicable) and to generally manage the hiring process and communicate with you about it.

If you are accepted for a role at Signal, the information collected during the recruitment process will form part of your ongoing staff member record and will be processed in accordance with our Employee Privacy Notice.

If you are not successful, we may still keep your application to allow us to consider you for other suitable openings within Signal in the future unless you request that we delete your application. We retain applications for 5 years.

Who we share your personal information with and transfers abroad
We take care to allow access to personal information only to those who require such access to perform their tasks and duties, and to third parties who have a legitimate purpose for accessing it. Whenever we permit a third party to access personal information, we will implement appropriate measures to ensure the information is used in a manner consistent with this Notice and that the security and confidentiality of the information is maintained. We will share your personal information with our Signal UK entity to administer our recruitment processes and store data.

Transfers to third party service providers
We may make certain personal information available to third parties who provide services relating to the recruitment process to us, including:

  • recruitment or executive search agencies involved in your recruitment;
  • background checking or other screening providers and relevant local criminal records checking agencies
  • data storage, shared services and recruitment platform providers, IT developers and support providers and providers of hosting services in relation to our careers website, e.g. AWS;
  • third parties who provide support and advice including in relation to legal, financial / audit, management consultancy, insurance, health and safety, security and intel and whistleblowing / reporting issues.

We may also disclose personal information to third parties on other lawful grounds, including:

  • Where you have provided your consent;
  • To comply with our legal obligations, including where necessary to abide by law, regulation or contract, or to respond to a court order, administrative or judicial process, including, but not limited to, a subpoena, government audit or search warrant;
  • In response to lawful requests by public authorities (including for tax, immigration, health and safety, national security or law enforcement purposes);
  • As necessary to establish, exercise or defend against potential, threatened or actual legal claims;
  • Where necessary to protect your vital interests or those of another person; and/or
  • In connection with the sale, assignment or other transfer of all or part of our business.

In some cases, the sharing described above may result in your personal information being transferred internationally, including from the European Economic Area to a country outside it. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective).

Specifically, Signal and third party service providers operate around the world.  This means that when we collect your personal information we may process it in the US, Ireland, Japan, and Australia.

However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Notice. These include implementing the European Commission’s Standard Contractual Clauses (under Article 46.2 of the General Data Protection Regulation) in the context of intra-group transfers of personal information outside of the EEA.

Legal basis for processing personal information
Under European data protection law, our legal basis for processing your personal information as part of the recruitment process is:

  • our legitimate interests (as summarized above in Section 3);
  • to comply with applicable immigration and/or employment laws and regulations;
  • to take steps prior to entering an employment contract with you, where you are considered for employment;
  • in circumstances where you have made the data public;
  • where we have your consent to do so. Where we have requested your consent to process your personal data, you have the right to withdraw your consent at any time;
  • to protect the rights and interests of Signal, our employees, applicants and others, as required and permitted by applicable law.

If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided in Section 8 below.

Data retention periods
Personal information will be stored in accordance with applicable laws and kept as long as needed to carry out the purposes described in this Notice or as otherwise required by applicable law. Generally this means your personal information will be retained:  in accordance with the retention periods set out in the Company’s Employee Privacy Notice (where you become our employee); or for a period of five years after confirmation that your application was unsuccessful unless you request that we delete your application.

Your data privacy rights
You may exercise the rights available to you under applicable data protection laws as follows:

  • If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided below.
  •  If you are a resident of the EEA, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided below.
  • If we have collected and process your personal information with your consent, then you can withdraw your consent at any time.  Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
  • You have the right to complain to a data protection authority about our collection and use of your personal information.  For more information, please contact your local data protection authority. (Contact details for data protection authorities in the European Economic Area are available at http://ec.europa.eu/newsroom/article29/document.cfm?doc_id=50044he)

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

Contact details
Please address any questions or requests relating to this Notice to our Data Protection Officer (DPO) at dpo@signal.co or by mail at:

Signal Digital Inc.
222 N. LaSalle St.
Suite 1600
Chicago IL
60601

 


Signal Cookie Notice

The Signal Privacy Policy explains how we collect and use information from and about you when you visit our website. This Cookie Notice explains more about how we use cookies and your choices concerning cookies.

For EEA residents only: To select cookie preferences in the EU, click here.

When you visit any web site, it may store or retrieve information on your browser, mostly in the form of cookies and similar technologies to remember things about you so that we can provide you with a better web experience. We or one of our partners may place or recognize a unique cookie on your browser. These cookies do not contain personally identifiable information about you.

Cookies are small data files stored on your browser or device. They may be served by the entity that operates the website you are visiting (“first-party cookies”) or by other companies (“third-party cookies”). Pixels are small images on a web page or in an email. Pixels collect information about your browser or device and can set cookies. Local storage allows data to be stored locally on your browser or device and includes HTML5 local storage and browser cache.

We may also employ software technology known as “web beacons” or “tracking tags” to help us keep track of what content on our Websites is effective and to serve relevant advertising to you. Web beacons are small graphics with a unique identifier that may be invisible to you, and which are used to track the online activity of Internet users.

We use cookies for a number of reasons, like helping us see which features are most popular, counting visitors to a page, improving our users’ experience, keeping our services secure, and generally providing you with a better experience. We may use session cookies (which expire once you close your browser) and persistent cookies (which stay on your computer until you delete them).

The cookies we use generally fall into one of the following categories.

Strictly Necessary
These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms.

Performance Cookies
These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site.

Functional Cookies
These cookies enable the website to provide enhanced functionality and personalisation. They may be set by us or by third party providers whose services we have added to our pages..

Targeting Cookies
These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites.

You have a number of options to control or limit how we and our partners use cookies and similar technologies, including for advertising.

  • Although most browsers and devices accept cookies by default, their settings usually allow you to clear or decline cookies. If you disable cookies, however, some of the features of our services may not function properly.
  • To prevent your data from being used by Google Analytics, you can install Google’s opt-out browser add-on.
  • For information on how our advertising partners allow you to opt out of receiving ads based on your web browsing history, please visit http://optout.aboutads.info/. European users may opt out of receiving targeted advertising through the European Interactive Digital Advertising Alliance.

If you have any questions about our use of cookies, please contact us at privacy@signal.co or at
222 N. LaSalle St. Suite 1600
Chicago IL
60601