Signal APIs Privacy Policy

1. General Information

In this privacy policy (the ‘’Privacy Policy’’), “SIGNAL OCEAN LTD”, a private limited company organized and existing under the laws of England and Wales, whose registered office is at 83, Cambridge Street, Pimlico, SW1V 4PS, London, England (hereinafter referred to as “SO UK”), also deemed to include its wholly owned subsidiary “SIGNAL OCEAN SINGLE MEMBER PRIVATE COMPANY”, a single member private company organized and existing under the laws of Greece, whose registered office is at 110, Vouliagmenis Avenue, Glyfada, 166 74, Greece (hereinafter referred to as “SO GR”), the above entities to be referred to jointly as “Signal” or “we”, Signal states its practices regarding information it collects directly from its customers/users (hereinafter referred to as “you”) or automatically through the use of its Application Programming Interface Services (hereinafter referred to as “API(s)” including Add-Ins for Excel Services (hereinafter referred to as “Signal Ocean add-in for Excel”).

This Privacy Policy is intended to help you understand what data we collect, when you use the API(s) and the Signal Ocean add-in for Excel, why we collect it, how that data may be used, with whom it may be shared and your rights regarding our collection and use of that data. In case you use the API(s) via the Signal Ocean Platform (‘’TSOP’’), TSOP’s privacy policy will apply in conjunction with a)this Privacy Policy and b) the privacy policy of  Signal’s website www.thesignalgroup.com (the ‘’Website’’).  

Signal reserves the right to make changes to the Privacy Policy from time to time. We will notify you of any modifications or revisions, by posting the updated version of the Privacy Policy on the Website. Revised terms become effective on the first date that you use the API(s) and the Signal Ocean add-in for Excel, after the updated Privacy Policy has been posted. We advise you to periodically check the Privacy Policy for any such modifications or revisions. In the case of any material changes to the Privacy Policy, we will also notify you via e-mail at the email address you have provided us upon registration. 

Unless otherwise agreed in writing with us, the Privacy Policy remains an integral part of Signal’s APIs Terms of Use. Before you use the API(s) and the Signal Ocean Add-In for Excel, you should read carefully each of the documents comprising the above Terms, including the present Privacy Policy, and print or save a local copy for your records. 

For purposes of the present Privacy Policy, “personal information”, “processing”, “use”, “data controller”, “personal data breach”, “restriction of processing” shall have the same meaning as those specified by the “General Data Protection Regulation” (hereinafter referred to as “GDPR”) and the UK Data Protection Act 2018. 

In case you wish to address any questions regarding the present Privacy Policy, you may contact Dimitris Tsapoulis, by email in the following e-mail address support@thesignalgroup.com.\

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2. Our contact details as data controllers 

In relation to the processing of your personal information, we both act as “Data Controllers”. Our contact details are the following:

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3. The type of personal information we collect 

“Personal information” refers to information that allows us to identify you, directly or indirectly, in particular by reference to an identifier, in the course of your registering to, accessing and using the API(s) including the Signal Ocean Add-In for Excel. We currently collect and process the following personal information about you: 

• Name 
• Surname 
• Company/employer  
• Corporate e-mail address 
• Account log in details (username) and access key
• Any other personal information provided voluntarily by you, if applicable for a specific service, such as your telephone number

The above personal information shall be provided directly by you, in case you choose to register to the API(s) (including the Signal Ocean Add-In for Excel) and create an account. Failure to provide the above personal information will result in your inability to register to, access and use the API(s) and the Signal Ocean Add-In for Excel. 

In addition, we may also collect personal information automatically through your use of the API(s) (including the Signal Ocean Add-In for Excel), such as:

• Date and daytime of access call request
• Details of the specific request
• Username and access key information 
• Amount of data transmitted 

4. How and why we use your personal information

We use your personal information in order to:

1. Process your registration for the purposes of using the API(s) and the Signal Ocean Add-In for Excel, 
2. Provide you i) with the API(s) Service, including the Signal Ocean Add-In for Excel, and relevant products, including but not limited to integrated functionalities, such as instant messaging applications,  that we may deploy from time to time and which you have subscribed for, if applicable and ii) customer support,
3. Enforce our agreement,
4. Communicate with you with respect to the use of the API(s) and the Signal Ocean Add-In for Excel, 
5. Notify you of any modifications/revisions to the API(s) Terms of Use, including but not limited to the present Privacy Policy, 
6. Ensure compliance with our legal obligations, 
7. Improve the quality of Signal’s collaborations and provision of services and our unimpeded and effective communication and interaction with you, 
8. Establish, exercise or support our legal claims, 
9. Improve your interaction with the API(s) and optimize your experience with it and the Signal Ocean Add-In for Excel , 
10. Protect our network, devices and programs for cyber-security (i.e. ensuring confidentiality, integrity and availability of the information, data from attacks or unauthorized access etc..) and other risk management purposes,  
11. For our respective business purposes, such as data analysis, usage analytics, audits, fraud monitoring and prevention, improvement of the API(s) Service, including the Signal Ocean Add-In for Excel, development of new services, identification of usage trends, business development, research, integration of functionalities and/or applications etc. For these purposes, and in order to pursue our legitimate interests, we may de-identify and/or aggregate your personal information with other information. 

We do not in any way share your personal information for any financial or other consideration with any third-party private enterprises, natural or legal persons, public authorities or services or other organizations. 

However, your personal information may be disclosed in the following circumstances: 

• We may share your personal information with third-party service providers or affiliates, who provide technical, support and consulting services to us, such as data analysis, usage analytics, business development, functionality development and improvement, information technology, customer support, integration services provided that such service providers have provided us with satisfactory assurances of their technical and organizational ability to provide appropriate and sufficient data protection, in accordance with applicable law.  
• We may share your personal information to courts and other competent judicial, public, administrative, or law enforcement authorities, which may include such authorities outside of your country of residence, the UK or the European Economic Area, if it is required by any applicable law or any other lawful enforceable act or order, including those outside of your country of residence, the UK or outside of the European Economic Area, and in order to respond to their requests, take precautions against liability, and investigate and defend Signal against any third-party claims or allegations. 

It should be noted that any data transfer to countries outside the UK or the European Economic Area will only be made in compliance with the applicable data protection legislative framework and only when appropriate safeguards are in place to protect your personal data. 

• We may transfer your personal information, for troubleshooting, customer support, usage tracking and data storage purposes to any country, where Signal’s related companies, establishments or subsidiaries are based.It should be noted that prior to any data transfer to countries outside of the UK and/or the European Economic Area, which may not provide equivalent standards of data protection appropriate safeguards will be put in place to ensure the protection of your personal data. 
• In the event of a merger, sale or transfer of assets, joint venture, assignment, reorganization or bankruptcy or other similar proceedings, your personal information may be disclosed to a third party as part of those proceedings. 
• We may share your personal information in order to protect the rights, privacy, security, safety, integrity or Signal’s property, facilities or equipment used to make the API(s) and the Signal Ocean Add-In for Excel available and to enforce the API(s) Terms of Use and the respective Privacy Policies.  

We collect, use or share your personal information only when there is a valid legal basis allowing us to do so. Most commonly, the lawful bases we rely on for processing your personal information are: 

• We have a contractual obligation 
• We have a legal obligation 
• We have a legitimate interest, namely for the purposes described under section 6 (d), (g), (h), (i), (j), and (k).
• We have your consent. You are able to remove your consent at any time. You can do this, by contacting Dimitris Tsapoulis, at the following e-mail address: support@thesignalgroup.com 

5. How we secure and store your personal information 

We process your personal information in a way that ensures its confidentiality. 

We have put in place appropriate security measures to prevent your personal information from being accidentally or unlawfully destroyed, lost, altered, disclosed or accessed in an unauthorized way or otherwise processed. Such measures also apply to entities directly or indirectly controlling, controlled by or under common control with SO UK and/or SO GR. However, no data security measures are 100% secure. We suggest that you create a strong password and that you periodically change it. Moreover, if you have reason to believe that your interaction with us and/or the API(s) is no longer secure, please immediately notify us at the following e-mail address: support@thesignalgroup.com

In addition, we limit access to your personal information to those parties, who have a need to know for executing the tasks assigned to them (restricted access to authorized personnel). We shall take all reasonable steps to ensure that such employees are informed of the nature of your personal information and comply with the provisions of the present Privacy Policy. In any case, these parties will only process your personal information on Signal’s instructions. 

SO may transfer to, store and use your Personal Information – for troubleshooting, customer support, usage tracking and data storage purposes – in any country where SO UK’s and/or SO GR’s related companies, affiliates or third-party service providers are based, even countries outside of the European Economic Area, and which may have lower levels of data protection from those applicable in the European Economic Area. SO UK and/or SO GR also take steps to protect Personal Information in the country in which it is stored, used or to which it is transferred and to ensure that any such data storages, uses and transfers are subject to appropriate safeguards. To safeguard such transfers SO UK and/or SO GR use the European Commission-approved standard contractual data protection clauses, or other appropriate legal mechanisms to safeguard the transfer. If you require more details or wish to obtain a copy please contact support@thesignalgroup.com

We keep your personal information for up to seven (7) years from the termination of your right to use the API(s) Service and the Signal Ocean Add-In for Excel, in accordance with the API’s Terms of Use. 

Your data protection rights

Under data protection law, you have the following rights: 

• Your right to information/communication – You have the right to request and receive clear, transparent and easily understandable information regarding the processing of your personal information. 
• Your right of access - You have the right to ask us for copies of your personal information in a structured, commonly used and machine-readable format. 
• Your right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. 
• Your right to erasure/deletion - You have the right to ask us to erase or delete your personal information in certain circumstances, and especially when it is no longer necessary for the purposes collected or when there is no legitimate reason for us to continue processing it. The right of deletion is not absolute, especially in cases when there is a particular legal obligation or other legitimate reason for Signal to retain your personal information. 
• Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances. 
• Your right to object to processing - You have the right to object to the processing of your personal information in certain circumstances and especially when your personal information are processed for purposes of Signal’s legitimate interest.
• Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
• Your right to revoke your consent – You have the right to revoke your consent at any time, without prejudice to the lawfulness of the consent-based processing prior to its revocation, via e-mail to:  support@thesignalgroup.com

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you, starting from the date of your submission request.  

Please contact us at support@thesignalgroup.com if you wish to make a request.

6. How to complain

If you have any concerns about our use of your personal information, you can make a complaint to us at support@thesignalgroup.com

You can also complain to the relevant competent Data Protection Authority, if you are unhappy with how we have used your personal information. 

In particular, for complaints regarding the use of your personal information by the SO UK, you can contact ICO to the following contact details: (a) The ICO’s address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, (b) Helpline number: 0303 123 1113, (c) ICO website: https://www.ico.org.uk 

For complaints regarding the use of your personal information by the SO GR, you can contact the Hellenic Data Protection Authority to the following contact details: (a) Address: 1-3 Kifissias, 11523, Athens, (b) Telephone: +30 210 6475600 (c) Fax: +30 210 6475628 (d) E-mail: contact@dpa.gr 

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