Please read this policy carefully; your privacy and trust are important to us.
This Privacy Policy describes how Sifflet receives, collects, uses, shares, discloses, transfers, retains, or otherwise processes information, including any international disclosure and transfer relating to individuals (“Personal Information” or “Personal Data”) and the rights associated with that processing.
This Privacy Policy also describes your choices regarding using, accessing, deleting, and correcting your Personal Information.
Personal Information or Personal Data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
This website, siffletdata.com, and other websites ending in siffletdata.com (the “website” or “Site”), regardless of where you visit it from, is operated by Sifflet, Inc. (“Sifflet”, “we”, “us”, “our”, or the “Company”).
Sifflet is committed to complying with the applicable data privacy and security requirements in all jurisdictions in which it operates. In addition, Sifflet is committed to protecting the privacy of individuals (“Website Guests”) who visit or use Sifflet’s website(s). All users, whether Website Guests, are referred to as “User”, “you”, or “your.”
Sifflet respects your privacy. We invite you to carefully read this policy to understand our practices regarding processing Personal Information. When you use Sifflet’s websites, services, applications, and documentation, you agree to your information's collection, transfer, manipulation, storage, disclosure, and other uses as described in this Privacy Policy.
It is important that you read this Privacy Policy and any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing Personal Information about you so that you are fully aware of how and why we are using your information. This Privacy Policy supplements other notices and privacy policies and is not intended to override them.
If you have feedback on this Privacy Policy, please email us at privacy@siffletdata.com
Sifflet is responsible for processing your Personal Information as this Privacy Policy describes unless otherwise specified. Personal Information includes information about you that is personally identifying, such as your Internet Protocol (IP) address, first name, last name, email, and information that is not otherwise publicly available. Only the legal definition of Personal Information that applies in your location will apply to you under this Privacy Policy.
Sifflet strives to adhere to the following principles when it processes Personal Information:
Transparency. Sifflet discloses what information is processed and any Subprocessors used to provide services. Sifflet does not give away, sell, or loan Personal Information to third parties.
Control. Sifflet’s products are designed with security and privacy in mind to ensure you remain in control of your information.
Purpose Limitation. Sifflet processes Personal Information for only the reasons required by the Customers or Users of the Sifflet services. Sifflet only collects what is necessary to fulfill that purpose.
Security. Sifflet takes reasonable and appropriate measures to protect Personal Information.
Individual Rights. Sifflet allows Users of Sifflet services the opportunity to exercise their rights regarding their Personal Information. Therefore, opt-out requests are promptly honored.
We Listen. Sifflet appreciates and listens to your feedback. Maintaining the privacy of your Personal Information is a collaborative effort among Sifflet, our Customers, and our Users.
To the extent that Sifflet is deemed to be a data processor under data privacy laws, this notice fulfills our obligation to provide certain information to third parties whose Personal Information (as defined below) we process in such capacity, as required by the General Data Protection Regulation 2016/679 (GDPR) and other data privacy laws.
By using this Site, you accept and hereby expressly, explicitly, and unambiguously consent to our processing of your Personal Information in accordance with the terms of this Privacy Policy.
This Privacy Policy may change from time to time, so please check back periodically for the most recent modification date to ensure that you are aware of any changes in our processing of your Personal Information. If we make any material changes, we will provide notice on this Site before the change becomes effective, and we will notify our customers by email. Your continued use of the Site after any changes signifies your express and unambiguous consent to any such changes. If you disagree with such changes, you must immediately stop using the Site.
The Personal Information we hold about you must be accurate and current. Please keep us informed if your Personal Information changes during your relationship.
This Privacy Policy applies to the processing of Personal Information collected by us when you:
1. The information we collect
We may collect, use, store, and transfer different kinds of Personal Information about you, which we have grouped as follows:
1.1 The information you provide us directly if you are required to provide us with information, some of which may identify you. This is particularly the case when you fill in our forms, connect with us by telephone, email, or any other means of communication, or when you report a problem to us, or when you participate in one of our surveys, research studies, promotional offers, games, or contests. This information may include your first name, last name, email address, company, office number, mobile number, and postal address.
1.2 The information we automatically collect during each of your visits to our website(s), we may collect, in accordance with applicable legislation and with your consent, where applicable, information relating to the devices on which you use our services or the networks from which you access our services, such as your IP addresses, connection data, types and versions of Internet browsers used, types and versions of plugins in your browser, operating systems, and platforms, data about your browsing experience on our website, including your experience on the various URL pages of our website, the content you access or view, the search terms used, download errors, how long you have been viewing certain pages, your device’s advertising ID, interactions with the page and any telephone numbers used to contact us. Among the technologies used to collect this information, we use cookies (for more information, please refer to our legal notices).
1.3 How long your information will be kept
1.3.1 After the expiry of the applicable retention periods, your Personal Information will be deleted. However, if there is any information that we are unable to delete from our systems, due to technical reasons entirely, we will execute the appropriate action to prevent any further use of such information.
1.3.2 The following categories of Personal Information are kept as long as the consent to receive Sifflet news is activated (releases, sponsorship, event organizer, promotion, etc.).
2. How we use the information we collect
In accordance with applicable legislation and with your consent where required, we may use the information you provide to us on our sites for marketing purposes (for example,
(i) to send you our newsletters, (ii) to send you invitations to our events or other communications that may be of interest to you, and (iii) to display targeted advertising on social media platforms or third-party sites).
Opting out - with regard to promotional emails: You may withdraw your consent at any time by (i) unchecking the box in your account, (ii) clicking on the unsubscribe link provided in each of our communications, or (iii) contacting us at privacy@siffletdata.com
3. Where your information is stored
For Customers and Users located within the European Economic Area (EEA), residing in a country that is a member of the European Union (EU), or residing in the United Kingdom (UK) or Switzerland, we store your Personal Information using Cloud Services Providers (CSPs) within the European Union region.
Sifflet collects and processes Personal Information, including, where legally permissible, special categories of Personal Information for the following purposes and the legal basis on which we rely:
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If we need to collect and process Personal Information by law or under the contract we have entered into with you, and you fail to provide the Personal Information we request, we may not be able to perform as contracted with you.
Data Retention
We will only retain the information you provide for as long as reasonably as needed to fulfill the purposes for which we collected it and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information, and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances, we may anonymize your Personal Information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Given that the Internet operates in a global environment and that transfer of your information is necessary to provide you with requested services, to provide updates, and to respond to your inquiries; using the Internet to collect and process Personal Information necessarily involves the transmission of data on an international, or cross- border, basis. Accordingly, by providing Personal Information and/or communicating with us by email, you acknowledge and expressly consent to our processing and disclosure of your Personal Information in this way.
The Personal Information of Customers or Users located outside the European Union may be transferred outside of each eligible country to the European Union, where our servers are located, and where it will be processed and stored on servers in the European Union region. In addition, the servers and storage we use to provide you services are provided by Cloud services providers, such as Amazon Web Services (AWS). We may, from time to time, add other Cloud service providers. Your Personal Information is stored in one or more of their data centers located in the European Union region.
4. Your rights to your personal information
Under certain circumstances, you have rights under data protection laws concerning your Personal Information. Please see below to find out more about these rights:
4.1 Right of Access – You have the right to receive a copy of your Personal Information in our possession.
4.2 Right of Deletion – You have the right to request the deletion of your Personal Information.
4.3 Right of Rectification – You have the right to request the correction of erroneous or obsolete Personal Information.
4.4 Right of Opposition – You have the right to object at any time for reasons relating to your particular situation, (i) to process your Personal Information for direct marketing purposes, or to processing carried out based on your legitimate interest.
4.5 Right to Limit – You have the right to limit the processing of your Personal Information.
Please note that this right only applies if (i) you dispute the accuracy of your Personal Information during the period in which we verify its accuracy; (ii) in the event of unlawful processing by us and you request a limitation of their use rather than deletion, (iii) we no longer need the Personal Information for processing purposes, but they are still necessary for you to establish, exercise or defend legal rights; (iv) in the event of the exercise of your right of objection during the verification period as to whether the legitimate grounds we are pursuing prevail over yours.
4.6 Right to Complain – You have the right to file a complaint with the competent supervisory authority or to obtain compensation from the competent courts if you consider that we have not respected your rights.
4.7 Right to Portability – You have the right to the portability of your information, i.e., the right to receive the Personal Information you have provided us in a structured format, commonly used and readable by the machine, and the right to transmit this information to another controller.
4.8 Right to Opt-out – You have the right to opt out of certain disclosures of your Personal Information to third parties.
4.9 Right to Open Decision – You have the right not to be subject to a decision based solely on automated processing, including profiling, which may produce legal effects (“Automated Decision-Making”).
4.10 Right to Withdraw Consent – You have the right to withdraw your consent at any time (to the extent we base processing on consent) without affecting the lawfulness of the processing based on such consent before its withdrawal.
4.11 You also have the right to define guidelines regarding the fate of your Personal Information after your death.
4.12 Right to Fair Treatment – You have the right not to be discriminated against for exercising your rights as described above.
Sifflet, Inc. is committed to maintaining the privacy of our Customers and our customers’ users. We believe that the best way to secure your information is not to gather it in the first place. Therefore, we collect only the personal information we require to provide our services, we do not sell personal information, and we do not disclose personal information to third parties for direct marketing purposes.
To exercise any of the rights set out above, please submit an access request by email at privacy@siffletdata.com
Your Personal Information may be processed in response to your request to exercise your rights. We make every effort to respond to all legitimate requests within one month unless otherwise required by law. We will contact you if additional information is needed to honor your request or verify your identity. Occasionally, it may take us longer than one month to process a request, considering the complexity and number of requests we receive.
5. Cookies and similar tracking technologies
We use “cookies” when you visit the Site. These are pieces of information stored on your web browser temporarily, allowing us to uniquely identify your browser while browsing or interacting with the Site. Cookies also help us confirm your identity and are required to log into your Sifflet account.
If you wish to prevent cookies from being used as you navigate our Site, you can reset your browser to refuse all cookies and/or indicate when a cookie is being sent. However, users who disable their web browser’s ability to accept cookies can browse the Site but cannot access or take advantage of its features and services. We, therefore, recommend you do not block or disable these cookies. To learn more about cookies, including how to see what cookies have been sent and how to manage and delete them, visit www.allaboutcookies.org.
As you navigate the Sifflet website, we may collect information through commonly-used information-gathering tools, such as Web Beacons (“Web Site Navigational Information”). Web Site Navigational Information includes standard information from your web browser (such as browser type and browser language), your Internet Protocol (“IP”) address, and the actions you take on the Sifflet websites (such as the web pages viewed and the links clicked).
We use first-party secure session cookies to provide our services to Subscribers and Visitors. We cannot provide services unless Subscribers and Visitors accept those cookies.
6. Links to other websites and social networks
Sifflet website pages may occasionally contain links to the websites of our partners or third-party companies. Please note that these websites have privacy policies and that we are not responsible for using them or the information collected when you click these links. Therefore, we encourage you to review the privacy policies of these sites before providing them with your Personal Information.
7. Specific jurisdiction responsibilities
Our Site is meant for individuals who are the age of majority or older in their jurisdiction. We do not knowingly collect information from children. However, if you believe we have mistakenly or unintentionally collected the Personal Information of a child without the appropriate consent, please contact us using the information below in section 10. Contact
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclose to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information shared and the names and addresses of all third parties with whom we shared information in the preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to our Privacy Officer, as listed below in section 10. Contact. We currently do not honor Do Not Track signals.
Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to this designated address: privacy@siffletdata.com. However, please know we do not currently sell data triggering that statute’s opt-out requirements.
8. Change of purpose
We will only use your Personal Information for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason, and that reason is compatible with the original purpose. If you wish us to explain how the processing for the new purpose is consistent with the original purpose, please contact us.
If we need to use your Personal Information for an unrelated purpose, we will notify you (if we have collected your Personal Information from you directly) or the Customer (if your Personal Information was collected by one of our Customers for purposes of our Services) and we will explain the legal basis which allows us to do so.
Please note that we may process your Personal Information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
9. Modification of our privacy policy
We may occasionally change this Privacy Policy from time to time. We will inform you and/or seek your consent before using our website(s) when necessary. Therefore, we recommend that you visit this page regularly to review any changes or updates to our privacy policy.
10. Contact
Sifflet has appointed a Data Protection Officer (DPO). To exercise your rights regarding your Personal Information, or if you have any questions about this Privacy Policy or if you have any questions about your Personal Information, you can contact us at privacy@siffletdata.com or write to us at:
Sifflet Data Protection Officer
149 Avenue du Maine
75014 Paris, France
When contacting us, please indicate the country and/or state in which you reside.
Sifflet is committed to working with you to obtain a fair resolution to a concern or complaint about privacy. However, if you believe that we have not been able to assist with your concern or complaint, and you are located in the European Economic Area (EEA) or the United Kingdom (UK), you have the right to submit a complaint with the competent supervisory authority. If you work or reside in a country that is a member of the European Union or that is in the EEA, you may discover the contact details for your appropriate data protection authority on this website (linked).
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