US Signal Company, L.L.C. Privacy Policy

Last updated: May 22, 2018

We value your business and we know your privacy is important to you. Accordingly, we have implemented this Privacy Policy which describes: how we collect and use personal information that you provide to us when you request or purchase service from US Signal Company, L.L.C. (US Signal), or interact with our website or Apps; what we do with the information collected; and how you can exercise your privacy rights.

This Privacy Policy applies only to the information collected in respect of your account and does not apply to the content that customers store on our systems or at our locations, including any personal information. US Signal will not disclose, move, access or use customer content except as provided in US Signal’s terms and conditions.

General Collection and Use of Information

US Signal is a company headquartered in the United States that may collect different types of information on its Customers and users based on its business relationship with the Customer or user of its website.  Any personal information collected is stored and processed within the United States.

When requesting or purchasing US Signal services or using US Signal’s website, we may ask you to provide personal information to us. For example, when you create a US Signal portal account, we will ask you for your email address and to create a password. We may also ask for your phone number for purposes such as two-factor verification. If you choose to sign up for one of US Signal's services, we will ask you for billing information. To complete your order we may ask for financial information to determine credit, physical address to install services or send billing notifications, authorized usernames, email addresses, and phone numbers. At times we may ask for other information such as your name or the name of your company.

During your interaction with US Signal, you may choose to provide us with personal information when you email us, chat with us, answer a survey, comment on our blog, or communicate with us through social media services like Twitter, Linkedin, or Facebook.

If you refer an associate to US Signal, we will ask you for their email address. US Signal will then contact your referred associate to determine whether your associate consents to us contacting them.

US Signal allows you to upload your files to our cloud services. While the content of your files may include personally identifiable information, both in the content of a file and in metadata, this Privacy Policy, as stated at the outset, only applies to the information collected in respect of your account and not to the content that you store on our system.

When you use US Signal websites, we may collect certain information automatically from and about your device. This includes data about your software, the operating system you use when accessing our service, your Internet Protocol address and the date and time of each request you make to US Signal. Collecting this information enables us to better diagnose problems with our products, provide customer support more effectively, ensure the security of your data, as well as, ensure the continuous functionality of our products.

We may receive or collect additional information about you from third parties, including event sponsors and web tools.  This is primarily to assist us in understanding how we can maintain and improve the services we offer to best serve you. Third party tools that we use for this are from:

  • Google Analytics which informs US Signal about page visits which in turn allows US Signal to decide if it needs to update certain pages.
  • SurveyMonkey, which US Signal uses to distribute surveys for users to voluntarily complete, will collect the user's IP address.

US Signal may use the information we collect through our products, orders, and Customer contacts for a number of reasons, including to:

  • provide, operate, optimize and maintain our online platforms, products and services;
  • understand how you use our products and customize your experience;
  • set up online accounts;
  • process, fulfill and provide any updates to online orders and address customer needs when purchasing and using its products and services;
  • send you marketing communications we think you'll find valuable, where it is in accordance with your preferences;
  • provide customer support via online chat services; address your online inquiries and requests sent by email or through the US Signal portal or website;
  • communicate with Customers regarding service updates and offers, and provide you with information and access to resources or services that you have requested from us;
  • improve the layout, navigation, and content of our online products;
  • identify and address any server problems or other IT, security, or network issues;
  • investigate, prevent or take action against any violation of its Acceptable Use Policy;
  • prevent abuse of the products and services we offer; and
  • carry out other legitimate business purposes, such as to improve our products and services, as well as other lawful purposes about which we will notify our users and clients.

If we ask you to provide personal information to comply with a legal requirement or to enter into 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). Similarly, if we collect and use your personal information in reliance on our legitimate business interests, we will make clear to you at the relevant time what those legitimate business interests are.

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.

Communication

From time to time, US Signal will communicate with you via email. There are two types of email you may receive:

  1. Service Emails: These are service related emails such as confirmation of password change, expiration of credit card, or a reply to a support issue. You cannot opt out of receiving these messages as they are part of the service which US Signal provides to you. You can manage certain Service Emails by signing in to your Account. To stop receiving all Service Emails, you must cancel the service and uninstall the US Signal software from your devices.
  2. Marketing Emails: These will include US Signal company news, tips-and-tricks, service promotions (e.g., refer-a-friend) and similar types of material. Upon creating a US Signal Account you will be able to manage your email preferences, including opting out of receiving all Marketing Emails. You will also be able to unsubscribe at any time by using the unsubscribe link provided in any given email.

Information Sharing

Under no circumstances do we rent, trade or share your physical address or e-mail addresses with any other company for their marketing purposes.

We may share and disclose your personally identifiable information only in the limited circumstances described below:

  • To vendors and other third-party service providers who require access to your personal information to assist in providing and improving our products. The third parties that access and use your information only on our behalf include companies such as Stripe, Salesforce, Google Analytics, Freshservice, Facebook, Twitter, Hubspot, Campaign Monitor, Slack, SurveyMonkey, Zoom, Eventbrite, and SalesForce. For example, we use Freshservice for Help Desk functions; Slack is used for internal communication between employees. Hubspot and Campaign Monitor enables us to send you marketing emails, subject to your preferences. Salesforce is used for CRM and opportunity tracking. We use Zoom to host meetings, and Eventbrite to schedule and host events.
  • We may also disclose your information to third parties: (a) where required by law or regulatory requirement, court order or other judicial authorization, (b) in response to lawful requests by public authorities, including for the purposes of meeting national security and law enforcement requirements; (c) in connection with the sale, transfer, merger, bankruptcy, restructuring or other reorganization of a business; (d) to protect or defend our rights, interests or property, or that of third parties; (e) to investigate any wrongdoing in connection with our products and services; and (f) to protect the vital interests of an individual.
  • To any other person with your consent.
  • If you use our services as part of a business, group, or organization where US Signal was set up by an administrator, the administrator may be able to access and control your account. Refer to your organization's internal policies for more information.
  • Users can give third parties the ability to access information and content in their account (e.g., through APIs). When other services access and use your information, their conduct is governed by their own terms and policies.
  • We may disclose aggregate, non-identifying information about how our users use US Signal products.

Information not subject to this Privacy Policy

  1. If Customer or User participates in public forums of any kind including but not limited to social networking sites, social media, blogs, chat rooms, or forums, even if US Signal participates in these sites, the Customer or User is advised the information submitted to these sites is considered public.  Any information considered public may be read, collected, distributed or used by others without the consent of the Customer or user. Use of the sites referenced herein are at Customer or users sole discretion. Information shared on these sites is not covered by this Policy.
  2. Our Website contains links to third-party websites and third-party plugins (such as social media sharing buttons) operated by other companies. We are not responsible for the privacy practices of such other websites. We encourage you to be aware that when you leave our site you read the Privacy Policy/Notices of such other websites. This Privacy Policy applies solely to information collected by US Signal's products.

We will retain your personal information for the period necessary to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law, for legal, tax or regulatory reasons, or other lawful purposes.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

Privacy of Children

  1. US Signal websites are not designed nor intended for children under the age of 18. US Signal does not knowingly collect any information from children under the age of 18.
  2. The US Signal website, applications and services are designed specifically for individuals over the age of 18.

Customer Proprietary Network Information (“CPNI”)

CPNI is information that is available to US Signal due to its business relationship with a Customer.  This information includes quantity, location, type of service ordered, amount of service used and billing information related to the service.  Customer’s name, address and telephone number are not considered to be CPNI. US Signal does not disclose CPNI to any third-party without written permission by the Customer of record.

Personal Information Security

The security of your personal information is very important to us.

We use appropriate technical and organizational security measures to protect your personal information from loss, misuse, and unauthorized access, disclosure, alteration and destruction, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore we cannot guarantee its absolute security.

Privacy Policy Relating to EU-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield (Applicable to data subjects within the European Union)

US Signal complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from European Union member countries and Switzerland.  US Signal has certified to the Department of Commerce that it adheres to the Privacy Shield Principles of Notice; Choice; Accountability for Onward Transfer; Security; Data Integrity and Purpose Limitation; Access; and Recourse, Enforcement, and Liability. If there is any conflict between the policies in this US Signal Privacy Shield Policy (“Privacy Shield Policy”) and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.

Please note that for the purposes of EU data protection legislation, US Signal is the processor of your personal information. With respect to personal data received or transferred pursuant to the Privacy Shield Framework, US Signal is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.  US Signal complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.

Data Protection Rights

You have the following rights:

  • If you wish to access your personal information that US Signal collects, you can do so at any time by contacting us using the contact details provided under 'How to contact us' heading below.
  • You can correct, update or request deletion of your details in your Account by logging in to your Account. You can also contact us using the contact details provided under 'How to contact us' heading below in order to request that your data is deleted.
  • If you are located in 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 where it is technically possible. Again, you can exercise these rights by contacting us using the contact details below.
  • Similarly, if we have collected and processed 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 file a complaint with the data protection authority about our collection and use of your personal information. Contact details for data protection authorities in the EEA, Switzerland and certain non-European countries (including the U.S. and Canada) are available here.)
  • You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” link in the marketing emails we send you. Alternatively, please contact us at privacy@US Signal.com. Please include your complete name and email address. Note that it may take up to 30 business days to remove you from our marketing lists and, after this point you will still receive Service Emails from us.

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

Data Integrity and Purpose Limitation

US Signal limits the collection of personal data covered by this Privacy Policy to information that is relevant for the purposes of processing. US Signal does not process such personal data in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by the covered individual.

US Signal takes reasonable steps to ensure that such personal data is: reliable for its intended use, accurate, complete, and current. US Signal takes reasonable and appropriate measures to comply with the requirement under the Privacy Shield to retain personal data in identifiable form only for as long as it serves a purpose of processing, which includes US Signals obligations to comply with other applicable laws or compliance frameworks, and US Signal’s business purposes.  US Signal will adhere to the Privacy Shield Principles for as long as it retains such personal data for covered individuals.

Complaints / Dispute Resolution

You can direct any questions or complaints about the use or disclosure of your personal information to us at privacy@ussignal.com. We will investigate and resolve any complaints or disputes regarding the use of personal information within forty-five (45) days of receiving your complaint.

We have committed to using the European Union Data Protection Authorities (EU DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) to serve as the independent recourse mechanisms to handle any complaints US Signal is unable to resolve.  You are able to contact the EU DPAs and FDPIC free of charge for any unresolved data or privacy concerns. Under certain conditions, more fully described on the Privacy Shield website (www.privacyshield.gov/article?id=How-to-Submit-a-Complaint), you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

US Signal commits to cooperate with the European Union Data Protection Authorities (EU DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and comply with the advice given by EU DPAs and the FDPIC  with regard to human resources data transferred from the EU and/or Switzerland.

Privacy Policy Updates

Updates to this Privacy Policy will be made when required in response to changing legal, technical or business developments. The Privacy Policy is subject to change and without notice.  US Signal encourages its Customers and users to check its website periodically for any changes or revisions to this Privacy Policy. When we update our Privacy Policy, we will take appropriate measures to inform you when required by law.  You can see when this Privacy Policy was last updated by checking the “last updated” date displayed at the top of this Privacy Policy.

How to Contact Us

If you have any questions or concerns regarding the use or disclosure of your personal information, you can contact us by sending an email to privacy@ussignal.com or by contacting us at:

US Signal Company
Attn: Data Protection Officer
201 Ionia, SW
Grand Rapids, MI 49503
616.233.5701

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