Privacy Policy

This Privacy Policy (“Privacy Policy”) explains how information is collected and used by Singular Labs, Inc. (“Singular” or “we”, “us”, “our”) and its subsidiaries and affiliated companies.

This Privacy Policy applies to the following:

  1. 1. The data practices on the Singular website at https://www.singular.net (“Website”).
  2. 2. The data practices relating to the unified marketing data, intelligent insights, and automation services (our “Platform”) that Singular provides its partners and customers (“Businesses”). The Platform offer a Businesses the ability to administer, measure and monitor their mobile advertising activities. Singular’s technology includes a plug-in that Business’s incorporate into their online services (which may be a website or mobile app). With the plug-in, Singular collects and process certain end-user personal data on the Business’s behalf.
  3. 3. Our relationship with representatives of our existing and prospective Businesses using our Platform.

We are committed to protecting and respecting data privacy. Please read this Privacy Policy carefully.

Personal Data Processed

We process the information you provide us when you submit an inquiry on our Website.

When you visit our Website, you can submit an inquiry through our online contact forms or through our chat-bot. You can also request a free trial of our Platform. When you contact us, you will be asked to provide information such as your name, work email address, phone number, company name and the subject of your inquiry. We refer to this entire data as “Inquiry Information”.

We collect and process your contact information when you engage us to use our Platform.

When a representative of an existing or prospective Business uses or wishes to use our Platform, we collect that representative’s contact details such as name, email, phone number, position and company, Platform login information, and information relating to the engagement between us and the Business which is made with the involvement of the representative. We refer to this entire data as “Contact Information”.

You do not have a legal obligation to provide us with your Inquiry Information or Contact Information; however, if you choose to not share this information with us we may not be able to respond to your inquiry or provide you the Platform.

The Platform we provide involves processing information of the Business’s data subjects.

In order to provide the Platform to a Business, we process personal information of the Business’s end-users. We do this as a data processor (also known as a service provider) on behalf of the Business and under the Business’s instructions.

Generally, the Platform processes personal data regarding the behavior and usage patterns of the end-users of mobile applications and other mobile properties operated by the Business. Subject to the Business’s discretion, the personal data processed by the Platform can include, among others, the end-user’s IP address, Apple’s ID for Advertising (IDFA), Google Android ID and Advertising ID for Android (AIFA), carrier user “ID”, and geo-location information.

We refer to this type of data as “Platform Information”.

If you are a data subject of the Platform Information (i.e., you are a Business’s end-user), and would like to obtain more information on the collection and processing of your personal data, please contact the Business which is the data controller of your personal data.

We also collect analytics information about your use of the Training Program and Website.

When you visit the Website or the Platform, we record and collect certain information about your interaction with the Website or the Platform, including the IP address from which you access the Website or Platform, time and date of access, type of browser used, language used, links clicked, and actions taken while using the Website or Platform (“Analytics Information“).

Data Controller and Data Processor

The Business is the data controller of the Platform Information, and Singular is its data processor.

Each Business is the data controller of its own Platform Information. They determine the purposes and means of processing that data. We only process such data based on their instructions and for the purpose of providing the Platform to them.

Singular is the data controller of Inquiry, Information Contact Information and Analytics Information

Singular is the data controller for the Inquiry Information, Contact Information and Analytics Information, as explained below.

How we process personal data

To respond to and handle your inquiry.

We process your Inquiry Information to contact you about your inquiry and handle your inquiry.

To send you administrative communications.

We process your Contact Information to send you communications and administrative emails, to manage the provision of the Platform to you and to provide you with further information and updates about Singular’s products and technology.

To send you marketing communication.

We process your Inquiry Information and Contact Information to send you marketing communications such as newsletters, know-how articles, webinar and event invitations, and other useful industry information and announcements. We will do so if we believe you might be interested in receiving these communications from us. You may unsubscribe at any time by contacting us via our online contact form available at Contact Us or via the unsubscribe link in each marketing communication you receive from us. If you provided your personal email address to us and we believe that you are a representative of a prospective Business, we will use the Inquiry Information and Contact Information to determine your business email address (using third party tools) so that we can communicate with you through your business email address.

To provide and maintain the Website and Platform.

We process your Analytics Information to provide, maintain and improve your user experience when accessing our Website or when using our Platform. We also will use the Analytics Information for quality assurance and for development and enhancement of the Platform.

We also process the Analytics Information to improve our email communications.

We will use the Analytics Information to prevent fraud, resolve disputes, troubleshoot problems, assist with any investigations, enforce our terms of use for the Platform and take other actions otherwise permitted by law.

In order to provide the Platform to a Business, we process Platform Information as a data processor (also known as a service provider) on behalf of the Business and under the Business’s instructions.

Who processes your data

We will not share your information with third parties, except in the events listed below or when you provide us your explicit and informed consent.

We will process information with our service providers helping us to operate our business.

We will process personal information with the assistance of our service providers as third parties who assist us with the internal operations of the Website and Platform. These companies are authorized to use your personal information in this context only as necessary to provide these services to us and not for their own promotional purposes. These service providers include Amazon Web Services, Inc. and Snowflake, Inc.

Our third parties are obligated to provide the same level of privacy protection.

We only transfer data to these service providers for limited and specific purposes under a contract, and ensure that they effectively process the personal information in a manner consistent with our obligations. The service providers are required to notify us if they can no longer meet their requirements, and upon notice take reasonable and appropriate steps to stop and remediate unauthorized processing. We can provide a summary or a representative copy of the relevant privacy provisions of our contracts with these third parties upon request to privacy@singular.net.

We will share information with competent authorities, if you abuse your right to use the Platform, or violate any applicable law.

If you have abused your rights to use the Website or Platform, or violated any applicable law, we will share information with competent authorities and with third parties (such as legal counsels and advisors), for the purpose of handling of the violation or breach.

We will share your information if we are legally required.

We will share information if we are required to do so by a judicial, governmental or regulatory authority.

We will share your information with our corporate group of companies.

Because we operate our business as a corporate group of companies, we may also share your information with companies in our corporate group for the same purposes set out in this Privacy Policy. They include:

  • Singular Labs, Ltd. (Israel)
  • Singular (UK) Limited

We will share your information with third parties in any event of a change in our structure.

If the operation of our business is organized within a different framework, or through another legal structure or entity (such as due to a merger or acquisition), we will share information only as required to enable the structural change in the operation of the business.

You may choose to opt out of disclosing your personal information or limiting its use.

You may choose whether your personal information is to be disclosed to a third party, or to be used for a purpose that is materially different from the purposes for which it was originally collected. To exercise that choice, send an email to privacy@singular.net.

We will never ask you for sensitive information (i.e. medical or health conditions, racial or ethnic origin, political opinions, etc).

Cookies

What are cookies?

Cookies are text files, comprised of small amount of data, that are saved on your computer or other device (e.g. smartphone, tablet, etc.) when you use the internet and visit various websites.

The information that the cookies maintain is read by the website you visit, during the session of your visit to the website (these are called ‘session’ cookies), and when you return to visit it again (these are called ‘persistent’ cookies). We also use techniques called web beacons and web pixels for purposes similar to the use of cookies.

We use cookies necessary to operate the Website, for website statistics, for marketing purposes and to remember your website preferences.

We use cookies for a number of purposes, as briefly explained below:

Necessary: Cookies that are strictly necessary for the functioning of the Website. The Website cannot operate properly without these cookies. You can set your browser to block or alert you about these cookies, but some parts of the Website may not function properly.

Statistics: Analytics cookies that help us understand how you and other users interact with our Website by collecting data that does not directly identify you.

Marketing: Marketing cookies help us to deliver ads that we believe are relevant to you. For example, we may use retargeting cookies to deliver ads you receive when you visit other websites.

You can always delete or disable cookies.

You can always delete the cookies saved on your device through the settings of your computer browser or device. You can also disable cookies for future use through the settings of your computer browser or device.

Security and data retention

We will retain your Inquiry Information, Analytics Information and Contact Information for as long as we need it for business purposes, and thereafter as needed for record-keeping matters.

We will retain Inquiry Information, Analytics Information and Contact Information for the duration needed to support our ordinary business activities operating the Website and Platform. Thereafter, we will still retain it as necessary to comply with our legal obligations, resolve disputes, establish and defend legal claims and enforce our agreements.

We will retain Business Information in accordance with the Business’s instructions and only while the Business uses the Platform.

We will retain Business Information pursuant to the Business instructions, and only for the duration needed to provide the Platform to you. Upon the termination of the agreement with us for the provision of the Platform, we will return or delete you Business Information, unless we are required to retain such information under applicable law.

We implement measures to secure your Information.

We implement measures to reduce the risks of damage, loss of information and unauthorized access or use of information. However, these measures do not provide absolute information security. Therefore, although efforts are made to secure personal information, it is not guaranteed, and you cannot expect that the Website or Platform will be immune from information security risks.

International Data transfers

We will internationally transfer information in accordance with applicable data protection laws.

If we transfer your personal data for processing at locations outside your jurisdiction, we will abide by data transfer rules applicable to these situations.

Additional information for individuals in the EU, UK or Switzerland

Singular is the data controller of the Inquiry Information, Contact Information and Analytics Information.

The following is the contact information of Singular as the primary data controller of the Inquiry Information, Contact Information, and Analytics Information:

Singular Labs, Inc.
181 South Park Street, Unit 2
San Francisco, CA 94107
United States of America
Email: privacy@singular.net

For any additional inquiries, contact Eran Friedman at eran@singular.net

Legal basis under EU law for processing your personal data.

The legal basis for processing Analytics Information is our legitimate interest in maintaining, developing and enhancing the Website and the Platform.

The legal basis for processing your Inquiry Information for the purpose of responding to and handling your inquiry is our legitimate interests in responding to your inquiry.

The legal basis for processing your Contact Information and Inquiry Information for the purpose of marketing our services or offering the Platform to you is our legitimate interests in developing and maintaining our business relationship with you as a representative of an existing or prospective Business.

The legal basis for processing your Analytics Information for the purpose of handling instances of abusive use of the Platform is our legitimate interests in defending and enforcing against violations and breaches that are harmful to our business.

The legal basis for processing your information where we are legally required to share it, is our legitimate interests in complying with mandatory legal requirements imposed on us.

The legal basis for processing your information in the event of a change in our corporate structure is our legitimate interests in our business continuity.

With respect to Singular’s processing of your Inquiry Information, Contact Information and Analytics Information, you have certain rights to access, update or delete information, obtain a copy of your information, withdraw your consent and object or restrict certain data processing activities.

If you are in the EU, UK or Switzerland, you have the following rights under the GDPR in relation to Singular’s processing of your Inquiry Information, Contact Information and Analytics Information:

Right to Access your personal data that we process and receive a copy of it.

Right to Rectify inaccurate personal data we have concerning you and to have incomplete personal data completed.

Right to Data Portability, that is, to receive the personal data that you provided to us, in a structured, commonly used and machine-readable format. You have the right to transmit this data to another service provider. Where technically feasible, you have the right that your personal data be transmitted directly from us to the service provider you designate.

Right to Object, based on your particular situation, to using your personal data on the basis of our legitimate interest, including processing your information for marketing communications. However, in cases other than processing your information for marketing communications, we may override the objection if we demonstrate compelling legitimate grounds, or for the establishment, exercise of defense of legal claims. You may also object at any time to the use of your personal data for direct marketing purposes.

Right to Restrict the processing your personal data (except for storing it) if you contest the accuracy of your personal data, for a period enabling us to verify its accuracy; if you believe that the processing is unlawful and you oppose the erasure of the personal data and request instead to restrict its use; if we no longer need the personal data for the purposes outlined in this Policy, but you require them to establish, exercise or defense relating to legal claims, or if you object to processing, pending the verification whether our legitimate grounds for processing override yours.

Right to be Forgotten. Under certain circumstances, such as when you object to us processing your data and we have no compelling legitimate grounds to override your objection, you have the right to ask us to erase your personal data. However, we may still process your personal data if it is necessary to comply with a legal obligation we are subject to under laws in EU Member States, the UK and Switzerland, or for the establishment, exercise or defense of legal claims.

If you wish to exercise any of these rights, contact us at privacy@singular.net.

We reserve the right to ask for reasonable evidence to verify your identity before we provide you with information. Where we are not able to provide you the information that you have asked for, we will explain the reason for this.

If you are the data subject of the Business Information we process on behalf of a Business, and would like to exercise any of your EU, UK or Switzerland rights, please contact the Business.

You have a right to submit a complaint to the relevant supervisory data protection authority.

Subject to applicable law, you have the right to lodge a complaint with your local data protection authority. If you are in the EU, UK or Switzerland, then according to Article 77 of the GDPR, you can lodge a complaint to the supervisory authority, in particular in the Member State of your residence, place of work or place of alleged infringement of the GDPR.

In the United Kingdom, this is the Information Commissioner’s Office (ICO)
– Water Lane, Wycliffe House, Wilmslow – Cheshire SK9 5AF
– Tel. 0303 123 1113.
– Website: https://ico.org.uk/

For a list of national supervisory authorities in the member states of the European Economic Area and their contact information, click here: https://edpb.europa.eu/about-edpb/about-edpb/members_en

CPRA Information for consumers residing in California

If you are an individual residing in California, we provide you with the following information pursuant to the California Privacy Rights Act (CPRA).

We do not collect, use, or disclose sensitive personal information.

This is the personal information we have collected over the past 12 months when we operate as a “business” under the CPRA:

Categories of Personal Information

Specific Types of Personal Information Collected

Source of Information

Identifiers

Name, work email address, phone number (within Inquiry information, and Contact Information)

Platform login information (within Contact Information)

The consumer themselves

Information that identifies, relates to, describes, or is capable of being associated with, a particular individual

Subject of your inquiry (within Inquiry information and Contact Information)

The consumer themselves

Professional or employment-related information

Company name and position (within Inquiry information and Contact Information)

The consumer themselves or the Business they are associated with

Commercial information, including products or services purchased, obtained, or considered

Subject of your inquiry expressing interest in our Platform

Information relating to the engagement between us and the Business which is made with the involvement of the consumer as a representative of the Business

The consumer themselves or the Business they are associated with

Internet or other electronic network activity information

IP address from which you access the Website or Platform, time and date of access, type of browser used, language used, links clicked, and actions taken while using the Website or Platform

The consumer’s device

 

The following are the CPRA specific business or commercial purposes for which we use each category of personal information. Details about the information we collect for each category are provided in the table above. More details about the business or commercial purposes are provided in the Privacy Policy’s section titled ‘HOW WE PROCESS PERSONAL DATA’:

Categories of Personal Information

Business or commercial purposes pursuant to the CPRA

Identifiers

Professional or employment-related information

Commercial information, including products or services purchased, obtained, or considered

Information that identifies, relates to, describes, or is capable of being associated with, a particular individual

Providing customer service, processing or fulfilling orders and transactions, verifying customer information

Auditing related to a current interaction with the consumer who is a job applicant

Processing transactions and verifying customer information

Internet or other electronic network activity information

Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, prosecuting those responsible for that activity

Undertaking internal research for technological development and demonstration

Undertaking activities to verify or maintain the quality of the service and to improve, upgrade or enhance the service

Debugging to identify and repair errors

 

The chart below explains the personal information we disclosed for a business purpose to third parties in the preceding 12 months:

Categories of personal information (under the CPRA)

Categories of third parties to whom we disclose your information and the specific business or commercial purpose for the disclosure

Identifiers

Professional or employment-related information

Commercial information, including products or services purchased, obtained, or considered

Information that identifies, relates to, describes, or is capable of being associated with, a particular individual

Internet or other electronic network activity information

With outside legal counsels and authorities, for the purpose of responding to, handling, and mitigating suspected violations of law in connection with our business.

With third parties to which a law or binding order requires us to disclose your information to. Our purpose in doing so is complying with our obligations under the law or the binding order.

With the target entity of our merger, acquisition or reorganization, and legal counsels, and advisors, for the purpose of facilitating the structural change in the operation of our business within a different framework, or through another legal structure or entity (such as due to a merger or acquisition).

 

The chart below explains about the personal information we shared for online behaviorally targeted ads in the preceding 12 months. Other than this sharing, we have not sold your personal information in the preceding 12 months.
We do not have actual knowledge that we share the personal information of consumers under 16 years of age.

Categories of personal information

Categories of third parties to whom the information is shared for online behaviorally-targeted ads, and the specific business or commercial purpose for sharing 

Internet Protocol (IP) address identifier that your device uses to connect to the internet, and mobile device advertising ID

Internet or other electronic network activity information

Location data

Inferences

Advertising networks, to show you ads based on your visit to our Website.

 

The following rights apply only to a California resident who is not a representative of a Business receiving a product or service from Singular and only in relation to personal information that is not in the context of the Business receiving a product or service from Singular:

Categories of Personal Information

Business or commercial purposes pursuant to the CPRA

Disclosure of Personal Information We Collect About You

You have the right to know:

·  The categories of personal information we have collected about you;

·  The categories of sources from which the personal information is collected;

·  Our business or commercial purpose for collecting personal information;

·  The categories of third parties with whom we share personal information, if any;

·  The specific pieces of personal information we have collected about you.

Right to Deletion

Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:

·  Delete your personal information from our records; and

·  Direct any service providers to delete your personal information from their records.

Please note that we may not delete your personal information if it is necessary to:

·  Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;

·  Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;

·  Debug to identify and repair errors that impair existing intended functionality;

·  Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;

·  Comply with the California Electronic Communications Privacy Act;

·  Engage in public or peer-reviewed scientific, historical, or statistical research that adheres or conforms to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;

·  Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us and compatible with the context in which you provided the information; or

·  Comply with an existing legal obligation.

We also will deny your request to delete if it proves impossible or involves disproportionate effort, or if another exception to the CPRA applies. We will provide you a detailed explanation that includes enough facts to give you a meaningful understanding as to why we cannot comply with the request to delete your information.

Right to correct inaccurate personal information

If we receive a verifiable request from you to correct your information and we determined the accuracy of the corrected information you provide, we will correct inaccurate personal information that we maintain about you.

In determining the accuracy of the personal information that is the subject of your request to correct, we will consider the totality of the circumstances relating to the contested personal information.

We also may require that you provide documentation if we believe it is necessary to rebut our own documentation that the personal information is accurate.

We may deny your request to correct in the following cases:
• We have a good-faith, reasonable, and documented belief that your request to correct is fraudulent or abusive.
• We determine that the contested personal information is more likely than not accurate based on the totality of the circumstances.
• Conflict with federal or state law.
• Other exception to the CPRA.
• Inadequacy in the required documentation
• Compliance proves impossible or involves disproportionate effort.

We will provide you a detailed explanation that includes enough facts to give you a meaningful understanding as to why we cannot comply with the request to correct your information.

Right to Opt-Out of the Sharing of Personal Information

We share your personal information for behaviorally-targeted ads, as explained above. You have a right to opt-out of that sharing. If you would like to exercise your right to opt-out, please send an email to privacy@singular.net.

Protection Against Discrimination

You have the right to not be discriminated against by us because you exercised any of your rights under the CPRA. This means we cannot, among other things:

·  Deny goods or services to you;

·  Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;

·  Provide a different level or quality of goods or services to you; or

·  Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Please note that we may charge a different price or rate or provide a different level or quality of goods and/or services to you, if that difference is reasonably related to the value provided to our business by your personal information.

Disclosures to third parties

California Civil Code Section 1798.83 (and other, similar state statutes) permits our customers who are California residents (or residents of states with similar legislation) to request certain information regarding our disclosure of Personal Data to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@connatix.com. Please note that we are only required to respond to one request per customer each year.

 

Exercising your rights

If you would like to exercise any of your CPRA rights as described above, you should email us to: privacy@singular.net

You may designate an authorized agent to make a request under the CPRA on your behalf. To do so, you need to provide the authorized agent with written permission to do so and the agent will need to submit to us proof that they have been authorized by you. We will also require that you verify your own identity, as explained below.

We may ask you for additional information to confirm your identity and for security purposes, before disclosing the personal data requested to you, by using two or three points of the data verification process, depending on the type of information you require.

Data Privacy Framework

We comply with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce.

We have certified to the U.S. Department of Commerce that we adhere to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF.

We have certified to the U.S. Department of Commerce that we adhere to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF.

We are subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, we commit to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF to ICDR-AAA, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://go.adr.org/dpf_irm.html for more information or to file a complaint. The services of ICDR-AAA are provided at no cost to you.

For complaints regarding DPF compliance not resolved by any of the other DPF mechanisms, you have the possibility, under certain conditions, to invoke binding arbitration. Before you can invoke this binding arbitration mechanism, you must take the following steps:
(1) raise the claimed violation directly with us, and give us an opportunity to resolve the issue within 45 days;
(2) make use of the independent dispute resolution mechanism explained above, which is at no cost to you; and
(3) raise the issue through your Data Protection Authority to the U.S. Department of Commerce and give the Department of Commerce an opportunity to use best efforts to resolve the issue.

If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) Program, and to view our certification, please visit https://www.dataprivacyframework.gov/

Limited Use Policy in Relation to Google APIs

Our use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

Privacy Notice in Relation to Children’s Privacy

For children’s privacy information, refer to our Children’s Privacy Notice here: www.singular.net/children-privacy-notice

Changes to this privacy notice

If we change this Privacy Policy, we will make efforts to proactively notify you of such changes.

From time to time, we may change this Privacy Policy. If we do so, we will make efforts to proactively notify you of such changes. In any event, the latest version of the Privacy Policy will always be accessible at https://www.singular.net/privacy-policy.

Last Updated: May 12, 2024