Stoic Privacy Policy
Effective date: October, 2022Welcome to the Cindicator, Inc., (hereinafter,
“Cindicator,” “us,” “our,” or “we”) Privacy Policy (the
“Policy”). This Policy governs our information-handling
practices as applicable to individuals that are visiting our
websites,
www.cindicator.com
or
https://stoic.ai/, (the “Website”), and customers who use our mobile and desktop
applications, chat bots, tools or any related services (together
with the Website, the “Service”)
This Policy explains how
we collect, use, disclose, and protect data subjects’
information as part of the Service in accordance with data
protection laws. Any discussion of your use of the Service in
this Policy is meant to include your visits and other
interactions with the Website and Services, whether or not you
are a user of the Cindicator’s mobile application(s).
By
accessing and using the Service, you agree to the terms of this
Policy. If you do not agree with any aspect of this Policy or
Terms of Use, you should immediately discontinue access or use
of our Services.
Our Website may contain links to
third-party websites. If you follow a link to any of those
third-party websites, please note that they have their own
privacy policies and that we do not accept any responsibility
for their policies or processing of your personal data. Please
check these policies before you submit any personal data to such
third-party websites.
Information We May CollectWe may collect and process data about you from several
sources.
1. Information that you provide to usYou will be asked to provide us with your information
when you:
-
fill in forms on our Website, or correspond with us by
phone, email or otherwise;
- register to use our Services;
-
register to our services with one of the following services:
Google, Apple;
- use the Services;
- report a problem with our Website or Services; or
-
complete any surveys we ask you to fill in that we use for
research purposes.
If you provide us with data about other individuals, you must
ensure to have obtained clear permission from such individuals
before share the data with us. For the avoidance of any doubt,
any reference in this Policy to your data shall include data
about other individuals that you have provided us with.
The
information you will be asked to provide to us for these
purposes may include, but is not limited to, your name, address,
email address, payment information such as credit card
information, social media authentication data (where you
authorize us to access this), public address of cryptocurrency
wallets, mailing address and country of residence, proof of
address, and scan of your personal ID.
If you communicate
with us regarding career opportunities, you will be asked to
provide us with details of your current employment, such as
company name, job title, details about your educational history
including school(s) attended, previous employer(s) and work
experience information, and other relevant information from your
CV (where you provide this to us).
2. Information we collect about youWith regard to each of your visits to our Website and use
of our mobile applications, we may automatically collect the
following information:
• device-specific information, such
as your hardware model, operating system version, unique device
identifiers, and mobile network information;
• technical
information about your computer, including your IP address,
operating system and browser type; or
• details of your
visits to our website, including the full Uniform Resource
Locators (URL) clickstream to, through and from our Website
(including date and time), length of visits to certain pages,
and page interaction information.
We use cookies and other
tracking technologies to collect some of this information. Our
use of cookies and other tracking technologies is discussed in
more detail below.
3. Information we receive from other sourcesThird parties may provide us with certain information
about you in order to enable your use of the Services. From time
to time, we may obtain information about you from third-party
sources, such as public databases, social media platforms,
third-party data providers and our joint marketing partners.
When
you sign in to your account using your social internet service
credentials (Google, Apple), such service sends us your username
and the email address associated with the credentials you've
used. We neither control nor take any responsibility for the way
third parties provide information about you and/or process your
personal data.
4. Information we may collect about othersWe may collect and process data about others that you
provide us with, including (but not limited to) information that
you provide by filling in forms on our Website or that you
provide to us by email. This information might include
information you provide to us on your CV, if relevant, such as
employer details including your references’ name, email address,
telephone number, and address, or may include emails you provide
to us in order to share articles or jobs.
How We Use Your InformationUse of personal data must be justified under one of a
number of legal grounds and we are required to set out the
ground in respect of each use of your personal data in this
Policy. These are the principal grounds that justify our use of
your information about you and others:
• Consent — Where
you have consented to our use of your personal data (you are
providing explicit, informed, freely given consent, in relation
to any such use and may withdraw your consent in the
circumstance detailed below by notifying us);
• Contract
performance — Where your information is necessary to enter into
or perform our contract with you;
• Legal obligation —
Where we need to use your information to comply with our legal
obligations;
• Legitimate interests — Where we use your
information to achieve a legitimate interest and our reasons for
using it outweigh any prejudice to your data protection rights;
and
• Legal claims — Where your information if necessary
for us to defend, prosecute or make a claim against you or a
third party.
We may use the personal data we collect
through the Services or other sources for a range of reasons,
including:
• To communicate with you about your account and
provide customer support — For example, if you use our mobile
apps, we may ask you if you want to receive push notifications
about activity in your account;
• To send you system alert
messages — For example, we may inform you about temporary or
permanent changes to our Services, such as planned outages, or
send you account, security or compliance notifications, such as
new features, version updates, releases, abuse warnings, and
changes to this Policy;
• To provide, support and improve
the Services — For example, this may include sharing your with
third parties in order to provide and support our Services or to
make certain features of the Services available to you;
•
For our data analytics projects — For example, our data
analytics projects may use data from Cindicator accounts,
including personal data, to provide and improve the Services;
•
Combined information — We may combine personal data with other
information we collect or obtain about you (such as information
we source from our third-party partners) to serve you
specifically, such as to deliver a product or service according
to your preferences or restrictions, or for advertising or
targeting purposes in accordance with this privacy policy. When
we combine personal data with other information in this way, we
treat it as, and apply all of the safeguards in this Policy
applicable to, personal data;
• To bill and collect money
owed to us by you — For example, this may include sending you
emails, invoices, receipts, notices of delinquency, and alerting
you if we need a different credit card number. We may use third
parties for secure credit card transaction processing, and those
third parties collect billing information to process your orders
and credit card payments;
• To enforce compliance with our
Terms of Use and applicable law, and to protect the rights and
safety of our customers and third parties, as well as our own —
This may include developing tools and algorithms that help us
prevent violations;
• To meet legal requirements — For
example: (i) to comply with court orders, valid discovery
requests, valid subpoenas, and other appropriate legal
mechanisms; (ii) to provide information to representatives and
advisors, including attorneys and accountants, to help us comply
with legal, accounting, or security requirements; (iii) to
prosecute and defend a court, arbitration, or similar legal
proceeding; or (iv) to respond to lawful requests by public
authorities, including to meet national security or law
enforcement requirements;
• Other purposes — To carry out
other legitimate business purposes, as well as other lawful
purposes about which we will notify you.
We will not sell
your personal data (or any other data you provide us with) to
third parties; however, we reserve the right to share any data
which has been anonymized and/or aggregated. You acknowledge and
accept that we own all right, title and interest in and to any
derived data or aggregated and/or anonymized data collected or
created by us based on your personal data.
Your RightsUnder the General Data Protection Regulation (EU)
2017/676, you have various rights in relation to your personal
data. All of these rights can be exercised by contacting us at
support@cindicator.com. In certain circumstances, you have the following rights in
relation to your personal data:
• Right to withdraw consent
— When we rely on your consent for processing of your personal
data, you have the right to withdraw your consent at any time.
However, the withdrawal of your consent will not affect the
lawfulness of Cindicator’s processing based on consent before
your withdrawal;
• Right of access — You have the right to
obtain from us information as to whether your personal data is
being processed, and, where that is the case, access to such
personal data;
• Right to rectification — We will use
reasonable endeavors to ensure that your personal information is
accurate. In order to assist us with this, you should notify us
of any changes to the personal information that you have
provided to us by sending us a request to rectify your personal
data where you believe the personal data we have is inaccurate
or incomplete;
• Right to erasure — Asking us to delete all
of your personal data will result in Cindicator deleting your
personal data without undue delay (unless there is a legitimate
and legal reason why we are unable to delete certain of your
personal data, in which case we will inform you of this). Asking
us to stop processing your personal data or deleting your
personal data will likely mean that you are no longer able to
use our Services;
• Right to restriction of processing —
You have the right to ask us to stop processing your personal
data at any time;
• Right to data portability — You have
the right to request that Cindicator provides you with a copy of
all of your personal data and to transmit your personal data to
another data controller in a structured, commonly used and
machine-readable format, where it is technically feasible for us
to do so and the processing is based on consent or contractual
performance;
• Right to complain — Although we encourage
our customers to engage with us in the event they have any
concerns or complaints, you have the right to lodge a complaint
to a supervisory authority;
• Right to object automated
processing — You have the right not to be subject to a decision
based solely on automated processing of your personal data,
including profiling, which produces legal or similarly
significant effects on you. There may be exceptions or
limitations to this right as defined under relevant data
protection laws.
We will not ordinarily charge you in
respect of any requests we receive to exercise any of your
rights detailed above, However, if you make excessive,
repetitive or manifestly unfounded requests, we may charge you
an administration fee in order to process such requests or
refuse to act on such requests.
Where you request us to
rectify or erase your personal data or restrict any processing
of such data, we may notify third parties to whom such personal
data has been disclosed of such request. However, such third
party may have the right to retain and continue to process such
personal data in its own right, for example to enable it to
comply with its own legal obligations.
How We Share Information1. Our service providersSometimes,
we share your information with our third-party service
providers, who help us provide and support our Services and
other business-related functions. Examples include analyzing
data, hosting data, engaging technical support for our Services,
processing payments, and delivering content. These third-party
service providers enter into a contract that requires them to
use your personal data only for the provision of services to us
and in a manner that is consistent with this privacy policy.
2. Advertising partnersWe may partner with third-party advertising networks and
exchanges to display advertising on our Website or to manage and
serve our advertising on other sites and may share personal data
with them for this purpose.
3. Institutions that require KYCWe may be required to disclose your personal data to
various institutions that are subject to KYC rules. For example,
banks and exchanges may request us to provide personal
information about you to complete their internal KYC
procedures.
4. RegulatorsWe may
share your information with any competent law enforcement body,
regulatory body, government agency, court or other third party
if we believe disclosure is necessary: (a) as a matter of
applicable law or regulation, (b) to exercise, establish, or
defend our legal rights, or (c) to protect your vital interests
or those of any other person.
5. A potential buyer or business partnerWe may also share your personal data with a potential
buyer or business partner of Cindicator in the case of a sale,
merger, consolidation, liquidation, reorganization, acquisition,
joint venture, or partnership. In that event, any acquirer will
be subject to our obligations under this Policy, including your
rights to access and choice. We will notify you of the change
either by sending you an email or posting a notice on our
Website.
6. Our current or future affiliates7. Any other person with your consentSubprocessorsList of
subprocessors:
-
Amplitude (amplitude.com). Purpose: Product
analytics. Country: USA;
-
Typeform (typeform.com). Purpose: Surveying
Tool. Country: Spain;
-
Intercom (intercom.com). Purpose: Chat & Help Desk tool.
Country: USA;
-
Appsflyer (appsflyer.com). Purpose: 3rd
Party Tracking Marketing Tool. Country: Israel;
-
Google analytics (analytics.google.com).
Purpose: Product Analytics. Country: USA;
-
Uploadcare (uploadcare.com). Purpose: Data
Hosting. Country: USA;
-
SendGrid (sendgrid.com). Purpose: Email
Delivery Service. Country: USA;
-
Yandex Metrics (metrika.yandex.ru).
Purpose: Product Analytics. Country: Russia;
-
Pushwoosh (pushwoosh.com). Purpose: In-App
Push Notifications. Country: USA;
-
Microsoft Azure (azure.microsoft.com).
Purpose: Cloud Server Infrastructure. Country: USA.
CookiesWe and our partners may use
various technologies to collect and store information when you
use our Services, and this may include using cookies and similar
tracking technologies, such as pixels and web beacons.
What cookies areA cookie is a small software file stored temporarily on
your computer’s hard drive. The main purpose of cookies is to
allow a web server to identify a user’s computer and web browser
and tailor web pages or login information to a user’s
preferences. Cookies help us promptly display the information
needed to use the capabilities of the Service and other
information which we consider to be of interest to visitors to
the Website and users of the Service. Cookies do not give us
access to your computer.
Cookies and your personal dataSome cookies are associated with your account and
personal data, while others are not. We generally treat
information collected by cookies and other technologies as
non-personal data. However, to the extent that IP addresses or
similar identifiers are considered personal data by local law,
we also treat these identifiers as personal data.
Types of cookies we useCindicator uses cookies and similar tracking technologies
to enable functionality of its Services, and to assist with
marketing its products and services to interested individuals.
The following chart explains how we generally use cookies:
-
Authentication. These cookies help us show
you the right information by personalizing the Services to
your account;
-
Security. These cookies help us detect
suspicious or malicious activity on our Services and support
other security features;
-
Preferences and functionality. These
cookies allow our Services to recognize you and your
preferences. For example, they can auto-fill a form for you,
provide you with customized content, remember your
application settings, and more;
-
Advertising. These cookies allow us to show
you advertising about our Services. They also let our
advertising partners know how well our ads are doing by
measuring the ad’s success and the types of interactions
people have with our ads;
-
Research, performance, and analytics. These
cookies help us understand how well our Services are doing
by measuring your interactions with our Services. We use
insights from these cookies to improve on current Services,
and to research and develop new Services, features, or
products.
Third-party cookies, advertising and analytics
cookiesCookies set by us are called “first-party cookies” while
cookies set by others are called “third-party cookies”. We do
not control how third-party cookies are used, so you should
check the website of a third-party cookie provider for more
information about how they are used. Both first-party and
thirdparty cookies can serve many functions, including
analytics, marketing, and advertising. We use third-party
advertising and analytics tools to help us measure traffic and
usage trends for the Service and to share offers with
individuals who may be interested in our Services.
Retention of DataWe retain personal data where we have an ongoing
legitimate business or legal need to do so. Our retention
periods will vary depending on the type of data involved, but,
generally, we'll take into account the following criteria to
determine a retention period:
• Whether we have a legal or
contractual need to retain the data;
• Whether the data is
necessary to provide the Services;
• Whether our customers
have the ability to access and delete the data within their
Cindicator accounts;
• Whether our customers would
reasonably expect that we would retain the data until they
remove it or until their Cindicator accounts are closed or
terminated.
When we have no ongoing legitimate business
need to process your personal data, we will either delete or
anonymize it or, if this is not possible (for example, because
your personal data has been stored in backup archives), then we
will securely store your personal data and isolate it from any
further processing until deletion is possible.
Changes to this PolicyWe may change this Policy at any time and from time to
time. Any revisions to this Policy will be posted on the
homepage of our Website. It is your obligation to periodically
visit our Website to review any changes that may be made to this
Policy. Your continued use of our Services constitutes your
agreement to be bound by any such changes to this Policy. Our
electronically or otherwise properly stored copies of this
Policy are each deemed to be the true, complete, valid,
authentic, and enforceable copy of the version of this Policy
that was in effect on each respective date you visited the
Website.
ContactIf you have any questions or comments, or if you have a
concern about the way in which we have handled any privacy
matter, you may contact us by email at
support@cindicator.com. Our data protection officer can be contacted at
dpo@cindicator.com.