Privacy Policy
Singlewire Software, LLC (“Singlewire”, “Company”, “we” or “us”) is committed to the privacy of our clients, website visitors, and users of our applications, products, and services. This privacy policy (“Privacy Policy”) discloses what information is gathered about visitors to our website (“Website”) and users of our applications, products and services (collectively the “Service(s)”), however accessed, and how that information is used.
We obtain and process Personal Information in different capacities. When we collect or process Personal Information for our own purposes, meaning that we determine how and what Personal Information is processed, we are the data controller. This Privacy Policy applies to our collection, use, disclosure, and protection of Personal Information where we are the data controller. It does not apply to Personal Information we process on behalf of our customers who are using our Services (“Clients”) based on their instructions. Any Personal Information we collect or process on behalf of our Clients is covered by our Clients’ privacy policies and notices.
For California Residents
If you are a California resident, please see the “YOUR CALIFORNIA PRIVACY RIGHTS” section below for additional terms that apply to you.
For Residents of the European Economic Area, Switzerland, or the United Kingdom, please see the section “EEA, UK & SWISS PRIVACY RIGHTS” below for additional terms that apply to you.
WHAT IS PERSONAL INFORMATION?
For purposes of this Privacy Policy, “Personal Information” means information that alone or in combination identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
CATEGORIES OF PERSONAL INFORMATION WE COLLECT
We collect certain categories of Personal Information. The categories and a description of the types of data collected in each category are as follows:
| Category | Examples of Personal Information Collected |
| Identifiers | A real name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers. |
| Customer Records | Name, address, telephone number and employment. |
| Internet Activity | Browsing history and information on a consumer’s interaction with our website. |
| Geolocation Data | Imprecise location information, like the city, state and ZIP code associated with your IP address. |
SOURCES OF PERSONAL INFORMATION AND THE PURPOSES FOR WHICH WE COLLECT AND USE IT
Singlewire obtains the categories of Personal Information listed above from the following categories of sources:
- Directly from you. For example, from forms you complete or products and services you purchase.
- Indirectly from you. For example, from observing your actions on our Website or from information your computer or mobile device transmits when interacting with our Website or mobile applications, among other things.
- From third-party data sources. For example, from consumer reporting agencies when we conduct credit checks or employee background checks.
We collect this Personal Information from you for the purposes described below.
| Purpose for Collection and Use | Examples | Category of Data |
| Business Purpose |
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| Communication Purposes |
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| Website Management Purposes |
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| Marketing & Advertising Purposes |
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| For Compliance and Legal Purposes |
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| Analytics |
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INFORMATION WE COLLECT FROM THIRD PARTY SOURCES
We collect Personal Information from various third-party companies and public sources as described below.
| Purpose for Collection and Use | Examples | Category of Data | Third Party Source |
| Commercial Purposes | We use a third party payment processor, Stripe. So, when you make a purchase online, we do not receive your credit card, debit card or other financial information. However, we do receive your contact information and purchase information from Stripe. To learn more about how Stripe protects your Personal Information, see their privacy policy at https://stripe.com/privacy |
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Payment Processors |
| Marketing & Advertising Purposes | We may receive information from our third-party advertising service providers. |
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Service Providers
Third Party Marketing and Analytics Companies |
| Website Management | We may also receive Personal Information from our third-party analytics providers. For more information about this, please visit our Cookie Policy. |
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Website-related Service Providers, including analytics providers
Third Party Marketing and Analytics Companies |
HOW LONG DO WE KEEP YOUR INFORMATION
We retain Personal Information only as long as we have a legitimate business purpose to do so. These purposes may include retaining Personal Information in order to:
- complete the transaction for which the Personal Information was collected;
- continue our ongoing business relationship with you; and
- satisfy any legal, regulatory, tax, accounting or reporting requirements.
To determine the appropriate retention period for individual categories of Personal Information we collect, we consider the nature and sensitivity of the Personal Information; the potential risk of harm from unauthorized use or disclosure of the Personal Information; the purposes for which we process that Personal Information and whether we can fulfill those purposes through other means; and applicable legal, regulatory, tax, accounting, reporting and other requirements.
WHO WE SHARE YOUR INFORMATION WITH
Singlewire limits the release of information, and we require privacy protections in our business relationships. We may share your Personal Information when required by law, or with third parties that perform functions on our behalf or for whom we perform services. We may also share information in order to protect the interests of individuals or in connection with a sale of our business or a merger or acquisition.
| With Whom We Disclose Personal Information | Purpose for Disclosing | Category of Information |
| Employees | Business Purposes including to process orders; communicate with you; provide customer service and improve our products and services.
Website Management including troubleshooting problems, improving the content and functionality of the Website, customizing the Website to you and our users. |
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| Service Providers | Business Purposes including payment processing, customer service, and performing analytics.
Website Management including hosting, troubleshooting problems, improving the content and functionality of the Website, and performing statistical and other analyses of the Website. |
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| Third-Party Advertising Networks and Social Media Platforms | Marketing & Advertising Purposes including to provide targeted advertising and other marketing communications.
Business Purposes including to perform data analysis and statistical analysis for us. |
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| Government and Law Enforcement | Legal Purposes. We will cooperate with law enforcement and other governmental agencies, and may disclose Personal Information: (i) if we believe in good faith we are legally required to disclose that Personal Information, (ii) if we are advised to disclose Personal Information by our legal counsel, or (iii) when necessary to identify, contact or bring a legal action against someone who may cause or be causing harm to, or interfering with the legal rights of, Singlewire or any other person or entity. We may also disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. |
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| Professional Advisors | Business Purposes. To receive advice from our professional advisors, such as our attorneys, accountants, financial advisors and business advisors, in their capacity as advisors to us. |
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| New Owners or Successors in Interest | Change in ownership/business successors. We may share your Personal Information in connection with a contemplated or completed strategic business transaction such as a merger, acquisition, sale of all or substantially all of our assets or stock to a subsequent owner or operator, a dissolution, bankruptcy, liquidation or other similar business transaction where Personal Information may be shared, sold or transferred to that third party, including during the due diligence process. |
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DE-IDENTIFIED / AGGREGATED DATA
We may aggregate or de-identify Personal Information we collect through our Website and when operating our business. For example, we may aggregate Personal Information to calculate the percentage of users in a particular zip code. Once information or data has been de-identified and/or aggregated, such information is no longer Personal Information.
CHILDREN
The Website is not directed at children under 16 years of age. We do not knowingly collect, use, share or sell Personal Information from children under 16. If a parent or legal guardian learns that their child provided us with Personal Information without their consent, please contact us and we will make commercially reasonable attempts to delete such Personal Information.
TOOLS WE USE AND YOUR CHOICES
Our Website utilizes cookies for a variety of purposes, including running our Website, enhancing your experience on the Website, and analyzing the effectiveness of our marketing. Our Cookie Policy provides additional information about the cookies used on our Website, as well as your options to control them.
Google Analytics
We use a tool called “Google Analytics” to collect information about use of the Website across devices. We have implemented the Remarketing and AdWords features of Google Analytics. The Remarketing feature allows us to serve you relevant advertising on third party websites if you have visited our Website, however accessed, but does not personally or directly identify you. AdWords allows us to manage our advertising and collect information about your visit to our Website. Visitors can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads using the Ad Settings. You can opt out of Google Analytics without affecting how you visit the Website. For more information on opting out of being tracked by Google Analytics, visit this Google page.
LEAVING OUR WEBSITE AND/OR LINKING TO THIRD PARTIES
When you leave this Website and go to another linked site, we are not responsible for the content or availability of the linked site. Please be advised that we do not represent either the third party or you, if you enter into a transaction on the third party site. Further, the privacy and security policies of the linked site may differ from ours.
CALIFORNIA PRIVACY RIGHTS
The California Consumer Privacy Act of 2018 and subsequent California Privacy Rights Act (together referred to herein as the “CCPA“) provide additional rights to California residents.
Subject to exceptions permitted by applicable laws and verification of your identity, if you live in California, you may exercise the following rights with regard to your Personal Information. Capitalized terms in this Section that are not defined elsewhere in this Privacy Policy have the definitions set forth in the CCPA.
Sharing Information
In the last 12 months we have not Sold your Personal Information to a third party for monetary compensation.
We may share the following categories of Personal Information with third parties that provide us with targeted advertising or data analytics services.
- Identifiers
- Commercial Information
- Internet Activity
- Inferences
We Do Not Use or Disclose Sensitive Information
We do not use or disclose sensitive Personal Information for any purpose other than our business purposes, as specified under the CCPA.
Your Rights and Choices
The CCPA provides consumers with specific rights regarding their Personal Information, subject to certain exceptions. If you live in California, this section describes your CCPA rights and explains how to exercise those rights.
Right to Know
You have a right to request that we disclose certain information about you and our collection of your Personal Information over the last 12 months. Once we receive your request and confirm your identity, we will disclose to you as required under the CCPA:
- The categories of Personal Information we collected about you;
- The categories of sources for the Personal Information we collected about you;
- Our business or commercial purpose for collecting, disclosing, sharing, or selling that Personal Information;
- The categories of third parties with whom we share that Personal Information; and
- The specific pieces of Personal Information we collected about you;
- The categories of Personal Information that we sold, shared, or disclosed for a business purpose; and
- The categories of third parties to whom Personal Information about you was sold, shared or disclosed for a business purpose.
Right to Delete
Except in certain cases where the CCPA does not require us to do so or provides an exception, you have the right to request that we delete any of your Personal Information that we collected from you and retain. Once we receive and verify your request, we will comply with such request (and direct our service providers and other applicable third parties to do the same).
Right to Correct
You have the right to request that we correct inaccurate Personal Information that we collect about you. If we receive a verifiable request, we will consider it, taking into account the nature of the Personal Information and the purposes of the processing of the Personal Information. We may deny your request if we are unable to verify your identity, or if we determine that the contested Personal Information is more likely than not accurate based on the totality of the circumstances. We may request that you provide us with documentation that is relevant to your request.
Please note, we may choose to delete the contested Personal Information as an alternative to correcting it if doing so would not negatively impact you or you consent to our deletion.
Right to Opt-Out of Sale or Sharing of Personal Information
We do not sell Personal Information. You have the right to opt-out of us sharing your Personal Information with a third party for targeted advertising. To make a request, please submit a secure request or contact us using the information in the “Contact Us” section below.
Exercising Your Rights
In addition to any other options provided in this Privacy Policy, to exercise your rights described above, please submit a verifiable consumer request to us by visiting the request portal or contact us using the information in the “Contact Us” section below us.
Who Can Make a Request
If you are a California resident, only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. See the section titled “Using an Authorized Agent” below for more information. A parent or legal guardian may make a request on behalf of their child.
Verifying Your Request
In order for us to process your request, you must provide:
- Information sufficient to allow us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
- A request with sufficient detail to allows us to properly understand, evaluate, and respond to it.
When we receive your request to exercise your rights under the CCPA, we will: (a) acknowledge receipt of your request; (b) try to match the information you provide in making the request with information we already maintain about you; (c) if required to verify your identity, we may ask you to provide additional information, including Personal Information; and (d) consider various factors when determining how to verify your identity, such as the sensitivity and value of the data, the risk of harm, the likelihood of fraud, etc.
We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (an additional 45 days up to a total of 90 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
For right to know requests, we will select a format to provide your Personal Information to you.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. If applicable, the response we provide will also explain the reasons we cannot comply with a request.
If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Using an Authorized Agent
You have a right to submit requests to exercise your rights under the CCPA through an authorized agent. If you choose to use an authorized agent, you must: (a) provide signed, written permission to that authorized agent to submit requests on your behalf; (b) verify your identity directly with us; and (c) directly confirm with us that you granted permission to the authorized agent to submit the request on your behalf. For clarity, you are required to verify the identity of both yourself and the authorized agent.
We may deny a request from an authorized agent if we do not have proof that they are authorized to act on your behalf.
Non-Discrimination
We will not discriminate against you for exercising any of your rights under the CCPA. Unless permitted by the CCPA, if you exercise your rights under the CCPA, we will not:
- deny you goods or services;
- charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
- provide you a different level or quality of goods or services; or
- suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
California Shine the Light
Under California Civil Code Section 1798.83, California residents have the right to obtain (a) a list of all third parties to whom the Company may have disclosed your Personal Information within the past year for direct marketing purposes; and (b) a description of the categories of Personal Information disclosed. Please contact us as set forth at the end of this Privacy Policy to receive this information.
EEA, UK & SWISS PRIVACY RIGHTS
The terms in this Section are only applicable to those located in the European Economic Area (“EEA”), Switzerland, and the United Kingdom (“UK”).
The purpose of this Section is to provide information and additional provisions that apply to Singlewire’s processing of Personal Information in accordance with the EU General Data Protection Regulation 2016/679, the UK General Data Protection Regulation, and the Swiss Federal Data Protection Act (collectively referred to herein as the “GDPR”). In the event of a conflict between this section and the remainder of the Privacy Policy, this section shall control for those persons located in the EEA, the UK, or Switzerland.
If you are located in the EEA, UK or Switzerland, you have certain rights with respect to your Personal Information. Below is a summary of those rights and additional information applicable to our collection and use of your Personal Information.
Legal Basis for Processing. We rely on several legal bases to process your Personal Information. These legal bases include where:
- the processing is necessary to perform our contractual obligations, such as to provide you with our Services;
- you have given your prior consent, which you may withdraw at any time (such as for marketing purposes or other purposes we obtain your consent for from time-to-time); and
- the processing is necessary for the purposes of our legitimate interests, such as in improving, personalizing and developing our Website and Services, marketing new features or products that may be of interest, and promoting safety and security as described above.
| Purpose | Legal Basis for Processing |
| Website Management: To offer, operate, maintain, deliver, troubleshoot and update the Website; for fraud prevention; and to help us provide safe and reliable services through the Website. | Legitimate Interest of maintaining the Website, preventing fraud and maintaining reliable services through the Website
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| Analytics and Marketing: To analyze and improve the Website and its features and content; to provide direct marketing to you about our products and services; for market research and/or data analysis; to evaluate user needs and customize the Website and services; and to help us understand demographics and content preferences. | Legitimate Interests of (a) providing marketing, (b) understanding our customer and visitor base, (c) Website, service and product improvement, and (d) to inform our internal policies |
| Communications: To communicate with you about changes to this Privacy Policy, our Terms of Use, or any other public facing policies; to respond to your requests or inquiries; and to notify you of new products, services and promotions. | Consent or Legitimate Interests (depending upon the communication) of (a) providing good customer service, (b) answering your requests or inquiries, and (c) notifying you of new products or services or updates to our policies |
| To comply with applicable law or other business purposes: To comply with legal requests or processes; to protect our interests or those of third parties; to address violations of the Terms of Use or this Privacy Policy; to communicate with our professional advisors; pursuant to a change in control or insolvency | Legitimate Interests of (a) protecting our legal rights and interests, and those of third parties, (b) complying with applicable laws, regulations or governmental requests, (c) to seek professional advice; and (d) to manage a change of control situation
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| Product Improvement: To support, analyze, develop, improve, and enhance our products, services, user experience, and operations, including the Website | Legitimate Interests of supporting, analyzing, developing, improving, and enhancing our products, services, user experience, and operations, including the Website
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| Information Received from Third Parties: To supplement Personal Information we already have about you; to improve our ability to contact you; and to enhance our marketing capabilities | Legitimate interests of improving our ability to contact you and market to you. |
| When you contract directly with us: To inform, process, and manage our business transactions with you and provide customer service for you | Contract |
Right to Withdraw Consent. In the event you provide your consent for us to process your Personal Information, you may withdraw your consent at no additional cost by emailing [email protected] to request such change or by contacting us via secure request.
Additional Privacy Rights. You also have the following privacy rights under GDPR:
- Right of access
- Right to rectification
- Right to erasure
- Right to restriction of processing
- Right to data portability
- Right to object
To exercise the above rights, please submit a request to [email protected] or submit a secure request. Additionally, you may contact Singlewire at
Singlewire Software
P.O. Box 46218
Madison, WI 53744
608.661.1140
Marketing. Singlewire does not process Personal Information for the purpose of marketing without first obtaining your express, opt-in consent or having a legitimate interest for doing so. You have the right to object to the processing of Personal Information for marketing purposes at any time by contacting us at [email protected].
Automated Decision Making. Singlewire does not make any automated decisions on your behalf or about you without first obtaining your express, opt-in consent. In the event we secure your consent to do so, you have the right to object to the processing of Personal Information via automated decision making at any time by contacting us at [email protected].
Data Privacy Framework
Singlewire complies with the EU-U.S. Data Privacy Framework (“EU-U.S. DPF“), 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. Singlewire has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (“EU-U.S. DPF Principles“) with regard to the processing of Personal Information received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. Singlewire has also certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (“Swiss-U.S. DPF Principles“) with regard to the processing of Personal Information received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this Privacy Policy and the EU-U.S. DPF Principles, including the UK Extension, 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/.
Singlewire remains responsible for any of your Personal Information that is shared under the Onward Transfer Principle with third parties for external processing on our behalf, as described in the “Who We Share Your Information With” section of this Privacy Policy.
Logging a Complaint
In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Singlewire commits to resolve DPF Principles-related complaints about our collection and use of your Personal Information. EU, UK and Swiss individuals with inquiries or complaints regarding our handling of Personal Information received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF should first contact Singlewire at:
Singlewire Software
P.O. Box 46218
Madison, WI 53744
[email protected]
608.661.1140
If we cannot resolve the conflict internally, in compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, Singlewire commits to refer unresolved complaints concerning our handling of Personal Information received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF to JAMS, an alternative dispute resolution provider 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://www.jamsadr.com/dpf-dispute-resolution for more information or to file a complaint. The services of JAMS are provided at no cost to you.
The U.S. Federal Trade Commission has jurisdiction over Singlewire’s compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF.
An individual may, under certain conditions, invoke binding arbitration. Please see ANNEX I for more information on conditions giving rise to binding arbitration.
Response to Requests from Authorities
We will respond diligently and appropriately to requests from supervisory authorities about this Privacy Policy or compliance with applicable data protection privacy laws and regulations. We will, upon request, provide supervisory authorities with names and contact details of the individuals designated to handle this process. With regards to transfers of Personal Information, we will (1) cooperate with inquiries from the supervisory authority responsible for the entity exporting the data and (2) respect its decisions, consistent with applicable law and due process rights. With regards to transfers of data to third parties, we will comply with supervisory authorities’ decisions relating to it and cooperate with all supervisory authorities in accordance with applicable legislation.
CONTACT US
If you have any questions about this Privacy Policy, please contact us at:
Singlewire Software
P.O. Box 46218
Madison, WI 53744
[email protected]
608.661.1140
We will periodically review and update this Privacy Policy and reserve the right to change or update it.
Last updated July 2024