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Privacy Policy

Effective: 03 January 2022

Please read this policy carefully, your privacy is important.


This policy is intended to inform you of our practices regarding the collection, use, and sharing of information you may provide to us through our website: www.siffletdata.com 


We invite you to read this document carefully to know and understand our practices regarding the processing of your personal information that we implement.


Sifflet respects your privacy. This Privacy Policy explains Sifflet’s privacy practices and how information Sifflet processes is handled. When you use Sifflet, Inc.’s websites, services, applications, and documentation, you are agreeing to the collection, transfer, manipulation, storage, disclosure, and other uses of your information as described in this Privacy Policy.


If you have feedback on this Privacy Policy, please email us at privacy@siffletdata.com


Sifflet, Inc. (“Sifflet” or the “Company”) is committed to complying with the applicable data privacy and security requirements in all jurisdictions in which it operates. This website operated by Sifflet, Inc. Sifflet is committed to protecting the privacy of individuals (“Website Guests”) who visit Sifflet’s website(s). All users, whether Website Guests are referred to as “User” or “you” or “your.”


It is important that you read this Privacy Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal information about you so that you are fully aware of how and why we are using your information. This Privacy Policy supplements other notices and privacy policies and is not intended to override them.


This Privacy Policy covers how Sifflet collects, uses, receives, retains, discloses and transfers, including any international disclosure and transfer, (collectively “processes” or “processing”) Personally Identifiable Information or Personal Data (“Personal Information”) on www.siffletdata.com and other websites ending in siffletapp.com (the “website” or “Site) (regardless of where you visit it from). This Privacy Policy also describes your choices regarding use, access, deletion and correction of your Personal Information.


Personal Information includes information about you that is personally identifying, such as your Internet Protocol (IP) address, first name, last name, email address, and which is not otherwise publicly available. Only the legal definition of Personal Information that applies in your location will apply to you under this Privacy Policy.

Sifflet strives to follow the following principles when it processes Personal Information:

  • Transparency. Sifflet discloses what information is processed, any sub processors that are used to provide services, and Sifflet does not give away, sell, or loan Personal Information to third parties.
  • Purpose Limitation. Sifflet processes Personal Information for only the reasons required by the customer or users of the Sifflet services. Sifflet only collects what is necessary to fullfil that purpose.
  • Security. Sifflet takes reasonable and appropriate measures to protect Personal Information.
  • Individual Rights. Sifflet allows users of Sifflet services the opportunity to exercise their rights regarding their Personal Information. Opt-out requests are promptly honored.


To the extent that Sifflet is deemed to be a data processor under data privacy laws, this notice fulfills our obligation to provide certain information to third parties whose Personal Information (as defined below) we process in such capacity, as required by the General Data Protection Regulation 2016/679 (GDPR) and other data privacy laws.

Agreement and Affirmative Consent

By using this Site, you accept and hereby expressly, explicitly and unambiguously consent to our processing of your Personal Information in accordance with the terms of this Privacy Policy.


This Privacy Policy may change from time to time, so please check back periodically for the most recent modification date to ensure that you are aware of any changes in our processing of your Personal Information. If we make any material changes, we will notify everyone by means of a notice on this Site prior to the change becoming effective, and we will notify our customers by email. Your continued use of the Site after any changes signifies your express and unambiguous consent to any such changes. If you do not agree to such changes, you must immediately stop using the Site.


It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes during your relationship with us.


1. The information we collect

Personal Data, or Personal Information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).


We may collect, use, store and transfer different kinds of Personal Information about you which we have grouped together as follows:


1.1. The information you provide us directly if you are required to provide us with information, some of which may identify you. This is particularly the case when you fill in contact us forms, connect with us by telephone, email or any other means of communication, or when you report a problem to us, or when you participate in one of our games, contests, promotional offers, studies or surveys. This information may include your first name, last name, e-mail address, postal address, telephone number, mobile number, company, and post office address.


1.2 The information we automatically collect during each of your visits to our website(s), we may collect, in accordance with applicable legislation and with your consent, where applicable, information relating to the devices on which you use our services or the networks from which you access our services, such as your IP addresses, connection data, types and versions of Internet browsers used, types and versions of plugins in your browser, operating systems and platforms, data about your browsing experience on our website, including your experience on the various URL pages of our website, the content you access or view, the search terms used, download errors, how long you have been viewing certain pages, your device’s advertising ID, interactions with the page and any telephone numbers used to contact us. Among the technologies used to collect this information, we use cookies (for more information, please refer to our legal notices).


1.3 How long your information will be kept

1.3.1 Your Personal Information is archived at the end of the following periods 5 years after your last action in relation to our website or one of our digital communications.
1.3.2 The following categories of Personal Information are kept as long as the consent to receive Sifflet news is activated (releases, sponsorship, event organiser, promotion, etc.).

2. How we use the information we collect

In accordance with applicable legislation and with your consent where required, we may use the information you provide to us on our sites for marketing purposes (for example, (i) to send you our newsletters, (ii) to send you invitations to our events or other communications that may be of interest to you, and (iii) to display targeted advertising on social media platforms or third-party sites).


Opting out - With regard to promotional emails: You may withdraw your consent at any time by (i) unchecking the box in your account, (ii) clicking on the unsubscribe link provided in each of our communications or (iii) contacting us at privacy@siffletdata.com

3. Where your information is stored

We store your Personal Information within the European Union.


Data Retention

We will only retain the information you provide for as long as reasonably as needed to fulfill the purposes for which we collected it, and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.


To determine the appropriate retention period for Personal Information, we consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.


In some circumstances we may anonymize your Personal Information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.


International or Cross-Border Transfer of Your Personal Information and Your Express Consent

Given that the Internet operates in a global environment and that transfer of your information is necessary to provide you with requested services, to provide updates, and to respond to your inquiries, using the Internet to collect and process Personal Information necessarily involves the transmission of data on an international, or cross-border, basis. By providing Personal Information and/or by communicating with us by email, you acknowledge and expressly consent to our processing and disclosure of your Personal Information in this way. The Personal Information of users who are located outside the European Union may be transferred outside of each eligible country to the European Union, where our servers are located and where it will be processed and stored on servers in the European Union. In addition, the servers and storage we use to provide you services are provided by Cloud vendors, such as Amazon Web Services (AWS). We may from time to time add other Cloud vendors. Your Personal Information is stored in one or more of their data centers located in the European Union.

4. Your rights to your personal information

Under certain circumstances, you have rights under data protection laws in relation to your Personal Information. Please see below to find out more about these rights:

4.1 Right of Access - You have the right to receive a copy of your Personal Information in our possession.

4.2 Right of Deletion - You have the right to request the deletion of your Personal Information.

4.3 Right of Rectification - You have the right to request the correction of erroneous or obsolete Personal Information.

4.4 Right of Opposition - You have the right to object at any time for reasons relating to its particular situation, (i) to the processing of your Personal Information for direct marketing purposes or to processing carried out on the basis of our legitimate interest.

4.5 Right to Limit - You have the right to limit the processing of your Personal Information. 

Please note that this right only applies if (i) you dispute the accuracy of your Personal Information during the period in which we verify its accuracy; (ii) in the event of unlawful processing by us and you request a limitation of their use rather than deletion, (iii) we no longer need the Personal Information for processing purposes but they are still necessary for you to establish, exercise or defend legal rights; (iv) in the event of the exercise of your right of objection during the verification period as to whether the legitimate grounds we are pursuing prevail over yours.

4.6 You have the right to file a complaint with the competent supervisory authority or to obtain compensation from the competent courts if you consider that we have not respected your rights.

4.7 Right to Portability - You have the right to the portability of your information; i.e., the right to receive the Personal Information you have provided us in a structured format, commonly used and readable by the machine and the right to transmit this information to another controller.

4.8 You also have the right to define guidelines regarding the fate of your Personal Information after your death.


Accessing Your Information

Sifflet, Inc. is committed to maintaining the privacy of our customers and our customers’ users. We believe that the best way to secure your information is not to gather it in the first place. We gather only the personal information we require to provide our services, we do not sell personal information, and we do not disclose personal information to third parties for direct marketing purposes.


To exercise any of the rights set out above, please submit an access request by email at privacy@siffletdata.com

5. Cookies and similar tracking technologies

We use “cookies” when you visit the Site. These are pieces of information stored on your web browser temporarily, to allow us to uniquely identify your browser while you are browsing or interacting with the Site. Cookies also help us confirm your identity and are required in order to log into your Siffletapp account. 


If you wish to prevent cookies from being used as you navigate our Site, you can reset your browser to refuse all cookies and/or indicate when a cookie is being sent. Users who disable their web browsers’ ability to accept cookies will be able to browse the Site, but will not be able to access or take advantage of all of the features and services on the Site. We therefore recommend you do not block or disable these cookies. To find out more about cookies, including how to see what cookies have been sent and how to manage, as well as delete them, visit www.allaboutcookies.org.


As you navigate the Sifflet website, Sifflet may also collect information through the use of commonly used information-gathering tools, such as Web Beacons (“Web Site Navigational Information”). Web Site Navigational Information includes standard information from your web browser (such as browser type and browser language), your Internet Protocol (“IP”) address, and the actions you take on the Sifflet websites (such as the web pages viewed and the links clicked).


We use first-party secure session cookies to provide our services to Subscribers and Visitors. We cannot provide services unless Subscribers and Visitors accept those cookies.


6. Links to other websites and social networks

Sifflet website pages may occasionally contain links to the websites of our partners or third party companies. Please note that these websites have their own privacy policies and that we are not responsible for the use made by these websites or the information collected when you click on these links. We encourage you to review the privacy policies of these sites before providing them with your Personal Information.

7. Specific jurisdiction responsibilities

Children’s Privacy

Our site is directed to individuals who are the age of majority or older in their jurisdiction. We do not knowingly collect information from children. If you believe your child has provided information to the Site please contact us using the information provided below.


California Privacy Rights; California Do Not Track Disclosures

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to our privacy officer as listed below. We currently do not honor Do Not Track signals.


Nevada Residents

Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to this designated address: privacy@siffletdata.com However, please know we do not currently sell data triggering that statute’s opt-out requirements.


8. Change of purpose

We will only use your Personal Information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.


If we need to use your Personal Information for an unrelated purpose, we will notify you (if we have collected your Personal Information from you directly) or the Customer (if your Personal Information was collected by one of our Customers for purposes of our Services) and we will explain the legal basis which allows us to do so.


Please note that we may process your Personal Information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

9. Modification of our privacy policy

We may occasionally change this Privacy Policy from time to time. When necessary, we will inform you and/or seek your consent before use of our website(s). We recommend that you visit this page regularly to review any changes or updates to our privacy policy.


10. Contact

If you have any questions about this privacy policy or if you have any questions about your Personal Information, you can contact us at privacy@siffletdata.com