Privacy Policy

Privacy Policy

Last Updated and Effective: October 1, 2021

In order to provide the SIGND™ marketplace platform through our website (signd.com), mobile application, and through the products and services we provide(collectively, the website, application, and products and services are referred to as our “Site”), and continue to make them better, Ashbry Inc. d/b/a SIGND (“SIGND,” “we,” “us,” or “our”) collects information from you. If you are a resident of California or Nevada, you should read this policy and the applicable sections below for residents of California and Nevada.

This Privacy Policy explains how SIGND collects, stores, uses, transfers, and discloses your personal information. We describe the types of personal information we obtain, how we may use the information and the purposes for which we may use it, with whom we may share it and the choices available to you below. We also describe the measures we take to safeguard the information and tell you how to contact us about our privacy practices.

From time to time, SIGND may revise this Privacy Policy. We will give you notice by posting the revised Privacy Policy on our Site and updating the “Last Updated and Effective” date at the top of this Privacy Policy; we may also notify you in other ways, such as through the contact information you have provided or via a pop-up notification on our Site. Any changes to this Privacy Policy will be effective immediately on posting the updated Privacy Policy unless otherwise stated or as required by applicable law (for example, a different form of notice and your opt-in or opt-out consent, etc.). By continuing to use our Site, you agree to the revised Privacy Policy to the fullest extent permitted by applicable law.

Please also review the applicable Terms of Service, which also apply to use of our Site. This Privacy Policy is incorporated by reference into the Terms of Service. Terms that are defined in the Terms of Service have the same meaning in this Privacy Policy.

You should read the policy in full, but here are a few key things:

  • When you use our Site, even if you’re just browsing, we receive some information from you, such as the type of device you’re using and your IP address.
  • You can choose to share additional information with us, such as your email address, by creating an account, making purchases, or providing content to our Site.
  • If you have questions about this  policy, how we collect or process your personal data, or anything else related to our privacy practices, we want to hear from you; see Contact Us.

Table of Contents

  1. Scope of SIGND Privacy Policy
  2. Information We Collect
  3. Information We Collect Automatically
  4. How We Use Information
  5. How We Share Information
  6. Children and Parents
  7. Your Choices and Rights With Respect to the Personal Information We Have Collected
  8. Accessing Personal Information and Retention Period
  9. Data Security and Protection of Personal Information
  10. Information From Users Outside of the USA and Consent to Transfer Jurisdiction
  11. Links to Other Websites and Services
  12. Notice to California Residents
  13. Notice to Nevada Residents
  14. EU Data Subject Rights
  15. Contact Us

1. Scope of SIGND Privacy Policy

This Privacy Policy applies to all aspects of our Site as well as to information we may collect offline.

This Site may link to or incorporate websites or content hosted and served by others over which we have no control, such as third-party websites, online properties, platforms, social media, or systems, which are each governed by the privacy policy and business practices of the associated third party. You understand and agree that SIGND is not responsible for the security, privacy, or business practices of any third party.

2. Information We Collect

We collect information from you directly, automatically when you visit the Site, and sometimes from third parties. Some of this information may be considered “personal information” under various applicable laws. We consider information that identifies you as a specific, identified individual to be personal information(such as your name, telephone number, and email address), as well as additional information, including IP addresses and cookie identifiers, where required by applicable law. And, if we combine information that we consider to be non-personal with personal information, we will treat the combined information as personal information under this Privacy Policy. Note that we may de-identify personal information so that it is non-personal, such as by aggregating it or converting it to a code, sometimes using a function known as a “hash.” We will treat de-identified information as non-personal to the fullest extent permitted by applicable law.

(a)Information You Provide

SIGND may collect personal information from you when you:

i.         Create an Account on, Login to, or Interact with the Site. SIGND collects your name and email address and the other information that you provide, such as a telephone number, when you register or login, update, or add information or content to your account. We require you to create a username and password if you create an account, although we may enable other methods such as logging in through one of your existing social media accounts such as Facebook, Instagram, and Twitter(collectively, “Social Media Platforms”) or your Apple ID. SIGND also collects certain information relating to any Social Media Platform account or Apple ID that you use to login to or link to your SIGND account (such as your username, bio, and number of followers), as further detailed in sub-section (vii), below, although linking any such account to your SIGND account or logging into SIGND via such account is entirely up to you. We may store payment information (such as credit or debit card details) but only if you choose to save it to your account. If you create an account using a SIGND-provided referral link or code through one of our referral programs, we also receive certain information relating to your use of the unique link.

ii.         Make a Purchase through the Site. SIGND collects the information that you provide when you make a purchase at SIGND, including, for example and as applicable, your name and email address, any mobile telephone contact number (of you or the Recipient) you choose to provide, the name of the Recipient, and the details that you provide as part of your request. When you make a purchase, we may also collect payment information, such as card type, card issuer, credit or debit card number, expiration date, CVV code, billing address, bank account number, and other bank account details, and shipping and delivery information. SIGND processes payment information you provide when you pay for a purchase. We collect information regarding the Recipients that you provide to us to the extent necessary to provide the SIGND Experience, either as part of the content or for the transaction itself (for example, we share the Recipient’s name and the details of the request with the applicable SIGND “Icon User”) or to deliver Merchandise.

iii.         Participate in Sweepstakes, Contests, or Other Promotional Activities. SIGND collects the information that you provide when you enter a sweepstakes, contest, or promotional activities (each, a “Promotion”) through our Site. Each Promotion has its own terms and conditions or official rules, which you should review as they may contain other requirements (such as, allowing use of your name or likeness in advertising unless prohibited by applicable law).

iv.         Contact Customer Service Through the Site. SIGND collects the information that you provide in connection with us providing you customer service.

v.         Provide Content to the Site. We collect information when you submit content to us, such as a video, review, photo, email, text, social media post, or other communication (each, a “Submission”)and, if you are an Icon User, when you submit “Icon Content”. Each Submission, whether submitted to our Site directly or through a Social Media Platform, and all Icon Content, and any other content submitted via the Site, is subject to the applicable Terms of Service. As a result, others may access it, use it, and share it in accordance with the Terms of Service.

vi.         Use Social Media With the Site. We collect information when you interact with our Site through any Social Media Platform. For example, we may enable you to use certain of your existing Social Media Platform accounts to create an account on our Site or “like” or “share” content from our Site. Doing so may allow us to collect (or the third party to share) information about you. Some of your information, such as your username, may be publicly displayed. We may also receive information about you if other users of a Social Media Platform give us access to their profiles and you are one of their connections or “friends”. In addition, we and the Social Media Platform may have access to information about you and your use of our Site and the Social Media Platform. The information we collect is subject to this Privacy Policy. The information that any third party collects is subject to its privacy practices (including whether it shares information with us, the types of information shared, and your choices about what may be visible to others).

vii.         Use the Site as an Icon User. When you use our Site to become or as an Icon User, we collect, in addition to information provided when you create your account, your name, email address, telephone number, and the social media usernames you provide, SIGND Videos and other offerings prepared by you, including any Promotional Materials, and other information relating to our relationship with you, such as payment information. SIGND’s payments to you are made through the third-party payment provider selected by SIGND. You should review the payment provider’s privacy policy before providing your personal information, as it is responsible for personal information in its own right, and its privacy practices may vary from ours.

(b)Information from Third Parties

We may also obtain information, such as contact details (for example, name and email address), country, IP address, purchase histories, marketing preferences, cookie information, hardware and software information and other technical information about you from third parties, such as other users of the Site who upload information or sync their contacts, analytics companies, Social Media Platforms, and other third-party business partners.

We and our third-party business partners may collect information about your visits to and activity on our Site and other websites and services. We may combine that information with other personal information we have collected from or about you, but we will treat the acquired information in the same way we treat that information according to the terms of this Privacy Policy. We may share certain of this information with third party business partners for similar purposes.

3. Information We Collect Automatically

When you visit our Site or otherwise interact with us or our content, we and third-party advertising and analytics companies and other third-party business partners may use a variety of tracking and other technologies that automatically or passively collect certain information (“Usage Information”).

We may use these technologies for a number of reasons, including to save your preferences for future visits to our Site, keep you logged in between visits, to serve targeted advertising to you, and to provide you with improved services. The information we collect may include (but is not limited to):

·       date and time of your visit to our Site;

·       areas you visit within our Site;

·       links that you click on within our Site;

·       websites or advertisements you visit before or after visiting our Site;

·       terms you entered into a search engine that lead you to our Site;

·       IP address, mobile device identifier, or other unique identifier and usage information for the device used to access our Site;

·       precise location data from your device, if you have opted-in to the collection of that information (you may be able to disable the collection of precise location data through the settings on the device used to access our Site, but your approximate location may remain available through its IP address or other information that we collect);

·       device and connection information, such as browser type and version, operating system, and platform; and

·       whether an email message we sent was opened and whether a link in the email message was clicked.

The methods that may be used to collect Usage Information include the following:

1.     Cookies and Local Storage. A cookie is a data file placed on a device when it is used to visit the Site or otherwise access our content. Certain web browsers and certain browser add-ons, such as Adobe Flash, may provide additional local data storage mechanisms that are used in a manner similar to cookies, and some of the content included on our Site may make use of this local storage. To get information about cookies from All About Cookies.org, click here. Cookies and other local storage devices may be used for a variety of purposes (for example ,to identify your device when you revisit our Site, to recall your authentication information, to store information related to your navigation throughout our Site, or to enable certain features on our Site). Some cookies are essential to the functioning of the Site, and, without them, some features and services you have requested cannot be provided. Below is more detail about the types of cookies that we use:

•   Required cookies are required for the functioning of the Site and may be used to implement security features or embed video or sound files. Disabling these cookies will encumber the Site’s performance.

•   Functional cookies allow the Site to help maintain your session and remember choices you have made in order to provide functionality for your benefit. For example, functional “session” cookies allow the Site to remember settings specific to you, such as whether you have previously visited the Site and clicked to acknowledge our cookie banner, which ultimately improves your web experience. Functional cookies also include persistent cookies which are used to remember your preferences when you subsequently visit our Site.

•   Analytics cookies are used to gather statistics about the use of the Site in order to improve the performance and design of the Site. For these purposes, analytics cookies collect information about your device type, operating system type, browser type, domain, other system settings, IP-address, referring URLs, information on actions taken on the Website and the dates and times of your visits, as well as the country and time zone in which your device is located. These cookies are provided by third-party analytics providers, including Google Analytics, and the information obtained through these cookies will be disclosed to or collected directly by these third-party service providers.

•   Advertising cookies are used to control and manage advertisements and our marketing initiatives. These cookies may collect information about how you interacted with our Site, whether you interacted with an advertisement, and whether you visited another website. Such cookies help us to offer you content that may be of interest to you and provide targeted information that seems more relevant to your interests. They also help us to measure the effectiveness of our advertisements and to control and limit the frequency of advertisements and other information being displayed to you. Some of these cookies are persistent cookies, which remain on your computer or other Internet-connected device for a certain period of time after you end your browsing session, unless you delete them. These cookies are provided by third parties such as LinkedIn, Facebook, YouTube and Google Ads.

2.     You may restrict or disable the use of cookies through your web browser, although doing so may prevent you from using the full features of the Site. Each type of web browser offers ways to restrict and delete cookies. For mobile devices, you can manage how your device and browser share certain device data by adjusting the privacy and security settings on your mobile device or browsers. Please refer to the “Your Choices and Rights With Respect to the Personal Information We Have Collected” section below for more options on how to opt out. Web Beacons. Small graphic images or other web programming code called web beacons (also known as “pixels”, “1x1GIFs” or “clear GIFs”) may be included in our web pages and email messages. Web beacons may not be visible to you. Web beacons or similar technologies may be used for a number of purposes, including to count visitors to the Site, to monitor how users navigate the Site, to count how many email messages we sent were opened, and to count whether a link in an email message we sent was clicked.

3.     Embedded Scripts. An embedded script is a programming code that is designed to collect information about your interactions with the Site, such as the links you click on. The code is temporarily downloaded onto your device from our server or a third-party service provider, is active only while you are connected to the Site, and is deactivated or deleted after you are no longer connected.

4.     Other Technologies. We may also use other technologies that collect similar information for security and fraud detection purposes.

“Do Not Track” Signals

Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, SIGND does not currently alter our practices when we receive a “Do Not Track” signal from a visitor’s browser except as specifically required by law. For information about “do not track” from The Future of Privacy Forum, click here.

4. How We Use Information

We may combine information that we have received from you with information from other sources to operate, tailor content, personalize, adjust, and improve our Site. We use your information:

·       to fulfill your request for a purchase, accept your payment, ship and deliver your orders, deliver email messages, and process information you provide through our Site;

·       to maintain your account, to assist with payment transactions, to facilitate use of the Site, and to communicate with you about your account, our relationship with you, and your use of the Site, such as by verifying your information, requesting that you respond to a survey, or checking on the status of an order or request. We may send you text messages if you have provided us with your mobile telephone number for that purpose;

·       to establish and manage a relationship with you as an Icon User;

·       to send you promotional email communications from SIGND(not from any third party) if you have opted in to receive them. To stop receiving email messages, click on the “unsubscribe” link in the footer of the promotional email; please note that even if you unsubscribe, we may send you communications relating to your account or use of the Site, such as administrative and services announcements;

·       to conduct and administer a Promotion if you have chosen to participate. We will not share your information with a third party for the third party’s marketing or promotional purposes unless you agree when you choose to participate in the Promotion;

·       to provide you and others with customer service, to assist in resolving issues, and to evaluate and improve our customer service and processes;

·       to use any Submission or Icon Content as set forth in the applicable Terms of Service, which may include the public display of some information, such as your name, username, or where you reside;

·       to consider your job application and, in connection with the application, to fulfill legal reporting requirements, for internal business purposes (such as evaluating and improving our recruiting processes), or to defend against employment-related claims;

·       to contact you about administrative matters, such as the applicable Terms of Service, or other issues;

·       to better understand your personal preferences and to enable us to provide you with improved and personalized communications and services;

·       to compile aggregate data about Site traffic and interaction;

·       to tailor the content and advertising we display to you or others, on our Site or elsewhere, and to analyze trends and statistics;

·       to create advertising models through lookalike modelling or other research methodologies;

·       for internal business purposes, such as improving our Site, products, and services and to comply with legal requirements and our business practices, such as our recordkeeping, backup, and document retention policies;

·       enforce this Privacy Policy, the Terms of Service, any Additional Terms, and any other terms that you have agreed to;

·       maintain and enhance the safety and security of our Site and prevent misuse;

·       protect against, identify and prevent fraud and other criminal activity, claims and other liabilities; and

·       for other reasons (a) that we disclose when asking you to provide your information, (b) with your consent, or (c) as described in this Privacy Policy.

5. How We Share Information

We share non-personal information, such as aggregated statistics and de-identified information, with third parties to the extent permitted by applicable law. SIGND also shares personal information as provided below in more detail. We do not share personal information with any third party to use for its own marketing or promotional purposes without your consent.

(a)Third Parties Providing Services on our Behalf

We use third parties to perform certain services on our behalf, such as hosting the Site or Site features, providing website usage analytics, fulfilling orders, processing payments, sending email or other communications, providing marketing assistance and data analysis or enhancement, running Promotions, or performing other administrative services. We may share information about you with these third parties to allow them to execute, deliver, or improve the services that they provide for you and for SIGND.

(b)Employment Applications

If you apply for a job with SIGND or any of our subsidiaries or affiliates, we or our service providers may ask you to provide self-identifying information (such as veteran status, gender, and ethnicity) in conjunction with laws and regulations enforced by the U.S. Equal Employment Opportunity Commission and other regulatory agencies. Providing such self-identifying information is voluntary, but if you do provide such information, we and our service providers may submit that information to the appropriate government or regulatory agencies to fulfill reporting requirements and use that information to defend against employment-related complaints.

(c)Sweepstakes, Contests, and Other Promotional Activities

If you participate in a Promotion, we may disclose your information to third parties or to the public in connection with conducting and administering the Promotion, for example, to select a winner, provide a prize, as required by applicable law(such as publishing a list of winners), or as permitted by the applicable terms and conditions or official rules of the Promotion.

(d)When You Request That We Share Your Information

We may share information when you request us to do so, for example, if you opt-in to receive a communication from a third party or if you engage with a Social Media Platform or other third-party application or feature through which information about you is shared.

(e)Administrative Reasons, To Enforce and Protect Legal Rights

1.   To the extent permitted by applicable law, we will disclose your personal information pursuant to a law, regulation, court order, or other legal request or process, such as disclosure to law enforcement or other government officials or agencies in connection with any investigation, for example of fraud, intellectual property infringement, or any other activity that is or may be illegal or may expose SIGND, you, or another to legal liability. This disclosure may include legal requests from a jurisdiction outside of the United States when we have a good faith belief that the response is required by law, regulation, court order, or other legal request or process in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally-recognized standards.

2.   We will disclose your personal information when necessary to exercise, enforce, establish, or defend our legal rights. For example, we may review your account information in order to investigate allegations of hacking or a breach of the applicable Terms of Service. We will disclose your personal information to our legal and other advisors, consultants, and law enforcement or other government entities.

(f)Protecting Others

We will disclose your personal information to third parties when we believe the disclosure is necessary to protect rights, property, or safety of another. For example, we disclose personal information relating to a Site account if we in good faith believe that a Site account is being used in ways that are harmful to another or contrary to the applicable Terms of Service.

(g)Business Transfers

In evaluating or engaging in a sale of assets, merger, acquisition, reorganization, bankruptcy, or other transaction, we reserve the right to disclose, transfer, or assign your personal information and communications. By providing your personal information, you agree that we may transfer such information to the acquiring entity without your further consent.

We may also share with third parties, such as advertisers, aggregated or de-identified information and we do not limit our third-party providers from using, selling, licensing, distributing, or disclosing de-identified data.

We do not sell personal information, and we will not sell personal information except as described in this Privacy Policy or if we provide you with notice and aright to opt-out of such sale.

6. Children and Parents

Our Site is intended for a general audience and not for use by anyone younger than the age of 16 in the United States (or under the applicable legal age outside of the United States). We do not knowingly collect personal information from children younger than the age of 16 (or under the applicable legal age outside of the United States), without the consent of a parent or legal guardian; if we learn that we have done so, we will promptly remove the information from our active databases. If you are a parent or legal guardian who believes that we have collected or used your child’s personal information without your consent, please contact us; see Contact Us.

7. Your Choices and Rights With Respect to the Personal Information We Have Collected

You may have the right to:

  • Know what personal information we have about you and request a copy of the same;
  • Update or change any incorrect personal information;
  • Ask us to stop collecting, processing and using your personal information in certain ways;
  • Request the portability of your personal information; and
  • Raise concerns regarding automated decision-making processes.

You also have the right to do the following:

(a)Marketing Preferences

To stop receiving promotional email communications from SIGND, click on the “unsubscribe” link in the footer of the promotional email. As noted above, we may send you email communications relating to your account or use of the Site even if you have unsubscribed.

(b)Third Party Advertising and Analytics Companies

SIGND works with third-party network advertisers, ad agencies, and other advertising partners to serve SIGND ads online. We may use information we have learned about you to target ads to you and to allow third parties to target ads to you. We also use third-party analytics providers to provide us with information regarding the use of the Site and the effectiveness of our advertisements. These third parties may set and access their own tracking technologies on your device (including cookies and web beacons), and they may otherwise collect or have access to information about you, including Usage Information. We and our third-party advertising and analytics providers may collect personal information over time when you visit the Site or other online websites and services.

We may share non-personal information, including information that has been de-identified, aggregated user statistics, and Usage Information, directly or indirectly through third-party business providers, with third-party advertising companies, analytics providers, and other third parties, including for the purpose of serving you more relevant ads. We may retain third-party providers to help us perform these tasks. For example, we may share personal information with third parties who combine and link information from SIGND with information from other sources. These third-party providers may then make non-personal information available to third-party advertisers, including information about your interests and preferences, to enable them to serve you more relevant ads.

1.     Some of these third parties may be members of the Network Advertising Initiative (“NAI”) or Digital Advertising Alliance (“DAA”)Self-Regulatory Program for Online Behavioral Advertising. NAI and DAA each provide information regarding procedures for opting-out of targeted online advertising from participating companies. For information from NAI about opting out, click here. For information from DAA about opting out, click here, and for information about DAA’s App Choices application, click here.

2.     For mobile applications, you may be able to limit certain advertising practices using the settings on your mobile telephone, tablet, or other mobile device. On most mobile devices, you can install the DAA’s App Choices app to make choices about cross-app interest-based advertisements from participating third parties. For information from NAI about opting out on mobile devices, click here.

3.     SIGND uses Google Analytics. Google Analytics uses cookies and similar technologies to collect and analyze information about the use of the Site and report on activities and trends. This service may also collect information regarding the use of other websites, apps, and online resources. For information from Google about opting out, click here, and to download the Google Analytics opt-out browser add-on from Google, click here.

If you are a California resident, please see our Notice to California Residents regarding additional rights you have, including how to exercise your “Do Not Sell” right.

Opting out through these mechanisms does not block all online advertising; you will continue to receive generic advertisements.

8. Accessing Personal Information and Retention Period

(a)Accessing Your Account

Please note that if you choose not to provide us with certain personal information, we may not always be able to provide you with the relevant SIGND product or service that you request. For example, without providing an email address, you will not be able to create a Site account.

1.     If you have a Site Account, you may access, view, correct, or update certain personal information collected about you, as well as deactivate or delete the account through the account services portal on signd.com or in the mobile application. Icon Users may also deactivate their account by contacting their SIGND Icon Concierge.

2.     If you have any concerns about how we are using your personal information, would like to access, correct, or delete the personal information that you have provided to us, please contact us; see Contact Us. We may refuse to comply with a request if the request is manifestly unfounded, excessive, or repetitive in nature or if the request is for erasure of personal information, i.e., where the processing is necessary to comply with a legal obligation or necessary for the establishment, exercise or defense of legal claims or for record-keeping and research purposes. We also may be entitled to refuse your request, wholly or partly, where exceptions under the applicable law apply.

(b)Retention Period

When you request that we delete your personal information, we will take commercially reasonable steps to remove it from our active databases but will keep original information consistent with our business practices to the extent permitted by applicable law (for example, for purposes of dispute resolution, enforcement of agreements, complying with legal requirements, recordkeeping, backup, and document retention). 9. Data Security and Protection of Personal Information

SIGND takes commercially reasonable security measures to protect the information submitted to us. No method of transmission over the Internet, or method of electronic storage, is 100% secure and therefore you use our Site and transmit information to us at your own risk. Although we use our best efforts to protect the security of your personal information and our system, due to the inherent open nature of the Internet, we cannot assure you that personally identifiable information that we collect will never be disclosed in a manner inconsistent with this Privacy Policy. Inadvertent disclosures may occur. As a result of this and other factors beyond our control, we cannot guarantee the security of the information that you transmit to us, and you do so at your own risk. If you have any questions about security on our Site, please contact us; see Contact Us.

10. Information From Users Outside of the USA and Consent to Transfer Jurisdiction

The Website and its servers are operated in the United States. If you are located outside of the United States, please be aware that any personal information you provide to us will be transferred to the United States. By using the Website and the Services, and by providing us with personal information, you hereby consent to this transfer and our use of the personal information in accordance with this Privacy Policy. By using the Website and our Services you understand and consent to the collection, storage, processing, and transfer of your information to our facilities in the United States and to those third parties with whom we share it as described in this Privacy Policy.

11. Links to Other Websites and Services

For your convenience and information, our Site may contain links to other online services, and may also include third-party features such as apps, tools, widgets and plug-ins. These online services and third-party features may operate independently of SIGND. The privacy practices of these third parties, including details on the information they may collect about you, is subject to their own privacy policies or notices, which we strongly suggest you review. We urge you to review the privacy policies of such entities before providing any personal information. To the extent permitted by applicable law, we are not responsible for the privacy policies of these third parties, including our vendors, or the privacy practices of other service providers.

As discussed above, the providers of third-party apps, tools, and plug-ins on our Site also may use automated means to collect information regarding your interactions with these features. These third parties may collect information about your online activities over time and across third-party websites. This information is collected directly by the providers of the features and is subject to the privacy policies or notices of these providers. To the extent permitted by applicable law, we are not responsible for these providers’ information practices.

12. Notice to California Residents

(a) California Privacy Notice

This California Privacy Notice is effective as of October 1, 2021 and was last updated as of October 1, 2021.

This notice supplements SIGND’s privacy policy and applies only to California residents. This California Privacy Notice sets forth disclosures and rights for California consumers regarding their personal information, as required by the California Consumer Privacy Act (“CCPA”). Terms (including any defined capitalized terms) used in this California Privacy Notice have the same meanings given in the CCPA and the regulations of the Attorney General implementing the CCPA, unless otherwise defined.

i.         Information SIGND Collects. The following table lists the categories of Personal Information that we will collect from our users and will disclose over the next 12 months. The Personal Information we collect and disclose about you will depend on how you use our Site or otherwise interact with us. In addition to the below, we may collect and/or disclose additional types of information, and we will do so after notifying you and get your consent to the extent such notice and consent is required by the CCPA.

Category   of Personal Information Collected

Categories/Sources   of Personal Information

Business/Commercial   Purposes for which Personal Information is Collected

Categories   of Third Parties to whom Personal Information is Disclosed for a Business  Purpose

Identifiers

We  may collect this type of information from these sources as detailed in Information We Collect:
 • Consumers
 • Cookies and Tracking Technologies
 • Third Party Service Providers
 • Third Party Social Media Companies
 • Third Party Business Partners
 • Third Party Data Resellers

We  may use this type of information as detailed in How We Use Information:
 • To fulfill your request, process your payment, deliver your orders,  communicate with you, and provide customer service
 • To maintain your account
 • If you are an Icon User or SIGND Partner, to establish and manage our  relationship and assist with a transaction
 • To use Submissions and Icon Content as set as set forth in the  applicable Terms of Service
 • To contact you about administrative matters
 • To conduct and administer sweepstakes, contests, or promotions
 • To understand your preferences and provide improved services
 • To tailor the content and advertising we display on our Site and elsewhere
 • To analyze Site traffic and interaction
 • To create advertising models
 • To consider your job application
 • For internal business purposes, such as to comply with legal requirements  and business policies and/or to protect the Site, ourselves, and our users

We  may disclose this type of information as detailed in How We Use Information and How We Share Information:
 • Service Providers, such as third parties who deliver our communications
 • Third parties we partner with for contests, sweepstakes, or promotions
 • Third party advertising and analytics companies
 • Other third parties (including government agencies) as required by law or  in connection with court proceedings (such as pursuant to subpoenas or court  orders)
 • Third parties who may acquire your information as a result of a merger,  acquisition or other ownership transition
 • Third parties when you agree to or request that we share your information  with them

The  categories of personal information in CCPA§ 1798.80(e)

We  may collect this type of information from these sources as detailed in Information We Collect:
 • Consumers
 • Cookies and Tracking Technologies
 • Third Party Service Providers
 • Third Party Social Media Companies
 • Third Party Business Partners
 • Third Party Data Resellers

We  may use this type of information as detailed in How We Use Information:
 • To fulfill your request, process your payment, deliver your orders,  communicate with you, and provide customer service
 • To maintain your account
 • If you are an Icon User or SIGND Partner, to establish and manage our  relationship and assist with a transaction
 • To use Submissions and Icon Content as set as set forth in the  applicable Terms of Service
 • To contact you about administrative matters
 • To conduct and administer sweepstakes, contests, or promotions
 • To understand your preferences and provide improved services
 • To tailor the content and advertising we display on our Site and elsewhere
 • To analyze Site traffic and interaction
 • To create advertising models
 • To consider your job application
 • For internal business purposes, such as to comply with legal requirements  and business policies and/or to protect the Site, ourselves, and our users

We  may disclose this type of information to as detailed in How We Use Information and How We Share Information:
 • Service Providers, such as third parties who deliver our communications
 • Third parties we partner with for contests, sweepstakes, or promotions
 • Third party advertising and analytics companies
 • Other third parties (including government agencies) as required by law or  in connection with court proceedings (such as pursuant to subpoenas or court  orders)
 • Third parties who may acquire your information as a result of a merger,  acquisition or other ownership transition
 • Third parties when you agree to or request that we share your information  with them

Characteristics  of protected classifications under California or federal law

We  may collect this type of information from these sources as detailed in Information We Collect:
 • Job Applicant

We  may use this type of information as detailed in How We Use Information:
 • To consider your job application.

We  may disclose this type of information to as detailed in How We Use Information and How We Share Information:
 • Service Providers, such as third parties who deliver our communications
 • Other third parties (including government agencies) as required by law or  in connection with court proceedings (such as pursuant to subpoenas or court  orders)
 • Third parties who may acquire your information as a result of a merger,  acquisition or other ownership transition
 • Third parties when you agree to or request that we share your information  with them

Commercial  information

We  may collect this type of information from these sources as detailed in Information We Collect:
 • Consumers
 • Third Party Service Providers
 • Third Party Business Partners

We  may use this type of information as detailed in How We Use Information:
 • To fulfill your request, process your payment, deliver your orders,  communicate with you, and provide customer service
 • To maintain your account
 • If you are an Icon User or SIGND Partner, to establish and manage our  relationship and assist with a transaction
 • To use Submissions and Icon Content as set forth in the applicable Terms of Service
 • To contact you about administrative matters
 • To conduct and administer sweepstakes, contests, or promotions
 • To understand your preferences and provide improved services
 • To tailor the content and advertising we display on our Site and elsewhere
 • To analyze Site traffic and interaction
 • To create advertising models
 • To consider your job application
 • For internal business purposes, such as to comply with legal requirements  and business policies and/or to protect the Site, ourselves, and our users

We  may disclose this type of information to as detailed in How We Use Information and How We Share Information:
 • Service Providers, such as third parties who deliver our communications
 • Third parties we partner with for contests, sweepstakes, or promotions
 • Third party advertising and analytics companies
 • Other third parties (including government agencies) as required by law or  in connection with court proceedings (such as pursuant to subpoenas or court  orders)
 • Third parties who may acquire your information as a result of a merger,  acquisition or other ownership transition
 • Third parties when you agree to or request that we share your information  with them

Professional  or employment-related information

We  may collect this type of information from these sources as detailed in Information We Collect:
 • Job Applicant

We  may use this type of information as detailed in How We Use Information:
 • To consider your job application.

We  may disclose this type of information as detailed in How We Use Information and How We Share Information:
 • Service Providers, such as third parties who deliver our communications
 • Other third parties (including government agencies) as required by law or  in connection with court proceedings (such as pursuant to subpoenas or court  orders)
 • Third parties who may acquire your information as a result of a merger,  acquisition or other ownership transition
 • Third parties when you agree to or request that we share your information with them

Internet  or other electronic network activity information

We  may collect this type of information from these sources as detailed in Information We Collect:
 • Consumers
 • Cookies and Tracking Technologies
 • Third Party Service Providers
 • Third Party Social Media Companies
 • Third Party Business Partners
 • Third Party Data Resellers

We  may use this type of information for:
 • To better understand your preferences and provide improved services
 • To tailor the content and advertising we display to you on our Site and  elsewhere
 • To compile and analyze statistics about Site traffic and interaction
 • To create advertising models
 • For internal business purposes, such as to comply with legal requirements  and business policies and/or to protect the Site, ourselves, and our users

We  may disclose this type of information to:
 • Service Providers
 • Third party advertising and analytics companies
 • Other third parties (including government agencies) as required by law or  in connection with court proceedings (such as pursuant to subpoenas or court  orders)
 • Third parties who may acquire your information as a result of a merger,  acquisition or other ownership transition
 • Third parties when you agree to or request that we share your information  with them  

Inferences  drawn from any of the information identified above to create a profile about  a consumer

We  may collect this type of information from these sources as detailed in Information We Collect:
 • Consumers
 • Cookies and Tracking Technologies
 • Third Party Service Providers
 • Third Party Social Media Companies
 • Third Party Business Partners
 • Third Party Data Resellers

We  may use this type of information for:
 • To better understand your preferences and provide improved services
 • To tailor the content and advertising we display to you on our Site and  elsewhere
 • To compile and analyze statistics about Site traffic and interaction
 • To create advertising models
 • For internal business purposes, such as to comply with legal requirements  and business policies and/or to protect the Site, ourselves, and our users

We  may disclose this type of information to:
 • Service Providers
 • Third party advertising and analytics companies
 • Other third parties (including government agencies) as required by law or  in connection with court proceedings (such as pursuant to subpoenas or court  orders)
 • Third parties who may acquire your information as a result of a merger,  acquisition or other ownership transition
 • Third parties when you agree to or request that we share your information  with them

iii.         Exercising Your CCPA Access, Deletion, and Do-Not-Sell Rights.

                 A.  CCPA Rights. If you are a California resident, your rights include the right to ask us: to let you know and access the specific pieces of Personal Information we have collected about you over the last 12 months, to delete Personal Information we have collected about you, and to opt-out of the sale of Personal Information, all subject to some limits under the CCPA. You are not required to create an account to make a request under CCPA; more information on each of these rights is set out below.

                 B.  Authorized Agent. If you are an agent submitting a request on a consumer’s behalf, please complete, date, and sign the Verification of Identity and Designation of Authorized Agent form at this link and send a copy, by email to [email protected], you may submit a copy of a power of attorney under California Probate Code Sections 4000-4465. In either case, please also indicate in your email the nature of your request. The consumer’s identity, in addition to your own, will need to be independently verified for us to be able to fulfill your request. We may also ask the consumer to directly confirm to us that they gave you permission to submit the request. Keep in mind that if we do not receive adequate proof that an agent is authorized to act on a consumer’s behalf, we may deny the request.

iv.         Response Timing. We typically process: an access or deletion request within 45 days from the day we receive it (and will notify you within that period if we need more time); and an opt-out of sale request within 15 business days from the day we receive it.

v.         Request to Know/Access or Request to Delete.

                 A.         Making A Request. If you are a California resident and would like to request information about the Personal Information we have collected about you over the last 12 months or to request that we delete your information, you (or an authorized agent) may submit your request, along with the first and last name of the subject of there quest, the email address used to interact with SIGND, and confirmation that the subject is a California resident by either: (1) sending an email to [email protected]; or(2) calling us toll-free at 1-855-66-SIGND.

                 B.         Verifying A Request. We will use the information you provide to verify your request and may request additional information if needed. If we are unable to verify that the individual submitting the request is the same individual about whom we have collected information (or someone authorized by that individual to act on their behalf), we will not be able to process the request.

                 C.         Other Important Information.

                                      1.         Request to Know/Access. You(or an authorized agent) must provide us with enough information to verify your identity. In order to provide specific pieces of information, we require a declaration, signed under penalty of perjury, stating that you are the subject of the request (or an authorized agent). If we are unable to verify that you are the subject of the request (or an authorized agent), we will not provide the information requested.

                                      2.         Request to Delete. In addition, if you have a Site account, you may submit your request through the account services portal on signd.com. You may also delete certain Personal Information you have provided to us through your online account (if you have one).

vi.         Right to Opt-Out of Sale of Personal Information. SIGND does not sell your Personal Information for monetary or other direct compensation; however, SIGND does engage in online advertising practices (and certain analytics or similar activities) that might be considered “sales” under the CCPA. The DAA offers tools for California consumers to send requests under the CCPA to opt out of the sale of personal information by some or all of its participating companies, for information from DAA, click here. In addition, please see the other third-party opt-out mechanisms described in Your Choices. Note that these are cookie-based opt-outs. If, after opting out, you disable cookies, upgrade your browser, or use a different device or browser, you will need to indicate your opt-out choices for each device or browser. For information about DAA’s App Choices application, click here. You may be able to opt-out from interest-based advertising on a mobile device through the device settings. You may also be able to limit the access these third-party advertising companies have to information about you when you use our Site by installing a browser or browser extension that can enable you to block the functionality of some tracking technologies. Please be aware that utilizing these mechanisms does not opt you out of being served advertising. You will continue to receive generic ads while online.

vii.         Users Younger than 16. SIGND does not knowingly sell Personal Information of minors younger than 16 years of age.

viii.         Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights. California consumers have the right to not receive discriminatory treatment for exercising CCPA rights. We will not discriminate against you for exercising your CCPA rights.

ix.         For More Information. See Contact Us.

(b)Other California Rights/Your California Privacy Rights

i.         SIGND does not share your personal information with any unaffiliated third party for its direct marketing purposes without your express consent.

ii.         California residents who have provided us with personal information have the right (under California Civil Code§ 1798.83) to request and obtain from us, once each year, the details of any personal information we shared with a third party for the third party’s direct marketing purposes during the prior calendar year. The details would include the categories of personal information and the names and addresses of the third party with which it was shared.

iii.         To request information about this sharing, you may submit a request with “Your California Privacy Rights” in the subject line, along with your first and last name, and complete mailing address (including street address, city, state, and zip code) by either: sending an email messageto [email protected]; or writing to us at the mailing address in Contact Us.

iv.         If you do not submit and send your request with complete information as set forth above, we will not process it.

(c)California Residents Younger than 18 Only

If you are a California resident below the age of 18 years who has created an account on our Site, you may request that we remove content or information that you have publicly posted by sending an email message to [email protected]; along with your full name and complete mailing address (including street address, city, state, and zip code), a detailed description of the content or information, and confirmation that you are a California resident below the age of 18 years. At our discretion, we may either remove your personal information(but not other content) or remove the content and information, subject to any applicable legal requirements and exceptions.

13. Notice to Nevada Residents

SIGND does not currently sell your covered information as defined under applicable Nevada law; however, you may submit an opt-out request, which we will honor as required by Nevada law should we engage in such a sale in the future.

(a)Making a Request

You may submit an opt-out request by sending an email message to [email protected] along with your full name, any user name, and complete mailing address (including street address, city, state, and zip code), email address (so that we can contact you, if needed, in connection with the request) and confirmation that you are a Nevada resident.

(b)Verifying a Request

You must provide us with information reasonably requested by us to verify your identity and the authenticity of the request.

We typically process these requests within 60 days from the day we receive it (and will notify you within that period if we need an additional 30 days to do so).

14. EU Data Subject Rights

Under the General Data Protection Regulation (“GDPR”), if you are an EU resident and we are processing your personal information, you have the following rights:

•           Right of access: You have the right to request a copy of the information that we hold about you.

•           Right of rectification: You have the right to have information that we hold about you that is inaccurate or incomplete corrected.

•           Right to be forgotten: In certain limited circumstances, you have the right to request that we erase from our records the information that we hold about you.

•           Right to restriction of processing: In certain limited circumstances, you have the right to restrict the processing of your information.

•           Right to withdraw consent: If you have provided consent for the processing of your information you have the right (in certain circumstances) to withdraw that consent at any time which will not affect the lawfulness of the processing before your consent was withdrawn.

•           Right of portability: In certain limited circumstances, you have the right to have the information we hold about you transferred to another organization.

•           Right to object: You have the right to object to certain types of processing of your information such as direct marketing (to the extent applicable).

•           Right to object to automated processing, including profiling: You have the right to not be subject to the legal effects of automated processing or profiling (to the extent applicable).

•           Right to lodge a complaint: You have the right to lodge a complaint to your country's data protection authority if you believe that we have not complied with the requirements of the GDPR with regard to your personal information.

15. Contact Us

(a) To contact us about this Privacy Policy only:

i.         send an email to [email protected];

ii.         call us toll-free at 1-855-66-SIGND; or

iii.         write to us at:

SIGND
1181 S. Rogers Circle

#18

Boca Raton, FL 33487

Attention: Data Protection

(b) To contact us on other matters:

write to us at:

SIGND
1181 S. Rogers Circle

#18

Boca Raton, FL 33487