www.signalscv.com respects the privacy of visitors to our site. This Privacy Policy governs the use and collection of information from you by Paladin Multi-Media Group, Inc., d/b/a The Newspaper (“we” or “us”) through your use of this site. This Privacy Policy does not apply to any information you may provide to us through other means; for example, at a live event, via mail, or via telephone. Please read this Privacy Policy carefully so that you understand our online privacy practices. By visiting this site, you agree that your visit, and any dispute over our online privacy practices, is governed by this Privacy Policy.

CHILDREN’S PRIVACY

Children should always get permission from their parents before sending any information about themselves (such as their names, email addresses, and phone numbers) over the Internet, to us or to anyone else. We won’t knowingly allow anyone under 13 to register with our site or to provide any other personally identifying information. If you’re under 13, please do not provide us with any personally identifying information about yourself (such as your name, your email address or your phone number).

TYPES OF DATA COLLECTED

Among the types of Personal Data that this Website collects, by itself or through third parties, there are: Cookies; Usage Data; first name; last name; phone number; address; email address; country; city.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.

Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.

Unless specified otherwise, all Data requested by The Signal (signalscv.com) is mandatory and failure to provide this Data may make it impossible for The Signal to provide its services. In cases where The Signal specifically state that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.

Users who are uncertain about which Personal Data is mandatory are welcome to contact The Signal at signalscv.com/contact.

Any use of Cookies – or of other tracking tools – by The Signal or by the owners of third-party services used by The Signal serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through this Website and confirm that they have the third party’s consent to provide the Data to The Signal.

MODE AND PLACE OF PROCESSING THE DATA

Methods of processing
The Signal takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.

The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to The Signal, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by The Signal. The updated list of these parties may be requested from The Signal at any time.

Legal basis of processing
The Signal may process Personal Data relating to Users if one of the following applies:

·      Users have given their consent for one or more specific purposes. Note: Under some legislations The Signal may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;

·      provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;

·      processing is necessary for compliance with a legal obligation to which The Signal is subject;

·      processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in The Signal;

·      processing is necessary for the purposes of the legitimate interests pursued by The Signal or by a third party.

In any case, The Signal will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract. 

Place
The Data is processed at The Signal’s operating offices and in any other places where the parties involved in the processing are located.

Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by The Signal to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with The Signal using the information provided in the contact section.

Retention time
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:
·      Personal Data collected for purposes related to the performance of a contract between The Signal and the User shall be retained until such contract has been fully performed.

·      Personal Data collected for the purposes of The Signal’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by The Signal within the relevant sections of this document or by contacting The Signal.The Signal may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, The Signal may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The purposes of processing
The Data concerning the User is collected to allow The Signal to provide its Services, as well as for the following purposes: Displaying content from external platforms, Managing data collection and online surveys and Interaction with external social networks and platforms.

Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.

Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:

Displaying content from external platforms

This type of service allows you to view content hosted on external platforms directly from the pages of this Application and interact with them.

This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.

YouTube video widget (Google LLC)
YouTube is a video content visualization service provided by Google LLC that allows this Application to incorporate content of this kind on its pages.

Personal Data collected: Cookies; Usage Data.

Place of processing: United States – Privacy Policy. Privacy Shield participant.

Interaction with external social networks and platforms

This type of service allows interaction with social networks or other external platforms directly from the pages of this Application.

The interaction and information obtained through this Application are always subject to the User’s privacy settings for each social network.

This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.

It is recommended to log out from the respective services in order to make sure that the processed data on this Website isn’t being connected back to the User’s profile.

Twitter Tweet button and social widgets (Twitter, Inc.)
The Twitter Tweet button and social widgets are services allowing interaction with the Twitter social network provided by Twitter, Inc.

Personal Data collected: Cookies; Usage Data.

Place of processing: United States – Privacy Policy. Privacy Shield participant.

Facebook Like button and social widgets (Facebook, Inc.)
The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Facebook, Inc.

Personal Data collected: Cookies; Usage Data.

Place of processing: United States – Privacy Policy. Privacy Shield participant.

Managing data collection and online surveys

This type of service allows this Website to manage the creation, deployment, administration, distribution and analysis of online forms and surveys in order to collect, save and reuse Data from any responding Users.

The Personal Data collected depend on the information asked and provided by the Users in the corresponding online form.

These services may be integrated with a wide range of third-party services to enable The Signal to take subsequent steps with the Data processed – e.g. managing contacts, sending messages, analytics, advertising and payment processing.

Wufoo (SurveyMonkey Inc.)
Wufoo is a form builder and data collection platform provided by SurveyMonkey Inc.

Personal Data collected: address; country; email address; first name; last name; phone number; various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy. Privacy Shield participant.

Analytics

The services contained in this section enable The Signal to monitor and analyze web traffic and can be used to keep track of User behavior.

Google Analytics (Google LLC)
Google Analytics is a web analysis service provided by Google LLC (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services.

Google may use the Data collected to contextualize and personalize the ads of its own advertising network.

Personal Data collected: Cookies; Usage Data.

Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant.

Managing contacts and sending messages

This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.

These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

OneSignal (Lilomi, Inc.)
OneSignal is a message sending service provided by Lilomi, Inc.

OneSignal allows The Signal to send messages and notifications to Users across platforms such as Android, iOS, and the web.

Messages can be sent to single devices, groups of devices, or specific topics or User segments. Depending on the permissions granted to this Website, the Data collected may also include precise location (i.e. GPS-level data) or WiFi information, apps installed and enabled on the User’s device. This Website uses identifiers for mobile devices (including Android Advertising ID or Advertising Identifier for iOS, respectively) and technologies similar to cookies to run the OneSignal service.

The Data collected may be used by the service provider for interest-based advertising, analytics and market research. In order to understand OneSignal’s use of Data, consult OneSignal’s privacy policy.

Push notifications opt-out
Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then changing those settings for some or all of the apps on the particular device.

Interest-based advertising opt-out
Users may opt-out of OneSignal advertising features through applicable device settings, such as the device advertising settings for mobile phones. Different device configurations, or updates to devices, may affect or change how these indicated settings work.

Personal Data collected: Cookies; email address; geographic position; language; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data; various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy – Opt out.

Mailchimp (The Rocket Science Group LLC)
Mailchimp is an email address management and message sending service provided by The Rocket Science Group LLC.

Personal Data collected: email address; first name; last name; various types of Data.

Place of processing: United States – Privacy Policy. Privacy Shield participant.

Contacting the User

Contact form (this Website)

By filling in the contact form with their Data, the User authorizes this Application to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.

Personal Data collected: email address; first name; last name; various types of Data.

Content Commenting

Content commenting services allow Users to make and publish their comments on the contents of this Application.

Depending on the settings chosen by The Signal, Users may also leave anonymous comments. If there is an email address among the Personal Data provided by the User, it may be used to send notifications of comments on the same content. Users are responsible for the content of their own comments.

Disqus (Disqus)
Disqus is a content commenting service provided by Big Heads Labs Inc.

Personal Data collected: Cookies; Usage Data; various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy – Opt out.

Platform services and hosting
These services have the purpose of hosting and running key components of this Application, therefore allowing the provision of this Application from within a unified platform. Such platforms provide a wide range of tools to The Signal – e.g. analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Data. 

Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

Apple App Store (Apple Inc.)
This Application is distributed on Apple’s App Store, a platform for the distribution of mobile apps, provided by Apple Inc.

By virtue of being distributed via this app store, Apple collects basic analytics and provides reporting features that enables The Signal to view usage analytics data and measure the performance of this Application.

Much of this information is processed on an opt-in basis.
Users may opt-out of this analytics feature directly through their device settings. More information on how to manage analysis settings can be found on this page. 

Personal Data collected: Usage Data.

Place of processing: United States – Privacy Policy. Privacy Shield participant.

Registration and authentication
By registering or authenticating, Users allow this Application to identify them and give them access to dedicated services.

Depending on what is described below, third parties may provide registration and authentication services. In this case, this

Application will be able to access some Data, stored by these third-party services, for registration or identification purposes.

Direct registration (this Website)
The User registers by filling out the registration form and providing the Personal Data directly to this Application.

Personal Data collected: address; email address; first name; last name; password; username; various types of Data.

The rights of Users
Users may exercise certain rights regarding their Data processed by The Signal.
In particular, Users have the right to do the following:
·      Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
·      Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
·      Access their Data. Users have the right to learn if Data is being processed by The Signal, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
·      Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
·      Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, The Signal will not process their Data for any purpose other than storing it.
·      Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from The Signal.
·      Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
·      Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in The Signal or for the purposes of the legitimate interests pursued by The Signal, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether The Signal is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document. 

How to exercise these rights
Any requests to exercise User rights can be directed to The Signal through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by The Signal as early as possible and always within one month.

Additional information about Data collection and processing
Legal action
The User’s Personal Data may be used for legal purposes by The Signal in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services.

The User declares to be aware that The Signal may be required to reveal personal data upon request of public authorities.

Additional information about User’s Personal Data
In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance
For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from The Signal at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled
This Website does not support “Do Not Track” requests.

To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy
The Signal reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page and possibly within this Website and/or – as far as technically and legally feasible – sending a notice to Users via any contact information available to The Signal. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. 

Should the changes affect processing activities performed on the basis of the User’s consent, The Signal shall collect new consent from the User, where required.

Definitions and Legal References

Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

Usage Data
Information collected automatically through this Website (or third-party services employed in this Website), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Website, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Website) and the details about the path followed within the Website with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.

User
The individual using this Application who, unless otherwise specified, coincides with the Data Subject.

Data Subject
The natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller (or The Signal)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is The Signal of this Website.

This Website (or Application)
The means by which the Personal Data of the User is collected and processed.

Service
The service provided by this Application as described in the relative terms (if available) and on this site/application.

European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

Cookies
Small sets of data stored in the User’s device.

Legal information
This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).

This privacy policy relates solely to this Website, if not stated otherwise within this document.