Privacy Policy of Sigon (GDevs Ltd)

Sigon and GDevs Ltd collects some Personal Data from its Users.

Policy summary

Personal Data collected for the following purposes and using the following services:

• Analytics

  • Google Ads conversion tracking and Google Analytics with anonymized IP
    Personal Data: Cookies; Usage Data

• Contacting the User

  • Contact form
    Personal Data: email address; first name; last name; phone number

• Displaying content from external platforms

  • Google Fonts
    Personal Data: Usage Data; various types of Data as specified in the privacy policy of the service

• Handling payments

  • Stripe and Chargebee
    Personal Data: various types of Data as specified in the privacy policy of the service

• Managing contacts and sending messages

  • Sendgrid
    Personal Data: email address

• Registration and authentication

  • Google OAuth
    Personal Data: various types of Data as specified in the privacy policy of the service

• Remarketing and behavioral targeting

  • Remarketing with Google Analytics
    Personal Data: Cookies; Usage Data

• Tag Management

  • Google Tag Manager
    Personal Data: Usage Data

Further information about Personal Data

• Google Cloud Platform
  Provider
  Google inc.
  
  Purpose
  Hosting and backend infrastructure
  
  Personal Data collected
  Various types of data as specified in the privacy policy of the service
  Privacy Policy
  
  Google Cloud Platform is a hosting and computing service provided by Google Inc.

• Google user data handling
  Sigon is designed as a Google Workspace Marketplace application. We adhere to a set of best practices of secure enterprise application development defined by Google.

We use OAuth 2.0 for G Suite authentication and authorization.

Our application doesn't work with nor doesn't access any data in consumer Google accounts (@gmail.com).

Our application is built with a single purpose: to allow companies with Google Workspace to centrally manage email signatures for users in their domain.

The list below contains all the scopes we use for API access to customer data. We also specify for what exact purpose we need it and as you can see, we often use only a small part of the granted access level. [These may be updated or changed at any time.]

Manage your basic mail settings
Manage basic mail settings in a user's Google email account.

We use this scope to retrieve and edit a user's primary email address signature.

Manage your sensitive mail settings
Manage sensitive mail settings in a user's Google email account.

We use this scope to retrieve and edit a user's non-primary (alias) email address signature.

View and manage the provisioning of user schemas on your domain

Retrieve the data schema used in your Admin Console.

We use this read-only access to retrieve and display your custom schema fields for use when composing your signatures.

View users on your domain

Retrieve a list of all users in your domain. Retrieve an individual user's details.

We use this read-only access to display the list of users in your domain and what data is available (which fields are populated) for each user in your admin console. This information includes the profile image, full name and email address for the signed-in user.

View delegated admin roles for your domain
Retrieve the set of privileges that are granted to the role(s) assigned to a user.

We use this read-only access to determine if a user is allowed to manage your user's data on the console and as such to manage signatures.

Contact information

• Owner and Data Controller
  GDevs Ltd
  Owner contact email: privacy@gdevs.co.uk

Full policy

Owner and Data Controller

GDevs Ltd
Owner contact email: privacy@gdevs.co.uk

Types of Data collected

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

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 Sigon.

Unless specified otherwise, all Data requested by Sigon is mandatory and failure to provide this Data may make it impossible for Sigon to provide its services. In cases where Sigon specifically states 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 Owner.

Any use of Cookies – or of other tracking tools – by Sigon or by the owners of third-party services used by Sigon 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 Sigon and confirm that they have the third party's consent to provide the Data to the Owner.

Mode and place of processing the Data

Methods of processing

The Owner 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 Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of Sigon (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 Owner. The updated list of these parties may be requested from the Owner at any time.

Legal basis of processing

The Owner 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 Owner 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 Owner 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 Owner;

• processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner 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 Owner'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 Owner 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 Owner 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 Owner and the User shall be retained until such contract has been fully performed.

• Personal Data collected for the purposes of the Owner’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 Owner within the relevant sections of this document or by contacting the Owner.

The Owner 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 Owner 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 Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Tag Management, Registration and authentication, Handling payments, Interaction with live chat platforms, Managing contacts and sending messages, Displaying content from external platforms, Analytics, Remarketing and behavioral targeting, User database management and Contacting the User.

For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

• Analytics
  The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
  Google Ads conversion tracking (Google Inc.)
  Google Ads conversion tracking is an analytics service provided by Google LLC or by Google Ireland Limited, depending on the location Sigon is accessed from, that connects data from the Google Ads advertising network with actions performed on Sigon.
  Personal Data processed: Cookies; Usage Data.
  Place of processing: US – Privacy Policy.
  Google Analytics with anonymized IP (Google Inc.)
  Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of Sigon 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.
  This integration of Google Analytics anonymizes your IP address. It works by shortening Users' IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the US.
  Personal Data processed: Cookies; Usage Data.
  Place of processing: United States – Privacy Policy – Opt Out.

• Contacting the User
  Contact form (GDevs Ltd)
  By filling in the contact form with their Data, the User authorizes GDevs Ltd 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 processed: email address; first name; last name; phone number.

• Displaying content from external platforms
  This type of service allows you to view content hosted on external platforms directly from the pages of Sigon 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.
  Google Fonts (Google Inc.)
  Google Fonts is a typeface visualization service provided by Google LLC or by Google Ireland Limited, depending on the location Sigon is accessed from, that allows Sigon to incorporate content of this kind on its pages.
  Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.
  Place of processing: US – Privacy Policy.

• Handling payments
  Payment processing services enable GDevs Ltd to process payments by credit card, bank transfer or other means. To ensure greater security, GDevs Ltd shares only the information necessary to execute the transaction with the financial intermediaries handling the transaction.
  Some of these services may also enable the sending of timed messages to the User, such as emails containing invoices or notifications concerning the payment.
  Chargebee (Chargebee inc)
  Chargebee is the subscription billing and revenue management platform used to manage your subscriptions and the products purchased.
  Personal Data processed: various types of Data as specified in the privacy policy of the service.
  Place of processing: See the Chargebee privacy policy – Privacy Policy.
  
  Stripe (Stripe, Inc.)
  Stripe is a payment service provided by Stripe, Inc., which allows Users to make online payments.
  Personal Data processed: various types of Data as specified in the privacy policy of the service.
  Place of processing: See the Stripe privacy policy – Privacy Policy.

• 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.
  Sendgrid (Sendgrid)
  Sendgrid is an email address management and message sending service provided by Sendgrid Inc.
  Personal Data processed: email address.
  Place of processing: US – Privacy Policy.
  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 processed: email address.
  Place of processing: US – Privacy Policy.

• Registration and authentication
  By registering or authenticating, Users allow GDevs Ltd 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, GDevs Ltd will be able to access some Data, stored by these third party services, for registration or identification purposes.
  Google OAuth (Google Inc.)
  Google OAuth is a registration and authentication service provided by Google Inc. and is connected to the Google network.
  Personal Data processed: various types of Data as specified in the privacy policy of the service.
  Place of processing: US – Privacy Policy.

• Remarketing and behavioral targeting
  This type of service allows GDevs Ltd and its partners to inform, optimize and serve advertising based on past use of Sigon by the User.
  This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity.
  Some services offer a remarketing option based on email address lists.
  In addition to any opt-out feature provided by any of the services below, Users may opt out by visiting the Network Advertising Initiative opt-out page.
  Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.
  Remarketing with Google Analytics (Google Inc.)
  Remarketing with Google Analytics is a remarketing and behavioral targeting service provided by Google LLC or by Google Ireland Limited, depending on the location Sigon is accessed from, that connects the tracking activity performed by Google Analytics and its Cookies with the Google Ads advertising network and the Doubleclick Cookie.
  Personal Data processed: Cookies; Usage Data.
  Place of processing: US – Privacy Policy – Opt Out.

• Tag Management
  This type of service helps the Owner to manage the tags or scripts needed on Sigon in a centralized fashion.
  This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.
  Google Tag Manager (Google Inc.)
  Google Tag Manager is a tag management service provided by Google LLC or by Google Ireland Limited, depending on the location Sigon is accessed from.
  Personal Data processed: Usage Data.
  Place of processing: US – Privacy Policy.

• User database management
  This type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to GDevs Ltd, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks' profiles) and used to build private profiles that the Owner can display and use for improving Sigon.
  Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on Sigon.
  
  

Further information about Personal Data

• Google Cloud Platform
  Provider
  Google inc.
  
  Purpose
  Hosting and backend infrastructure
  
  Personal Data collected
  Various types of data as specified in the privacy policy of the service
  Privacy Policy
  
  Google Cloud Platform is a hosting and computing service provided by Google Inc.

• Google user data handling
  Sigon is designed as a Google Workspace Marketplace application. We adhere to a set of best practices of secure enterprise application development defined by Google.
  We use OAuth 2.0 for G Suite authentication and authorization.
  
  Our application doesn't work with nor doesn't access any data in consumer Google accounts (@gmail.com).
  
  Our application is built with a single purpose: to allow companies with Google Workspace to centrally manage email signatures for users in their domain.
  
  The list below contains all the scopes we use for API access to customer data. We also specify for what exact purpose we need it and as you can see, we often use only a small part of the granted access level.
  
  

• View users on your domain

  • Retrieve a list of all users in your domain. Retrieve an individual user's details.

  • We use this read-only access to display the list of users in your domain and what data is available (which fields are populated) for each user in your admin console. This information includes the profile image, full name and email address for the signed-in user.

• View your email messages and settings

  • View all account information and metadata, such as current signature information.

  • We use it only to load existing email signature information to provide an overview of current signatures across the entire domain. 

• See, edit, create or change your email settings and filters in Gmail

  • View primary email address, view and manage primary Reply-To, display name and signature, view and manage vacation responder settings, view and manage filters, view and manage POP settings, view and manage IMAP settings, view forwarding settings, view mail delegates with access to your account, view "Send mail as" aliases

  • We use it only to load existing Send as addresses which is necessary to change users signatures using the following scope.

• Manage your sensitive mail settings, including who can manage your mail

  • Start and stop forwarding all your mail to another address Create, update, and delete forwarding addresses, grant and revoke access to your account by mail delegates, create, update, and delete "Send mail as" aliases

  • We use this scope to retrieve and edit a user's non-primary (alias) email address signature.

• Manage your basic mail settings

  • Manage basic mail settings in a user's Google email account.

  • We use this scope to retrieve and edit a user's primary email address signature.

• View your email address

  • View the email address associated with your account

  • We use it for User identification.

• View your basic profile info

  • View your full name, profile picture and profile URL View any publicly available information on your Google+ profile (if you have one or create one in the future)

  • We use it to load profile pictures for users.

• View and manage the provisioning of user schemas on your domain

  • Retrieve the data schema used in your Admin Console.

  • We use this read-only access to retrieve and display your custom schema fields for use when composing your signatures.

• View delegated admin roles for your domain

  • Retrieve the set of privileges that are granted to the role(s) assigned to a user.

  • We use this read-only access to determine if a user is allowed to manage your user's data on the console and as such to manage signatures.

The rights of Users

Users may exercise certain rights regarding their Data processed by the Owner.

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 Owner, 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 Owner 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 Owner.

• 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 Owner or for the purposes of the legitimate interests pursued by the Owner, 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 Owner 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 Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

Cookie Policy

Sigon does not use Trackers. Google Single Sign On does make use of Cookies. To learn more, the User may consult the Google Cookie Policy.

Additional information about Data collection and processing

Legal action

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of GDevs Ltd or related Services.

The User declares to be aware that the Owner 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, GDevs Ltd 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, GDevs Ltd and any third-party services may collect files that record interaction with Sigon (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 Owner at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled

GDevs Ltd 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 Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within Sigon and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. 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 Owner 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 Sigon (or third-party services employed in Sigon), which can include: the IP addresses or domain names of the computers utilized by the Users who use Sigon, 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 Application) and the details about the path followed within the Application 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 Sigon  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 Owner)

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 Sigon. The Data Controller, unless otherwise specified, is the Owner of Sigon (GDevs Ltd).

Sigon (or this Application)

The means by which the Personal Data of the User is collected and processed.

Service

The service provided by GDevs Ltd 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.

Cookie

Cookies are Trackers consisting of small sets of data stored in the User's browser.

Tracker

Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on 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 GDevs Ltd and its products, if not stated otherwise within this document.