Squigl privacy policy

1. Important information and who we are
2. The data we collect about you
3. How is your personal data collected?
4. Legal basis for using your personal data
5. Disclosures of your personal data
6. International transfers
7. Data security
8. Data retention
9. Your legal rights
10. Glossary
11. Our Commitment to Children’s Privacy
12. The Information Squigl Collects

Squigl respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website & Office word addin (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. Please use the glossary to understand the meaning of some of the terms used in this privacy notice.

1. 1. Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how Squigl collects and processes your personal data through your use of this website & Office word addin, including any data you may provide through this website & Office word addin.

This website & Office word addin is not intended for children and we do not knowingly collect data relating to children.

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

Controller

Squigl is associated with different legal entities, namely Squigl, LLC. 313 Software, LLC. and Purcell Road Medi. with offices in the US. This privacy notice is issued on behalf of the Squigl, LLC. as a whole so when we mention “Squigl”, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in Squigl, LLC. Responsible for processing your data. Squigl, LLC. is the controller and responsible for this website & Office word addin.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact details

Our full details are:

Full name of legal entity: Squigl, LLC.Ltd.
Name of DPO: Ahmad Roowala
Email address: aroowala@squigl.ai
Postal address: Squigl, LLC. 7101 Northland Circle N. Suite 208, Minneapolis, MN. 55428, USA.

You have the right to make a complaint at any time to your respective supervisory authority.

Your duty to inform us of changes

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

Third-party links

This website & Office word addin may include links to third-party website & Office word addins, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites & Office word addin and are not responsible for their privacy statements. When you leave our website & Office word addine, we encourage you to read the privacy notice of every website  & Office word addin you visit.

2. The data we collect about you

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

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

• Identity Dataincludes first name, last name, username or similar identifier, title, and gender.
• Contact Dataincludes email address, telephone numbers, company or other mailing address.
• Technical Dataincludes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website & Office word addin.
• Profile Dataincludes your username and password, information about your company, your interests, preferences and any feedback or comments you make on our website & Office word addin.
• Usage Dataincludes information about how you use our website & Office word addin, products and services.
• Marketing and Communications Dataincludes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website & Office word addin feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact and Profile Data by filling in forms or providing other information via our website & Office word addin. This includes personal data you provide when you:

• Register for our events;
• Request our services;
• subscribe to our publications;
• request marketing to be sent to you; or
• give us some feedback.

Automated technologies or interactions. As you interact with our website & Office word addin, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites & Office word addin employing our cookies.

Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

• Technical Data from the following parties:

o   analytics providers such as Google (based outside the EU);

• Our social media pages:

o   Twitter (firm/marketing) https://twitter.com/Squiglit

o   LinkedIn –https://www.linkedin.com/company/Squiglit

o  Facebook –https://www.facebook.com/squiglit/

5. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

• Internal Third Parties as set out in the Glossary.
• External Third Parties as set out in the Glossary.
• Third party partners for the purposes of hosting events.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

We share your personal data within Squigl, LLC.. This will involve transferring your data outside the European Economic Area (EEA).

Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data to external third parties based outside of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

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

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Glossary

Lawful basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Third parties

Internal third parties

Other companies affiliated with Squigl, LLC. acting as joint controllers or processors and who are based in the EEA or US and provide IT and system administration services and undertake leadership reporting.

External third parties

Service providers acting as processors based in the EEA and US who provide IT and system administration services. May 2018.

11. Our Commitment to Children’s Privacy

Protecting the privacy of young children is especially important. If Squigl learns that personally identifiable information of children has been collected on the Website without parental consent, then Squigl will take the appropriate steps to delete this information. If you are a parent or legal guardian and discover that your child has a registered account with the Website without your consent, then you may alert Squigl at support@squigl.ai and request that Squigl delete that child’s personal information from its systems. In particular, we never share the personal information of any user with third parties.

A note to minors: If you are under the age of 13, please get permission from your parent/legal guardian before using this website(s) or app(s) or sending us any communication including social media. You must be 18 or older to order a subscription to any Squigl websites or apps. We will not sell or market directly to minors, and we always seek authorization from a parent or legal guardian whenever we identify that a minor has attempted to purchase a Squigl product or service.

A note to schools and districts: Wherever we collect student identifiable information, we do so in support of the educational purposes for which Squigl is designed. Such information is collected only in conjunction with the use Squigl Assessments (in Alpha testing), which is an optional feature into which schools, homeschools and districts can opt – schools and districts can choose whether to allow their teachers and students the use of this feature.

​Here is the 2nd part of the new privacy policy updates, re: compliance: this part please add as a sub-section Compliance under section 11.

Squigl’s terms state they make contractual commitments in their Privacy Policy and commit to comply with privacy and security standards. From system performance to infrastructure details, the terms state Squigl is committed to providing all its users with utmost transparency.

G Suite for Education’s terms state its core services aim to comply with the Family Educational Rights and Privacy Act (FERPA).  Additionally, if schools allow users under the age of 13 to use Squigl Education, Squigl’s terms can contractually require schools using Squigl Education to obtain parental consent as required by COPPA.

The parents of Squigl Education users in Primary/Secondary (K-12) schools can request through the administrator to stop any further collection or use of the child’s information, the parent can request that the administrator contact Squigl and/or use the service controls available to them to limit the child’s access to features or services, or delete the child’s account entirely.

12. The Information Squigl Collects

User-provided Information: When you register for, browse and use the Website, you may provide to Squigl what is generally called “personally identifiable information”. Certain information has to be given by a user in order to register for a Squigl Account, such as:

• A unique username
• E-mail address