The Signal takes your privacy seriously. This Privacy Policy describes the kinds of personal information we may gather about you in connection with the Services, how we use that information, to whom we disclose it, and how you can manage it.
Should you have any questions or concerns, please reach out to us at privacy@thesgnl.com.
1. Introduction and overview
This Privacy Policy describes how Marlborough House ("The Signal," "we," "our," or "us") collects, uses, and shares information about you as well as your rights and choices about such use and sharing, and applies to your use of our website, thesgnl.com, and your interaction with all features, content, related emails, and other services we offer (collectively, the "Service").
This Privacy Policy does not apply to any information-collection activities that take place outside of the Service (unless otherwise stated below or at the time the information is collected).
By using the Service, you consent to our collection, use, and disclosure practices, and other activities as described in this Privacy Policy.
2. Information collection
A. Information you provide
We collect information at certain points when you use the Service, including when you create an account, update your profile, access our content, make a purchase, or contact customer support. We may use Service Providers (defined below) to collect information. The information we collect includes information that identifies you personally (whether alone or in combination). We do not collect any information about you that you do not knowingly provide.
Some examples of information you may provide are:
- Contact data, including your first and last name, and email address.
- Demographic data: this is general information that tells us something about you but that doesn't identify you specifically, such as the state you live in or your gender.
- Billing data, including your credit- or debit-card number, card expiration date, and security code as necessary to process your payments.
- Content, including information contained within any messages you send to us (such as feedback and questions to customer support) or publicly post on the Service.
B. Information collected automatically
In addition, we automatically collect certain non-personal information when you use the Service.
Some examples of information we automatically collect are: website-use data, including data about the pages you visit, the emails and advertisements you view, the time of day you browse or review the emails, and your referring and exiting pages; and device-connectivity data, including data about the type of device or browser you use, your device's operating software, your Internet-service provider, your device's regional and language settings, and imprecise location data (such as locations derived from an I.P. address or data that identifies you at a city or Zip Code level).
We use certain technologies to automatically collect this information ("Tracking Technologies"), which may include the following:
- Log files, which automatically record events that occur in connection with your use of the Service.
- Cookies, which are small data files stored on your device that act as a unique tag to identify your browser. We use two types of cookies: session cookies and persistent cookies. Session cookies make it easier for you to navigate our website and expire when you close your browser. Persistent cookies help with personalizing your experience, remembering your preferences, and supporting security features.
- Pixels (also known as Web beacons), which is code embedded in a website, video, email, or advertisement that sends information about your use to a server. We may incorporate pixels from third parties that allow us to track advertising and other engagement with the Service, bring you advertising, and provide you with additional functionality that you may use, such as the ability to connect our Service with a social-media account.
- Location-identifying technologies, which are technologies used to collect your location. For example, G.P.S., Wi-Fi, and Bluetooth may be used to gather precise location data when you consent to precise location tracking. Location data may be used for purposes such as verifying your device's location and delivering or restricting relevant content and advertising based on that location. We do not collect this data without your express consent.
you may always opt out of any or all of these Tracking Technologies (although we may not be able to customize content or advertising for you in that case). For further information on Tracking Technologies and your rights and choices regarding them, see the "Third Parties" and "your Rights and Choices" sections below.
3. Use of information
We use information we collect in accordance with the practices described in this Privacy Policy in order to:
- Manage our Service, including your registration and account.
- Perform services requested by you, including processing and fulfilling your purchases.
- Respond to your comments, questions, and requests, and to provide better customer service.
- Deliver marketing that is of interest to you, both on our own behalf and on that of third parties.
- Send you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages.
- Prevent and address fraud, breach of policies or terms, and threats or harm.
- Monitor and analyze trends, usage, and activities on the Service.
- Improve the Service or other The Signal websites, marketing efforts, products, and services.
- Fulfill any other purpose disclosed to you and with your consent.
4. Sharing of information
We share information we collect in accordance with the practices described in this Privacy Policy, including as follows:
- With Service Providers: We may share your personal information with Service Providers to monitor and analyze the use of our Service, to contact you. Service Providers are prohibited from using information about you for any purpose other than to provide this assistance, although we may permit them to use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law.
- For business transfers: We may share or transfer your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
- With Affiliates: We may share your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
- With business partners: We share non-personal aggregated information with partners and advertisers to describe how an advertising campaign performed or how our subscribers responded to a promotion or re-published content. We do not share your personal information with any of our partners.
- Security and compelled disclosure: We share information to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national-security or law-enforcement requirements. We also share information, if necessary, to protect the rights, property, life, health, security, and safety of us, the Service, or any third party.
- With your consent: We may disclose your personal information for any other purpose with your consent.
Notwithstanding the above, we may share information that does not identify you (including information that has been aggregated or de-identified) with third parties except as prohibited by applicable law.
We will not disclose, rent, sell, share or otherwise transfer your personal data with third parties for marketing purposes.
For information on your rights and choices regarding how we share information about you, please see the "your Rights and Choices" section below.
5. Third parties
A. Third-party services
Our Service may contain links to other websites that are not operated by Us. If you click on a third-party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.
B. Third-party features
We may allow you to connect our Service to a Third-Party Service or offer portions of our Service through a Third-Party Service ("Third-Party Features"). For example, we may offer our content on social networks such as LinkedIn, X and Instagram. Any information you provide to us when you engage with our content is treated in accordance with this Privacy Policy. Also, if you publicly reference our Service on a Third Party Service (e.g., by using a hashtag associated with The Signal in a post), we may use your reference on or in connection with our Service.
C. Analytics
We use certain third-party providers to analyze the performance of our Service and various parts of it. As a result, our Service contains Tracking Technologies owned and operated by third parties that perform certain analyses. While these Tracking Technologies may collect data about your use, we do not use this data to identify who you are or to target you with advertising or specific marketing.
For further information on Tracking Technologies and your rights and choices regarding them, please see the "Information Collected Automatically" and "your Rights and Choices" sections.
6. Your rights and choices
A. Account information
you may access, update, or remove certain information that you have provided to us through your account by sending an email to the email address set out in the "Contact Us" section below and specifying your request. We may require additional information from you to allow us to confirm your identity. Please note that we will retain and use information about you as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
B. Tracking technology choices
- Cookies and pixels: Most browsers accept cookies by default. you can instruct your browser, by changing its settings, to decline or delete cookies. If you use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies is subject to your browser settings and limitations.
- Do Not Track: your browser settings may allow you to automatically transmit a "Do Not Track" signal to online services you visit. Note, however, that there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, we do not monitor or take action with respect to "Do Not Track" signals or other mechanisms. For more information on "Do Not Track," visit allaboutdnt.com.
Please be aware that if you disable or remove Tracking Technologies, some parts of the Service may not function correctly.
C. Communications
you can opt out of receiving emails from us at any time by following the instructions as provided in emails to click on the "Unsubscribe" link, or by emailing us at the email address provided in the "Contact Us" section below. Be sure to include the words "OPT OUT" in the subject field of the email.
Please note that your opt-out is limited to the email address and device used on your profile and will not affect subsequent subscriptions or subscriptions tied to other contact information.
D. Your California privacy rights
California's "Shine the Light" law permits customers in California to request certain details about how specific types of their personal information are shared with third parties and, in some cases, affiliates, for those third parties' and affiliates' own direct-marketing purposes. Under the law, a business should either provide California customers with certain information upon request or permit California customers to opt into, or opt out of, this type of sharing.
The Signal will not share personal information as defined by California's "Shine the Light" law with third parties and/or affiliates for such third parties' and affiliates' own direct-marketing purposes. If you are a California resident and wish to obtain information about our compliance with this law, please contact us as set out in the "Contact Us" section below. Requests must include "California Privacy Rights Request" in the first line of the description and include your name, street address, city, state, and Zip Code. Please note that The Signal is not required to respond to requests made by means other than the provided email address.
7. Children
The Service is intended for a general audience and is not directed at children under thirteen (13) years of age. The Signal does not knowingly collect personal information as defined by the U.S. Children's Online Privacy Protection Act ("COPPA") in a manner that is not permitted by COPPA. If you are a parent or guardian and believe The Signal has collected such information in a manner not permitted by COPPA, please contact us as set out in the "Contact Us" section below, and we will remove such data to the extent required by COPPA.
8. Data security
We implement and maintain reasonable administrative, physical, and technical security safeguards to help protect information about you from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. Nevertheless, transmission via the Internet is not completely secure and we cannot guarantee the security of information about you.
9. International transfer
This Service is targeted to the United States. We are based in the U.S., and the information we collect is governed by U.S. law. If you are accessing the Service from outside of the U.S., please be aware that information collected through the Service may be transferred to, processed, stored, and used in the U.S. and other jurisdictions. Data-protection laws in the U.S. and other jurisdictions may be different from those of your country of residence. your use of the Service or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of information about you in the U.S. and other jurisdictions as set out in this Privacy Policy.
10. Changes to this privacy policy
We may update Our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.
We will let you know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
Contact Us
If you have any questions about this Privacy Policy, you can contact us by email: privacy@thesgnl.com.
Updated: Monday, March 4, 2024