Privacy Policy

Privacy Policy

Your privacy is critically important to us. At Sincera, we have a few fundamental principles:

• We minimize the personal information we ask you to provide and the personal information that we collect about you through the operation of our services.
• We store personal information for only as long as we have a reason to keep it.
• We help protect you from overreaching government demands for your personal information.
• We aim for full transparency on how we gather, use, and share your personal information.

Below is our Privacy Policy, which incorporates and clarifies these principles.

Who We Are and What This Policy Covers

This Privacy Policy applies to information that we collect about you when you use:

• Our websites (including app.sincera.io and sincera.io);
• Our other Sincera products, services, and features that are available on or through our websites. This Privacy Policy also applies to information we collect when you apply for a job at Sincera or one of our subsidiaries. Throughout this Privacy Policy we’ll refer to our websites and other products and services collectively as “Services.” Below we explain how we collect, use, and share information about you, along with the choices that you have with respect to that information.

Information We Collect

We only collect information about you if we have a reason to do so — for example, to provide our Services, to communicate with you, or to make our Services better. We collect this information from three sources: if and when you provide information to us, automatically through operating our Services, and from outside sources. Let’s go over the information that we collect.

Information You Provide to Us

It’s probably no surprise that we collect information that you provide to us directly. Here are some examples:

• Basic account information: We ask for basic information from you in order to set up your account. For example, we require individuals who sign up for a Sincera account to provide an email address and password, along with a name — and that’s it.
• Payment and contact information: There are various ways in which you may provide us payment information and associated contact information. For example, if you buy something from us — a subscription to Sincera, you’ll provide additional personal and payment information like your name, credit card information, and contact information. We also keep a record of the purchases you’ve made.
• Credentials: Depending on the Services you use, you may provide us with credentials like webhook configuration information or AWS access keys, in order to deliver our services.
• Communications with us (hi there!): When you communicate with us via form, email, phone, or otherwise, we store a copy of our communications.
• Job applicant information: If you apply for a job with us — awesome! You may provide us with information like your name, contact information, resume or CV, professional or personal references, similar professional and employment-related data, and work authorization verification as part of the application process. We may also collect additional information about you during the process, like background and credit checks (in applicable jurisdictions and only for certain job roles). You may also provide us with demographic information when required by law or to support our diverse workplace initiatives, such as your gender, racial or ethnic origin, veteran status, and disability status if you voluntarily submit such information as part of your application. We collect demographic information in accordance with applicable law, and do not request demographic information in jurisdictions where it may be prohibited. We will only use this sensitive information to accommodate a disability or illness, comply with legal obligations, protect the health and safety of our employees, and facilitate our internal programs relating to diversity, inclusion, and anti-discrimination.

Information We Collect Automatically

We also collect some information automatically:

• Log information: Like most online service providers, we collect information that web browsers, mobile devices, and servers typically make available, including the browser type, IP address, unique device identifiers, language preference, referring site, the date and time of access, operating system, and mobile network information. We collect log information when you use our Services.
• Transactional information: When you make a purchase through our Services, we collect information about the transaction, such as product details, purchase price, and the date and location of the transaction.
• Usage information: We collect information about your usage of our Services. For example, we collect information about the actions that customer administrators and users perform on our site — in other words, who did what and when (e.g. user viewed SSP comparison data). We use this information to, for example, provide our Services to you, get insights on how people use our Services so we can make our Services better, and understand and make predictions about user retention.
• Location information: We may determine the approximate location of your device from your IP address. We collect and use this information to, for example, calculate how many people visit our Services from certain geographic regions.
• Information from cookies & other technologies: A cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. Pixel tags (also called web beacons) are small blocks of code placed on websites and emails. Sincera uses cookies and other technologies like pixel tags to help us identify and track visitors, usage, and access preferences for our Services, as well as track and understand email campaign effectiveness. For more information about our use of cookies and other technologies for tracking, including how you can control the use of cookies, please see our Cookie Policy.

Information We Collect from Other Sources

We may also get information about you from other sources. For example:

• Third Party Login: If you create or log in to your Sincera account through another service (like Google) we’ll receive associated login information (e.g. a connection token, your username, your email address)
• Financial Account Info: If you use Stripe to pay for Sincera products and services, we’ll receive your payment information from Stripe.

The information we receive depends on which services you use or authorize and what options are available.

How and Why We Use Information

Purposes for Using Information

We use information about you for the purposes listed below:

• To provide our Services. For example, to set up and maintain your account, provide customer service, process payments and orders, and verify user information.
• To ensure quality, maintain safety, and improve our Services. For example, by monitoring and analyzing how users interact with our Services so we can create new features that we think our users will enjoy and that will help them create and manage websites more efficiently or make our Services easier to use.
• To protect our Services, our users, and the public. For example, by detecting security incidents; detecting and protecting against malicious, deceptive, fraudulent, or illegal activity; fighting spam; complying with our legal obligations; and protecting the rights and property of Sincera and others, which may result in us, for example, declining a transaction or terminating Services.
• To fix problems with our Services. For example, by monitoring, debugging, repairing, and preventing issues.
• To communicate with you. For example, by emailing you to ask for your feedback, share tips for getting the most out of our products, or keep you up to date on Sincera or texting you to verify your payment. If you don’t want to hear from us, you can opt out of marketing communications at any time. (If you opt out, we’ll still send you important updates relating to your account.)
• To recruit and hire new Sincera employees. For example, by evaluating job applicants (including verifying their identity, experience, and other information submitted) and communicating with them by phone, email, or social media platforms. If the application progresses, we may also collect interview information and background check information. This may also include verifying information required to initiate employment, for purposes such as confirming ability to legally work in a specific location, setting up payroll, and complying with statutory reporting requirements.

Legal Bases for Collecting and Using Information

A note here for those in the European Union about our legal grounds for processing information about you under EU data protection laws, which is that our use of your information is based on the grounds that: (1) The use is necessary in order to fulfill our commitments to you under the applicable terms of service or other agreements with you or is necessary to administer your account — for example, in order to enable access to our website on your device or charge you for a paid plan; or (2) The use is necessary for compliance with a legal obligation; or (3) The use is necessary in order to protect your vital interests or those of another person; or (4) We have a legitimate interest in using your information — for example, to provide and update our Services; to improve our Services so that we can offer you an even better user experience; to safeguard our Services; to communicate with you; to measure, gauge, and improve the effectiveness of our advertising; and to understand our user retention and attrition; to monitor and prevent any problems with our Services; and to personalize your experience; or (5) You have given us your consent — for example before we place certain cookies on your device and access and analyze them later on, as described in our Cookie Policy.

Sharing Information

How We Share Information

We share information about you in limited circumstances, and with appropriate safeguards on your privacy. These are spelled out below.

• Subsidiaries and independent contractors: We may disclose information about you to our subsidiaries and independent contractors who need the information to help us provide our Services or process the information on our behalf. We require our subsidiaries and independent contractors to follow this Privacy Policy for any personal information that we share with them.
• Third-party vendors: We may share information about you with third-party vendors who need the information in order to provide their services to us, or to provide their services to you. This includes vendors that help us provide our Services to you (like Stripe, payment providers you use, fraud prevention services that allow us to analyze fraudulent payment transactions, cloud storage services, and customer chat and email support services that help us communicate with you); those that help us understand and enhance our Services (like analytics providers); those that make tools to help us run our operations (like programs that help us with task management, scheduling, word processing, email and other communications, and collaboration among our teams); other third-party tools that help us manage operations. Other vendors are listed in our more specific policies (e.g., our Cookie Policy).
• Legal and regulatory requirements: We may disclose information about you in response to a subpoena, court order, or other governmental request.
• Business transfers: In connection with any merger, sale of company assets, or acquisition of all or a portion of our business by another company, or in the unlikely event that Sincera goes out of business or enters bankruptcy, user information would likely be one of the assets that is transferred or acquired by a third party. If any of these events were to happen, this Privacy Policy would continue to apply to your information and the party receiving your information may continue to use your information, but only consistent with this Privacy Policy.
• With your consent: We may share and disclose information with your consent or at your direction.
• Aggregated or de-identified information: We may share information that has been aggregated or de-identified, so that it can no longer reasonably be used to identify you. For instance, we may publish aggregate statistics about the use of our Services.

How Long We Keep Information

We generally discard information about you when it’s no longer needed for the purposes for which we collect and use it — described in the section above on How and Why We Use Information — and we’re not legally required to keep it.

If you are a job applicant, we will keep your personal data during the application process, and for a certain period thereafter. To determine that period, we take into account a number of factors, like our legal and regulatory obligations (such as equal opportunity obligations) and whether we may need to retain personal data for internal business purposes like analyzing our applicant pool.

Security

While no online service is 100% secure, we work very hard to protect information about you against unauthorized access, use, alteration, or destruction, and take reasonable measures to do so. We monitor our Services for potential vulnerabilities and attacks.

Choices

You have choices available when it comes to information about you:

• Opt out of marketing communications: You may opt out of receiving promotional communications from us. Just follow the instructions in those communications or let us know. If you opt out of promotional communications, we may still send you other communications, like those about your account and legal notices.
• Close your account: While we’d be very sad to see you go, you can close your account if you no longer want to use our Services. Please keep in mind that we may continue to retain your information after closing your account, as described in How Long We Keep Information above — for example, when that information is reasonably needed to comply with (or demonstrate our compliance with) legal obligations such as law enforcement requests, or reasonably needed for our legitimate business interests.

Your Rights

If you are located in certain parts of the world, including California and countries that fall under the scope of the European General Data Protection Regulation (aka the “GDPR”), you may have certain rights regarding your personal information, like the right to request access to or deletion of your data.

European General Data Protection Regulation (GDPR)

If you are located in a country that falls under the scope of the GDPR, data protection laws give you certain rights with respect to your personal data, subject to any exemptions provided by the law, including the rights to:

• Request access to your personal data;
• Request correction or deletion of your personal data;
• Object to our use and processing of your personal data;
• Request that we limit our use and processing of your personal data; and
• Request portability of your personal data.

You also have the right to make a complaint to a government supervisory authority.

US Privacy Laws

Laws in some US states, including California, Colorado, Connecticut, Utah, and Virginia, require us to provide residents with additional information about the categories of personal information we collect and share, where we get that personal information, and how and why we use it. You’ll find that information in this section (if you are a California resident, please note that this is the Notice at Collection we are required to provide you under California law).

In the last 12 months, we collected the following categories of personal information, depending on the Services used:

• Identifiers (like your name, contact information, and device and online identifiers);
• Commercial information (your billing information and purchase history, for example);
• Characteristics protected by law (for example, you may choose to voluntarily disclose your race or veteran status as part of your job application);
• Internet or other electronic network activity information (such as your usage of our Services);
• Geolocation data (such as your location based on your IP address);
• Professional or employment-related information (for example, information you provide in a job application); and
• Inferences we make (such as likelihood of retention or attrition).

If you are a job applicant, we may have also collected:

• Education information, such as the education you disclose in your job application.

You can find more information about what we collect and sources of that information in the Information We Collect section above.

We collect personal information for the business and commercial purposes described in the How and Why We Use Information section. And we share this information with the categories of third parties described in the Sharing Information section. We retain this information for the length of time described in our How Long We Keep Information section.

In some US states you have additional rights subject to any exemptions provided by your state’s respective law, including the right to:

• Request a copy of the specific pieces of information we collect about you and, if you’re in California, to know the categories of personal information we collect, the categories of business or commercial purpose for collecting and using it, the categories of sources from which the information came, and the categories of third parties we share it with;
• Request deletion of personal information we collect or maintain;
• Request correction of personal information we collect or maintain;
• Opt out of any sale or sharing of personal information;
• Receive a copy of your information in a readily portable format; and
• Not receive discriminatory treatment for exercising your rights.

Right to Opt Out

We do not collect or process your sensitive (and potentially sensitive) personal information except where it is strictly necessary to provide you with our service, where the processing is not for the purpose of inferring characteristics about you, or for other purposes that do not require an option to limit under California law. We don’t knowingly sell or share personal information of those under 16.

Contacting Us About These Rights

You can usually access, correct, or delete your personal data using your account settings and tools that we offer, but if you aren’t able to or you’d like to contact us about one of the other rights, you may do so by emailing hello (at) sincera.io.

When you contact us about one of your rights under this section, we’ll need to verify that you are the right person before we disclose or delete anything. For example, if you are a user, we will need you to contact us from the email address associated with your account. You can also designate an authorized agent to make a request on your behalf by giving us written authorization. We may still require you to verify your identity with us.

Appeals Process for Rights Requests Denials

In some circumstances we may deny your request to exercise one of these rights. For example, if we cannot verify that you are the account owner we may deny your request to access the personal information associated with your account. As another example, if we are legally required to maintain a copy of your personal information we may deny your request to delete your personal information.

In the event that we deny your request, we will communicate this fact to you in writing. You may appeal our decision by responding in writing to our denial email and stating that you would like to appeal. All appeals will be reviewed by an internal expert who was not involved in your original request. In the event that your appeal is also denied this information will be communicated to you in writing. Please note that the appeal process does not apply to job applicants.

If your appeal is denied, in some US states (Colorado, Connecticut, and Virginia) you may refer the denied appeal to the state attorney general if you believe the denial is in conflict with your legal rights. The process for how to do this will be communicated to you in writing at the same time we send you our decision about your appeal.

How to Reach Us

If you have a question about this Privacy Policy, or you would like to contact us about any of the rights mentioned in the Your Rights section above, please contact us through email at hello (at) sincera.io

Other Things You Should Know (Keep Reading!)

Transferring Information

Because Sincera’s Services are offered worldwide, the information about you that we process when you use the Services in the EU may be used, stored, and/or accessed by individuals operating outside the European Economic Area (EEA) who work for us, or third-party data processors. When providing information about you to entities outside the EEA, we will take appropriate measures to ensure that the recipient protects your personal information adequately in accordance with this Privacy Policy as required by applicable law.

Privacy Policy Changes

Although most changes are likely to be minor, Sincera may change its Privacy Policy from time to time. Sincera encourages visitors to frequently check this page for any changes to its Privacy Policy. Your further use of the Services after a change to our Privacy Policy will be subject to the updated policy.

Cookie Policy

This policy specifically explains how we, our partners, and users of our services deploy cookies, as well as the options you have to control them.

What are cookies and local storage?

Cookies are small pieces of data, stored in text files or local databases, that are stored on your computer or other device when websites are loaded in a browser. They are widely used to "remember" you and your preferences, either for a single visit (through a "session cookie") or for multiple repeat visits (using a "persistent cookie"). They ensure a consistent and efficient experience for visitors, and perform essential functions such as allowing users to register and remain logged in. Cookies may be set by the site that you are visiting (known as "first party cookies"), or by third parties, such as those who serve content or provide advertising or analytics services on the website ("third party cookies"). Both websites and HTML emails may also contain other tracking technologies such as "web beacons" or "pixels." These are typically small transparent images that provide us with statistics, for similar purposes as cookies. They are often used in conjunction with cookies, though they are not stored on your computer in the same way. As a result, if you disable cookies, web beacons may still load, but their functionality will be restricted.

How we use cookies and local storage

We use cookies for a number of different purposes. Some cookies are necessary for technical reasons; and some enable a personalized experience for both visitors and registered users. Some of these cookies may be set when a page is loaded, or when a visitor takes a particular action. Many of the cookies we use are only set if you are a registered app.sincera.io user (so you don’t have to log in every time, for example), while others are set whenever you visit one of our websites, irrespective of whether you have an account. For more information on the choices you have about the cookies we use, please see the Controlling Cookies section below.

Where we use cookies

We set cookies in different locations across our services. These include:

• On our websites (including app.sincera.io and corp.sincera.io).

Types of Cookies

The table below explains the types of cookies we use on our websites and why we use them.

Required

These cookies are essential for our websites and services to perform basic functions and are necessary for us to operate certain features. These include those required to allow registered users to authenticate and perform account-related functions, store preferences set by users such as account name, language, and location, and ensure our services are operating properly.

Examples

Below are examples of the cookies set by Sincera, with explanations of their purpose.

Required

• cf_clearance Cloudflare cookie used to protect Sincera technical assets.
• visit_count Meter visitor access
• qs_mode Dashboard ranking preference
• ahoy_visitor Internal event tracking
• ahoy_visit Internal event tracking
• remember_user_token Optionally used to persist user session
• _headliner_session User session information

Controlling Cookies

Visitors may wish to restrict the use of cookies or completely prevent them from being set. Most browsers provide for ways to control cookie behavior such as the length of time they are stored – either through built-in functionality or by utilizing third party plugins. If you disable cookies, please be aware that some of the features of our service may not function correctly. To find out more on how to manage and delete cookies, visit aboutcookies.org.

Our Internal Analytics Tool

In order to better understand how our services are used, we monitor certain user activities that take place within our products, including page views and clicks on any links used when managing a site via our dashboards. We call each one of these actions an “event.” Analytics events are attached to your Sincera account and are handled via a first party system that Sincera owns and maintains. In general, we record the following data for each event: IP address, userId, user agent, referring URL, timestamp of event, browser language, and country code. We use this information to improve our products.

Contact Us

If you have any questions about our use of cookies, you can find the most relevant contact details in our Privacy Policy.