SIG9 LLC - Notice of Processing

Updated: December 12, 2023

Sig9 LLC (doing business as “Samwise AI” and referenced herein as “we,” “our,” and “us”) is committed to protecting the privacy of your personal information. Although we do not direct our services to non-United States individuals, we may still come into possession of personal information relating to non-United States individuals as part of our United States service offerings. This Notice of Processing (“Notice”) supplements our Privacy Policy and provides additional information for non-United States individuals relating to personal information that has been collected by or provided to us through any of our websites, web-based and mobile applications, meetings and events (in-person and virtual), communications, marketing materials and content and services (collectively, “Activities”).

Please note that your rights for any particular product or service may be determined by the notice or terms provided with such product or service, and in the event of a conflict between this notice and that notice or terms, the specific notice or terms provided with the product or service shall control.

1. How Do We Collect and Process Personal Information?

Directly. We obtain personal information directly from individuals in a variety of ways, including obtaining personal information from individuals who subscribe for the Activities, complete our online forms, subscribe to our newsletters and register for webinars, attend meetings or events we host, provide us their business card, visit our offices, or communicate directly with us. We may also obtain personal information directly when, for example, we are establishing a business relationship, performing professional services through a contract, or through our hosted software applications.

Indirectly. We obtain personal information indirectly about individuals from a variety of sources, including our use of third-party service providers. We may attach personal information to our customer relationship management records to better understand and serve our subscribers and other individuals, to satisfy a legal obligation, or to pursue our legitimate interests.

Public sources – Personal information may be obtained from public registers, news articles, sanctions lists and Internet searches.
Social and professional networking sites – If you register or login to our websites using social media platforms (e.g., Facebook, Instagram, LinkedIn or Twitter) to authenticate your identity and connect your social media login information with us, we will collect information or content needed for the registration or login that you permitted your social media provider to share with us. That information may include your name and email address and depending on your privacy settings, additional details about you, so please review the privacy controls on the applicable service to set how much information you want shared with us.

2. What Categories of Personal Information Do We Collect?

We may obtain the following categories of personal information about individuals through direct interactions with us, or from information provided through our third-party service providers or vendors, and through other situations including those described in this Notice.

Personal information.
- Contact details (i.e., name, telephone numbers, email and mailing address).
- Personal Interests when using the Activities.
- Financial information you input to use the Activities.
Sensitive personal information. We typically do not collect sensitive or special categories of personal information about individuals, such as personal information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometrics information for the purpose of uniquely identifying a natural person, information concerning health or information concerning a natural person’s sex life or sexual orientation. When we do need to process sensitive personal information, it is with the consent of the individual unless it is obtained indirectly for certain legitimate purposes. Examples of sensitive personal information we may obtain include:
- Information, including preferences or interests, provided to us by users of the Activities in the course of their use.
- Dietary restrictions or access requirements when registering for in-person events that reveal religious beliefs or physical health.
- Personal identification documents that may reveal race or ethnic origin, and possibly biometric information of private individuals, or beneficial owners of corporate entities.
Location-based information. We may collect or process geographical locations you enter when you engage in certain Activities, such as the use of certain apps.

3. Why Do We Need Personal Information?

We aspire to be transparent when we collect and use your personal information and tell you why we need it, which typically includes reasons such as the following and others listed in our Privacy Policy:

Providing the Activities specific to certain parameters you input.
Personalizing online landing pages and communications we think would be of interest based on interactions with us or our affiliates or contractors.
Authenticating registered users to certain areas of our websites.
Administering, maintaining, and ensuring the security of our information systems, applications and websites.
Promoting and marketing our services, products, and capabilities to existing and prospective users, including the services, products, and capabilities of our affiliated entities, contractors, or other third parties.
Sending invitations and providing access to guests attending our events, webinars or our sponsored events, or video conferences.
Processing online requests or inquiries, including responding to communications from individuals.
Contacting journalists regarding company press releases, invitations to annual press parties, highlighting messages that may be of interest on specific industry topics.
Complying with legal and regulatory obligations relating to countering money laundering, terrorist financing, fraud, and other forms of financial crime.

In general, you are not obligated to provide your personal information to us. But in some circumstances not providing your personal information to us may have the consequence that we are unable to provide a service or Activity requested by you if your information is necessary for the provision of the service or Activity.

4. What Lawful Grounds Do We Have for Processing Personal Information?

Where required and applicable, we may rely on one or more of the following lawful grounds when we collect and use personal information to operate our business and provide the Activities and other products and services:

The Activities – We may process personal information to the extent it is necessary in order to provide the Activities to you.
Consent – We may rely on your freely given consent at the time you provided your personal information to us.
Legitimate interests – We may process your personal information to meet our legitimate interests insofar as the processing is necessary for these interests based on our evaluation that the processing is fair, reasonable, and balanced. These interests include:
- Delivering services to our users – To deliver the Activities and other products and services our users; and
- Direct marketing – To deliver timely market insights and specialty knowledge we believe is welcomed by our users, subscribers, and/or individuals who have interacted with us.
Legal obligations and public interests – We may process personal information in order to meet regulatory and public interest obligations or mandates.
To protect vital interests – We may process personal information in order to protect the vital interests of individuals.
For legal claims – We may process personal information in order to establish, exercise, or defend legal claims.

5. What Privacy Rights Do Non-U.S. Data Subjects Have?

Certain country laws provide individuals with rights related to the use and protection of their personal information. Where applicable, those rights may include:

Access – You may ask us to verify whether we are processing personal information about you, and if so, to provide more specific information about the personal information concerned.
Rectification – You may ask us to correct our records if you believe they contain incorrect or incomplete information about you.
Erasure – You may ask us to erase (delete) your personal information after you withdraw your consent to processing such information or when we no longer need it for the purpose it was originally collected.
Processing Restrictions – You may ask us to temporarily restrict our processing of your personal information if you contest the accuracy of your personal information, prefer to restrict its use rather than having us erase it, or need us to preserve it for you to establish, exercise, or defend a legal claim. A temporary restriction may apply while verifying whether we have overriding legitimate grounds to process it. You may ask us to inform you before we lift that temporary processing restriction.
Information Portability – In some circumstances where you have provided personal information to us, you may ask us to transmit that personal information (in a structured, commonly used, and machine-readable format) directly to another entity if this is technically feasible.
Right to Object to Direct Marketing – You may object to our use of your personal information for direct marketing purposes, including profiling. We may need to keep some minimal information to comply with your request to cease marketing to you.
Right to Withdraw Consent – You may withdraw the consent that you have previously given to one or more specified purposes to process your personal information. This will not affect the lawfulness of any processing carried out before you withdraw your consent. It may mean we are not able to provide certain Activities, products, or services to you and we will advise you if this is the case.
Right to Lodge a Complaint with a Data Protection Authority – If you have any complaints about the processing of personal information you may contact us using the information below or submit a Data Privacy Request. But irrespective of whether you want to contact us, you have the right to lodge a complaint with a data protection authority in your country.

We may need to request specific information from you to help us verify your identity and ensure your right to access the information or to exercise any of your other rights. This helps us to ensure that your personal information is not disclosed to any person who has no right to receive it. No fee is required to make a request unless your request is clearly unfounded or excessive.

Regarding cross-border transfers of personal information you may request from us more information on the safeguards that are put in place, such as a copy of the safeguards. We will make all reasonable and practical efforts to comply with your request as required by applicable law, so long as our doing so would be consistent with Samwise AI’s contractual requirements, and/or the industry standards applicable to Samwise AI.

If you have questions or comments about our administration of your personal information or wish to make a Data Privacy Request, please contact us by:

Submitting a Data Privacy Request through our webform; or
Contacting our Privacy Officer at support@samwiseai.com.

6. How Long Do We Retain Personal Information?

We retain personal information to provide the Activities and our other products and services, stay in contact with you, and to comply with applicable laws, regulations, contractual obligations and our policies. We dispose of personal information in a secure manner when we no longer need it.

7. Do We Change This Notice?

We regularly review this Notice and will post any updates to it on this website, noting the date of last modification at the top of the page. You are responsible to review our policies periodically and be informed of their current status.