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Privacy Policy

 

SILENCIO PRIVACY POLICY FOR WEBSITE AND APP

 

Effective Date: January 20th, 2023

Last Modified: April 4th, 2024

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This Website Privacy and Cookie Notice ("Notice") explains the processing of your personal data by Silencio Network LLC ("Silencio" or “we”) as the data controller when using our app or visiting silencio.network, our social media pages and other Silencio websites.

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1 Purposes of processing

1.1 Providing our app

If you use our app, personal data is stored. In particular, the following data is collected in this context:

  • User ID

  • User email address
     

The storage of this personal data is necessary to ensure the functional use of our app. The legal basis for this processing of your personal data is the necessity of the processing for the performance of the contract to provide the app (Art. 6 (1) b) GDPR).

1.2 Data measurement and sharing

Based on your consent within the app (Art. 6 (1) a) GDPR), we will measure the following data:

  • Geolocation:

    • Latitude & longitude

    • Horizontal accuracy

    • Altitude

  • Average decibel reading (not: microphone recordings)

  • User ID

  • User email address

  • Device data

    • Device ID (IDFA or Android Advertising ID)

    • ID Type (IDFA or AAID)

    • Operating system version

    • Device manufacturer

    • Device model

  • Network data:

    • WiFi BSSID

    • WiFi SSID

    • IP address

    • Cell service provider

    • Network speed

  • UTC Timestamp

We will share this data with business partners (e.g. real estate companies, location service providers and advertisers) in pseudonymized form for research and advertising purposes based on your consent. In return, you receive noise coins. You can withdraw your consent at any time with effect for the future.

1.3 Providing our website

If you access our website some personal data is temporarily stored. In particular, the following data is collected in this context:

  • IP address and host name of your computer

  • Date and time of access

  • Browser meta data, incl. your browser type and operating system, whether the access was successful and the amount of data transferred, page visited on our website, third-party-website from which you clicked on a link to our website.

The temporary storage of this personal data is necessary to provide you with the website. The legal basis for this processing of your personal data is our legitimate interest in providing the website (Art. 6 (1) f) GDPR).

1.4 Log data

Further storage of this data takes place in log files, in order to ensure the functionality of our website and, if necessary, to check and enforce our rights or property, our terms of use and the rights of third parties. The log files are stored as long as necessary for the respective purpose, usually no longer than 14 days. The legal basis is our legitimate interest in providing the website securely (Art. 6 (1) f) GDPR).

1.5 Registration, communication and contact forms

We process personal data that you provide in the context of using certain content and functions on our website. For example, if you use the contact form, we use this personal data to respond to your queries, and/or provide the services and/or information that you have requested. The same applies to communication by other means, such as e-mail, messenger or telephone. The legal basis for this data processing is the performance of a contract (Art. 6 (1) b) GDPR).

1.6 LinkedIn and other social media pages

We use LinkedIn and other social media services to communicate with you and to advertise our work. The legal basis is our legitimate interest in corporate communications (Art. 6 (1) f) GDPR).

Our social media partners provide us with statistics and analytics on the use of our social media offerings. These statistics do not contain any names or other information about individual users. With the help of these services we can analyze and improve our social media activities. This is our legitimate interest for using these statistics.

When processing personal data on our LinkedIn page, we and LinkedIn act as so called "Joint Controllers". We have therefore concluded a separate joint controller agreement. For any further processing of your data, LinkedIn is the sole controller. If you wish to exercise your rights to information, deletion, etc., LinkedIn is responsible for the fulfillment of your rights as part of our Joint Controllership.

1.7Other purposes for which we process your personal data

Furthermore, we process your personal data:

  • to fulfill contracts and in the context of existing or new business relationships. We will retain this personal data at least for the duration of our business relationship. The legal basis is the performance of a contract (Art. 6 (1) b) GDPR).

  • to meet our legitimate interests (Art. 6 (1) f) GDPR), including the following:

    • Enter into corporate transactions (e.g., restructuring, asset deals, mergers)

    • Protect our rights or property, enforce our terms of use and legal notices, and provide for the establishment, exercise, and defense of legal claims

  • to fulfill our legal obligations, court orders or other binding decisions (Art. 6 (1) c) GDPR).

  • with your consent for other purposes (Art. 6 (1) a) GDPR), such as subscription to a newsletter; in this case, you have the option to revoke your consent at any time.

2 Recipients of personal data

In addition to the recipients of personal data mentioned above, we also use other companies to process personal data on our behalf, for example for hosting of our website or sending newsletters. Such processors only process the data on our behalf. For example, our hosting provider is Google Cloud Services.

Furthermore, we transmit personal data to third parties if this is required by law, necessary for the exercise and defense of legal claims or if third parties provide certain services for us (e.g., lawyers, tax advisors).

Silencio is a company operating globally. Therefore, personal data of individuals who visit our website and/or who use our app or otherwise interact with us may be transferred and accessed from around the world, such as from countries where Silencio operates.  Silencio will share your personal data within its own organization in accordance with its given purpose.

If we transfer your personal data outside of the European Economic Area (“EEA”) to a country which provides a different level of privacy and protection of data, Silencio will make sure that it has arranged the same level of data protection as within the EEA. For this purpose Silencio mainly uses Standard Contractual Clauses ("SCC") and in individual cases other appropriate guarantees. You can request a copy of the SCC or other contract ensuring the appropriate level of data protection by contacting privacy@silencio.network.

3 Cookies

In addition to the processing purposes mentioned above, we also use cookies that are technically necessary to offer our website or if we are obliged to do so. The legal basis for the use of necessary cookies is § 25 (2) no. 2 TTDSG.

Cookies that are not technically necessary (e.g. for analytics purposes) are only processed with your consent. This concerns the following cookies:

  • Marketing Cookies: These cookies are used to track advertising effectiveness to provide a more relevant service and deliver better ads to suit your interests.

  • Functional Cookies: These cookies collect data to remember choices users make to improve and give a more personalized experience.

  • Analytics Cookies: These cookies help us to understand how visitors interact with our website, discover errors and provide better overall analytics.

The legal basis for the data processing in connection with these cookies is § 25 (1) 1 TTDSG.

Unless otherwise stated in this privacy policy, cookies remain stored as long as necessary to fulfill the respective processing purposes. You can object to the storage of cookies by browser preferences and delete them manually in your browser settings. Please note, however, that some cookies may be mandatory for the use of our website or its individual functions.

For more information about the cookies set on this website and how to revoke or give your consent, please visit here.

4 Data Security

Silencio observes a strict duty of confidentiality about your personal data. We have implemented technical and organizational measures intended to protect the personal data that we process. However, no environment or security protocols are ever guaranteed to be completely secure or error-free.

5 Privacy of Children

Our website and app are not designed for, or directed to children under the age of 16 and we do not knowingly collect personal data from children. If you have reason to believe that we have inadvertently collected personal data about a child, please contact us and we will take steps to delete this data.

6 Regular deletion of personal data

Unless a specific duration of data storage is specified in this Notice, we will only process your data as long as this is necessary for the respective purposes or as long as there are legal retention obligations. After the respective processing purpose ceases to apply and retention obligations end, your data will be routinely deleted.

Unless otherwise stated in this privacy notice, Cookies remain stored as long as necessary to fulfill the respective processing purposes. You can object to the storage of Cookies by browser preferences and delete them manually in your browser settings. Please note, however, that some Cookies may be mandatory for the use of our website or its individual functions.

7 Your rights

You can request access to the personal data stored by us. If you have provided personal data on the basis of a contract or consent, you have the right to receive this personal data in a standard and machine-readable format.

You can also request the deletion, correction or restriction of the processing of your personal data subject to the conditions and limitations subject to certain exceptions or limitations. You can revoke your consent at any time without affecting the lawfulness of processing based on your consent before its withdrawal.

In case of questions and in case of possible concerns about the data processing, you can also complain to a data protection authority.

You can object to the data processing on the basis of our legitimate interests at any time based on grounds relating to your particular situation.

8 Contact

The website and app are owned and managed by Silencio. Silencio is controller of personal data collected on the websites and in the app:

Silencio Network LLC
2056 1001 N. Orange St. 4th Floor
US 19801 Wilmington, New Castle, Delaware, USA

If you wish to exercise your rights or have any questions or concerns regarding the processing of your personal data, please send your request via e-mail to privacy@silencio.network.

9 Additional information for US residents

You may have additional rights under US state privacy laws, including under the California Consumer Privacy Act of 2018 ("CCPA"), as amended by the California Privacy Rights Act of 2020. While these US state laws may not apply to us currently, we voluntarily still extend the same rights provided under GDPR to US residents.

If you are a California resident, you have rights under the California Consumer Privacy Act of 2018 ("CCPA") as amended by the California Privacy Rights Act of 2020 (“CPRA”). These rights also apply for residents of other US states that have passed similar state privacy laws, incl. Colorado, Connecticut, Delaware, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah and Virginia.

This section both explains which personal data is collected directly from you (Notice at Collection) and comprehensively describes our online information practices together with information (Privacy Policy).

Notice at collection: We may collect and may have disclosed the following categories of personal information during the past twelve months for a business purpose:

  • Identifiers, such as your real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, and other similar identifiers.

  • Personal information categories listed in the California Customer Records provisions, including telephone number, and payment information, such as your credit card number.

  • Characteristics of protected classifications under California or federal law, such as your gender and age.

  • Commercial information, such as the record of Silencio products or services purchased, obtained or considered.

  • Internet or other electronic network activity information, such as session logs.

  • Geolocation data (such as usage data from your performance metrics related to your use of the website)

  • Audio, electronic, visual, or similar information, such as voice recording, voice prints, keystrokes and photos.

  • Professional or employment‑related information.

  • Inferences drawn from any of the above information to create a profile reflecting your preferences, characteristics, behavior, abilities, and aptitudes.

None of this personal information will be sold or shared. The purposes and retention periods are set out above. We do not sell your personal information or share it for cross-contextual advertising. All information shared by us with third parties is deidentified or aggregated personal information.

Sources: We may collect the categories of personal information identified in the table above from the following categories of sources:

  • Directly from you, esp. when you fill out a form

  • Collected automatically, e.g. by data analytics providers

  • Third parties, e.g. by social media networks

Recipients: We may transfer each of these categories of personal information to:

  • Group entities

  • contractors and service providers, incl. business partners and advisors

  • other third parties, incl. government entities and law enforcement

However, we have not sold or shared, as defined in the CCPA, any personal information in the last twelve months.

Sensitive personal information: We may collect additional sensitive personal information as defined by the CCPA: social security number, driver’s license, state ID card, passport number, union membership, your account log‑in, password, credentials allowing access to an account, financial account, debit and credit card numbers, and contents of your email and/or text messages, precise geolocation data, and your information collected and analyzed concerning your health information. However, we only use these sensitive personal information to perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services and other legitimate purposes set out by 11 Cal. Code of Regulation § 7027(m).

Your Rights and Choices: If you are a California resident, you have (1) the right to know what personal information we have collected about you, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about you; (2) the right to delete personal information that we have collected from the consumer, subject to certain exceptions; (3) the right to correct inaccurate personal information that we maintain about you; (4) the right not to receive discriminatory treatment by us for the exercise of privacy rights conferred by the CCPA, including an employee’s, applicant’s, or independent contractor’s right not to be retaliated against for the exercise of their CCPA rights.

These rights also apply for residents of other US states that have passed similar state privacy laws.

If you would like an authorized agent to submit a CCPA request on your behalf, please have the authorized agent send an email containing your name, email address, phone number, and type of request to privacy@silencio.network. In situations where we receive a request from an authorized agent on your behalf, we may (a) require signed proof that the agent is, in fact, authorized to act on your behalf; and (b) take additional steps to verify your identity.

To exercise your rights under the CCPA and similar US state privacy laws, please send us your request via email to privacy@silencio.network. All requests are subject to verification of your identity. We may require at least two (2) pieces of identifying information that match information maintained by us. In some cases, we may require additional identifying information and a signed declaration attesting to your identity.

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