This Privacy Policy describes our policies and procedures on the collection, use and disclosure of your information when you use the Service and tells you about your privacy rights and how the law protects you.
We use your Personal Data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this Privacy Policy.
The words whose initial letters are capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.
For the purposes of this Privacy Policy:
Account means a unique account created for You to access our Service or parts of our Service.
Affiliate means an entity that controls, is controlled by, or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
Application refers to Undersignal, the software program provided by the Company.
Business, for the purpose of CCPA/CPRA, refers to the Company as the legal entity that collects Consumers' personal information and determines the purposes and means of the processing of Consumers' personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers' personal information, that does business in the State of California.
CCPA and/or CPRA refers to the California Consumer Privacy Act (the "CCPA") as amended by the California Privacy Rights Act of 2020 (the "CPRA").
Company (referred to as either "the Company", "We", "Us" or "Our" in this Privacy Policy) refers to Undersignal LLC, 186 E Hampton Way, Jupiter FL 33458.
For the purposes of the GDPR, the Company is the Data Controller.
Consumer, for the purpose of the CCPA/CPRA, means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.
Country refers to: Florida, United States
Customer Content means any text, documents, transcripts, URLs, or other materials You submit to the Service for analysis, including draft statements, press releases, articles, transcripts, regulatory filings, and any associated metadata or context You provide. Customer Content is distinct from account, usage, and billing data.
Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
Device means any device that can access the Service such as a computer, a cell phone or a digital tablet.
Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.
GDPR refers to EU General Data Protection Regulation.
Personal Data (or "Personal Information") is any information that relates to an identified or identifiable individual.
For the purposes of GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.
For the purposes of the CCPA/CPRA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.
We use "Personal Data" and "Personal Information" interchangeably unless a law uses a specific term.
Service refers to the Application.
Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used. For the purposes of the GDPR, Service Providers are considered Data Processors.
Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
Under GDPR, You can be referred to as the Data Subject or as the User as you are the individual using the Service.
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to:
Usage Data is collected automatically when using the Service.
Usage Data may include information such as your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When you access the Service by or through a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device's unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.
We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device.
The Company may use Personal Data for the following purposes:
To provide and maintain our Service, including to monitor the usage of our Service.
To manage your Account: to manage your registration as a user of the Service. The Personal Data you provide can give you access to different functionalities of the Service that are available to you as a registered user.
For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services you have purchased or of any other contract with us through the Service.
To contact you: To contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
To provide you with news, special offers, and general information about other goods, services and events which we offer that are similar to those that you have already purchased or inquired about unless you have opted not to receive such information.
To manage your requests: To attend and manage your requests to us.
For business transfers: We may use your Personal Data to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by us about our Service users is among the assets transferred.
For other purposes: We may use your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.
We may share your Personal Data in the following situations:
The Company will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
Where possible, we apply shorter retention periods and/or reduce identifiability by deleting, aggregating, or anonymizing data. Unless otherwise stated, the retention periods below are maximum periods ("up to") and we may delete or anonymize data sooner when it is no longer needed for the relevant purpose. We apply different retention periods to different categories of Personal Data based on the purpose of processing and legal obligations:
Account Information
Customer Support Data
Usage Data
Marketing Data
Financial and Transaction Data
Usage Data is retained in accordance with the retention periods described above, and may be retained longer only where necessary for security, fraud prevention, or legal compliance.
We may retain Personal Data beyond the periods stated above for different reasons:
You may request information about how long we will retain your Personal Data by contacting us.
When retention periods expire, we securely delete or anonymize Personal Data according to the following procedures:
Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those from your jurisdiction.
Where required by applicable law, we will ensure that international transfers of your Personal Data are subject to appropriate safeguards and supplementary measures where appropriate. The Company will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.
You have the right to delete or request that we assist in deleting the Personal Data that we have collected about you.
Our Service may give you the ability to delete certain information about you from within the Service.
You may update, amend, or delete your information at any time by signing in to your Account, if you have one, and visiting the account settings section that allows you to manage your personal information. You may also contact us to request access to, correct, or delete any Personal Data that you have provided to us.
Please note, however, that we may need to retain certain information when we have a legal obligation or lawful basis to do so.
If the Company is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.
Under certain circumstances, the Company may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
The Company may disclose your Personal Data in the good faith belief that such action is necessary to:
The security of your Personal Data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially reasonable means to protect your Personal Data, we cannot guarantee its absolute security.
The Service Providers we use may have access to your Personal Data. These third-party vendors collect, store, use, process and transfer information about your activity on our Service in accordance with their Privacy Policies.
We currently do not use third-party analytics service providers. Rate limiting, usage monitoring, and security telemetry are performed using software that runs on our own servers and does not transmit Personal Data to external parties. If we add third-party analytics providers in the future, we will update this Privacy Policy and list them here.
We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt-out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us.
We may use Email Marketing Service Providers to manage and send emails to you.
Postmark
Their Privacy Policy can be viewed at https://postmarkapp.com/eu-privacy#security-and-privacy
We may provide paid products and/or services within the Service. In that case, we may use third-party services for payment processing (e.g. payment processors).
We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.
Stripe
Their Privacy Policy can be viewed at https://stripe.com/us/privacy
"Customer Content" means any text, documents, transcripts, URLs, or other materials you submit to the Service for analysis, including but not limited to draft statements, press releases, articles, transcripts, regulatory filings, and any associated metadata or context you provide. Customer Content is distinct from the account, usage, and billing data described elsewhere in this Privacy Policy.
We treat Customer Content as confidential. We do not sell, license, publish, or share Customer Content with third parties except as strictly necessary to provide the Service (for example, transmitting the content to the AI model providers we use to perform analysis, under contractual confidentiality obligations) or as required by law.
Customer Content may contain confidential business information, attorney work product, draft communications subject to internal review, or information about identifiable third parties. By submitting Customer Content, you represent that you have the right to submit it for analysis and that doing so does not violate any confidentiality, contractual, or legal obligation you owe to any third party.
Undersignal does not operate a public directory of reports and does not auto-generate, index, or publish individual reports to any public surface on its own initiative. Every report is produced only on your request, about Customer Content you submit.
We treat Customer Content differently based on how it is submitted to the Service. We do not use any Customer Content to train, fine-tune, or otherwise improve general-purpose AI models, and we do not permit the AI model providers we use to retain Customer Content for training purposes. The AI providers we use for analysis are contractually bound to process Customer Content solely to return analytical output to us and not to retain it for model improvement.
URL-Submitted Content. When you submit a URL pointing to publicly published content (for example, a news article, press release, regulatory filing, transcript, or other publicly accessible document), we may retain the analyzed content and the analytical report in our corpus for methodology development, calibration, benchmarking, and research purposes. This corpus is internal to Undersignal and is not redistributed or sold as raw content. Because the source material is already public, we treat the analyzed text as publicly referenceable. Aggregated analytical insights derived from this corpus may inform our methodology, benchmarking features, published case studies, and research outputs.
Pasted or Uploaded Content. When you submit content by pasting text directly into the Service or by uploading a document (rather than by URL), we treat it as confidential to you. Pasted and uploaded content is not added to our corpus, is not used for methodology calibration beyond returning your analytical report, and is not referenced in case studies, research outputs, or aggregated insights without your explicit written consent. We may retain pasted and uploaded content only as needed to provide the Service to you, subject to the retention terms below.
Aggregated Statistics. Regardless of submission method, we may compute and retain aggregated, deidentified statistical signals about analytical patterns across the Service (for example, distributional statistics about rhetorical features). Such aggregated statistics do not identify you, your organization, or any specific submission and cannot reasonably be linked back to individual Customer Content.
We retain Customer Content and the analytical reports generated from it for the duration of your account relationship, so you can access your historical analyses. You may delete individual reports at any time from within the Service. Upon account closure, we will delete or anonymize Customer Content and associated reports within 90 days, except where retention is required for legal, tax, audit, or dispute-resolution purposes.
Enterprise customers may negotiate custom retention terms, including shorter retention windows, single-tenant deployment, or contractually required deletion timelines, as part of their service agreement.
Customer Content you submit may reference or describe identifiable third parties (for example, public figures, executives, journalists, or organizations named in a press release or article you upload for analysis). You may name the outlet or author of the text you analyze; doing so is attribution for the analyzed text, not a claim by Undersignal that the named entity lies, deceives, or manipulates. Our analysis of such Customer Content constitutes analytical opinion about the construction of the submitted text, not factual assertions about the third parties referenced. We do not maintain persistent profiles or scores of named third parties based on Customer Content submitted by our users.
If you submit Customer Content that contains personal data about identifiable individuals (other than yourself), you are responsible for ensuring you have any rights or permissions necessary to do so under applicable law.
Customer Content may be subject to legal process, including subpoenas, court orders, or discovery requests directed to us or to you. We will resist overbroad requests to the extent permitted by law and will notify you of any legal process seeking your Customer Content unless legally prohibited from doing so. Customers concerned about discovery exposure should review our retention practices and may request shorter retention windows.
The Service provides analytical opinion about the rhetorical construction of submitted text, grounded in published methodology. Analytical output is not legal advice, financial advice, public relations advice, or any other form of professional advice. You remain solely responsible for any communications, decisions, or actions you take based on the analytical output. The Service is intended for use by professional practitioners who bring their own professional judgment and, where appropriate, their own professional advisors to the decisions they make.
We may process Personal Data under the following conditions:
In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
We may transfer, store, and process Personal Data in countries other than the country in which you are located, including countries outside the European Economic Area ("EEA") and the United Kingdom ("UK"), where data protection laws may differ.
Where we transfer Personal Data outside the EEA/UK to a country that has not been recognized as providing an adequate level of protection, we rely on appropriate safeguards, such as:
We transfer Personal Data internationally only as needed to provide the Service and to work with our Service Providers (for example, hosting, analytics, email delivery). You may contact us using the details in the "Contact Us" section of our Privacy Policy to request further information about the safeguards we use for international transfers, including copies of relevant contractual protections (redacted where necessary).
The Company undertakes to respect the confidentiality of your Personal Data and to guarantee you can exercise your rights.
You have the right under this Privacy Policy, and by law if you are within the EU, to:
You may exercise your rights of access, rectification, cancellation and opposition by contacting us. Please note that we may ask you to verify your identity before responding to such requests. If you make a request, we will try our best to respond to you as soon as possible. We generally respond within one month, and may extend by two further months where necessary, in accordance with applicable law.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, if you are in the European Economic Area (EEA), please contact your local data protection authority in the EEA.
This privacy notice section for California residents supplements the information contained in our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Device. The following is a list of categories of personal information which we may collect or may have been collected from California residents within the last twelve (12) months.
Please note that the categories and examples provided in the list below are those defined in the CCPA/CPRA. This does not mean that all examples of that category of personal information were in fact collected by us, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of Personal Information would only be collected if you provided such personal information directly to us.
Category A: Identifiers.
Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver's license number, passport number, or other similar identifiers.
Collected: Yes.
Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
Examples: A name, signature, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Some personal information included in this category may overlap with other categories.
Collected: Yes.
Category C: Protected classification characteristics under California or federal law.
Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
Collected: No.
Category D: Commercial information.
Examples: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Collected: Yes.
Category E: Biometric information.
Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
Collected: No.
Category F: Internet or other similar network activity.
Examples: Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
Collected: Yes.
Category G: Geolocation data.
Examples: Approximate physical location, physical location or movements.
Collected: No.
Category H: Sensory data.
Examples: Audio, electronic, visual, thermal, olfactory, or similar information.
Collected: No.
Category I: Professional or employment-related information.
Examples: Current or past job history or performance evaluations.
Collected: Yes.
Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Examples: education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
Collected: No.
Category K: Inferences drawn from other personal information.
Examples: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Collected: No.
Category L: Sensitive personal information.
Examples: Government-issued identifying numbers, financial account details, genetic data, precise geolocation, race or ethnicity, religious or philosophical beliefs, union membership, mail, email, text messages, biometric data, health data, and sexual orientation or sex life.
Collected: No.
Under CCPA/CPRA, Personal Information does not include:
We obtain the categories of personal information listed above from the following categories of sources:
We may use or disclose personal information we collect for "business purposes" or "commercial purposes" (as defined under the CCPA/CPRA), which may include the following examples:
Please note that the examples provided above are illustrative and not intended to be exhaustive. For more details on how we use this information, please refer to the "Use of Your Personal Information" section.
If we decide to collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes, we will update this Privacy Policy.
We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:
Please note that the categories listed above are those defined in the CCPA/CPRA. This does not mean that all examples of that category of personal information were in fact disclosed, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been disclosed.
When we disclose Personal Information for a business purpose or a commercial purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
We do not share your personal information for cross-context behavioral advertising, and we have not done so in the preceding twelve (12) months.
We do not sell your personal information, and we have not sold personal information in the preceding twelve (12) months. We do not use your personal information for advertising, and we have no advertising partners or ad networks.
We have not sold or shared any categories of personal information in the preceding twelve (12) months.
We retain California residents' Personal Information for as long as reasonably necessary to achieve the purposes described in this Privacy Policy (including the purposes disclosed in this CCPA/CPRA notice), taking into account: (i) how long we need the information to provide and maintain the Service and your Account; (ii) whether you have requested deletion (subject to applicable exceptions); (iii) our legal, tax, accounting, and regulatory obligations; (iv) security, fraud prevention, and abuse monitoring needs; and (v) the time periods needed to resolve disputes and enforce our agreements.
Specific retention periods for major data categories are described in the "Retention of Your Personal Information" section of our Privacy Policy, and we may retain certain information longer where required or permitted by law (for example, to comply with recordkeeping obligations or to establish, exercise, or defend legal claims).
We do not sell or share the personal information of any consumer, including consumers we know to be under 16 years of age.
The CCPA/CPRA provides California residents with specific rights regarding their personal information. If you are a resident of California, you have the following rights:
Please see the "Do Not Sell or Share My Personal Information" section and "Limit the Use or Disclosure of My Sensitive Personal Information" section for more information on our sale and sharing practices and limit the use of sensitive information collected.
Additionally, in order to exercise any of your rights under the CCPA/CPRA, and if you are a California resident, you can contact us:
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable request related to your personal information.
Your request to us must:
We cannot respond to your request or provide you with the required information if we cannot:
We will disclose and deliver the required information free of charge within 45 days of receiving your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.
Any disclosures we provide will only cover the 12-month period preceding the verifiable request's receipt.
For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not sell or share your personal information, and we do not use it for interest-based or cross-context behavioral advertising. Because there is no sale or sharing, there is nothing to opt out of. You may still contact us to exercise the other rights described in this notice.
If you are a California resident, you have the right to limit the use and disclosure of your sensitive personal information to that use which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests such services or goods.
We collect, use and disclose sensitive personal information in ways that are necessary to provide the Service. For more information on how we use your personal information, please see the "Use of Your Personal Information" section or contact us.
To submit a request to limit the use or disclosure of sensitive personal information, please contact us using the methods listed in the "Contact Us" section of our Privacy Policy.
Our Service does not respond to Do Not Track signals.
However, some third-party websites do keep track of your browsing activities. If you are visiting such websites, you can set your preferences in your web browser to inform websites that you do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of your web browser.
California's Shine the Light law (Civil Code Section 1798.83) permits California residents to request information about a business's disclosure of their personal information to third parties for those third parties' own direct marketing purposes. We do not share your personal information with third parties for their own direct marketing purposes.
If you'd like to request more information under the California Shine the Light law, and if you are a California resident, you can contact us using the contact information provided below.
California Business and Professions Code Section 22581 allows California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.
To request removal of such data, and if you are a California resident, you can contact us using the contact information provided below, and include the email address associated with your Account.
Be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.
Our Service does not address anyone under the age of 16. We do not knowingly collect personally identifiable information from anyone under the age of 16. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from anyone under the age of 16 without verification of parental consent, we take steps to remove that information from our servers.
If we need to rely on consent as a legal basis for processing your information and your country requires consent from a parent, we may require your parent's consent before we collect and use that information.
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.
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.
If you have any questions about this Privacy Policy, you can contact us: