Privacy Notice.

1. Who is responsible for your data

The data controller is Aligned Software Solutions Inc., a company incorporated in British Columbia, Canada, which operates The Signal Engine™ service.

Data controller

Aligned Software Solutions Inc., trading as The Signal Engine™

Registered address

170–422 Richards Street
Vancouver, BC V6B 2Z4
Canada

Email

Telephone

+1 604 259 7676

Data protection officer

Not appointed. We are not required to appoint one, and privacy questions are handled by the contact above.

2. The three ways we may hold data about you

The information we hold depends on your relationship with us. The following categories explain which parts of this notice apply.

• You visited this website. We hold analytics data only, and only if you accepted analytics cookies.
• You contacted us through the research walkthrough, the outreach self-assessment or the free lead sample form. We hold the information you submitted.
• We contacted you as part of a client’s outbound programme. We hold business contact details and the verified signal that prompted the message. You did not give us this data directly, so section 4 explains where it came from.

3. What we collect, why, and on what legal basis

We do not collect special category data, we do not knowingly process data about anyone under 18, and we do not make automated decisions that produce legal or similarly significant effects about you.

4. Where outbound prospect data comes from

If we contacted you without receiving your details directly from you, this section explains the sources of that information, as required by Article 14 GDPR.

• Public professional profiles, principally LinkedIn, for your name, role and employer.
• Company websites, public registers and published announcements, for the event the message refers to.
• Business email verification services, to confirm a work address is valid and belongs to the domain we expect.

We do not buy contact lists or present guesses as facts. Factual claims in outreach are checked against dated primary sources. A possible business need is treated as a hypothesis, not as a verified fact. You can inspect our research criteria in the Quality standards.

Our legitimate interests, stated plainly

We rely on legitimate interests to contact business people in a professional capacity about a matter relevant to their role. We have weighed that against your interests and rights: we contact you at a business address, about your work, in low volume, with a stated reason, and we stop permanently the moment you ask. You can object at any time — see section 8 — and we will action it without argument.

5. Who else sees your data

We do not sell personal data, and we never share it with other advertisers. We use a small number of service providers who process data on our instructions under a written agreement:

Where a client engages us to run outbound, that client is a separate controller for the conversations that result. If you appear in a free lead sample, your business contact details and the event we cite are shared with the company that requested the sample, which becomes a separate controller for its use of them. We may also disclose data where the law requires it.

Sending data outside the EEA

We are based in Canada, so data reaches us there. The European Commission has decided that Canada offers an adequate level of protection for personal data handled by commercial organisations, which is the basis for that transfer. Transfers to providers in the United States are made under the European Commission’s standard contractual clauses.

6. How long we keep it

We keep personal data for 3 months, after which it is deleted. Website analytics data is the exception and is kept for 14 months, the retention period configured in Google Analytics. Two further exceptions: data that forms part of a signed client contract is kept for as long as that contract and the legal claim periods that follow it require, and an opt-out is kept permanently on a suppression list — that is the only way to guarantee you are never contacted again. Marketing consent is the last exception: we use your email for marketing until you withdraw consent, and keep the record of that consent for 3 years afterwards.

7. Cookies

This website sets analytics cookies only after you accept them, and functional storage that remembers your colour theme. The full list, with providers and expiry dates, is in the Cookie Notice, where you can also change or withdraw your choice.

8. Your rights

Under the GDPR you can exercise all of the following, free of charge. We answer within one month.

• Access — a copy of the data we hold about you, and where we got it.
• Rectification — correction of anything inaccurate.
• Erasure — deletion of your data.
• Restriction — a freeze on processing while a dispute is resolved.
• Portability — the data you gave us, in a machine-readable format.
• Objection — to processing based on legitimate interests. Where you object to direct marketing, including outbound contact, we stop immediately and permanently. There is no balancing test for that one.
• Withdraw consent — at any time, for anything based on consent, without affecting what was lawful before. That includes consent to marketing emails: use the unsubscribe link in any marketing email, or write to us.

To exercise any of these, email . You do not need to explain why, and you do not need to use a particular form of words. Asking us to stop is enough.

9. Complaints

If you are unhappy with how we handled your data, please tell us first so we can put it right. You also have the right to complain to a supervisory authority — the data protection authority in the EU or EEA country where you live or work, or where you believe the problem occurred. The full list is published by the European Data Protection Board at edpb.europa.eu.

10. Changes to this notice

If we change how we handle personal data we will update this page and the date at the top. Where the change is significant and affects people we already hold data about, we will say so directly rather than relying on you noticing.