Privacy Policy

SILO Compliance Ltd.
Privacy Policy
Last Updated: 17 May 2022

This Privacy Policy (“Privacy Policy”) describes how SILO Compliance Ltd. and its wholly owned subsidiaries and Affiliates (except as described below) (together, “SILO” or “we” or “us” or “our”) use and disclose the Personal Information we collect from or about you when you:

  • Use the SILO website (silocompliance.com) or any blogs or pages that link to this Privacy Policy (together, the “Sites”);
  • Communicate with us electronically, such as via email; or
  • Interact with us offline, including in person, at an event or via phone.

Before submitting Personal Information to us or using the Sites, please review this Privacy Policy carefully.

Certain SILO services or subsidiaries may use different privacy policies to provide notice to you about how your Personal Information is used and disclosed.

To the extent that SILO services or subsidiaries post or reference a different privacy policy, that different privacy policy, not this Privacy Policy, will apply to your Personal Information collected in the context of those services or by that subsidiary.

Note to SILO Licensees If you are a licensee of SILO, please refer to our SILO Client Data Privacy Policy for information about how we use and disclose the Personal Information we collect about you (and your employees, customers, clients and other individuals about whom you collect Personal Information) in the context of our licensee relationship with you.  Unless we state otherwise in our communication with you or in a license agreement, this Privacy Policy does not apply to the Personal Information we collect in the context of our licensee relationship.

How We Collect and Use Your Personal Information “Personal Information” is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household such as your name, email address, IP address, telephone number, and broader categories of information such as your professional, educational or health information, commercial information and internet activity. We may collect some Personal Information directly from you and automatically through our use of cookies and other data collection technologies on our Sites.  We may also collect some Personal Information from third-party sources, such as social media platforms (if you interact with us through your social media account).  We may also collect some Personal Information directly from you if you provide us with references you list on applications and forms that we may request.   We may also collect some Personal Information on you from third parties that you have directed or consented to providing us with your Personal Information. We will treat Personal Information collected from third-party sources in accordance with this Privacy Policy, but we are not responsible or liable for the accuracy of such information or for the third party’s policies or practices. The categories of Personal Information that we collect from you depend on your interactions with us.

For example, we may collect:

Direct Identifiers, such as your name, postal address, phone number, e-mail address, IP address, online identifiers, account names, associated passwords, social media profiles and other similar identifiers.  We may collect this information to verify your identity and information, to communicate with you for marketing purposes and/or to create your SILO User Account (“Account”) to facilitate your use of our Sites.

Professional and Employment-Related Information, such as your current and former employment, professional degrees and certifications, education background, information about references you list on any application forms, and any other employment-related information.  We may collect this information to process and manage your profile when you subscribe to our newsletter or marketing events.

Commercial Information, such as products and services purchased from us. We may collect this information to conduct business analytics in order to improve our products and services.

Internet Activity Information, such as your browsing history on our Sites, specifically which pages you visit on the Sites, and which browser you used to view our Sites.  See more information in the section “Cookies and Other Technologies” below.  We may collect this information to understand your use of the Sites and, if you have a SILO User Account with us, your use of the SILO User Account.

Profile Information, such as information about your preferences and characteristics.  We may collect this information in order to understand how our products and services and communicates can be enhanced to better serve you. In addition to the purposes for collection described above, we also may collect each category of information for the purpose of performing services for you and maintain our relationship with you, which include:

  • Maintaining and servicing your Account, including managing your preferences.
  • Taking steps to improve our services to you, including to run analytics, improve any technology, assess the quality of our services, and for other related internal business purposes.
  • Administering and improving our Sites, including to measure the effectiveness of the Sites, diagnosing problems with our server, analyzing where Site traffic is coming from, and to identify our Site users.
  • Communicating with you to personalize your experience with us and improve our understanding of your needs, and to respond to inquiries you send to us.
  • Sending you messages promoting our products and services. You may opt out of receiving certain promotional e-mail messages from us as described in the “Marketing Opt-Out” section below.
  • Complying with our legal, regulatory and risk management obligations, including establishing, exercising and/or defending legal claims.

How We Disclose Your Personal Information We may share your Personal information in the following circumstances: We may share your Personal Information with companies or individuals that we contract with to receive services (our “Service Providers”).  These services may include, among other things, providing products or services to you on our behalf, creating or maintaining our databases, payment processing, researching, and analyzing the people who request information from us, preparing distribution communications or responding to inquiries.

  • We may share your Personal Information with companies that we own or control.
  • We may share your Personal Information with companies or individuals outside of SILO who may use your Personal Information for their own purposes (a “Third Party”). For example:
    • If you choose to submit Personal Information by providing a testimonial or link on our website to your own sites.
    • If we are required to provide Personal Information to a Third Party in response to a court order, subpoena, government investigation, or as otherwise required by law or legal process.
    • If we, in good faith, believe you or others are acting unlawfully and (i) believe it is necessary or appropriate to satisfy any law, regulation or other governmental request; (ii) need to protect our business and Sites properly, (iii) we believe disclosure is necessary to protect our personnel, clients, guests, or the general public.
  • We may, as a result of a sale, merger, consolidation, change in control, transfer of assets, reorganization or liquidation of our company (a “Reorganization Event’), transfer or assign your Personal Information to parties involved in the Reorganization Event. You acknowledge that such transfers may occur and are permitted by and subject to this Privacy Policy.

Cookies and Other Technologies We may use “cookies” to keep, and sometimes track, information about you on our Sites. Cookies are small data files sent to your browser or related software from a Web server and stored in your computer’s hard drive. Cookies track where you travel on the Sites and what you look at. In doing so, a cookie may enable us to relate your use of the Sites to your Personal Information. Most Web browsers can be set to inform you when a cookie has been sent to you and provide you with the opportunity to refuse that cookie. Additionally, your Flash player can be set to reject or delete Flash cookies. Refusing a cookie will generally not interfere with your use of the Sites. However, refusal of a cookie may, in some cases, preclude you from using or negatively impact the display or function of the Sites or certain areas or features of the Sites. For complete information about our use of cookies and your consent, please refer to our Cookie Policy.

We may also use web beacons (a.k.a clear GIFs, web bugs or pixel tags) to personalise your experience on the Sites, to generate information about Site traffic and trends, and to verify your viewing and/or receipt of communications. Web beacons collect information automatically, such as the type of browser that you use and your IP address. Web beacons may be used alone or in conjunction with cookies. When web beacons are used with cookies, they may link this information to other Personal Information that you have provided to us. Web beacons usually are not visible to you.

Third Party Analytics We use automated devices and applications, such as Google Analytics, to evaluate usage of our Sites. We also may use other analytic means to evaluate our Sites and services. We use these tools to help us improve the Sites, performance, and user experiences. These entities may use cookies and other tracking technologies to perform their services. We do not share your Personal Information with these third parties. To learn how Google Analytics collects and processes data, please visit “How Google uses data when you use our partners’ sites or apps” located at https://policies.google.com/privacy/google-partners?hl=en-US.

How We Respond to Do Not Track Signals Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that a user does not want to have his or her online activity and behaviour tracked. If a website that responds to a particular DNT signal receives the DNT signal, the browser can block that website from collecting certain information about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many digital service operators, including SILO, may not recognize or respond to DNT signals.

Marketing Opt-Out If you would like to opt out of receiving promotional or marketing e-mail from us, you may use the “unsubscribe” mechanism included in each marketing message.  Alternatively, you may let us know by sending us an email to info@silocompliance.com with REMOVE in the subject line and stating the e-email address that you wish to be removed from our mailing list.  If you are a SILO user or licensee, your unsubscribing from marketing communications will not preclude us from corresponding with you by email regarding user or licensee information (for example, new features, invoices, training videos or other communications).

Information for Non-US Visitors If you visit the Sites or provide us your Personal Information from outside the United States, your information will be transferred, to, stored and processed in the United States and other countries where SILO or its vendors operate in accordance with their Privacy Policy and applicable laws.  Data protection and consumer protection laws of the United States and such other countries may differ from the data protection or consumer protection laws in your own country.  By using the Sites or providing us with your Personal Information, you understand and agree that your Personal Information will be collected from and processed in the United States and other countries where SILO or its vendors operate and acknowledge that your information may be subject to access by law enforcement and other government entities, including courts and tribunals, in accordance with the laws of those jurisdictions.

Security We maintain one or more databases to store your Personal Information and may retain it as reasonably required to serve you, run our business, and comply with our legal obligations. We have implemented reasonable safeguards designed to protect your information from loss, misuse, alteration or destruction. We also take reasonable steps to ensure that third parties we work with have reasonable data privacy policies in place and posted on their websites. Without limiting any other terms that apply to our Sites and this Privacy Policy, you understand and agree that we cannot guarantee that your Personal Information will be private and secure. Except to the extent provided by law, we are not responsible or liable to you for any lack of privacy or security you may experience. You are fully responsible for taking precautions and providing security measures best suited for your situation and intended use of the Sites and our services.  Please be careful whenever sending Personal Information to us via e-mail. E-mail is not a secure means of transferring information.

Third Parties Our Sites, services and materials may contain references or links to third-party websites and services. Except as described above regarding Service Providers, we do not control what information third parties track or collect.  Any access to and use of such third-party websites and services are not governed by this Privacy Policy but instead are governed by the privacy policies of those third parties. We are not responsible for the information practices of such third parties.

Children’s Privacy We do not knowingly collect any Personal Information from children under 13.  If SILO learns that a child under the age of 13 has submitted Personal Information, we will take all reasonable measure to delete the information as soon as it is brought to our attention.   If you believe a child under the age of 13 has provided us with Personal Information, please contact us at info@silocompliance.com.

Questions about our Privacy Policy If you have questions about this Privacy Policy, please contact us at info@silocompliance.com.   You can also send us physical mail to SILO Compliance Ltd., Attention: Data Privacy Officer, PO Box 10297, Grand Cayman, Cayman Islands, KY1-1003.

Changes to our Privacy Policy We may update this Privacy Policy to reflect changes in our practices or the law.  When we post modification to this Privacy Policy, we will revise the “Last Updated” date at the top of this web page.  If the changes are deemed material, we will endeavor to notify you in advance of such changes taking place.  If you object to modifications, your sole recourse is to stop using the Sites. We encourage you to periodically review this page for the latest information on our privacy practices.