Sigma Accolade, Inc. Privacy Policy

Last Revised: 2017-08-15

Sigma Accolade, Inc. (“Sigma” or "we") provides a merit-based digital recognition service utilizing various tools, including, but not limited to, the Sigma website at and related mobile apps (collectively, the “Site”), that allows users to interact online and issue and receive merits (collectively, the “Service”). Sigma respects your preferences concerning the treatment of information that we may collect from and during your use of the Site and the Service. This Privacy Policy lets you know how we may collect, use, and share your information, and the choices available to you to control how we collect, use, or share your information. This Privacy Policy describes the broadest potential use of your information throughout the Site and the Service that is consistent with the terms of this policy. However, please note that we may make far less use of your information. By visiting the Site or using the Service, you consent to our collection, use, disclosure, and processing of your information as described in this Privacy Policy. “Processing”, in this context, means using or touching your information in any way, including, among other things, collecting, storing, deleting, using, combining and disclosing your information, and/or transferring it to and from the United States and internationally. We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this Privacy Policy. In some cases, if we make significant changes to this Privacy Policy, we may provide you with additional notice by adding a statement to our Site, or by sending you an email notification. By continuing to use the Site or the Service after an updated version of the Privacy Policy has been posted, you are agreeing to be bound by the updated Privacy Policy. We encourage you to review this Privacy Policy periodically, to stay informed about our practices. There are additional clauses located at the end of this policy that may apply to you if you are located in a country other than the United States of America.

Types of Information We Collect, and How We Collect It

At the outset, we would like to inform you that the information we collect about you, whether it is supplied directly to us by you or received by us from third-parties (as discussed in more detail below), may include information that identifies you personally or that may not identify you personally. Accordingly, when we refer to information about you in this Privacy Policy, it may include both categories of information.

Information That You Give Us. We collect any information that you give us. For example, we collect information about you when you register for the Service, participate in any interactive features of the Site or the Service, fill out a form, give us feedback, ideas, or submissions about the Site or the Service, communicate with us via third party social media sites, request customer support, or otherwise communicate with us via the Site, the Service, or any other means. The types of information we collect include your name, e-mail address, phone number, organizational affiliation, as well as any other information you choose to provide to us. The information you give us may also include statements you make on the Site or the Service, such as testimonials, services reviews, or other statements. Depending on the information you choose to include, any testimonials, service reviews, or statements you make may identify you personally. For information about ways to limit our collection of your information, please see the “Your Choices” section below. If you choose not to provide certain information, you understand that we may not be able to provide certain elements of the Service to you, and that certain features of the Site or the Service may be unavailable or work differently.

Information about You Received from Third-Party Services or Other Users. If you log in to the Service using credentials associated with your account at third-party services such as Facebook, LinkedIn or Twitter (each, a “Third Party Service”), you allow Sigma to access certain information associated with your account with the Third Party Service. The information you allow us to access may vary according to the privacy settings you establish with the Third Party Service. We encourage you to review the privacy policies of any Third Party Services from which you access the Service. In addition, if you utilize a Third Party Service to log in to the Service, other users to whom you may be connected through such Third Party Service may be able to see that you are a user of the Service, or may be able to view or follow information about you on the Service. Other users of the Service may also make statements about you on the Site or the Service such as testimonials, services reviews, or other statements. Depending on the information they choose to include, any testimonials, service reviews, or statements made about you by other users may include information about you that identifies you personally.

Electronic Communications Protocols and Web Beacons. We may collect information about you and your use of the Site and the Service through electronic communications protocols, web beacons, embedded URLs, pixel tags and related devices or technologies. As is true when you visit most websites, certain information is automatically generated and stored about your visits to such websites. As such, Sigma may automatically receive information about you as part of the communication connection itself between you and the Site or the Service. This type of information may include things like network routing information (for example, where you came from), equipment information (for example, device type, operating system, browser type), your internet protocol (“IP”) address, and the dates and times of your visits.

Sigma Cookies. Sigma's server will query your browser to see if there are "cookies" previously set by the Site or the Service. A cookie is a small piece of information sent by a web server that is stored on your computer by a web browser, so that it can later be read back from that browser or Sigma's server. The main purpose of cookies is to facilitate and enhance communications and interactions between you and the Site or the Service, but cookies can be used for other purposes as well. Cookies for the Site and the Service may collect a unique identifier, user configuration settings, and profile information. Sigma also uses cookies to collect general usage and volume statistical information that does not include personally identifiable information. Some cookies may remain on your computer after you leaves the Site or the Service. While we do not offer an opt-out for cookies, browsers provide you with information on and control over cookies, including a feature to opt-out of the use or storage of cookies. You can set your browser to alert you when a cookie is being used, and you will then have the option to accept or reject the cookie. You can also set your browser to refuse all cookies, or accept only those cookies returned to the originating servers. However, if you disable the use of cookies, you may not be able to use some features of the Site or the Service.

Third-Party Cookies and Functions. Sigma may use third-party advertisers to serve or track advertisements on or within the Site or the Service. These third parties may use cookies, pixel tags and other technologies to, among other things, enable themselves to record which ads your browser has loaded and which pages you may have been viewing when the ads were delivered or accessed. The information collected through these functions is subject to the privacy policies of those third parties, which you should carefully review.

Location Based Services. The device you use to access the Site or the Service may provide your location to the Site or the Service. If you enable the location-based feature on your device, we will automatically receive information about your location when you use the Site or the Service. Your device may allow you to deactivate location-based services. If you deactivate location-based services, your device should no longer send information about your location to third parties, including Sigma; but be advised that if you turn off location-based services on your device, certain aspects of the Site and the Service may not be available to you.

How We Use Your Information

Sigma uses your information for the following purposes:

To issue, process and display a Merit. Sigma may use your information to determine whether you meet the criteria for receipt of a Merit (as defined in our Terms of Service) For example, the issuance of Merit may be based upon your attendance of an event at a particular time and location. Your information, including location information from your device or the event's organizer, may be used to confirm whether you meet the criteria for receipt of such a Merit. Sigma may also use information that you provide to confirm your identity, and to display a Merit that you receive on the Service or on Third Party Services, such as through Sigma's or others' application programming interfaces used by those Third Party Services, embeds that you may make on Sigma's or Third Parties' sites, or on social network services you might link to your account.

To provide support or other services. Sigma may use your information to provide you with support or other services that you have requested. In addition, Sigma may use your information to respond to your inquiries or requests for information.

To send you technical notices. Sigma may use your information to send you technical notices, updates, confirmation, security alerts, and support and administrative messages.

To communicate to you about products and service we think you might enjoy. Sigma may use your information to communicate with you about products, services, offers, promotions, rewards, and events offered by Sigma and its partners, and to provide news and information that we think may be of interest to you.

To engage in transactions. Sigma may use your personally identifiable information such as name, physical address, telephone number, e-mail address and/or company/institution to engage in transactions with you, including contacting you about your account or transactions. We may also use your information to bill you for the Service, and to process payments.

To interact with Third Party Services. If you choose to log in using an account from a Third Party Service, Sigma may contact you via an e-mail address associated with your account at the Third Party Service and post status updates, notes, photos, videos and other materials to the Third Party Service on your behalf pursuant to the permissions that you grant.

To post on online forums and social networks, if you choose to do so. The Service allows users to participate in interactive discussions and post comments and other content. You are not required to participate in such discussions, or to post comments or other content; whether you choose to do so is entirely at your discretion. You should carefully consider whether you wish to submit personal information in these settings, because any information you share may become publicly accessible. You should tailor any content you submit accordingly.

To provide, deliver, maintain, test, and improve quality and facilitate use of the Site and the Service. Sigma may use your information, including the information gathered as a result of site navigation and electronic protocols and cookies (including third-party cookies), to improve the quality of the Site and the Service, to better serve you and enhance your experience with the Site and the Service, and to track marketing campaign responsiveness and evaluate page response rates. The foregoing uses may include our having to modify or copy the information you provide, such as, for example, textual or narrative content, images, or video content. We may also use your information to monitor and analyse trends, usage, and activities in connection with the Site and the Service.

How We Share Your Information

To operate the Site or the Service. We may share your information with vendors, consultants, and other service providers who need access to such information to perform work or to provide services on our behalf, to perform or administer certain Site- or Service-related activities (such as providing hosting or maintenance services, managing databases, processing payments, or supporting/improving the features of the Site or the Service), or to perform or administer the Service. These third parties will only have access to your information as necessary to perform their functions, and may not use your information for any other purpose.

To comply with legal requirements, or to enforce our rights. Sigma cooperates with government and law enforcement officials and private parties to enforce and comply with the law. Sigma may disclose information about you to government or law enforcement officials or to private parties as we, in our sole discretion, believe necessary or appropriate: (i) to respond to claims and/or legal process (including subpoenas); (ii) to protect the property and/or rights of Sigma or any third party; (iii) to protect the safety of the public or any person; (iv) to prevent or stop any illegal, unethical, or legally actionable activity; (v) to comply with applicable law or regulation; or (vi) in response to any lawful request by public authorities, including, without limitation, to meet national security or law enforcement requirements. We may also share your information as needed to enforce our terms of use with respect to the Site and the Service, or to protect the rights, property, or safety of Sigma or other third parties.

Aggregated or anonymized information. We may share, for any reasonable business purpose, aggregated or anonymized information that does not directly identify you. In addition to the foregoing, we may also provide our investors, partners, affiliates and others with aggregated information (information that does not identify you or other users personally) concerning of the Site and the Service. Such aggregated information may include, among other things, number of users, countries of residence, average page views per session, and average length of time as a member.

To facilitate a financing, merger or acquisition. Sigma may disclose your information in confidence to an actual or prospective provider of financing to Sigma, or in connection with an actual or intended merger, acquisition, reorganization or other transaction involving all or substantially all of Sigma's assets.

With your consent, or at your direction. Sigma will share your information with your consent or at your direction, including if we notify you through the Site or the Service that the information you provide will be shared in a particular manner, and you choose to provide such information.

Your Choices

Account information. You can review, amend, correct, or delete your personal information by accessing your password-protected account page via the Site or the Service. If you want us to delete information relating to any of your accounts on your behalf, please email us at with your request, and we will take steps to delete your information as soon as we can. Note that we may retain certain information as required by law, or for business reasons as we deem necessary to fulfil the purposes identified in this Privacy Policy. We may also retain cached or archived copies of your information (including location information) for a certain period of time. The Site and the Service also provide tools for you to customize the information about yourself that is made accessible to others. Certain information about yourself, such as your full name, will always be visible to other users of the Service, and your decision to use the Service indicates your acceptance of these settings. You should review your privacy preferences regularly, to ensure that the settings match your preferences.

Promotional communications. You may opt out of receiving promotional communications from Sigma by following the instructions in those communications. If you opt out, we may still send you other kinds of communications, including those related to your current accounts or your use of the Service.


Sigma is committed to safeguarding the confidentiality of information that we collect about you. As part of that commitment, we take reasonable administrative, physical, and electronic measures to help protect your information from loss, theft, misuse, unauthorized access, disclosure, alteration, or destruction. Our efforts include protecting the security of your information during transmission by using Secure Sockets Layer (SSL) software or other encryption technology, which encrypts information you input. Wherever appropriate, we also obfuscate and/or encrypt information in our systems and/or during information transfer.

We destroy personal information in a secure manner when we no longer need it. Please be aware that no method of transmitting information over the Internet or storing of information is completely secure. Accordingly, we cannot guarantee the absolute security or secrecy of any of your information.

It is important for you to protect against unauthorized access to your passwords to use the Service and to your computer. Be sure to log off the Service when finished, if you are using a shared computer.


Your California Privacy Rights. Under California Civil Code Section 1798.83, if you are a California resident and your business relationship with Sigma is primarily for personal, family or household purposes, you may request certain data regarding Sigma's disclosure, if any, of personal information to third parties for the third parties' direct marketing purposes. To make such a request, please send an e-mail message to with "Request for California Privacy Information" in the subject line of your email. You may make such a request up to once per calendar year. If applicable, we will provide you, by e-mail, a list of the categories of personal information disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year, along with the third parties& names and addresses. Please note that not all personal information sharing is covered by Section 1798.83&s requirements.

Third-Party Sites. The Site and the Service may provide links to third-party sites. If you choose to visit another website by clicking on an advertisement, hyperlink, or otherwise, you will be directed to that party's website. The fact that we link to a website is not an endorsement, authorization, or representation of our affiliation with that third party. Those sites are beyond our control. Those other websites may place cookies or other files on your computer, collect your data, or solicit personal information from you. Your interactions with those third parties are subject to their own privacy policies and terms of use. We encourage you to read the privacy policies of other websites you visit, before providing your information to them.

Transfer of Information to Other Countries. Sigma is based in the United States, and the information we collect is governed by U.S. law. Sigma's processing and storage of the information about you that it collects may involve the transfer of that information to various countries around the world, including the United States of America or countries other than the one in which you reside, where the privacy laws may not be as protective as those in your jurisdiction. By submitting your information to Sigma via the Site or the Service, you consent to such transfers and to the processing and storage of that information in various countries around the world, including countries other than the one in which you reside. If you are located outside of the United States and you choose to provide your information to us, you agree that we have the right to transfer your information to the United States, and process it there.

Privacy Shield. Sigma adheres to the EU-U.S. Privacy Shield Framework Principles issued by the U.S. Department of Commerce. See the “EU-U.S. Privacy Shield” Section below for more information.

No Use by Minors. The Site and the Service are intended for use by adults only. Sigma does not promote the Site or the Service to children, and does not intentionally collect any personally identifiable information from children under the age of thirteen (13). If you believe that a person under the age of thirteen (13) has disclosed personally identifiable information through the Site or the Service, please report this to us immediately by emailing us at, with “Notice of Underage Person” in the subject line of your email, and we will remove such information from our files.

Applicable Law and Jurisdiction. This Privacy Policy shall be governed by, construed and entered in accordance with the laws of the State of California, applicable to contracts deemed to be made within such State, without regard to choice of law or conflict of law provisions thereof. All disputes with respect to this Privacy Policy shall be brought and heard either in the California State Courts located in the county of Santa Clara, California, or the federal district court for the Northern District of California. You consent to the in personal jurisdiction and venue of such courts. YOU HEREBY WAIVE YOUR RIGHT TO A TRIAL BY JURY WITH RESPECT TO ANY CLAIM, ACTION OR PROCEEDING, DIRECTLY OR INDIRECTLY, ARISING OUT OF, OR RELATING TO, THIS AGREEMENT TO THE FULLEST EXTENT PERMITTED BY LAW. For Australian residents, the preceding sentence shall not apply and all disputes with respect to this Privacy Policy will be dealt with in accordance with the complaints procedure set out below. For Swiss and European Union residents, the preceding sentence shall not apply and all disputes with respect to this Privacy Policy will be dealt with in accordance with the complaints procedure set out under the Privacy Shield.

Additional Clauses For Australian Users

Access or correction of personal information and questions about this Privacy Policy

If you would like to access or correct the personal information which we hold about you, or you have a question or complaint about our use of your personal information please contact us at When contacting us please provide as much detail as possible in relation to your question, comment or complaint.

We will take any privacy complaint seriously and any complaint will be assessed with the aim of resolving any issue in a timely and efficient manner. We request that you cooperate with us during this process and provide us with any relevant information that we may need. If you are not satisfied with the outcome of our assessment of your complaint, you may wish to contact the Office of the Australian Information Commissioner.

Eu-us And Swiss-us Privacy Shield

In connection with the processing, collection, use and retention of personal information that Sigma receives from data subjects in the European Union and Switzerland (“EU Data”), Sigma complies with the EU-U.S. Privacy Shield Framework Principles and the Swiss-U.S. Privacy Shield Framework Principles as set forth by the U.S. Department of Commerce (collectively, the “Principles”). Sigma has certified to the Department of Commerce that it adheres to the Principles. If there is any conflict between the terms in this privacy policy and the Principles, the Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit

Sigma is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).

In compliance with the Privacy Shield Principles, Sigma commits to resolve complaints about our collection or use of your EU Data. European Union and/or Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Sigma Accolade Inc. at We will work with you to resolve your issue promptly.

Sigma has further committed to refer unresolved Privacy Shield complaints from EU and/or Swiss individuals to the BBB EU Privacy Shield, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not resolved your complaint, please contact The services of the BBB EU Privacy Shield are provided at no cost to you.

Finally, and under limited circumstances, EU and Swiss individuals with unresolved complaints may invoke a binding arbitration option before a Privacy Shield Panel.

Note that we may be required to release EU Data in response to requests from public authorities, including to meet national security and law enforcement requirements.

If Sigma shares EU Data with a third party service provider that processes the data solely on Sigma's behalf, then Sigma may be liable for that third party's Processing of the EU Data in violation of the Principles, unless Sigma can prove that it is not responsible for the event giving rise to the damage.

We acknowledge the rights of Swiss and EU individuals to access their personal data to inspect, correct, or amend it. Swiss and/or EU individuals wishing to access their personal data may do so by following the steps listed in “Your Choices”, above.

Contact Us

If you have any questions or concerns about the Privacy Policy or any privacy issues, please email us at

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