PRIVACY POLICY 

SIGMA SOFTWARE INC (“we”, “us”, or “our”) operates https://vbc.sigma.software/ (the “Website”) and provides software / content services related to transplant centers (the “Services”). We are committed to protecting your privacy and handling your personal information in a transparent manner. This Privacy Policy describes what information we collect, why we collect it, how we use it, how we share it, and your rights, including under Californian and U.S. federal law. 

Definitions 

For the purposes of this Privacy Policy, the following terms shall have the meanings set forth below: 

• “Company”, “we”, “us”, or “our” – refers to SIGMA SOFTWARE INC the entity responsible for operating the Website and processing personal data. 

• “Website” – refers https://vbc.sigma.software/ and any subdomains, content, features, or services made available through it. 

• “Services” – refers to any products, offerings, or functionalities provided by the Company through the Website or related platforms. 

• “Personal Data” / “Personal Information” – means any information that directly or indirectly identifies, relates to, describes, or could reasonably be linked to an individual (such as name, email address, IP address, identifiers, or usage data). 

• “Processing” – means any operation or set of operations performed on Personal Data, such as collection, recording, storage, use, disclosure, transfer, or deletion. 

• “Data Subject”, “User”, or “you” – refers to any identified or identifiable individual who accesses or uses the Website or Services. 

• “Service Providers” – means trusted third-party vendors, contractors, or partners engaged by the Company to perform certain services (e.g., hosting, analytics, marketing support, or email delivery) on our behalf. 

• “Cookies” – refers to small text files stored on a user’s device by a website, used to remember preferences, support functionality, enable analytics, or deliver targeted advertising. 

• “Do Not Track” (DNT) – refers to a browser setting that allows users to signal that they do not want certain web tracking practices. 

• “International Transfer” – means the movement of Personal Data to a country outside of the individual’s country of residence, including storage and processing in such jurisdictions. 

• “Applicable Law” – refers to any data protection, privacy, or consumer protection laws and regulations that govern the processing of Personal Data, depending on the jurisdiction (e.g., general privacy regulations, consumer rights laws). 

1. Information We Collect and How We Do It 

We may collect and process the following types of personal data: 

• Information you provide directly: 

Name, email address, job title/role, organization / transplant center affiliation, any other information you provide in the course of using contact forms, requesting downloads (e.g., a PDF), subscribing to communications. 

Any additional information you voluntarily submit (feedback, surveys, etc.). 

• Information collected automatically: 

IP address, browser and device type, operating system, referring/exit pages, pages visited, time spent, screen resolution, language preferences, etc. 

Cookies and similar tracking technologies. 

• Information from third parties: 

Publicly accessible sources (business directories, media, etc.) 

Partners / vendors, if applicable. 

2. Purposes for Which We Use Your Information 

We use personal data for several purposes: 

• To perform and fulfill your requests, including but not limited to sending the requested materials (e.g., PDFs) and responding to inquiries. 

• To maintain accurate and up-to-date internal records. 

• To analyze, enhance, and improve our products, services, and overall user experience on the Website, including customization of its content. 

• To send promotional communications, newsletters, and updates, subject to your prior consent where required. 

• To conduct market research and statistical analysis, insofar as it is permitted by applicable law. 

• To comply with legal obligations, regulatory requirements, and enforceable governmental requests. 

• To safeguard our legitimate interests, including the protection of our rights, property, and systems, as well as the prevention, detection, and investigation of misuse, fraud, or other unlawful activities. 

3. Legal Basis for Processing  

Our collection and use of personal information is conducted in accordance with applicable U.S. privacy laws, including the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA/CPRA”). Under these laws, we process personal information only for specific “business purposes” or “commercial purposes,” as defined by the CCPA/CPRA. These include: 

• With your consent – For example, where you voluntarily provide your email address to receive resources, newsletters, or marketing communications. You may withdraw your consent at any time. 

• To perform a transaction or provide requested services – For example, to deliver requested materials, respond to your inquiries, or otherwise make our Services available to you. 

• For our internal business purposes – Including maintaining the security of our systems, detecting and preventing fraud, measuring and improving our Website and Services, and conducting internal research and analytics. 

• For compliance with law and legal obligations – We may process and disclose personal information as necessary to comply with applicable U.S. federal, state, or local laws, regulations, and legal processes, or to protect our legal rights. 

We do not process personal information for purposes materially different, unrelated, or incompatible with those described in this Privacy Policy without providing you with notice and, where required, obtaining your consent. 

4. Retention of Data 

We retain personal data only for as long as is necessary to fulfill the purposes outlined in this Policy, unless a longer retention period is required or permitted by applicable law. 

The specific retention period may vary depending on the type of data, the purpose of its processing, and applicable legal, regulatory, or contractual obligations. 

In the event of a dispute, investigation, or legal requirement, we may retain relevant personal data for the duration of such proceedings and until their final resolution. 

5. Security 

We implement appropriate technical, organizational, and administrative safeguards to ensure a level of security appropriate to the risks associated with the processing of personal data. Such measures are designed to protect against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. These safeguards may include, where appropriate, encryption, secure transmission protocols (such as HTTPS/SSL), strict access controls, and other industry-standard security practices. 

6. Personal Information Sharing & Disclosure 

We may disclose personal data under the following circumstances: 

• To trusted third-party service providers who perform services on our behalf, such as website hosting, email delivery, analytics, customer relationship management (CRM), and similar operational support. 

• To marketing and advertising partners, but only where you have provided explicit consent to such disclosure. 

• Where disclosure is required by applicable law, regulation, legal process, or enforceable governmental request (including court orders and regulatory inquiries). 

• In connection with a corporate transaction, such as a merger, acquisition, reorganization, or sale of assets, where personal data may be transferred as part of the business assets. 

We do not sell personal data as defined under applicable data protection laws, including the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA), unless expressly disclosed to you and only after providing the opportunity to exercise your right to opt out. 

7. Cookies and Other Tracking Technologies 

We use cookies and similar tracking technologies to support website functionality, perform analytics, and, where applicable, deliver targeted advertising and remarketing services. 

Such technologies may include, for example, Google Analytics, behavioral analytics tools, and social media pixels. 

You may manage or disable cookies through your browser settings. Please note, however, that restricting cookies may limit certain features or functionalities of the Website. 

8. Do Not Track 

Our Website [does / does not] honor “Do Not Track” (DNT) signals from browsers. 

9. Children’s Privacy 

Our Services are not intended for children under 13 years old. 

We do not knowingly collect personally identifiable information from children under age. In case we discover that a child under age has provided us with personal information, we immediately delete this from our servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us at the e-mail provided in the next section so that we will be able to do the necessary actions to delete their personal data.

10. Rights of Users (including California Residents) 

Depending on your place of residence and applicable data protection laws, you may have the following rights regarding your personal data: 

• Right of access: to request information about what categories of personal data we collect, how it is used, and with whom it may be shared. 

• Right to rectification: to request correction or updating of your personal information if it is inaccurate or incomplete. 

• Right to deletion: to request the erasure of your personal data, subject to certain legal or legitimate business exceptions. 

• Right to restrict or object: to object to certain types of processing, including direct marketing, or to restrict processing in specific circumstances. 

• Right to data portability: where applicable, to obtain a copy of your personal data in a structured, commonly used, and machine-readable format. 

• Right to withdraw consent: if processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing. 

• Right to opt out of sale or sharing: you may request that your personal data not be sold, shared, or disclosed for cross-context behavioral advertising. 

• Right to non-discrimination: exercising your privacy rights will not result in discriminatory treatment regarding access to services or pricing. 

To exercise any of these rights, please contact us at info@sigma.software or by mail at 06 W 32nd Street, 2nd Floor, SV#05, The Yard – Herald Square, New York, NY 10001 
We will respond to verified requests within the timeframes required by applicable law. 

11. Medical / Health-Related Information Disclaimer 

We do not collect, process, or maintain Protected Health Information (PHI) as defined by the Health Insurance Portability and Accountability Act (HIPAA), unless expressly agreed to in a HIPAA-compliant written agreement. 

Any information provided through the Website or in related materials is for general informational purposes only and should not be considered a substitute for professional medical advice, diagnosis, or treatment. Always seek the advice of qualified healthcare providers with any questions you may have regarding a medical condition. 

12. International Transfers 

If you access or use our Services from outside the United States, please note that your personal data may be transferred to, stored, and processed in the United States or other jurisdictions where data protection laws may differ from those in your country of residence. 
We take appropriate safeguards, including contractual protections and technical measures, to ensure that your data is handled securely and in compliance with applicable legal requirements. 

13. Changes to This Policy 

We may update this Privacy Policy from time to time. When we do, we will post the updated version on this page and update the “Last updated” date. Your continued use of the Website after changes indicates acceptance of the revised policy. 

14. Contact Us 

If you have any questions about this Privacy Policy or wish to exercise your rights, you may contact: 

SIGMA SOFTWARE INC 

06 W 32nd Street, 2nd Floor, SV#05,  

The Yard – Herald Square, New York, NY 10001 
Email:  info@sigma.software 

Disclaimer  
By providing your email address, you consent to our collection and use of your personal information for the purpose of sending you the requested material (e.g., PDF download) and related communications. You may also receive updates or newsletters if you opt in. You can unsubscribe at any time by using the link provided in our emails. 

Your information will be processed in accordance with our Privacy Policy, which describes how we collect, use, and protect your data, and outlines your rights under applicable laws (including rights to access, deletion, and opting out of data sharing). 

We will not sell your personal information.