This Privacy Policy is outdated, effective May 1, 2024. View our updated Privacy Statement here.
1. Introduction
Sling (or “we”) understands and respects the importance of privacy rights and data protection of its customers. We have thus amended our Privacy Policy to adhere to new privacy and data protection laws, including the European Union’s General Data Protection Regulation (GDPR), also known as Regulation (EU) 2016/679, while remaining compliant with other legal regulations.
Sling’s business comprises the sale and distribution of the Sling Application (the “Service”) to companies and organizations and the individuals within them via a number of electronic devices, including but not limited to mobile phones, desktop computers, laptop computers, and tablets (otherwise known as “Devices”).
Sling’s Privacy Policy delineates our guidelines for the collection, usage, storage, and disclosure of personal data, which we define below. This policy clarifies how we handle your data in each of the following circumstances:
- You visit Sling’s website (www.getsling.com) while browsing the internet (during and after which you are known as a “Website User”), although you may not have necessarily procured or plan to procure an account of any kind with Sling. Sling collects a limited amount of data (which means we are a “data controller,” according to data protection laws) from Website Users primarily to improve our users’ experiences with the site. For more information, see section 4 (“What does Sling do with your personal data?”).
- Your organization or company signs up for the Service, and you access the Sling Application via our website (www.getsling.com), via Devices, or via other means (during and after which you are known as an “Application User”). Sling makes use of Application Users’ data in order to provide the Service for your company or organization. When we employ your data to grant you access to the Service, we do so on behalf of your company or organization. This means we are a “data processor,” according to data protection laws. In addition, we may use your data, primarily to improve our users’ experiences with Sling, making us a “data controller” in such a scenario. For more information, see section 4 (“What does Sling do with your personal data?”).
- You leave your organization or company and cease accessing the Sling Application via the account associated with your former organization or company (after which you are known as a “Former Application User”). We may retain your data within a limited iteration of your company- or organization-related profile. For more information, see section 4 (“What does Sling do with your personal data?”).
- You call Sling’s customer service or sales team (during and after which you are known as a “Phone User”). Sling may record your call for our own purposes, which means we are a “data controller,” according to data protection laws. When we do so, it is primarily to improve our users’ experiences with our customer service team. For more information, see section 4 (“What does Sling do with your personal data?”).
Sling reserves the right to update or amend this policy in the future.
2. Types of Personal Data
Application Users
In order to provide your company or organization with the Service, we must collect and make use of your personal data. Such data may include some or all of the following:
- Name
- Contact information
(including phone number(s), email addresses, physical addresses, etc.) - Date of birth
- Credit card or other billing information
- Profile photograph
- Further personal data associated with files that you upload, or create within the Sling application
- Log data from any of your Devices and their software, as well as your activity using the Sling application, including your Devices’ Internet Protocol (IP) addresses; type of browser; geo-location; identification data associated with your Devices; mobile carrier information; dates and timestamps associated with transactions; system configurations; metadata on files you upload or create within the Sling application; and other data related with your use of the Sling Application.
Former Application Users
Sling will preserve some or all of the following data:
- Name
- Contact information
(including phone number(s), email addresses, physical addresses, etc.) - Date of birth
- Credit card or other billing information (if you were the primary account holder)
- Profile photograph
- Further personal data associated with files that you upload, download, or create within the Sling application
- Log data from any of your Devices and their software, as well as your activity using the Sling application, including your Devices’ Internet Protocol (IP) addresses; type of browser; geo-location; identification data associated with your Devices; mobile carrier information; dates and timestamps associated with transactions; system configurations; metadata on files you upload or create within the Sling application; and other data related with your use of the Sling Application.
Website Users
In order to help us improve users’ experiences with our website, we collect a limited amount of your personal data. Such data may include some or all of the following:
- Log data, including your Devices’ Internet Protocol (IP) addresses; type of browser; the website you visited before entering Sling’s site; information you search for within Sling’s site; identification data associated with your Devices; mobile carrier information; dates and timestamps associated with transactions; system configurations; and other data related with your perusal of Sling’s website.
Phone Users
In order to improve users’ experiences with our customer service, we collect a limited amount of your personal data when you place a call to our service and sales teams. We will notify you that the call is being recorded. Some of the data we will collect include:
- Name
- Contact information (phone number(s), email addresses, physical addresses, etc.)
3. Manner of Collection
Application Users
We collect your data when you provide it to us; when we receive it from your organization, company, or other sources; when you use the Service.
- Personal data you provide to us includes data you provide when you use the Sling application; data you provide when you contact Sling via its application; data you provide when you upload or create a file on the Sling Application.
- Personal data we receive from your organization, company, or other sources includes data your company, organization, or another source provides when they use the Sling Application.
- Personal data that the Sling Application collects includes data automatically collected by the Sling Application, including log data from your Device, its software, and your activity on the Sling application. It also includes data we collect from cookies, according to the cookie settings you have set in your browser. To find out more about cookies, please see section 11.
Former Application Users
We retain some of the personal data we collected from you during the time you were an Application User. See above for more information.
Website Users
We collect a limited amount of data automatically when users visit our website. We collect some of these data via cookies, according to the cookie settings you have set in your browser. To find out more about cookies, please see section 11.
Phone Users
We collect a limited amount of data when users place a call to us by recording calls and storing information. When we do so, we notify users that we are recording their calls.
4. What Does Sling Do with Your Personal Data?
Application Users
Our primary purpose in collecting and making use of your data is to provide the Service to your company or organization. When we do so, it is on behalf of your company or organization, making us a “data processor,” according to data protection laws. As data processors, we may use your data to do the following:
- Grant you access to and use of the Sling Application
- Provide you with assistance in your use of the Sling Application
- Personalize, optimize your experience with the Sling Application
- Provide you with updates to the Sling Application
- Ensure compliance with the terms of our agreement with your company or organization
In addition to the above, we may also make use of your data for other purposes, including those not on behalf of your company or organization. When we do so, it makes us a “data collector,” according to data protection laws. As data controllers in such circumstances, we may use your data to do the following:
- Send you marketing materials and information
- Ensure compliance with relevant laws and regulations
- Establish, exercise, or defend legal claims
- Conduct analysis in order to improve the Service
We may only use your data under these circumstances if we have a legal basis for doing so. For more on this, see section 11.
Former Application Users
Once you leave your organization or company and cease accessing the Sling Application via the account associated with your former organization or company, we may retain your data within a limited iteration of your company- or organization-related profile and for our own purposes. When we do so, we are known as a “data controller,” according to data protection laws. As data controllers in such circumstances, we may use your data to do the following:
- Send you marketing materials and information
- Ensure compliance with relevant laws and regulations
- Establish, exercise, or defend legal claims
We may only use your data under these circumstances if we have a legal basis for doing so. For more on this, see 12.
Website Users
Our primary purpose in collecting and making use of your data is to improve users’ experiences with Sling’s website. When we do so, we act as a “data controller,” according to data protection laws. This data is, however, collected in an aggregate and can’t be personalized.
Phone Users
Our primary purpose in collecting and making use of your data is to improve users’ experiences with Sling’s customer service. When we do so, we act as a “data controller,” according to data protection laws.
5. Marketing
We may wish to use Application Users and Former Application Users’ personal data to inform you of and invite you to participate in our products and services.
We require your consent for certain aspects of these activities, such as those not covered under our legitimate interests. We may ask for your consent via opt-in or soft opt-in practices. “Soft opt-in” consent involves previous user engagement. We will market products and services similar to the ones you have engaged with. For “soft opt-in” consent, Sling takes your consent as given unless or until you opt out. For other kinds of marketing activities, we require your explicit consent.
We will not request your consent when sending marketing materials to a corporate or professional email address. If you would like to learn more about how Sling obtains consent, see section 12, “Legal Basis for Processing Your Personal Data.”
You have the right to opt out of receiving marketing materials and to withdraw your consent to receiving marketing materials. See section 9, “Your Rights with Regard to Your Personal Data.”
6. How Long Does Sling Keep Your Data?
Sling will only retain your data for the amount of time stipulated in the terms of your company or organization’s user agreement. The only exceptions to this rule involve regulations and legal circumstances that require us to keep your data (e.g., tax laws).
When we are no longer permitted to retain your data according to the stipulations in the terms of your company or organization’s user agreement, or when it is no longer legally necessary for us to keep your data, we will delete your personal data from our systems. When we delete your data, we attempt to do so on a permanent basis, but some information may remain in our systems for the purpose of providing the service or for legal reasons. We do not have access to that information, nor can we make use of it.
Phone Users
Recording of phone calls are retained for one year from the data of the phone call, after which they are deleted.
7. Data Sharing & Disclosure
In accordance with relevant privacy and data protection regulations, we (as “data processors”) may share your data in the following manners:
- Your use: Sling displays your personal data on your user profile page, and this information may be viewable by other users in your company or organization, depending on their access level. Furthermore, if you use any of the public or group features, such as Messages or Announcements, be aware that any data you share may be collected, stored, or used by other Sling Application users who have access to them. Your posts may remain visible even after you close your account.
- Service providers, business partners, and third parties: Sling may employ trusted third party companies, individuals, and third party service providers (including consultants and telecommunication service providers) that require access to your personal data in order to provide their services to Sling. Such companies, individuals, and providers will not be permitted to use your information for any other purposes.
- Third-Party Applications: We may share data through third-party applications that you elect to use. We maintain no responsibility for what third-party applications do with your personal data. In order to ensure that your data is in good hands, please read relevant privacy policies and proceed only if you agree with their terms of service.
- Compliance with Laws and Law Enforcement Requests: We may disclose your personal information to parties outside of Sling, including files stored in Sling’s Application when we believe in good faith that such a disclosure is reasonably necessary to comply with a law, regulation, or mandatory legal request, or to protect Sling’s intellectual property rights. In the event that we provide your files to a law enforcement agency, we will remove Sling’s encryption of those files before providing them.
- Business Transfers: If Sling is involved in a merger, acquisition, or we sell part or all of our assets, we may transfer your personal data as part of that transaction. Before doing so, we will notify your company or organization and you via email or website banner of any change in the control or use of your data, or if your data will be subject to a new or revised Privacy Policy.
- Non-Private or Non-Personal Data: We may disclose your non-private, non-personal data (e.g., usage statistics of the Sling Application).
8. Keeping Your Data Safe
Sling will take reasonable, pertinent steps to protect any personal data that we collect and store from unauthorized access, misuse, loss, and destruction. We do so by implementing a number of measures, including the encryption of the processing of credit card or other payments via secure socket technology (SSL). Furthermore, all phone call recordings that we store are encrypted, using strict access controls.
9. Your Rights with Regard to Your Personal Data
You have a number of rights related to the personal data of yours that we collect and store. To learn more about these rights, please contact us directly or your company or organization.
If you are an Application User and would like to make a request relating to our use of your personal data in the context of the Service we provide to your company or organization and for which we are a data processor, please contact your company or organization initially. If you contact us initially, we will refer you to your company or organization.
If you are an Application User and would like to make a request relating to our use of your personal data in a context outside of the Service we provide to your company or organization, or if you are a Former Application User or Website User, please contact us directly with your request.
Data protection laws outline the following rights for individuals in relation to their personal data:
- Right to object: You have the right to object to our processing your personal data.
- Right to withdraw consent: In instances in which you have consented to our processing your personal data, you may withdraw your consent at any time. We will then cease to undertake any activity or practice that you previously consented to, unless we have a legal basis or justification for the continued processing of your personal data. In that event, we will inform you of those circumstances.
- Data Subject Access Request (DSAR): You have the right to ask us to confirm the personal data we hold about you and to request that we amend, delete, or update that information. You have the right to request a copy of the information we hold about you.
- Right to erasure: You have the right to request that we delete (or “erase”) your personal data under certain circumstances. Although we may endeavor to delete your data permanently, there is a chance that some of it may continue to exist within our systems. In this event, we consider the data put beyond use, which means that your data may exist in our systems, but Sling employees will no longer be able to access or use it. However, Sling may retain and use your personal data if there is a legal basis for us to do so (i.e., if any laws or agreements require us to preserve your data). If you are an Application User who is part of a company or organization, we will not delete or amend your personal data without the consent of your company or organization.
- Right to restrict processing: You have the right to ask us to restrict our processing of your personal data under certain circumstances (e.g., if you find the information we hold to be inaccurate). In the event that we have shared your personal data with third parties, we will notify them of your request for restrictions on processing, unless it is impossible to do so or it requires unreasonably great effort. We will notify you before lifting restrictions in place on processing your data.
- Right to rectification: You have the right to ask us to rectify inaccurate or incomplete personal data that we hold about you. In the event that we have shared your personal data with third parties, we will notify them of your request for rectification, unless it is impossible to do so or it requires unreasonably great effort. You may request information related to these third parties. In the event that we do not comply with your request, we will offer our reasons for not doing so.
- Right of data portability: You have the right to request that we transfer your personal data to another third party, although this right only applies to certain types of personal data. We may transfer the data for you, or, if you prefer, we will provide you with your personal data so that you can transfer it yourself.
- Right to lodge complaints with a supervisory authority: You have the right to submit a complaint to the relevant supervisory authorities in your jurisdiction.
10. International Data Storage, Transfer, and Processing
In order for Sling to provide users with the Service, we or our third-party providers may process your personal data outside of the European Economic Area (EEA), the United States, and other territories. We aim to make sure that any international transfer of your data is conducted in a secure fashion. If you are based in the EU, Sling will only process or transfer data outside of the EEA in compliance with data protection legislation. The means of transfer and processing may include the following protective measures:
- With regard to a data transfer agreement with your company or organization, implementing the current standard contractual clauses of the European Commission for the transfer of personal data by controllers in the EEA to controllers and processors in jurisdictions without adequate data protection regulations; or
- With regard to a data transfer agreement with a third party, implementing the current standard contractual clauses of the European Commission for the transfer of personal data by controllers in the EEA to controllers and processors in jurisdictions without adequate data protection regulations; or
- Transferring your personal data to an entity that has signed up for the EU-US Privacy Shield Framework for the transfer of personal data from entities in the EU to entities in the U.S. or an equivalent agreement with respect to other jurisdictions; or
- Transferring your personal data to a country that the European Commission has deemed adequate with regard to the level of data protection laid out within its legislation; or
- Transferring your personal data to a third party when it is in your interest and in the interest of fulfilling our contract with that third party; or
- Transferring your personal data where you have consented for us to do so.
11. Cookies
Sling uses “cookies,” or small data files stored on your computer and which we have access to. We do so to gather information and improve our services. Furthermore, Sling may use “persistent cookies” to allow users to save their user IDs and passwords for ease of future logins. Sling may use “session ID cookies” to enable features of the Service, gain an understanding of how users interact with the Service, and to monitor usage and web traffic on the Service. You may program your browser to stop accepting cookies or to prompt you to opt in to cookies from websites you frequent. When you do not accept cookies, you may limit the usability of the Service.
We may track usage patterns on our website via internal and external analytic platforms (“online tracking”). We do so in order to improve the design and functionality of our Service and site.
12. Legal Bases for Processing Your Personal Data
Where we process your personal data on behalf of your company or organization, your company or organization is responsible for ensuring the legality of the data processing.
Where we process your personal data as a data controller (outside of your company or organization), it is our duty to ensure that we have a legal basis or justification for doing so. There are several possible legal bases for Sling to process your personal data, including the following:
- In the event that processing your personal data is required for Sling to carry out its obligations under the terms of any contracts between you and us. In other words, we process your personal data when it is required “for the performance of a contract to which [you] are a party.”
- In the event that processing your personal data falls within our legitimate interests. In other words, we process your personal data when it “is necessary for the purposes of the legitimate interests pursued by [us] or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of [you] which require protection of personal data.”
- We may process your personal data for the purposes of our legitimate interests to enforce the terms of our website and to analyze log data/usage statistics in order to improve the Sling Application. You have the right to object to our processing your personal data on this basis (see section 9).
- In the event that you give us consent to process your personal data.
Where we seek out your consent prior to engaging in personal data processing, you must give us your consent freely, without our pressuring you to do so. You must be asked to give your consent to one processing act at a time and you have to know what you are consenting to, so we must provide you with relevant information. You must take positive, affirmative action in consenting to our processing of your personal data (e.g., by checking a box). We will obtain your consent before sharing your personal data with third party applications or undertaking certain marketing activities.
You have the right to withdraw your consent to personal data processing activities. See section 9, “Your Rights with Regard to Your Personal Data.”
Under certain circumstances, you have the right to object to our processing of your personal data. See section 9, “Your Rights with Regard to Your Personal Data.”
13. Further Information
If you have any questions regarding Sling’s Privacy Policy or if you would like to exercise your legal rights, please contact privacy@getsling.com. Please put forth your concerns in a clear manner, and a member of our team will contact you.