Privacy policy

Structure101 Privacy Policy

VERSION 1.0, LAST UPDATED: MAY 24, 2018

 

In this Privacy Policy, we describe the type of data, including personal data (collectively, “data”), that we collect from you when you use our websites and our Structure101 products and services as described in this Privacy Policy (collectively, our “services”), how we use and disclose that data, and your options to access or update your data.

This Privacy Policy may be amended from time to time. The respective latest version of the Privacy Policy at the point of time of the purchase or registration of a Structure101 Software Product (whichever occurs later) shall apply. The data controllers are Headway Software Technologies Ltd, t/a Structure101, Coxtown, Dunmore East, Co. Waterford, Ireland.

Structure101 acts as data controller, and are responsible for compliance with data protection legislation. Structure101 is primarily responsible for exercising of rights of data subjects and providing information about data processing.

Definitions

The following definitions are used throughout this Privacy Policy:

Structure101 Software Product. Any software product owned or created by Structure101 and provided under Structure101’s End User License  Agreement or other Structure101 Agreement EXCLUDING software that can be used by Structure101 software products but is not created by Structure101. This may include, but not be limited to, code that extends the functionality of a Structure101 software product (e.g., a “flavour”). Any such code is governed by its own terms and conditions and privacy policy.

Structure101 Downloadable Software Product. Any Structure101 Software Product that can be downloaded and installed on a device.

Structure101 Website. Any website that is the property of Structure101, including but not limited to everything hosted under the top-level domain Structure101.com.

Structure101 Terms of Use means Structure101 End User License Agreement, or other agreement you have in place with Structure101 covering Structure101 Products or services.

Structure101 Software Products, Structure101 Downloadable Software Products, and Structure101 Website may be collectively referred to as “Structure101 Products“.

Personal Data means any data relating to an identified or identifiable natural person.

 

Why We Collect Data and What We Collect

We collect data for various reasons, such as:

a) To provide you with software, services, or information. We may collect data which are required to provide you with the software, support, and services, including checking for license validation and updates, provision of support, reporting of issues and bugs, and other processing connected with use of Structure101 software, services, or information. You explicitly fill in the data required for you to receive the software, support, or services, whether you purchase or use Structure101 Products, use our support, register for a webinar, participate in a survey, and/or subscribe to receive marketing and/or technical information and content, or these data are collected in the course of use of Structure101 Products. We may use third-party service providers, acting as data processors, to assist us in provisioning Structure101 Products to you or in our operations. For example, we may use third-party service providers to provide data storage and backup services. . The legal basis for this data processing is performance of contract between you and us.

b) To protect us from piracy and unlawful use of our software or services. We may collect data which are required to protect us from any piracy, unlawful, or unauthorized use of our software or services, or which are necessary to ensure security of our software or services, including both data provided by you (see above) and data collected in the course of use of Structure101 Products. The legal basis for this data processing is Structure101s legitimate interest in protection from piracy and unlawful use of Structure101 software and services.

c) To improve our offerings based on usage. We may collect data based on your use of Structure101 Products and services. We use these data to manage access to Structure101 Software and better understand usage patterns of our products and behavior of our collective audience. We share this information with third party processors. The legal basis for this data processing is our legitimate interest in software license management, as well as improving our software and services.

d) For internal evidence of Structure101 and to protect the rights and interests of Structure101 and other users. We may collect data which are required to keep evidence of provision of software and services to you, of any communication between you and us, of your contact details, of your use of our software and services, of any payments, refunds, and of any issues or disputes between you and us. We may use and disclose these data where we believe, in our sole judgment, that it is legitimate and appropriate to do so to protect our rights and interests and the rights and interests of other users of Structure101 Products or services, or where we believe there has been a violation of this Privacy Policy that could affect the interests of Structure101 or its customers. The legal basis for this data processing is our legitimate interest in keeping internal evidence and protecting the rights and interests of us and other users.

e) To promote and market our products and services. We may use feedback that you provide voluntarily on our products or services. As permitted by applicable law, we may use this in the form of quotes or in other ways in accordance with the Structure101 Terms of Use. We also may use data that we collect and aggregate to assist us in determining appropriate marketing and advertising for our products and services. In doing so, we may share anonymous aggregated data with third parties to assist us with these efforts. With your consent or if permitted by applicable law, we may also use your contact details to send you commercial communications about our products and services. We also may use third-party service providers to assist us with our email marketing; in that case, the third-party service provider will have access to your email address, your name, and other information necessary to engage in the marketing. Such third-party service provider will act as a data processor and will not use your data for any other purpose. The legal basis for this data processing is our legitimate interest in promoting and marketing our products and services.

f) To fulfil legal duties stipulated by accounting, taxation and other laws. We may use and disclose your personal data where required by law, such as in keeping and disclosing our accounts, in keeping and disclosing our tax records, and in response to a court order, valid subpoena, or other legal process. The legal basis for this data processing is our compliance with our legal obligations.

 

You may object to the processing of your personal data for the purposes b) to e) at any time.

 

Categories of data involved in data processing include:

  • name
  • email address
  • job title
  • company
  • phone number
  • cookies
  • IP address
  • physical (company) address
  • information about subscription and payments
  • VAT ID.

Where appropriate, we will prompt you to give us your consent to the collection and processing of your data as described above. This may happen within Structure101 Products, on Structure101 Website, or in another environment set up by Structure101, always in a clear and conspicuous manner. You can manage your data and opt-outs as described in the Transparency section below.

How we collect your data

  • Information you provide when you download our products
  • Information you provide for licensing registration purposes
  • Information you provide when you contact us for administrational, product inquiry or support, sales inquiry, or any other reason
  • Publicly available information on professional profile websites, such as LinkedIn & Xing

We may augment this with publicly available data in order to create a more complete customer profile and provide a better customer support. “Public Data” is defined as information received from a third party partner named FullContact. Public Data may be claimed, edited or discarded from their systems and is subject to their privacy policy.

No special categories of personal data: We do not require or collect any personal data that is your sensitive personal data or any special category of personal data under the GDPR

Children

Our products and services are not designed for and are not offered to children under the age of 16. If we discover that a person under the age of 13 has submitted information directly to us, we will endeavor to delete the information from our systems.

Transparency

To respect your privacy, before usage of your personal data, we will inform you about the categories of data we collect and the purposes we use it for. Should you wish to access your data, please email us at privacy@structure101.com..

Personal Data

In connection with your use of the Site, Structure101 will process Your personal data for the following purposes:

a) To provide you with software, services, or information; for this purpose, mainly (i) your contact details and information from your posts, (ii) IP address and environment data, and (iii) data collected by cookies or other tracking technologies will be used.

b) To protect Structure101 from piracy and unlawful use of Structure101 software or services; for this purpose, mainly (i) IP address and environment data and (ii) data collected by cookies or other tracking technologies (including clear GIFs, pixel tags, and other technologies) will be used.

c) To improve Structure101 offerings based on usage; for this purpose, mainly (i) your contact details, and information from your posts, (ii) IP address and environment data, and (iii) data collected by cookies or other tracking technologies (including clear GIFs, pixel tags, and other technologies) will be used.

d) For internal evidence of Structure101 and to protect rights and interests of Structure101 and other users; for this purpose, mainly (i) data collected by cookies or other tracking technologies, (ii) audit records, application logs, weblogs, and/or backups will be used.

e) To promote and market Structure101 software and services; for this purpose, mainly (i) your username, contact details and information from your posts, (ii) IP address and environment data and (iii) data collected by cookies or other tracking technologies (incl. clear GIFs, pixel tags and other technologies and third-party cookies) will be used.

f) To provide third parties with information about Your use of the Site; for this purpose, mainly data collected by cookies or other tracking technologies will be used.

g) To fulfil legal duties stipulated by accounting, taxation and other laws.

Further, third parties listed in the third-party service provider will process your personal data, in particular data about your usage of site, to promote and market Structure101 software and services.

You may object to processing of your personal data for the purposes b) to e) at any time.

You may also withdraw your consent to processing of your personal data at any time when the processing is made based on consent. The withdrawal of consent will not affect the lawfulness of processing before the withdrawal.

IP address and environment data

Weblogs that may be generated during your use of Structure101 Website may include information about IP addresses used to access the service, browser, operating environment, Uniform Resource Locators (URLs) used to access the service, or other information. Cookies and Other Tracking Technologies

We, and our third party service providers, use cookies and other tracking technologies (“Cookies”) on our Website and client portals (collectively our “Website”). We use Cookies to identify you when you visit our Website, to deliver our products and services to you, to provide you with a service when you browse our Website and to improve our Website and the services that we provide (“Service Purposes”). With your consent, we may also use Cookies, for analytics purposes and for targeted advertising (“Commercial Purposes”). YOUR CONSENT/WITHDRAWING CONSENT

You acknowledge that the Site will use Cookies as explained above for the Service Purposes. If you provide us with your consent to use Cookies also for Commercial Purposes, then you can withdraw your consent at any time by emailing privacy@structure101.com.

If you do not wish Cookies to be stored on your device in connection with your use of this Website, you must stop using our Website and disable Cookies via your browser settings for this Website or globally (see below). Please note that disabling Cookies will affect the functionality of our Website, products and services, and may prevent you from being able to access certain features on our Website, products or services. For further information about deleting or blocking Cookies, please visit: http://www.aboutcookies.org/how-to-delete-cookies/.

 

THE TECHNOLOGIES WE USE

Cookies. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies as soon as you visit our Website. There are two types of cookies:

Persistent cookies: these cookies remain on a user’s device for the period of time specified in the cookie. They are activated each time that the user visits the website that created that particular cookie.

Session cookies: these cookies allow website operators to link the actions of a user during a browser session. A browser session starts when a user opens the browser window and finishes when they close the browser window. Session cookies are created temporarily. Once you close the browser, all session cookies are deleted.

Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Website to, among other things, track the activities of Website visitors, help us manage content, and compile statistics about Website usage. We and our third party service providers also use clear GIFs in HTML emails to our customers, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our emails are forwarded.

 

FIRST AND THIRD-PARTY COOKIES

In relation to whether a cookie is ‘first’ or ‘third’ party refers to the domain placing the cookie.

First-party cookies are those set by a website that is being visited by the user at the time (e.g., cookies placed by us). Cookies placed by Structure101 are used when creating an account, identifying yourself using Structure101 Account, purchasing products using the e-store, as well as using any of our services, including but not limited to, our issue tracker, blogs and discussions forums, newsletter sign-up, etc. At times we may also use cookies for testing out new features of our web site and/or services to a subset of our audience.

Third-party cookies are cookies that are set by a domain other than that of the website being visited by the user. If a user visits a website and another entity sets a cookie through that website, this would be a third-party cookie.

 

HOW TO DELETE AND BLOCK OUR COOKIES

You can block Cookies by activating the setting on your browser that allows you to refuse the setting of all or some Cookies. However, if you use your browser settings to block all Cookies (including essential Cookies for the Website to work), you may not be able to access all or parts of our Website, products or services. Unless you have adjusted your browser setting so that it will refuse Cookies, our system will issue Cookies as soon as you visit our Website.

 

WHAT COOKIES DO WE USE AND WHY?

Generally our Website uses Cookies to distinguish you from other users of our Website.

‘Performance’ Cookies collect information about how you use our Website e.g. which pages you visit, and if you experience any errors. These Cookies are only used to help us improve how our Website works, understand what interests our users and measure the effectiveness of our advertising. We use performance Cookies to:

  1. Carry out web analytics: Provide statistics on how our Website is used
  2. Obtain data on the number of users of the Website that have viewed a product
  3. Help us improve the Website by measuring any errors that occur
  4. Test different designs for the Website

Some of our performance Cookies are managed for us by third parties. We do not allow the third party to use the Cookies for any purpose other than those listed above.

‘Functionality’ Cookies are used to provide products or services or to remember settings to improve your visit. We use ‘Functionality’ Cookies for such purposes as:

  1. Remember settings you’ve applied such as layout, text size, language, preferences and colors
  2. Remember if we’ve already asked you if you want to fill in a survey
  3. Remember if you have engaged with a particular component or product list on the Website so that don’t show it again
  4. Show you when you’re logged in to the Website
  5. To provide and show embedded video content

Some of these Cookies are managed for us by third parties. We do not allow the third party to use the cookies for any purpose other than those listed above.

If you are in the EU, you may opt-out of certain third party Cookies that we and other websites may use for targeting through http://www.youronlinechoices.eu or www.aboutads.info. Opting out of one or more ad networks only means that those particular members no longer will deliver targeted content or ads to you. It does not mean you will no longer receive any targeted content or ads on our websites or other third party websites. If your browser is configured to reject Cookies when you visit one of the above referenced opt-out pages, and you later erase your Cookies, use a different computer or change Web browsers, your preference may no longer be active. Since all of these Cookies are managed by third parties, you should refer to the third parties’ own website privacy notifications and policies for further information (see below for more information about the particular targeting Cookies used on our Website).

Users in the United States may opt out of many third-party ad networks. For example, you may go to the Digital Advertising Alliance (“DAA”) Consumer Choice Page for information about opting out of interest-based advertising and their choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative (“NAI”) Consumer Opt-Out Page for information about opting out of interest-based advertising and their choices regarding having information used by NAI members.

Opting out from one or more companies listed on the DAA Consumer Choice Page or the NAI Consumer Opt-Out Page will opt you out from those companies’ delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Website or on other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject Cookies when you opt out on the DAA or NAI websites, your opt out may not be effective. Additional information is available on the DAA’s website at www.aboutads.info or the NAI’s website at www.networkadvertising.org.

 

DO NOT TRACK

Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking by disabling cookies in your browser. However, by doing so we cannot guarantee the correct behaviour of the services we provide to you.

 

LINKS

At times Structure101′ websites and/or Structure101 software products may contain links to other external non-Structure101 sites. Structure101 is not responsible for the privacy practices or content of such linked websites.

Sharing

Collected personal data are shared based on End User License Agreement, Terms of Use of a product or service in use, and this Privacy Policy.

According to Structure101 Terms of Use covering a particular product or service, as part of the product or service functionality, collected personal data may be shared with other representatives of your company.

We may share your data with certain third parties which help us provide you with Structure101 Products or services, or to run our business, for example to providers of data storage and backup services. We may also share your data with individual representatives of your company.

Your personal data may also be shared with other organizations or individuals if we have obtained your consent to do so.

We may also share your data with certain third parties if we are obliged to do so under applicable legislation (especially with tax authorities or with other government bodies exercising their statutory powers) or if such sharing is necessary to achieve the purposes defined above (especially with government bodies or with parties harmed by your illegal acts, if applicable).

Security

To secure your personal data, our products and services are designed with security and privacy in mind.

We encrypt your data in transfer and at rest where it is technically feasible. External web resources are protected by SSL encryption.

We review the processes of personal data usage before implementing them. This is done to minimize data usage and to make sure that you as the data owner is informed about the processing. When the reason for data storage expires, we remove your personal data from our servers or anonymize it for further usage. By the nature of the activity within which your data is collected, it may appear in datasets used for research. Before using the datasets for research or other purposes you are not informed of, we remove or anonymize your personal data in the datasets.

We use partners to host our services and websites and to process your data in accordance with this Privacy Policy. While choosing the partners, we ascertain their compliance with legal regulations and security standards to make sure your data are stored in a secure location with appropriate security measures in place.

Location of Your Information

Personal Data may be transferred to our trusted partners and service providers who maintain their servers outside of the European Economic Area (“EEA”), where the privacy and data protection laws may not be as protective as those in your jurisdiction. This is only for the purposes of providing, and to the extent necessary to provide, the Services to you. There are special requirements set out under Chapter V of the GDPR (with which we would comply) to regulate such data transfers and ensure that adequate security measures are in place to safeguard and maintain the integrity of your personal data on transfer. For more information about this and the safeguards in place relating to the transfer, please contact us by email at privacy@structure101.com.

Data retention, withdrawal of approval, access to data and your rights

If at any time you choose to cease using Structure101 Products, you may ask for your data to be removed from our servers by sending a request to privacy@Structure101.com. After the data removal, we may keep pseudonyms of your personal data solely for a record about the data removal. Generally, we retain your data as long as we need to in order to achieve the purpose for which it was collected. We may retain your information if it is required to comply with legal obligations and/or defense in case of violation of Structure101 Terms of Use and/or Privacy Policies. We may also have copies of your information in application logs, weblogs, and/or backups made for security and support purposes if this is mentioned in a Structure101 Terms of Use or consent text accepted before the personal data collection. Please note, however, that you must retain a copy of all data that you have placed on our servers in the case of any loss; further, if you cease using our software and/or services, we will not be responsible for retention of any of your data.

As permitted by applicable law, EU residents may request a copy of the information that we hold about them. To do so, please contact privacy@Structure101.com. We may charge a fee in accordance with applicable law for this service.

Moreover, as set out in locally applicable personal data protection law, you may have the right to: (i) request access to your personal data; (ii) request rectification of your personal data; (iii) request erasure of your personal data; (iv) request a restriction on the processing of your personal data; (v) request personal data portability; or (vi) object to the processing of your personal data.

  • Right of access. You may have the right to obtain from us a confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, to request access to your personal data. The information about personal data processing includes the purposes of the processing, the categories of personal data concerned, and the recipients or categories of recipient to whom your personal data have been or will be disclosed, etc. However, this is not an absolute right and the interests of other individuals may restrict your right of access. Further, you may have the right to obtain a copy of your personal data undergoing processing. For additional copies requested, we may charge a reasonable fee based on administrative costs.
  • Right to rectification. You may have the right to obtain from us the rectification of inaccurate personal data. Depending on the purposes of the processing, you may have the right to have incomplete personal data made complete, in particular by providing a supplementary statement.
  • Right to erasure (right to be forgotten). Under certain circumstances, you may have the right to require us to delete your personal data.
  • Right to a restriction on processing. Under certain circumstances, you may have the right to require us to restrict the processing of your personal data. In this case, the respective personal data will be marked and may only be processed by us for certain purposes.
  • Right to personal data portability. Under certain circumstances, you may have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used, and machine-readable format, and to transmit these personal data to another entity.
  • Right to object. Under certain circumstances, you may have the right to object, on grounds relating to their particular situation, at any time to the processing of your personal data by us and we can be required to no longer process your personal data.

These rights can be exercised via the email address privacy@Structure101.com.

You may also contact Structure101 to get up-to-date information about your personal data processing and any personal data recipients.

 

You may lodge a complaint related to the processing of your personal data with the competent data protection supervisory authority, i.e. in Ireland:

Data Protection Authority of Ireland:
Data Protection Commissioner
Canal House
Station Road
Portarlington
Co. Laois
Lo-Call: 1890 25 22 31
Tel. +353 57 868 4800
Fax +353 57 868 4757
e-mail: info@dataprotection.ie
Website: http://www.dataprotection.ie/

Changes to this Policy

This Privacy Policy is current as of the Effective Date set forth above. We may change this Privacy Policy from time to time, so please be sure to check back periodically. We will post any changes to this Privacy Policy on the Structure101 Website. If we make any changes to this Privacy Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with an advance notice of such change by highlighting the change on Structure101 Website.

Contact

If you have any questions or concerns, or feedback on this Privacy Policy, or you feel that this Privacy Policy has been violated in any way, please let us know immediately by contacting privacy@Structure101.com.