VERSION 1.0, LAST UPDATED: MAY 24, 2018
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.
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 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.
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:
- email address
- job title
- phone number
- 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
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
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.
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 email@example.com..
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
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
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.
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
WHAT COOKIES DO WE USE AND WHY?
‘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:
- Carry out web analytics: Provide statistics on how our Website is used
- Obtain data on the number of users of the Website that have viewed a product
- Help us improve the Website by measuring any errors that occur
- 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:
- Remember settings you’ve applied such as layout, text size, language, preferences and colors
- Remember if we’ve already asked you if you want to fill in a survey
- Remember if you have engaged with a particular component or product list on the Website so that don’t show it again
- Show you when you’re logged in to the Website
- 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.
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.
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).
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.
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 firstname.lastname@example.org.
Data retention, withdrawal of approval, access to data and your rights
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
Lo-Call: 1890 25 22 31
Tel. +353 57 868 4800
Fax +353 57 868 4757
Changes to this Policy