Effective Date: April 4, 2016
Last Updated: June 18, 2020
1. Types of Personal Information Collected
We collect a range of Personal Information. “Personal Information” is information that identifies, relates to, describes, or is reasonably capable of being associated with or linked to an individual. When we combine Personal Information with other information (i.e., information that does not, on its own, identify you), we treat the combined information as Personal Information.
Information you provide – When using the Platform, you may provide information about yourself. This may include your name and email address when signing up for our mailing lists and your name, email address, and/or phone number when contacting us with requests. Additionally, if you apply for employment with us, you will provide demographic information, as well as your education and employment history. Finally, if you create an account with us, you will create and provide us with a username and password and may upload other Personal Information through our customer portal.
Location Data – While navigating our website, your desktop, tablet, phone, or other mobile device may share your location data, both through WiFi and GPS. We will collect this information based on the settings of your device.
Usage Information – We may also collect usage and device information when you visit our Platform. This may include information about the browser, operating system, and/or device identifier for the device you are using, your ISP and IP information, as well as the websites that you came from and the site you visit when you leave.
2. Method of Information Collection
We collect Personal Information in a variety of ways. We collect information directly from you; for example, when you register an account on the Platform or correspond with us through the Platform.
We also collect information from third parties. For example, we work with business partners, subcontractors in technical and delivery services, advertising networks, analytics providers, and search information providers.
We also collect information from you passively. Our Platform uses tracking tools like cookies, pixels, and web beacons. We do this both on our Platform and in emails that we send to you. Through these tools we collect information about users over time when you use our Platform. This collection includes usage and browser information. We may also have third parties collect Personal Information in this way. For more information about the trackers that we use, please see Section 6 of this Policy. Additionally, if you enable location data on your device, this data will be collected passively based on the location settings on your device.
3. Combining Information
We may combine Personal Information we obtain. For example, we may combine information that we have collected online with information that we have collected offline; for instance, during your interactions with our staff by phone or in person. We may also combine information that we have collected across other third-party sites or from other third parties with information we already have. Finally, we combine information across devices.
4. How We Use Personal Information
We may also use your Personal Information to improve our Platform and services and for security purposes to protect our company, the Platform, and our customers. This may include using your information to customize your experience with us.
We may also use your information for marketing purposes. For example, we may send you information about new features on the Platform, new services we offer, and special offers.
Finally, we may use your information for other purposes, as permitted by law.
5. Sharing Personal Information
We may share your Personal Information in the following circumstances:
• Within the Structure Tone Organization – We may share your Personal Information within our family of companies.
• Service providers to the Structure Tone Organization – When we hire a service provider to help operate the Platform or our business, we may give access to Personal Information as necessary to perform the service for us.
• Merger or sale – If and when the Company is involved in a merger, acquisition, or any form of transfer or sale of some or all of its business, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding. Personal Information may be transferred along with the business.
We do not share Personal Information with third parties for their marketing purposes.
6. Cookies and Other Technologies
We collect information about users over time on the Platform by using several common types of cookies and other tracking technologies including web beacons, pixels, and flash cookies. We also have third parties that collect information in this way on our behalf and for their own purposes. Cookies are small files that download when you access certain websites. For more information about cookies, visit: http://www.allaboutcookies.org/Go to http://www.allaboutcookies.org/. Web beacons, pixels, and other tracking technologies operate independent of cookies.
To assist us with analyzing our website traffic through cookies and similar technologies, we use analytics services such as Google Analytics. For more information on Google Analytics’ processing of your information, please see “How Google uses information from sites or apps that use our services.” Go to http://www.google.com/policies/privacy/partners/You can opt out of Google Analytics by installing Google’s opt-out browser add-onGo to https://tools.google.com/dlpage/gaoptout.
We may use a variety of cookies:
Type of Cookies & Description
Required – Required cookies are essential for the Platform to function properly and for you to navigate our Platform and use its features, such as accessing secure areas of the Platform and using our services.
Performance – These cookies collect information about how you use the Platform, including which pages you go to most often and if you receive error messages from certain pages. These cookies do not collect information that individually identifies you. All information these cookies collect is aggregated and anonymous. It is only used to improve how the Platform functions and performs.
Functionality – Functionality cookies allow the Platform to remember information you have entered or choices you make (such as your username, language, or your region) and provide enhanced, more personal features. These cookies also enable you to optimize your use of the Platform after logging in. These cookies can also be used to remember changes you have made to text size, fonts, and other parts of web pages that you can customize.
By way of example, as you visit the Platform, advertising cookies may be placed on your computer so that we can understand what you are interested in. Our advertising partners then enable us to present you with retargeted advertising on other sites based on your previous interaction with the Platform.
Third parties, with whom we partner to provide certain features on the Platform or to display advertising based upon your web browsing activity, use Flash cookies to collect and store information. Flash cookies are different from browser cookies because of the amount of, type of, and how data is stored.
You can control cookies and tracking tools. Some browsers have a “do not track” feature that prevents a website from tracking you, as well as additional cookie settings. Our Platform does not currently respond to these signals. If you choose to block cookies and other trackers, certain features of the Platform may not work. Blocking or rejecting cookies will not stop all of the tracking described in this Policy. These features and options are browser- and device-specific and are not uniform. You can usually find these settings in the options or preferences menu of your browser. To understand these settings, the following links for commonly used browsers may be helpful, or you can use the Help option in your browser for more details:
• Cookie settings in Internet ExplorerGo to https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies#ie=ie-10
• Cookie settings in FirefoxGo to https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer?redirectlocale=en-US&redirectslug=Cookies
• Cookie settings in ChromeGo to https://support.google.com/chrome/answer/95647?hl=en&ref_topic=14666
• Cookie settings in Safari webGo to https://support.apple.com/en-gb/guide/safari/sfri11471/mac and iOSGo to https://support.apple.com/en-us/HT201265.
To find out more on how to manage and delete cookies, visit aboutcookies.orgGo to http://aboutcookies.org. For more details on your choices regarding use of your web browsing activity for interest-based advertising you may visit the following sites:
• networkadvertising.orgGo to http://networkadvertising.org
• optout.aboutads.infoGo to http://optout.aboutads.info
• youradchoices.comGo to http://youradchoices.com
• youronlinechoices.euGo to http://youronlinechoices.eu
On a mobile device, you may also be to adjust your settings to limit ad tracking.
7. Your Choices
You have certain choices about how we use your Personal Information. You can opt out-out of certain marketing. To opt-out of marketing communications, please email us at email@example.comGo to mailto:firstname.lastname@example.org or by following the instructions included in the email or text correspondence. Please note that, even if you unsubscribe from certain correspondences, we may still need to contact you with important transactional or administrative information, as permitted by law.
8. Children Under the Age of 13
The Platform is meant for adults and we will not knowingly collect personally identifiable information from any person under the age of 13 without permission from a parent or guardian. The Platform is not designed to attract the attention of persons under the age of 13. If you are a parent or legal guardian and think your child has given us information you can email us at email@example.comGo to mailto:firstname.lastname@example.org. You can also write to us at the address listed in the “Contact Us” section of this Policy. Please mark your inquiries “COPPA Inquiry.”
9. California Privacy Rights
Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), California residents have certain other rights concerning their personal information. This section describes (1) the categories of personal information, collected and disclosed by the Company, subject to California privacy law, (2) your privacy rights under California privacy law, and (3) how to exercise your rights.
When we use the term “personal information” in this section, we mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
a. Personal Information We Collect
If you are a California consumer, please be aware that we collect, process, and maintain personal information to fulfill certain business purposes related to our Platform. We will not collect additional categories of personal information or use personal information collected for additional purposes without providing you notice. Within the preceding twelve (12) months, we and our service providers have and may collect, and you may consent to provide, the categories of personal information set forth below. We disclose each of these categories of personal information with our service providers for our business purposes (to enable the service providers to provide their services) and as otherwise described in the “Sharing Personal Information” section above.
• Identifiers (for example, name, postal address, date of birth, email address, IP address, and online identifiers);
• Categories of personal information as defined by Cal. Civ. Code § 1798.80 (for example, name, signature, taxpayer Identification Number, telephone number, passport number, driver’s license number, insurance policy number, account numbers);
• Commercial information (for example, transaction history);
• Internet or other electronic network activity information, including information on your usage of our Sites;
• Geolocation data;
• Sensory data (for example, audio from call recordings);
• Inferences drawn from any information identified above to create a profile
b. Your Privacy Rights.
In accordance with the CCPA, California consumers may exercise under certain conditions the following four (4) categories privacy rights with respect to their personal information. Please note: you will not be discriminated against in any way by virtue of your exercise of the rights listed below, which means we will not deny goods or services to you, provide a different prices or rates for goods or services to you, or provide a different level or quality of goods or services to you.
Privacy Right & Description
Notice – You have the right to be notified of what categories of personal information will be collected at or before the point of collection and the purposes for which they will be used and shared.
Access – You have the right to request the categories of personal information that we collected in the previous twelve (12) months, the categories of sources from which the personal information was collected, the specific pieces of personal information we have collected about you, and the business purposes for which such personal information is collected and shared. You also have the right to request the categories of personal information which were disclosed for business purposes, and the categories of third parties in the twelve (12) months preceding your request for your personal information.
Data Portability – You have the right to receive the personal information you have previously provided to us.
Erasure – You can request to have your personal information deleted from our servers and we will direct our service providers to do the same. However, please be aware that we may not fulfill your request for deletion if we (or our service provider(s)) are required to retain your personal information for one or more of the following categories of purposes: (1) to complete a transaction for which the personal information was collected, provide a good or service requested by you, or complete a contract between us and you; (2) to ensure our website integrity, security, and functionality; (3) to comply with applicable law or a legal obligation, or exercise rights under the law (including free speech rights); (4) to otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
To Opt Out – You can request to opt out of us selling your personal information. To exercise this right please click hereGo to https://structuretone.com/, click on the “Privacy” button in the lower left-hand corner, select “Do Not Sell My Personal Data,” and follow the instructions to submit your request.
c. How to Exercise Your Rights
If you would like to exercise your rights listed above, please send (or have your authorized agent send) an email to email@example.comGo to mailto:firstname.lastname@example.org or call us toll-free at 833.903.2575. You have a right not to receive discriminatory treatment by any business when you exercise your CCPA rights.
While we take measures to ensure that those responsible for receiving and responding to your request are informed of your rights and how to help you exercise those rights, when contacting us to exercise your rights, we ask you to please adhere to the following guidelines:
• Tell Us Which Right You Are Exercising: Specify which right you want to exercise and the personal information to which your request relates (if not to you). If you are acting on behalf of another consumer, please clearly indicate this fact and your authority to act on such consumer’s behalf.
• Help Us Verify Your Identity: Provide us enough information to verify your identity. For example, provide us (at a minimum) your full name, address, and phone number. Please note that if we cannot initially verify your identity, we may request additional information to complete the verification process. Any personal information you disclose to us for purposes of verifying your identity will solely be used for the purpose of verification.
• Direct Our Response Delivery: Inform us of the delivery mechanism with which you prefer to receive our response. You may specify, for example, email, mail, or through your account (if you have one with us).
Please note that you don’t need to create an account with us in order to make a request to exercise your rights hereunder.
d. How We Respond to Your Requests
In all cases, we will respond to your request within 45 days. However, where reasonably necessary, we may extend our response time by an additional 45 days, provided we send you notice of such extension first. We will provide the information to you via your preferred delivery mechanism. If the information is provided to you electronically, we will provide you the information in a portable format and, to the extent technically feasible, in a machine readable, readily useable format that allows you to freely transmit this information without hindrance.
Please note that we will not charge you for making a request, provided that you make no more than two (2) requests per year. If you make three (3) or more requests in any given twelve (12) month period, we may refuse to respond to such requests, if determined by us to be unfounded or excessive (e.g., repetitive in nature), or we may charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested. If we refuse to act on the request, we will provide you notice and the reason for our refusal to act.
10. Information for Individuals in the EU
In accordance with the General Data Protection Regulation (“GDPR”), individuals in the EU have additional rights relating to the collection and processing of personal information. If you need more information or would like to exercise your rights under the GDPR, you may contact us at email@example.comGo to mailto:firstname.lastname@example.org.
a. Basis for Processing
• where we need it to perform a contract with you;
• where the processing is in our legitimate interests (including the purposes described, above, in How We Use Personal Information); or
• if we otherwise have your consent.
b. Your Privacy Rights
Depending on applicable law, you may have the right to:
• Request access to Personal Information about you.
• Request correction of the Personal Information that we hold about you.
• Request erasure of Personal Information about you. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request.
• Object to processing of Personal Information about you where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation that makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
• Request restriction of processing of Personal Information about you. You can ask us to suspend the processing of Personal Information in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of Personal Information to you or to a third party.
• Withdraw consent at any time where we are relying on consent to process Personal Information about you.
If you wish to exercise any of these applicable rights, please contact us at email@example.com.Go to firstname.lastname@example.org
Depending on where you live, you may have a right to lodge a complaint with a supervisory authority or other regulatory agency if you believe that we have violated any of the rights concerning Personal Information. We encourage you to first reach out to us at email@example.comGo to mailto:firstname.lastname@example.org, so we have an opportunity to address your concerns directly before you do so.
11. Storage, Security, and Retention of Information
We have taken reasonable steps to protect the information users share with us, including, but not limited to, setup of processes, equipment, and software to avoid unauthorized access or disclosure of this information. No transmission of information via the internet can be entirely secure, however, so please always use caution when submitting Personal Information. We will retain your Personal Information in compliance with the uses described in this policy, as well as to comply with our legal, financial reporting, or compliance obligations.
We store information both inside and outside the United States. If you live outside of the United States, be advised that we may transfer and store your information to the United States. US law may not provide the same protections as the laws in your country. By providing us with your personal information you agree to the processing of it in the United States as permitted by US law. Information transferred from the EU will be subject to the appropriate safeguards pursuant to GDPR and other applicable law.
12. Links to Third Parties and their Sites
Our Platform may include third-party content and links to third-party websites and services that collect Personal Information. We do not control these third parties, and this Policy does not apply to their privacy practices. We are not responsible for the practices of these third parties or how they use information you provide to them. Please read the third parties’ privacy policies carefully.
13. Contacting the Structure Tone Organization
Structure Tone Organization
330 W. 34th St.
New York, NY 10001
Please note that this Policy may be amended from time to time. Unless otherwise indicated, any changes to this Policy will apply immediately upon posting to the Platform so please check our Site periodically for updates. You can see when this Policy was last updated by reviewing the “Last Updated” legend at the top of this page. We will provide notice of material changes by updating the Policy here and communicating with you in the manner and format in which we typically communicate with you in our regular course of business, as required by applicable law.