Privacy Policy - Structure Tone
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Privacy Policy - Structure Tone
Structure Tone Privacy Policy
Structure Tone Privacy Policy
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Website Privacy Policy

Structure Tone (“we”, “our,” or “Structure Tone”) is committed to protecting and respecting your privacy including when you visit our website, https://structuretone.com (the/our “Website”). This policy sets out the basis on which any Data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your Data and how we will treat it.

Data is any information which is being processed by means of equipment operating automatically in response to instructions given for that purpose, is recorded with the intention that it should be processed by means of such equipment, or is recorded as part of a relevant filing system or with the intention that it should form part of a relevant filing system. It need not be held on a computer. Data consist of two subsets: “Personal Data” and “Other Data.” “Personal Data” is any information that we could use to identify an individual. It does not include personal information that is encoded or anonymized, or publicly available information that has not been combined with non-public information. Personal Data may include order numbers, location data, names, ages, dates of purchase, purchase information, card information, phone numbers, email addresses, physical addresses, and similar data types. “Other Data” means any other Data that is not “Personal Data.”

For the purpose of the UK Data Protection Act 1998 or any replacement legislation, including the EU General Data Protection Regulation (together, the “Data Protection Legislation”), the data controller is Structure Tone Ltd of 1st Floor, 77 Gracechurch St, London EC3V 0AS.

This website privacy policy covers:

Section No.
 1.  The Data that we collect from you
 2.  Data that we receive from other people
3.  Our use of your Data
 4.  How we might share your Data and Personal Data
5.  Our security, any transfers we make outside of the EEA, and our data retention measures
6.  Your rights in respect of your Data and third-party websites
7.  Your California Privacy Rights
8.  Accessing and updating your Personal Data
9.  Changes to our privacy policy
10.  Our contact information

 

1. DATA THAT WE COLLECT FROM YOU

When you visit our Website you have the option to provide your name and email address. We may also collect information about you, your work history, and/or your usage of our Website if you send us a resume or CV. We may also log general information about your browser whenever you visit our Website. This information may include your computer’s Internet Protocol (IP) address, your browser type and version, the pages you visit on our site, the time and date of your visit, and the time spent on each page. Like most website operators, we collect this data to better understand how our visitors use our services, and how we may improve your experience of our Website in the future.

Some of the above Data may be collected and processed for the purpose of legal compliance; some to perform a contract with you or your employer; and some for the purposes of our legitimate business interests (subject to your rights (e.g., to analyze the use of our Website and services in order to continually improve our services)).

2. DATA THAT WE RECEIVE FROM OTHER PEOPLE

We work closely with third parties (including, for example, business partners, subcontractors in technical and delivery services, advertising networks, analytics providers, and search information providers) who may collect Personal Data from you and pass it on to us. Where this is the case the relevant third party is responsible for obtaining the relevant consents from you (if necessary) to ensure you are happy with the ways in which your Personal Data will be used.

3. USE OF YOUR DATA

We use Data held about you in the following ways:

  • to provide you with access to the relevant parts of the Website;
  • where necessary, to notify you about changes to our services or our Website;
  • to administer our Website and for internal operations;
  • to keep our Website safe and secure;
  • to process any request you may have made;
  • to keep in touch with you as part of our professional network and let you know about opportunities; and
  • to improve your user experience, by ensuring that content is presented in the most effective manner.

Where you have consented at the time we collected your Personal Data or where we otherwise have a right to do so, we may use your Personal Data to let you know about our services that may be of interest to you and/or inform you about important changes or developments to the Website or our services, by mail, telephone, mobile messaging (e.g., SMS, MMS, etc.), as well as by email].

If you change your mind about us using your Personal Data in the ways described in this policy, please let us know by contacting us using the details set out in section 10 below. You may also opt out of receiving marketing emails from us by following the instructions outlined in the email.

4. SHARING YOUR DATA AND PESONAL DATA

In order to provide our services to you, we may have to share your Data, including Personal Data, with certain third parties such as our group companies (including our investee companies), professional advisors or analysts, and search engine providers that assist us in the optimization of our Website. By submitting Personal Data to us, you agree to such third parties processing your Personal Data. We require all third parties to whom we send your Personal Data to treat your data securely and in accordance with this policy, and we will take reasonable steps to enforce this.

If you have consented, we may allow carefully selected third parties, including marketing and advertising companies or our business partners, to contact you occasionally about services that may be of interest to you. They may contact you by mail, telephone, mobile messaging, as well as by email. We may also employ third-party companies and individuals on our Website (for example, analytics providers and content partners). If you change your mind about being contacted by these companies in the future, please let us know by contacting us using the details set out below. You may also opt out of receiving any marketing communications you receive by following the instructions outlined in these communications.

If any of our businesses enter into a joint venture with, purchase, or are sold to or merge with another business entity, or in the unlikely event that we go out of business or enter bankruptcy, your Data and Personal Data may be disclosed or transferred to the target company, our new business partners, administrators, or owners or their advisors.

We may use the Data, including Personal Data, that you provide to us if we are under a duty to disclose or share your information in order to (a) comply with (and/or where we believe we are under a duty to comply with) any legal obligation; (b) enforce or apply our terms of service at https://structuretone.com/policies/terms-of-service and any other agreement; or (c) protect the rights, property, or safety of Structure Tone, clients, employees, contractors, or others. This includes exchanging Data with other companies and other organizations for the purposes of fraud protection and prevention, or where we have to carry out an internal investigation.

5. SECURITY, DATA TRANSFERS OUTSIDE THE EEA, AND DATA RETENTION

We take security seriously, and do what we can within commercially acceptable means to protect your Personal Data from loss or theft, as well as unauthorized access, disclosure, copying, use, or modification, destruction, and damage. We will only keep Personal Data for as long as we reasonably require and, in any event, only for as long as Data Protection Legislation allows.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will take steps to protect Data, including your Personal Data, we cannot guarantee the security of Personal Data transmitted to the Website; any transmission is at your own risk.

The Data that we collect from you may also be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, the provision of support services. By submitting your Personal Data, you are acknowledging this transfer, storing, or processing. We will take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this privacy policy and the Data Protection Legislation. This means that we will only transfer your Personal Data to third parties that (a) are in countries that have been confirmed by the European Commission to provide adequate protection to personal information; (b) have agreed to provide all protections to your personal information as set out in the Data Protection Legislation; or (c) are otherwise provided for under the operation of the Data Protection Legislation.

6. YOUR RIGHTS AND THIRD-PARTY WEBSITES

We will usually inform you (before collecting your information) if we intend to use your Personal Data for marketing or research purposes or if we intend to disclose your Personal Data to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us through the mechanism provided in section 10 below.

Should you have any questions or complaints about how we use your Personal Data, please contact us through the mechanism provided in section 10 below. Should you wish to take any complaints or questions further, you have the right to contact, in the EEA, the Information Commissioner’s Office regarding such issues.

Our Website may link to external websites that are not operated by us. Please be aware that we have no control over the content and practices of these websites, and cannot assume responsibility for their treatment of your Personal Data. This privacy policy only covers our Website and privacy practices, and third-party websites will have their own privacy policies. Please check these policies before you submit any Personal Data via these websites.

7. YOUR CALIFORNIA PRIVACY RIGHTS

We do not share Personal Data (personal information) as defined by California Civil Code Section 1798.83 (“Shine the Light law“) with third parties for their direct marketing purposes absent your consent. If you are a California resident, you may request information about our compliance with the Shine the Light law by contacting us at privacy@structuretone.com or by sending a letter to Structure Tone, 330 W. 34th St., New York, NY 10001, Attention: Compliance. Any such request must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code.  Please note that we are required to respond to one request per customer each year, and we are required to respond to those requests made through that email address or mail address.

8. ACCESSING AND UPDATING YOUR INFORMATION

You have the right to see the Personal Data we hold about you and to ask us to: (a) make any changes to ensure that any information we hold about you is accurate and up to date; (b) erase or stop processing any Personal Data we hold about you where there is no longer a legal ground for us to hold it; or (c) in some cases, transfer any information we hold about you to a specified third party. If you wish to do this, please contact us using the contact details set out below.

9. CHANGES TO OUR PRIVACY POLICY

We may amend this privacy policy, at our discretion, at any time without notice. By continuing to use the Website, communicate with us, or otherwise provide us with your Data, including Personal Data, you acknowledge the updated privacy policy. If you do not agree to any changes that we make, you should not use or access (or continue to use or access) the Website and/or our services. Any changes to our privacy policy will be posted on the Website.

10. CONTACT US

Questions, comments, and requests for further information regarding this privacy policy are welcome and all questions, comments, and requests about our use of your information are also welcome (including those relating to the transfer of data outside the EEA) and should be addressed to us at privacy@structuretone.com.