Introduction
Welcome to the Sitenna’s privacy policy.
Sitenna respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
PURPOSE OF THIS PRIVACY POLICY
This privacy policy aims to give you information on how Sitenna collects and processes your personal data through your use of our website, including any data you may provide through our website, our software platform known as “Sitenna” (“Platform”), or when communicating with us by email, letter/post or telephone.
Our website or Platform is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
CONTROLLER
Satara Technologies, Inc. dba Sitenna of 2093 Philadelphia Pike #6228, Claymont, DE 19703, United States, and its subsidiaries in relevant geographic regions, is the controller and responsible for your personal data (collectively referred to as “Sitenna”, “we”, “us” or “our” in this privacy policy).
If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details set out below.
CONTACT DETAILS
If you have any questions about this privacy policy or our privacy practices, please contact us in the following ways:
Group entity, United States of America:
Satara Technologies, Inc. (dba Sitenna)
By email: support@sitenna.com
By Post: 2093 Philadelphia Pike #6228, Claymont, DE 19703, United States
United Kingdom
Satara Technologies Limited (trading as Sitenna)
By email: support@sitenna.com
By Post: Suite 2a, Blackthorn House, St. Pauls Square, Birmingham, B3 1RL
Ireland
Satara Technologies IRL Limited (trading as Sitenna)
By email: support@sitenna.com
By Post: 8 Larch Close, Bloomfield, Annacotty, V94702N, Limerick Ireland
Canada
For questions, concerns, or complaints made pursuant to Canada’s Consumer Privacy Protection Act (CPPA), including request for withdrawal of consent or deletion of data, please contact Joseph Ryan, our internal CPPA representative, at joe.ryan@sitenna.com.
If your privacy concerns in Canada are not addressed to your satisfaction by Sitenna, you may contact the Office of the Privacy Commissioner of Canada for further guidance. The contact details for the Office of the Privacy Commissioner of Canada can be found at www.priv.gc.ca.
You may lodge a complaint with a data protection authority for your country or region where you have your habitual residence, where you work, or where an alleged infringement of applicable data protection law occurs. A list of EEA data protection authorities is available here, and the contact details for the UK Information Commissioner’s Office is available here. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES
We keep our privacy policy under regular review. If we make changes to our privacy policy, our updated privacy policy will be made available to you on our website.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
THIRD-PARTY LINKS
Our website or Platform may include links to third-party websites, plug-ins and applications that allow you to connect with your social network in various ways. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website or Platform, we encourage you to read the privacy policy of every website you visit.
The data we collect about you
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- Identity Data includes your title, first name, maiden name, last name, position, username or similar identifier, and a profile picture if you choose to upload one with your user profile.
- Contact Data includes postal/billing address, email address and telephone numbers.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and geolocation, browser plug-in types and versions, operating system and platform, device information and other technology on the devices you use to access our website and/or Platform.
- Profile Data includes your username and password used on our Platform.
- Usage Data includes information about how you use our website and/or our Platform.
- Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
- Identity Data includes your title, first name, maiden name, last name, position, username or similar identifier, and a profile picture if you choose to upload one with your user profile.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
How is your personal data collected
- Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- enquire about or order our services;
- create an account on our Platform;
- request marketing to be sent to you;
- give us feedback or contact us.
- Automated technologies or interactions. As you interact with our website and/or our Platform we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, tracking pixels, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see the section below on cookies for further details.
How do we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you, such as the provision of the Platform services.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data although where required by law we will get your consent before sending any direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below a description of all the ways we plan to use your personal data.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.
- For our internal records and references.
- To provide and facilitate access to our Platform to you as a customer.
- To manage our relationship with you, including notifying you about changes to our privacy policy.
- To administer and protect our business, including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data.
- To use data analytics to improve our website and/or Platform, marketing, customer relationships and experience.
- To make suggestions and recommendations to you about services that may be of interest to you.
- To contact you in response to your query sent through the enquiry form on our website, by email or post.
MARKETING
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Where you have provided us with your consent for receiving marketing and advertising related communications, you may revoke such consent by contacting us.
Where you have consented to our marketing communications, depending on your opted preferences, we may provide you with information relating to other services that we think might be of interest to you. You may contact us to withdraw your consent if you prefer to not receive marketing and advertising communications from us.
THIRD-PARTY MARKETING
We will not share your personal data with any third parties for marketing purposes.
COOKIES
We also collect data on visits to our website and Platform using cookies. Cookies are small files stored on a user’s computer. We use cookies to ensure our website works efficiently; for example, to remember if you have logged into your account between page views. Some cookies are essential to ensure that your order is remembered between pages so that it can be processed properly.
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in section 4 above (under the heading Purposes for which we will use your personal data).
- Service providers acting as processors based in the UK who provide hosting, data storage and system administration services.
- Service providers acting as processors based outside the UK and the EEA who provide IT support services, to the extent that they need to access your personal data to provide such support service to us or to you.
- Professional advisers acting as processors or separate controllers including lawyers, bankers, auditors and insurers based in the UK and the EEA who provide consultancy, banking, legal, insurance and accounting services.
- Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions
International transfers
As described above, a limited number of our external third-party data processors are based outside the UK and the EEA so their processing of your personal data will involve a transfer of data outside the UK and the EEA, unless otherwise specified in any agreement that governs our relationship.
Whenever we transfer your personal data out of the UK or the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK or the European Commission as applicable. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in the European Union. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK or the EEA.
Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Data retention
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers (including Contact, Identity, and Transaction Data) for up to seven (7) years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see section 9 headed your legal rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. 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 your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- 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.
- 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 your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Supplemental notice for California
This section provides additional details about the personal information we collect about California consumers and the rights afforded to them under the California Consumer Privacy Act, as amended (CCPA).
Your Rights
Subject to applicable law, you have the following rights with respect to your personal information.
- Right to access. You have the right to request that we disclose to you what personal information we collect, use, disclose, share, and sell about you.
- Right to delete. You have the right to request that we delete your personal information that we’ve collected.
- Right to update. You have the right to request that inaccurate personal information we hold about you be corrected.
- Right to restrict the use and disclosure of your sensitive information. You have the right to request that we limit our use and disclosure of your sensitive personal information.
- Right to nondiscrimination. You have the right not to receive discriminatory treatment because you’ve exercised any of your rights under the CCPA.
If you or your authorized agent wishes to exercise any of these rights, please contact us as outlined in the “Contact Us” section below. Please note that we may ask you or your agent to provide us with additional information to confirm your identity.
CATEGORIES OF PERSONAL INFORMATION COLLECTED
The personal information that we’ve collected in the past 12 months fall into the following categories specifically established under the CCPA:
- Identifiers such as a real name, postal address, unique personal identifier, online identifier, internet protocol address, and email address.
- Information under Cal. Civ. Code §1798.80(e), such as your name, address, telephone number, or any financial information.
- Commercial information, such as information related to products or services you’ve purchased.
- Internet or other electronic network activity information, such information regarding your interaction with the Sitenna Products.
- Geolocation data.
- Audio, electronic, visual, or similar information, such as audio recordings of calls with you.
- Inferences drawn on the information above, such as aggregated metrics.
- Account log-in or credit card number in combination with your credentials allowing access to your account.
For more information about the categories of personal information we collect, please see the “Personal Information We Collect” section above.
CATEGORIES OF PERSONAL INFORMATION DISCLOSED FOR A BUSINESS PURPOSE
The personal information that we’ve disclosed for a business purpose (including to our service providers) in the past 12 months fall into the following categories specifically established under the CCPA:
- Identifiers such as a real name, postal address, unique personal identifier, online identifier, internet protocol address, and email address.
- Information under Cal. Civ. Code §1798.80(e), such as your name, address, telephone number, or any financial information.
- Commercial information, such as information related to products or services you’ve purchased.
- Internet or other electronic network activity information, such information regarding your interaction with the SitennaSitenna Products.
- Geolocation data.
- Audio, electronic, visual, or similar information, such as audio recordings of calls with you.
- Inferences drawn on the information above, such as aggregated metrics.
- Account log-in or credit card number in combination with your credentials allowing access to your account.
For more information about the categories of personal information we disclose to other parties, including to our services providers, please see the “How We Share Personal Information” section above.
NO SALE OR SHARING OF PERSONAL INFORMATION
We do not sell or share (for the purpose of cross-context behavioral advertising) your personal information, as those terms are defined under the CCPA.
