Informativa sulla privacy

For purposes of this Notice, “Constructor Technology” means the following companies:

• Constructor Technology AG, with its domicile at Rheinweg 9, 8200 Schaffhausen (CHE-502.198),
• Constructor Tech Bulgaria Ltd, with its domicile at 59 Dr. G.M. Dimitrov Blvd., NV Tower building, 11th floor, Bulgaria, Sofia, 1700 (205955023)
• Constructor Technology Pte. Ltd., with its domicile at 8 Temasek Boulevard #30-01 Suntec Tower Three Singapore 038988
• Constructor Knowledge Pte. Ltd., with its domicile at 8 Temasek Boulevard #30-01 Suntec Tower Three Singapore 038988
• Alemira Vietnam Co, with its domicile at Centec Business Center (CBC) located at 4/F, 72-74 Nguyen Thi Minh Khai St., District 3, Ho Chi Minh City
• Constructor Technology USA Inc., with its domicile at 8 The Green, Ste A, Dover, Kent, 19901, Delaware, USA
• Constructor Business Services LLC, with its domicile at Makedonska Street no. 12, floor 1, 11000 Belgrade – Stari grad, Serbia
• Constructor Turkey Teknoloji Eğitim Hizmetleri Anonim Şirketi, with its domicile at Ergenekon Mah. Halaskargazi Cad. No: 51 İç Kapı No: 4 Şişli/Istanbul, Türkiye
• PERCULUS TEKNOLOJI A.Ş. Esentepe Mah. Akademiyolu Sk. Teknoloji Geliştirme Bölgeleri Sitesi D Blok No: 10d İç Kapı No: 207 Serdivan/Sakarya
• CAZ BILIŞIM HIZMETLERI TICARET A.Ş. . Esentepe Mah. Akademiyolu Sk. No: 10 D/206 Serdivan/Sakarya  

(also referred to as “we”, “us” or “our”).

Our Privacy Notice includes information about data we collect in connection with Our services as well as how Our website automatically collects information.

1. What this Privacy Notice covers

This Notice applies to business contacts, visitors, Constructor Technology’s prospective clients, clients and partners (“individuals” or “you”) as applicable in the course of using our services or visiting our websites, including the constructor.tech domain (website) or liaising with us for other business reasons.

This Notice applies to personal data, as defined below in Section 2, we collect to provide you with certain products and services (collectively, “services”) or to keep contact for other business reasons. This Notice does not apply to anonymized, de-identified or aggregate information if it is not personal data.

This Notice describes the rights available to you regarding our use of your personal data. Use of personal data collected through our services shall be limited to the purposes of providing the services for which you have engaged us as described in this Notice and otherwise with your consent. Some information provided to us that may, either alone or when connected with other information to which we may have access, individually identify you.

If you are accessing or using our services on behalf of another person, you represent that you are authorized to accept the Agreement on behalf of that person and that the person agrees to be responsible to us if you or the other person violates the Agreement.

If you do not agree with our policies and practices described in this Notice, please do not use our services, do not visit our website, and do not provide your information to us.

Under the General Data Protection Regulation (EU) 2016/679 (GDPR), we might be both data controller and data processor (including data subprocessor) depending on the nature of the processing of your personal data. Please read on to find out about our different roles.

If you are a prospective or individual employee of Constructor Technology, this Notice does not apply to you. For more information on your privacy rights and our privacy practices, please refer to our employment guide.

2. What personal data we process and how

Personal data is information that relates to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. personal data does not include any anonymized and depersonalized data where an identity is absent or has been removed and cannot be recovered.

Below are the categories of information, including personal data that we may collect or share for a business purpose as permitted by law and depending on the services you receive:

(a) Information provided voluntarily by you:

Contact information, such as name, business email address, phone number, your photo, billing information, physical address, Telegram / Zoom / WhatsApp / Skype and similar services information, call recordings, information you input in open text fields in help/contact us forms. Depending on the services you use, you might choose to add a display name, profile photo, job title, and other details to your profile.

Content information, such the information you may choose to post, send, receive and share in our services (“content”). Examples of content information include the content viewed in the services, training interactions, the files and links you upload, and the aggregate insights obtained from this information.

Customer support information, such a summary of the problem you are experiencing, and any other documentation or information that would be helpful in resolving an issue submitted to us. We do not collect your payment information, such as your credit card, but we ask our payment providers to manage this information on our behalf.

(b) Information we collect automatically from you:

Analytics information, such as when you visit and interact with any of our services. This information includes the features you use; the links you click on; the type, size and filenames of attachments you upload to the services; frequently used search terms; and your interaction with third-party integrations and others on the services.

Device information, your connection type and settings, information about your operating system, browser type, IP address, URLs of referring/exit pages, device identifiers, and crash activity, collected through cookies, web beacons and similar technologies. For more information on how we use these technologies and how to turn them off from collecting your information, please see our Cookie Policy.

(с) Information we receive from other sources

From time to time, we may receive information about you from:

• other users,
• third-party providers,
• our corporate affiliates,
• professional social networks and publicly accessible websites,
• third-party integrations set up with your Constructor Technology account,
• and from our business partners.

We will collect this information only where these third parties are legally permitted or required to share your personal information to us. When required by law, we inform you on such collection of information in due course.

3. How we use your personal data and which legal basis we rely on

We collect and process personal data for a variety of purposes, including:

4. Children’s privacy

Children (as defined under the applicable data privacy laws) may only access or use our services with the consent and under the supervision of a parent or legal guardian who agrees to be bound by this Privacy Notice. If you are a parent or legal guardian of a child, you agree to be fully responsible for the acts or omissions of such user in connection with access to and use of the Services.

We do not knowingly collect or ask for information from minors, except for services that are intended to be used by children as part of their education. When required by law, we inform you on such data processing in due course.

5. Special categories of personal data

Special categories of personal data are subject to special protections under applicable law.

We do not ask you for any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we ask you for any information about criminal convictions and offences.

You may choose to provide us with special categories of personal data through your uploading of video or audio files or other data on to the service. Where you provide us with such special categories of personal data, you are giving us your explicit consent to process such data about you to the extent permitted by the UK and/or EU data protection regime or other jurisdictions as applicable.

Where you provide us with such special categories of personal data personal data about persons other than yourself, you must obtain each of their explicit written consent as per the applicable law for us to process their special categories of personal data to the extent permitted by the UK and/or EU data protection regime or other jurisdictions as applicable and in accordance with this Privacy Notice. Their explicit written consent which you obtain as per the applicable law must be supplied to us on our request. If an individual does not give explicit written consent to our processing their special categories of personal data, then their special categories of personal data must not be supplied to us. You must not upload video or audio files or other data containing special categories of personal data of anyone who you have not obtained explicit written consent from as per the applicable law.

You are liable for the exercise of the privacy rights listed in Section 11 of individuals who had given you their explicit consent on processing their special categories of personal data.

6. How long we keep your personal data

We retain personal data about you necessary to fulfil the purpose for which that information was collected, consistent with applicable laws.

We generally retain information regarding our services for a year from the date of our last interaction/account closure/etc., in compliance with our obligations under applicable laws, or for longer if required to do so according to our regulatory obligations or where we believe necessary to establish, defend, or protect our legal rights or those of others.

When we destroy your personal data, we do so in a way that prevents that information from being restored or reconstructed.

7. Cookies, tracking information and social media widgets

When you visit our website for the first time, you will be asked to consent or reject the use of cookies and the collection of data by cookies and similar tracking technologies. We do not use cookies until you consent or opt in using cookie preferences.

We use the following cookies on our website:

Strictly necessary cookies

These cookies are essential for websites (subdomains) within the website and services to function and cannot be switched off in Constructor Technology’s services. We usually set strictly necessary cookies in response to your actions that amount to a request for services, such as setting your privacy preferences, logging in, or filling in forms. You can set your browser to block or alert you about these cookies. This might result in some parts of the website or services not working properly.

Functional Cookies

These cookies enable the website to provide enhanced functionality and personalization. We set some functional cookies, while third party providers whose services we have added to the website set the rest of these cookies. If you do not allow functionality cookies, then the website relying on functionality cookies may not function properly. The information these cookies collect may be anonymous, and they are not used to track your browsing activity on other websites.

Performance Cookies

These cookies allow Constructor Technology to count visits and traffic sources in order to measure and improve the performance of the website. Performance cookies help us gauge the relative popularity of various pages on the website as well as see how visitors move around the website. We aggregate all information these cookies collect, making it anonymous as a result. If you do not allow performance cookies, we will not know when you have visited the website, will not be able to monitor its performance, and as a result we will not be able to improve the website’s services and make it more comfortable for use.

Targeting Cookies

Depending on the parts of the website you visit, our advertising and marketing partners may set these cookies. our advertising partners may use targeting cookies to build a profile of your interests and show you relevant adverts on the website. They use these cookies to uniquely identify your browser and internet device, which under certain privacy laws may amount to processing of personal data. If you do not allow targeting cookies, you will experience fewer targeted advertisements on the website.

The cookies simply assess how you interact with our website.

Please consult our Cookie Policy to learn which third-party services we use specifically on our website and as part of our services.

8. How we share your personal data

We only disclose your personal data

• at your request
• to the extent required by law
• to our business partner with your consent,
• to our business partner based on our contractual liability, and
• to our service providers for the business purpose(s) described below.

Our employees process your data only within the scope of their job responsibilities on the basis of the principle of necessity. Our employees are located all over the world. You can contact us if you have any questions or would like to know from which countries your data can be accessed.

We may share personal data listed in Section 3 of this Notice

• With your consent. We may disclose your personal data when you provide your consent and intentional direction. For example, when you request content or register for an event, you consent to receiving marketing communications from us and our third-party partner or co-sponsor of that content or event. For example, you may consent to participate in marketing, product, or customer service research or user surveys. Consent for children younger than 16 years old (or lower as required by law) must be given by the parent or guardian. You may always opt-out of receiving marketing communications by unsubscribing or submitting a privacy rights request. Please contact us at privacy@constructor.tech.
• Related to legal proceedings. We will share your information, including personal data, to respond to investigations, court orders, legal process, or to investigate, prevent or act regarding illegal activities, suspected fraud, or situations involving potential threats to the physical safety of any person, violations of Constructor Technology's Terms of service [SaaS], or as otherwise required by law. If we are required by law or an order of a court of competent jurisdiction to disclose your information, we will promptly notify you of this requirement, if permitted by the court or applicable law, so that you may seek a protective order or other appropriate relief.
• With service providers or data sub-processors. We may share personal data with our service providers, who help us to provide the services, such as cloud storage, security, application communications, customer support, backup, and data analytics. Please refer to the complete list of our sub-processors to know more. Processing of personal data by such third parties is governed by data processing agreements we have in place.

• Merger, Acquisition, Sales. If we are involved in a merger, acquisition, restructuring or sale of all or a portion of its assets, equity or similar transaction, personal data may be transferred to the acquiring person or entity. We will use reasonable efforts to direct the acquiring person or entity to use your personal data in a manner that is consistent with our Privacy Notice.

   

9. How we protect your information

The security of your personal information is important to us.

We follow generally accepted security standards and we have adopted commercially reasonable security measures to protect your personal data against accidental or unlawful destruction, loss, alteration, or unauthorized disclosure or access. We may use third-party products and services to secure or store your information.

Depending on where you live, you may have a legal right to be notified in case of security breach.

We may, subject to applicable law, transfer your information outside the country where you are located and to where information protection standards may differ (e.g. your information may be stored on servers located in other jurisdictions). We will utilize appropriate safeguards governing the transfer and usage of your personal information. See Section 9 for further information.

We will never request your account credentials. You should never share your Constructor Technology account information, including your username and password, with anyone else. We recommend that you use a unique password for your Constructor Technology account that is not associated with other websites. You should check your Constructor Technology account regularly to ensure that your personal data has not been tampered with or altered. You should only use the services within a secure environment.

Overall, if you have any reason to believe that your interactions with the services are no longer secure, please notify us immediately at privacy@constructor.tech.

10. How we transfer your data

Your personal data may be transferred to, and processed in, countries other than the country in which you are based, where our affiliates, subsidiaries, partners or our third-party service providers operate.

Some of these countries might not be considered as adequate by the European Commission and therefore not offer an adequate level of protection and security. As a result, we take measures to ensure that your information is safe and protected in compliance with the applicable data protection laws, including:

• reliance of Standard Contractual Clauses to transfer your data outside the European Economic Area, United Kingdom and Switzerland;
• implementation of organisational, contractual and technical security measures with our third-party service providers;
• establishment of an intra-group data transfer agreement for internal transfers of personal data within our group of companies around the world.

11. Your privacy rights

You may make certain choices regarding your personal data as permitted under applicable privacy laws. You may make these choices free of charge except as otherwise permitted under applicable law. We may ask you to further confirm your identity and limit our response to your requests as permitted under applicable law.

Individual Privacy Rights

Your privacy rights include:

• Right to be Informed: You have the right to be informed about the collection and use of your personal data. This includes your right to request a copy of the standard contractual clauses including completed and signed annexes and excluding any confidential information, business secrets, and personal data of third parties in case we process your personal data relying on such terms and conditions with other data processors.
• Right to Access: You have the right to view and request copies of your personal data. If you have an online account or profile with us, you may access your personal data via your account through the website or mobile app.
• Right to Rectify or Correct: You have the right to update the personal data that we have collected about your directly or indirectly, including personal data collected by a service provider or contractor on our If you have an online account or profile with us, you may update your personal data by accessing your account through the website and mobile app.
• Right to Request Erasure (Right to be Forgotten): You may request that we delete your personal data, subject to certain limited exceptions. For example, we may retain an archived copy of your records consistent with applicable law, to comply with legal obligations, or for other legitimate business purposes. Before processing a personal data deletion request, we might conduct a legitimacy assessment to verify the identity and authority of the requester. This is to ensure that the person making the request is authorized to do so and to prevent unauthorized access or deletion of personal data. We may request additional information or documentation to confirm your identity. We will use commercially reasonable efforts to honour your requests.
• Right to Data Portability: You have the right to request that we transfer data that we have collected to another organization, or directly to you under certain conditions.
• Right to Restrict Processing: You have the right to request that we restrict the processing of your personal data under certain conditions.
• Right to Withdraw Consent: You have the right to withdraw previously granted consent to process your personal data.
• Right to Object to Processing: You have the right to object to our processing of your personal data, under certain conditions.
• Right to Object to Automated Processing: You have the right to object to decisions being made with your information solely based on automated decision making or profiling. we do not currently engage in automated decision-making or profiling.

To exercise any of your above rights you may submit your request at privacy@constructor.tech.

Constructor Technology Communications, Service-related Communications

We may send a welcome email to Clients and Partners for billing purposes, and at times may send service-related announcements. A Client or Partner may not opt out of service-related emails, as this is part of our services.

Marketing Communications. You may choose to stop receiving our newsletter or marketing emails or texts by following the unsubscribe instructions included in each of these emails or texts, or you can contact us at privacy@constructor.tech.

Privacy Questions and Concerns

To speak with or file a complaint with our Data Protection Officer, please contact us at privacy@constructor.tech. You may also lodge a complaint with your supervisory authority. If you are and individual located in the EU, UK or Switzerland, please consult the below websites to figure out the supervisory authority applicable for you:

https://edpb.europa.eu/about-edpb/about-edpb/members_en https://www.edoeb.admin.ch/edoeb/en/home.html.

https://ico.org.uk/make-a-complaint/data-protection-complaints/data-protection-complaints/.

Privacy Rights Requests of clients of our clients

Our clients are responsible for processing privacy requests from their clients who have data in the Constructor Technology service. If we receive the request, we will forward the request to our client to process according to applicable privacy laws. Our clients may access, correct, amend, or delete the data without our involvement, but we will assist the client as needed. Please refer to Section 16 for more details.

Privacy Concerns and Complaints of clients of our clients

We will forward any concerns or complaints from a client of our client to our client. Please refer to Section 16 for more details.

12. Third party links and applications

Our website includes links to other websites whose privacy practices may differ from those of Constructor Technology. If you submit information to any of those sites, your information is governed by the privacy policies that apply to those sites. We encourage you to carefully read the privacy notice of any website or application you visit.

13. Publicly accessible parts of our website

Our website offers publicly accessible blogs and community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal data from our blog or community forum, please contact us at privacy@constructor.tech.

14. Processing your personal data if you are not our client

In certain circumstances, we process your personal data as a data processor, which means on behalf of our client (for example, where we provide services to an organization, a company or academic institution). In these cases, it is our client that is responsible for the processing of your personal data.

Our data protection practices will be regulated by the terms of a data protection agreement entered with our client.

If you have questions or concerns about how your personal data is handled in these circumstances, including how to exercise your rights, you should contact our client that has control over your account (e.g. your employer or account administrator) and refer to their separate privacy policies.

From time to time, we may include links on the website to third-party websites, or be able to integrate our services with third-party integrations. In these cases, your personal data may be transmitted or otherwise made available, automatically (e.g. through API) or otherwise, to third parties. Please be aware that we do not control, monitor or are responsible for such websites, their web content while you are visiting their websites, and the processing of your personal data required by the third-party to use this integration. We encourage you to review their privacy policies.

15. Content liability

Our services may allow you and other users to transform and share content, including photos, images, graphics, videos and other materials referred as content. We do not claim ownership of any i) content that you share on or through the services, or ii) content transformed through the services that you save or share on or through the services. You retain all rights in and to your content. You grant us a nonexclusive, sublicensable, royalty-free, worldwide, fully paid license to use, reproduce, temporarily caсhе, modify, adapt, create derivative works from, distribute, perform, and display your content solely for the purpose of providing you with the services.

You are solely responsible for the content that you upload to the services or otherwise make available to us or others through the services, including by selecting, posting, publishing, or displaying via the services or by texting, emailing or otherwise making available to us or others. You represent and warrant that:
(i) you own or otherwise have the right to use the content;
(ii) you agree to pay for all royalties, fees, and any other monies owed by reason of content. You will comply with all relevant laws, regulations and policies applicable in your jurisdiction when transferring your content to us, including but not limited to applicable intellectual property rights and data protection and privacy laws.

We do not provide backup services, and you agree that you will not rely on the services for the purposes of content backup or storage. You may not edit, save, post, share or transform any content that violates any applicable law or for which you do not have all the rights necessary to grant us the license described above. We have no obligation or ability to screen, edit or monitor content, and you are solely responsible for all content that you edit, save, post, share or transform through the service. Notwithstanding the foregoing, we reserve the right to investigate and take appropriate legal action against anyone who, in our sole discretion, violates this provision, including without limitation, suspending or terminating the subscription of such violators, and reporting the violator to the law enforcement authorities. We will not be liable to you for any content, modification, suspension, or discontinuation of the services and/or the loss of any content.

You will comply with all relevant laws, regulations and policies applicable in your jurisdiction when transferring your content to us, including but not limited to applicable intellectual property rights and data protection and privacy laws.

You understand that the technical processing and transmission of the services, including your content, may involve (i) transmissions over various networks; and (ii) changes to conform and adapt to technical requirements of connecting networks or devices.

16. Prohibited conduct and content

When using our services, you must not violate any applicable law, breach any contract, infringe any intellectual property rights or other third-party right, or commit a tort, and you are solely responsible for your conduct while accessing or using our services. You agree to strictly abide relevant national laws, regulations and rules. When accessing or using the services you must not:

• engage in any harassing, threatening, intimidating, predatory or stalking conduct or in any illegal/criminal activities such as money laundering;
• transmit or publish content that incites resistance or undermines the implementation of the EU (or your local jurisdiction) constitution, laws and administrative regulations, involves national security, incites to subvert state power, incites hatred, discrimination against minorities or vulnerable groups and undermines basic human rights;
• use the services for any commercial purpose or the benefit of any third party or in any manner not permitted by the Agreement;
• incite or instigate others to engage in behaviour prohibited by the applicable laws and/or this Privacy Notice;
• use our services in any manner that could interfere with, disrupt, negatively affect or inhibit other users from fully enjoying our services or that could damage, disable, overburden or impair the functioning of our services or the networks connected to our services in any manner;
• reverse engineer any aspect of our services or do anything that might discover source code or bypass or circumvent measures employed to prevent or limit access to any part of the services;
• attempt to circumvent any content-filtering techniques we employ or attempt to access any feature or area of our services that you are not authorized to access;
• develop or use any third-party applications that interact with our services without our prior written consent, including any scripts designed to scrape or extract data from our services;
• display, mirror or frame our services, or any individual element within our services, the company’s name, any companies trademark, logo or other proprietary information without our express written consent;
• delete logos and watermarks, trademarks or any other protected marks;
• further edit any content with our logos and watermarks, trademarks or any other protected marks using your own or any other third party editing tools;
• circumvent, remove, alter, deactivate, degrade, or thwart any of the content protections in or geographic restrictions on any content available on or through the services, including through the use of virtual private networks;
• attempt to gain unauthorised access to the services, the server on which the services are hosted, or any server, computer or database connected to the services.
• attack the services via a denial of service attack or a distributed denial of service attack;
• knowingly introduce to the services any viruses, trojans, worms, logic bombs or other material which is malicious or technologically harmful;
• use the services for any illegal or unauthorized purpose, or engage in, encourage or promote any activity that violates applicable laws;
• carry out unauthorized access to subscriptions to the services, provide third parties with the possibility of unauthorized access to subscriptions to the services (for example, by transferring access), or use any other method of bypassing payment systems to use subscriptions;
• encourage, assist, or enable any other party to do any of the foregoing.

You may also only save, disclose, upload, transform or share content that is non-confidential and you have all necessary rights to disclose, save, upload, transform or share. You may not upload, share, select, edit, or transform any content that:

• is unlawful, libelous, defamatory, obscene, pornographic, indecent, vulgar, lewd, suggestive, harmful, abusive, harassing, threatening, tortious, discriminatory, excessively violent, invasive of privacy or publicity rights, abusive, inflammatory or fraudulent;
• would constitute, encourage or provide instructions for a criminal offense, violate the rights of any party or otherwise create liability or violate any local, state, national or international law;
• does or may infringe, misappropriate or violate any patent, trademark, trade secret, copyright or other intellectual or proprietary right (including likeness) of any party;
• contains or depicts any statements, remarks or claims that do not reflect your honest views and experiences;
• constitutes unsolicited or unauthorized advertising, promotional materials, commercial activities and/or sales, “junk mail,” “spam,” “chain letters,” “pyramid schemes,” “contests,” “sweepstakes,” or any other form of solicitation;
• impersonates, or misrepresents your affiliation with, any person or entity;
• contains any unsolicited promotions, political campaigning, advertising or solicitations;
• contains any private or personal information of a third party without such third party’s consent;
• contains any viruses or any other computer code, files or programs, corrupted data or other harmful, disruptive or destructive files or content designed to interrupt, destroy, or limit the functionality of any computer software or hardware or telecommunications equipment; or
• is, in our sole judgment, objectionable or that restricts or inhibits any other person from using or enjoying our services, or that may expose us or others to any harm or liability of any type.

We reserve the right to investigate and take appropriate legal action against anyone who, in our sole discretion, violates this provision, including without limitation, suspending or terminating the subscription of such violators, and reporting the violator to the law enforcement authorities.

17. Related documents

For a comprehensive understanding of our policies and practices, please also review our Terms of Use and Data Processing Agreement. These documents outline the terms and conditions of using our services and detail how we handle and process personal data in accordance with applicable laws. By using our services, you acknowledge that you have read and understood our Terms of Use and agree to be bound by them. If your engagement with us involves data processing activities, our Data Processing Agreement will govern the specific terms of those activities.

For any questions regarding these documents, please feel free to contact us at privacy@constructor.tech.

18. Changes to Our Privacy Notice

We reserve the right to amend this Notice at our discretion and at any time. We will do so by updating this Notice. Amended terms take effect upon being incorporated into this Notice, and your continued use of the website or association with your employer following the posting of any changes constitutes acceptance of any updated terms. If the changes will materially affect the way we use your personal data in connection with services that we have already collected, we will notify you or your employer. You can always find the latest version of this Notice on our website: https://constructor.tech/privacy-policy.

19. Contact information

If you have questions or comments about this Notice, our other privacy notices, the ways in which we collect and use your information, your choices, and rights regarding such use, wish to exercise your rights under GDPR, or want to message our Data Protection Officer please contact us at privacy@constructor.tech.