Privacy notice

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

• Alemira AG, with its domicile at Rheinweg 9, 8200 Schaffhausen (CHE-198.218.273),
• Rolos AG, with its domicile at Rheinweg 9, 8200 Schaffhausen (CHE-291.055.243)
• Constructor Autonomous AG, with its domicile at Rheinweg 9, 8200 Schaffhausen (CHE-420.502.198)
• Dybuster AG, with its domicile at Lintheschergasse 7 8001 Zürich (CHE-113.435.589)
• Alemira Software Ltd, with its domicile at 59 Dr. G.M. Dimitrov Blvd., NV Tower building, 11th floor, Bulgaria, Sofia, 1700 (205955023)
• SIT Rolos Bulgaria Ltd, with its domicile at 59 Dr. G.M. Dimitrov Blvd., NV Tower building, 11th floor, Bulgaria, Sofia, 1700 (206851910)
• Alemira Pte. Ltd., with its domicile at 8 Temasek Boulevard #30-01 Suntec Tower Three Singapore 038988
• Rolos 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

(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 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).

This Notice applies to personal data, as defined below in Section 2, We collect to provide you with certain products and services (collectively, “Services”). 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 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 an individual in a service agreement with Our Client being your service provider, this Notice does not apply to you. For more information on your privacy rights and privacy practices of Our Client, please refer to their privacy notices.

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. 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.

(c) 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.

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

4. 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.

5. 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 here.

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 Cookies policy to learn which third-party services We use specifically on Our Website and as part of Our Services.

6. 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.  
   
• 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.

7. 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 utilise 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.

8. 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.

9. 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 behalf. 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. 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.

Privacy Questions and Concerns

To speak with or file a complaint with Our Data Protection Officer, please contact us. 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.

10. 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.

11. 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.

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

As discussed in Section 1 above, this Notice does not apply to you if you are in a service agreement with Our Client being your service provider. You should consult Our Client’s privacy notice to inquire on how your personal data is processed.

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 organisation, 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.

13. 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.

14. 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.