Privacy

1 About 3SL

Structured Software Systems Ltd (3SL) is registered in England and Wales, registered number 2153654, registered office Suite 2, 22a Duke Street, Barrow-in-Furness, Cumbria, LA14 1HH.

Questions regarding this statement should be directed to privacy@threesl.com

3SL may contact you by any of the following (but not limited to) post, messaging, telephone, email or social media with details of our products, services and promotions. All of our newsletter and marketing correspondence includes an unsubscribe option.

3SL is committed to protecting your data privacy and security. We collect personal information in order to provide our industry-leading products, services and support that you request (“Services”). The following privacy statement explains the collection, dissemination and use of your personal data. It is our policy to never share personally identifiable information to unrelated third parties.

We strongly believe in both minimising the data we collect and limiting its use and purpose to only that for which we have been given permission, as necessary to deliver the Services that you purchase, or as we might be required or permitted for legal compliance or other lawful purposes.

2 Scope of this Privacy Policy

This privacy policy applies to all personal data processed by 3SL. If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place.

3 Types of Data we Collect

When you use our website you may submit information to us through our online forms. We may also collect information about you from electronic communications, letters you send to us or by phone calls. You may choose to give us personal information directly in a variety of situations. For example, you may want to give us your name and contact information to communicate with you, to process an order or to do business with us if you are a supplier.

3.1 Website Cookies

3.1.1 What are Cookies?

Cookies are small text files placed on your computer or device to monitor how you use a website or an app.

Different types of cookies are used to do different things. These include letting you navigate between different pages on a website efficiently, remembering preferences you have given and helping us identify ways to improve your overall site experience. Others are used to provide you with advertising which is more tailored to your interests, or to measure the number of site visits and the most popular pages users visit.

This policy sets out the types of cookies we use when you use our website.

3.1.2 Our use of Cookies

Our website may place and access certain first party cookies on your computer or device. First party cookies are those placed directly by us and are used only by us. We use cookies to facilitate and improve your experience of our site and to provide and improve our products and services. We have carefully chosen these cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

Our site uses analytical services provided by Google and Piwik (locally hosted by 3SL). Website analytics refers to a set of tools used to collect and analyse anonymous information, enabling us to better understand how our website is used. This, in turn, enables us to improve our website and the products and services offered through it. You do not have to allow us to use these cookies, however whilst our use of them does not pose any risk to your privacy or your safe use of our website, it does enable us to continually improve our website, making it a better and more useful experience for you.

In addition to the controls that we provide, you can choose to enable or disable cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

You can choose to delete cookies on your computer or device at any time, however you may lose any information that enables you to access our website more quickly and efficiently including, but not limited to, login and personalisation settings.

It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

3.2 Mailing Lists

As part of the registration process for our monthly e-newsletter, we collect personal information. We use that information for a number of reasons: to provide information you have requested; to contact you if we need to obtain or provide additional information; to check our records are correct and to occasionally check business feedback/performance. We do not rent or trade email lists with other organisations and businesses.

3.3 Third Parties

We collect information from our authorised distributors/business partners. Please see our Contacts page.

3.4 Internet Interfaces

We maintain a small number of publically accessible IP addresses in the range 88.98.37.241 to 88.98.37.245. Our website is hosted on 88.98.37.241.

All servers behind these IP addresses are protected against intrusion attacks by a variety of methods including IP protocol restrictions, port restrictions, source IP address restrictions and others. All servers are maintained with all applicable security updates.

Some of our services are accessed over HTTPS. Our certificate is issued by GeoTrust, Inc. for *.threesl. We may also log your IP address for internal analytical purposes and for abuse protection.

3.5 Email

We operate a range of e-mail protection mechanisms including:

• We reject e-mails from malicious sources using external blocklists.
• We scan all e-mails using a variety of malware detection and other filters before they reach our network and reject or tag e-mails appropriately.
• We maintain a whitelist of domains that we trust. This list automatically includes all customer domains.
• For e-mails that could be allowed to reach their recipient, we divert all e-mails containing attachments that are potentially dangerous or could indicate spam. Therefore, if you send e-mail to 3SL with attachments of any of the following types, it may not be received by your intended recipient (including but not limited to): COM BAT SCR PIF LNK VBS JS CMD ZIP EXE JPG

4 How we use your Information

We will hold your information securely and use it only in compliance with the current UK data protection laws. We will use your information to provide you with product updates and any other information that you have requested. We may also use and analyse the information we collect so that we can administer, support, improve and develop our business. Further, where you have consented, we might also use your information to let you know about other services that we offer. If you change your mind about being contacted in the future, please let us know by contacting privacy@threesl.com and your details will be removed from our records.

We endeavour:

• To keep your data safe and private
• Not to sell your data or pass on to third parties
• To give you ways to manage and review your marketing choices at any time

3SL uses (and, where specified, shares) your personal information for the following purposes:

• To follow up on evaluation requests. When requesting product information or an evaluation of our software, you may be asked to provide your email address, telephone number, location, company name and whether you would like to request a webinar/demonstration. 3SL uses this personal information to send you information on how to download an evaluation of our product and to engage with you regarding product information, pricing information, order details, as well as to send you information regarding marketing related activities. By providing this information, you are agreeing that 3SL can contact you, send you important information about our products, including new product updates and releases. You may opt out of our email communication at any time by using the Unsubscribe link found at the bottom of an email or by contacting 3SL.
• To process transactions. 3SL uses personal information such as financial, credit card and payment information to process your order and may need to share some of this information with delivery services, credit card processing companies, and other third parties to complete the transaction. Your credit card information is only used for completing the purchase transaction. Your card details are not stored or processed by 3SL. They are processed by our card processor.
• To provide assistance through any of our support channels. You may choose to submit information regarding an issue you are experiencing with our Services. Whether you designate yourself as a technical contact, open a support call, speak to a member of our Support team, you will be asked to provide any of the following: contact information, a summary of the problem you are experiencing, project data, device information, documentation of the issue you are having, screenshots or information that would be helpful in resolving the issue. This information is never disclosed to any third party, except for our authorised distributors, and may be used to assist in resolving an issue you may experience with our products.
• To market, promote and drive engagement with our Services. We use your contact information and information about your needs and how you use our products to send you communications that may be of specific interest to you. These communications are aimed at driving engagement and maximising what you get out of our Services, including information about new features, newsletters, and events we think may be of interest to you. You may opt out of our email communication at any time using the Unsubscribe link on the bottom of the email.
• To provide social networks. 3SL does not control the content that users post to social networks. You should carefully consider whether you wish to submit personal information to these forums or social networks and tailor any content you submit appropriately and in accordance with the relevant terms of use. You should also review any additional terms and conditions that may govern your use of these services, including terms related to sharing your personal information and receiving communications.
• To provide products and services. 3SL may contact you if you purchase products to confirm certain information about your order (for example, that you did not experience problems in the download process). We may also use this information to confirm compliance with licensing and other terms of use and may share it with your company or institution.
• To engage with third parties. If we need to engage third parties we may share your personal data in connection with services or training that these individuals or entities perform for or with 3SL. These third parties are restricted from using this data in any way other than to provide services for 3SL or for the collaboration in which they and 3SL are contractually. These third parties are carefully selected by 3SL and obligated to keep your data secure. For example, a cloud provider for a SaaS deployment of Cradle or a venue that is provided for a training course and we are booking accommodation etc., for delegates.
• To get feedback or input from you. In order to deliver products and services of most interest to our customers, from time to time, we may ask members, customers, volunteers, and website visitors to provide us input and feedback (for example, through surveys, usability, studies, focus groups).

4.1 Marketing

We may use your personal information to tell you about relevant products and offers. This is what we mean when we talk about “marketing”.

The personal information we have for you is made up of what you tell us, and data we collect when you use our services.

We study this to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

We will only use your personal information to send you marketing messages if we have either your consent or a legitimate interest. That is when we have a business or commercial reason to use your information. It must not unfairly go against what is right and best for you.

You can ask us to stop sending you marketing messages by contacting us at any time.

We may ask you to confirm or update your choices. We will ask you to do this if there are changes in the law, regulation, or the structure of the business.

If you change your mind you can update your choices at any time by contacting us.

5 How we share your information

Our policy is not to disclose personally identifiable information to unrelated third parties unless required to do so by law or legal process.

5.1 Sharing with Third Parties

• Service providers. We work with third party service providers to provide hosting, payment processing, analysis and other services for us which may require them to access or use information about you. If a service provider needs to access information about you to perform services on our behalf, they do so under close instruction from us, including policies and procedures designed to protect your information.
• Affiliated companies and partners. 3SL may share your personal data with third parties in connection with services or training that these individuals or entities perform for or with 3SL. These third parties are restricted from using this data in any way other than to provide services for 3SL or for the collaboration in which they and 3SL are contractually engaged (for example, training or consultancy). These third parties are carefully selected by 3SL and obligated to keep your data secure.
• With your consent. We share information about you with third parties when you give us consent to do so. For example, we often display personal testimonials of satisfied customers on our website. With your consent, we may post your name alongside the testimonial.

6 How the Law Protects You

As well as our privacy promise, your privacy is protected by law. This section explains how that works.

Data Protection law says that we are allowed to use personal information only if we have a proper reason to do so. This includes sharing it outside 3SL. The law says we must have one or more of these reasons:

• To fulfil a contract we have with you, or
• When it is our legal duty, or
• When it is in our legitimate interest, or
• For vital interests, or
• For public task, or
• When you consent to it

A legitimate interest is when we have a business or commercial reason to use your information. But even then, it must not unfairly go against what is right and best for you. If we rely on our legitimate interest, we will tell you what that is.

Here is a list of all the ways that we may use your personal information, and which of the reasons we rely on to do so. This is also where we tell you what our legitimate interests are:

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7 Disclosure of your Information

Unless required to do so by law, we will not otherwise share, sell or distribute any of the information you provide to us without your consent.

8 Transfers of Data

Personal information in the European Union is protected by data protection laws but other countries do not necessarily protect your personal information in the same way.

Our website and some of our applications or services or parts of them may also be hosted in the United States or otherwise outside of the EEA (which means all the EU countries plus Norway, Iceland and Liechtenstein) (“EEA”) and this means that we may transfer any information which is submitted by you through the website or the application or service outside the EEA to the United States or to other territories outside of the EEA. When you send an email to us, this will also be stored on our email servers which are hosted in the UK.

We may use service providers based outside of the EEA to help us provide our website, applications and services to you (for example, platform and payment providers who help us deliver our applications and services, or advertising or execute your payments) and this means that we may transfer your information to service providers outside the EEA for the purpose of providing our applications, advertising and services to you.

We take steps to ensure that where your information is transferred outside of the EEA by our service providers and hosting providers, appropriate measures and controls are in place to protect that information in accordance with applicable data protection laws and regulations. For example, we may share information with our group companies or affiliates based outside the EEA for the purposes envisaged by this Privacy Notice.

By using our website, products or services or by interacting with us in the ways described in this Privacy Notice, you consent to the transfer of your information outside the EEA in the circumstances set out in this Privacy Notice. If you do not want your information to be transferred outside the EEA you should not use our website, applications or services.

9 Security and Data Retention

We employ security measures to protect your information from access by unauthorised persons and against unlawful processing, accidental loss, destruction and damage. We will retain your information for a reasonable period or for as long as the law requires.

All data and records are stored securely to avoid misuse or loss. All data records are stored in the most convenient and appropriate location having regard to the period of retention required and the frequency with which access will be made to the record. The degree of security required for file storage reflects the sensitivity and confidential nature of the material recorded. Any data file or record which contains personal data of any form is considered confidential in nature. Examples of appropriate storage include password protecting electronic documents and locking paper documents in a secure cupboard or drawer.

All information of a confidential or sensitive nature is securely destroyed when no longer required. The procedure for the destruction of confidential or sensitive records is as follows:

• Electronic files are deleted in such a way that they cannot be retrieved by simply undoing the last action or restoring the item from the Recycle Bin. Destruction of backup copies is also dealt with.
• Media and equipment is physically destroyed prior to disposal or wiped to an appropriate commercial standard.
• Paper is destroyed if the content is sensitive.

Please refer to our separate Data Retention Policy for further information. Please contact privacy@threesl.com to request a copy.

10 Access to your Personal Information

Under GDPR, the data subject has the right to access and amend any of their personal data that we hold.

You are entitled to view, amend or delete the personal information that we hold. Email your request to privacy@threesl.com or send your request in writing to 3SL at the address shown at the top of this privacy notice, for the attention of the Privacy Officer.

11 Stop using your Personal Information

You have the right to object to our use of your personal information, or to ask us to delete, remove, or stop using your personal information if there is no need for us to keep it. This is known as the “right to object” and “right to erasure”, or the “right to be forgotten”.

There may be legal or other official reasons why we need to keep or use your data. But please tell us if you think that we should not be using it.

We may sometimes be able to restrict the use of your data. This means that it can only be used for certain things, such as legal claims or to exercise legal rights. In this situation, we would not use or share your information in other ways while it is restricted.

You can ask us to restrict the use of your personal information if:

• It is not accurate
• It has been used unlawfully but you don’t want us to delete it
• It is not relevant anymore, but you want us to keep it for use in legal claims
• You have already asked us to stop using your data whilst waiting for us to confirm the reason of our continued use

If you want to object to how we use your data, or ask us to delete it or restrict how we use it please email your request to privacy@threesl.com or send your request in writing to 3SL at the address shown at the top of this privacy notice, for the attention of the Privacy Officer.

12 How to Withdraw your Consent

You can withdraw your consent at any time. Please email your request to privacy@threesl.com or send your request in writing to 3SL at the address shown at the top of this privacy notice, for the attention of the Privacy Officer.

13 Complaints or Queries

3SL tries to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures.

This privacy notice was drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of 3SL’s collection and use of personal information. However, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to privacy@threesl.com.

If you want to make a complaint about the way we have processed your personal information, you can contact us as follows (www.threesl.com/contact).

14 Changes to this Privacy Notice

We may change this Privacy Policy from time to time (for example, if the law changes). Any changes will be immediately posted on our website and you will be deemed to have accepted the terms of the Privacy Policy on your first use of our website following the alterations. We recommend that you check this page regularly to keep up-to-date.

This policy will be reviewed each year. The last date of review is 20.05.18.