Your Privacy Matters

At Structural, we value trust: the trust between co-workers, employees and employer, users and our company. Maintaining your trust extends to the decisions we make about how we gather and respect your personal information. We’ve crafted the policy below to be as clear and straightforward as possible. Our aim is for you—our users—to always feel informed and empowered with respect to your privacy on Structural.

Introduction

Structural’s mission is to help employees realize their full potential by facilitating new professional connections, building relationships with your co-workers, and deepening engagement with your employer. Our registered users (“Users”) share their professional identities, engage with their network, exchange knowledge and professional insights. We believe that our services allow our Users to build and enhance meaningful relationships with co-workers.

Maintaining your trust is our top priority, so we adhere to the following principles to protect your privacy:

  • We protect your personal information and will only provide it to third parties: (1) with your consent; (2) where it is necessary to carry out your instructions; (3) as reasonably necessary in order to provide our features and functionality to you; (4) when we reasonably believe it is required by law, subpoena or other legal process; or (5) as necessary to enforce our User Agreement or protect the rights, property, or safety of Structural, our Users, and the public.
  • We have implemented appropriate security safeguards designed to protect your information in accordance with industry standards.

This Privacy Policy applies to Structural.com, the Structural mobile applications, and all other Structural websites, apps, and other products and services (collectively the “Services”). We may modify this Privacy Policy from time to time, and if we make material changes to it, we will provide notice through our Service, or by other means so that you may review the changes before you continue to use our Services. If you object to any changes, you may close your account. Continuing to use our Services after we publish or communicate a notice about any changes to this Privacy Policy means that you are consenting to the changes.

  1. What information we collect

1.1. Data Controllers

The personal information provided to or collected by our Services is controlled by Structural, Inc., 370 Wabasha Street N, Suite 660, St. Paul, MN 55102. If you have any concern about providing information to us or having such information displayed on our Services or otherwise used in any manner permitted in this Privacy Policy and the User Agreement, you should not become a User, visit our websites, apps or otherwise use our Services. If you have already registered, you can close your accounts.

We collect your personal information in the following ways:

1.2. Registration

To create an account on Structural, you must provide us with at least company email address, and a password and agree to our User Agreement and this Privacy Policy, which governs how we treat your information. You may provide additional information during the registration flow (for example, your name, title, department, mobile phone number, start date, office location, birthdate, and gender) to help you build your profile and to provide you more customized services. You understand that, by creating an account, we and others will be able to identify you by your Structural profile.

1.3. Profile Information

After you create an account, you may choose to provide additional information on your Structural profile, such as descriptions of your skills, professional experience, and educational background, and other information including content and polls. Providing additional information enables you to derive more benefit from our Services by helping you express your professional identity; find other professionals and information; and help your company better get to know you.

1.4. Other Services That Sync with Structural

We may make other tools available to sync information with our Services, and may also develop additional features that allow Users to use their account in conjunction with other third-party services.

Any information that you upload or sync with our Services is covered by the Master Services Agreement your organization holds with Structural, your User Agreement, and this Privacy Policy. You can remove your information at any time using the features we make available or in accordance with Section 3.

1.5. Customer Service

When you contact our customer support services, we may have to access your profile and other contributions to our Services and collect the information we need to categorize your question, respond to it, and, if applicable, investigate any breach of our User Agreement or this Privacy Policy. We also use this information to track potential problems and trends and customize our support responses to better serve you. We do not use this information for advertising.

1.6. Using the Structural Sites and Applications

We collect information when you use our websites, applications, or other Services. For example, we collect information when you perform a search, participate in polls, install one of our mobile applications, make a phone call or send a text message, as well as your usage information and the log data described in Section 1.7 of this policy, such as your IP address, will be associated by us with your account. Even if you’re not logged into a Service, we log information about devices used to access our Services, including IP address.

1.7. Log Files, IP Addresses, and Information About Your Computer and Mobile Device

We also receive the internet protocol (“IP”) address of your computer or the proxy server that you use to access the web, your computer operating system details, your type of web browser, your mobile device (including your mobile device identifier provided by your mobile device operating system), your mobile operating system (if you are accessing Structural using a mobile device), and the name of your ISP or your mobile carrier. We may also receive location data passed to us from third-party services or GPS-enabled devices that you have set up, which we use to show you local information on our mobile applications and for fraud prevention and security purposes. Most mobile devices allow you to prevent real time location data being sent to us, and of course we will honor your settings.

In the case of our Android apps, you will be provided notice of the types of data (e.g. location) that will be sent to us. If you choose to use our app after this notice, we process this data to enable registration or preview product features for you (e.g. jobs near you). If you choose not to become a User, we will delete this information.

1.11. Other

Our Services are a dynamic, innovative environment, which means we are always seeking to improve the Services we offer you. We often introduce new features, some of which may result in the collection of new information. Furthermore, new partnerships or corporate acquisitions may result in new features, and we may potentially collect new types of information. If we start collecting substantially new types of personal information and materially change how we handle your data, we will modify this Privacy Policy and notify you in accordance with Section 2.2

  1. Protection of Collected Information & Security

2.1. Privacy Measures.

We take very seriously the privacy of your User Information. We use, SSL 256-bit encryption techniques, and authentication procedures, among others, to maintain the security of your online session and to protect Structural accounts and systems from unauthorized access. We may also place cookies and similar files on your hard drive for purposes such as security, to facilitate site navigation, and to personalize your experience on our Site. Our cookies do not identify you by name as an individual or by account number except as described in this Privacy Policy. See the “How we use cookies” section below for more information.

  1. How We Use Your Personal Information

3.1. Customer Data

Structural does not own and shall not be responsible for User Information that you authorize us to retrieve or submit to the Service in the course of using the Service. You, not Structural, shall be solely responsibility for the accuracy, quality, integrity, legality, reliability, appropriateness, and intellectual property ownership or right to use all User Information, and Structural shall not be responsible or liable for the deletion, correction, destruction, damage, loss or failure to store any User Information. Structural will have the right to exploit aggregated User Information or data generated by or on behalf of Structural in connection with the Service and to provide aggregate, de-identified data to third parties, so long as such data is presented in the aggregate and does not identify you. The personal information that you provide to us may reveal or allow others to identify aspects of your life that are not expressly stated on your profile (for example, your picture or your name.)

3.2. Requests, Inquiries, and Offers

We may use the information you provide about yourself and about your Third Party Sites to fulfill your requests for our products, programs, and Services, to respond to your inquiries about our Services, and to offer you other products, programs, or services that we believe may be of interest to you. We may use your information to pre-fill form fields on the Sites for your convenience.

3.3. Consent to Structural Processing Information About You

The personal information that you provide to us may reveal or allow others to identify aspects of your life that are not expressly stated on your profile (for example, your picture or your name may reveal your gender). By providing personal information to us when you create or update your account and profile, you are expressly and voluntarily accepting the terms and conditions of our User Agreement and freely accepting and agreeing to our processing of your personal information in ways set out by this Privacy Policy. Supplying to us any information deemed “sensitive” by applicable law is entirely voluntary on your part. You can withdraw or modify your consent to our collection and processing of the information you provide at any time, in accordance with the terms of this Privacy Policy and the User Agreement, by changing your profile settings, or by closing your Structural account.

3.4. Structural Communications

We communicate with you through email, notices posted on the Structural websites or apps, and other means available through the Services, including mobile text messages and push notifications. Examples of these communications include: (1) welcome and engagement communications – informing you about how to best use our Services, new features, updates about other Users you are connected to and their actions, etc.; (2) service communications – these will cover service availability, security, and other issues about the functioning of our Services. These messages will be sent to you based on your profile information and messaging preferences. We track the open rate of communications to gauge the impact of these efforts.  You may change your email and contact preferences at any time by signing into your account and changing your email settings.  Please be aware that you cannot opt out of receiving service messages from us.

3.5. User Communications

Many communications that you initiate through our Services (for example, announcements) will list your name and company email address in the header of the message. Phone calls or text messages you initiate in Structural may also provide the recipient with the phone number of the mobile device you are utilizing.

3.6. Service Development; Customized Experience

We use information and content that you and other Users provide to us to conduct research and development for the improvement of our Services in order to provide you and other Users with a better, more intuitive experience and drive membership growth and engagement on our Services and to help connect professionals to economic opportunity.

We also customize your experience and the experiences of others on our Services. We try to show you content, such as news and presentations, that is relevant to you, your company, your industry, or your profession. We also use Users’ information and content for invitations and communications promoting our Services that are tailored to the recipient.

In order to allow you to use certain Services, we may be required to verify your identity. To do so, we may, directly or through third parties, use information you provide to verify information you provide against third party databases or through other sources. We may also use your information to verify your identity in the event you contact us for assistance with the Services.

3.7. Sharing Information with Third Parties

We do not rent or sell personal information that you have not posted on our Services, except as described in this Privacy Policy. We will not disclose personal information that is not published to your profile or generated through engagement with our other services except to carry out your instructions or unless we have your separate consent, unless we have a good faith belief that disclosure is permitted by law or is reasonably necessary to: (1) comply with a legal requirement or process, including, but not limited to, civil and criminal subpoenas, court orders or other compulsory disclosures; (2) enforce this Privacy Policy or our User Agreement; (3) respond to claims of a violation of the rights of third parties; (4) respond to User service inquiries; (5) in order to investigate, prevent, defend against, or take other action regarding violations of our Terms of Service, illegal activities, suspected fraud, or situations involving potential threats to the legal rights or physical safety of any person or the security of our network or Services; or (6) protect the rights, property, or safety of Structural, our Services, our Users, or the public. See Section 2.9 for additional details about our compliance with legal requests for information.

Also, if you have opted to bind any of your Service accounts to your Twitter, Facebook, Instagram, Google, or other similar account, you can easily share content from our Services to these third party services, in accordance with your settings (which you may change at any time) and respective policies of these third parties.

3.8. Polls

Polls may be conducted by Users of your company. It is up to you whether you provide this information. Your consent to use any personal information for the purposes set forth in the poll will be explicitly requested by the party conducting it.

3.9. Search

You can search for Users, information about your company, and polls on our Services. We use personal information from our Services, including User profiles to inform and refine our search service.

3.10. Announcements

If you share content via Announcements, you should be aware that any information you choose to disclose using these services can be read, collected, and used by other Users in your company. We are not responsible for the information you choose to submit. Your contributions are typically searchable on our Services and others may copy and use the information that you share.

3.11. Compliance with Legal Process and Other Disclosures

It is possible that we may need to disclose personal information, profile information, or information about your activities as a User when required by law, subpoena, or other legal process, whether in the United States or other jurisdictions, or if we have a good faith belief that disclosure is reasonably necessary to (1) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce the User Agreement, investigate and defend ourselves against any third-party claims or allegations, or protect the security or integrity of our Service; or (3) exercise or protect the rights, property, or safety of Structural, our Users, personnel, or others. We attempt to notify Users about legal demands for their personal information when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. In light of our principles, we may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but do not commit to challenge every demand.

3.12. Disclosures to Others as the Result of a Change in Control or Sale of Structural, Inc.

We may also transfer, sell, or assign information concerning your relationship with us, including, without limitation, personally identifiable information that you provide and other information concerning your relationship with us to a third party as part of a sale of the assets of Structural, Inc., a subsidiary, or division, or as the result of a change in control of the company or one of its affiliates, or in preparation for any of these events. Any third party to which we transfer or sell our assets will have the right to continue to use the personal and other information that you provide to us in the manner set out in this Privacy Policy.

3.13. Service Providers

We may employ third party companies and individuals to facilitate our Services (e.g. maintenance, analysis, audit, marketing and development) if reasonably necessary to enable them to assist in fulfilling the requests you make or the transactions you conduct via the Sites, including the operation of certain Site functions and Services that require access to information you supply online. In such cases, if such affiliated companies or third parties acting on our behalf are given access to the User Information you have supplied to us, we require that the companies abide by our privacy policy and institute safeguards to protect the confidentiality of your information. These third parties have limited access to your information only to perform these tasks on our behalf and are obligated to Structural not to disclose or use it for other purposes.

3.14. Data Processing Outside Your Country

We may transfer your information and process it outside your country of residence, wherever Structural, its affiliates and service providers operate.

3.15. Analyzing User Behavior

We may use your information for internal analysis such as analyzing user behavior in aggregate for research.

3.16. Technical Information

When you visit our Sites, we may collect technical and navigational information, such as computer browser type, Internet protocol address, pages visited, and average time spent on our Site. This information may be used, for example, to alert you to software compatibility issues, or it may be analyzed to improve our web design and functionality.

3.17. Mobile Information

When you use the mobile versions of our Sites, we may collect the unique device identifier assigned to that device by phone makers, carriers, or makers of the operating system (the “Device ID”). Device IDs allow Structural and other app developers to uniquely identify your device for purposes of storing application preferences and other data. We may use your Device ID for security purposes. For example, if you have activated a feature that limits access to a Service from a specific device, our systems will access the Device ID from each device you attempt to access the Service with to determine if the device is the specific authorized device. Additionally, we may use Device IDs to monitor suspicious activity. For example, if we detect that a single account on a Site is being accessed from multiple devices, as determined by tracking the Device IDs that access an account, we may contact the user to ensure that such access has been authorized by the user.

3.18. User Feedback

Any feedback, questions, comments, suggestions, ideas, or the like that you send to Structural will be treated as being non-confidential and nonproprietary, and Structural will be free to use such information for any purpose whatsoever including, but not limited to, developing, manufacturing, and marketing products and services incorporating the information.

  1. Emails from Which You May Opt-Out

Structural complies with the Controlling the Assault of Non-Solicited Pornography and Marketing Act of 2003. Structural provides users periodic Site-related notifications, newsletters, or other information via email. Users may elect to stop receiving such messages at their discretion. If you no longer wish to receive periodic email updates from Structural, you may update your account preferences on the Site. You may also follow the unsubscribe instructions included in each promotional email. However, please note that certain Services-related (or transactional) email messages that we send users are necessary for the proper functioning and use of the Services, and users who participate in such Services do not have the ability to opt-out of such email messages.

  1. Third Party Providers

We may use third party service providers to help us analyze certain online activities. For example, these service providers may help us measure the performance of our online promotions or determine Site activity. We do not share any personally identifiable information about our users with these third parties, and these third parties do not collect such information on our behalf.

  1. Third Party Providers

6.1. How We Use Cookies.

To enhance your experience with our Sites, many of our pages use “cookies.” Cookies are text files that are placed on your computer to store your preferences or for other record-keeping purposes. Cookies and other user tracking mechanisms (e.g., local shared objects), by themselves, do not tell us your email address or other personally identifiable information unless you choose to provide this information to us by, for example, registering at our Site. However, once you choose to furnish us with personally identifiable information, this information may be linked to the data stored in the cookie or other tracking mechanism. We may use cookies and other user tracking mechanisms, including “persistent cookies”, which will remain on your computer even after you close your browser, to understand Site usage and to improve the content and offerings on our Sites. For example, we may use cookies to personalize your experience at our Site (e.g., to recognize you by name when you return to our Site), and to save your password in password-protected areas. We also may use cookies to offer you products, programs, or services. While most browsers are set to accept cookies and other tracking devices by default, you can set yours to refuse tracking devices or to alert you before accepting them. However, by disabling tracking devices, you may not have access to the entire set of features of our Sites. Your browser manufacturer has information on changing the default setting for your specific browser.

6.2. Other Internet Technology.

Structural may use standard Internet technology, such as web beacons and similar technologies, to track your use of the Site or to track your response to email messages that we send you in connection with the Sites or Services. Web beacons (sometimes called transparent GIFs, clear GIFs, or web bugs) are small strings of code that provide a way for us to deliver a small graphic image (usually invisible) on a web page or in an email. Web beacons can recognize certain types of information on your computer such as cookies, the time and date a page is viewed, and a description of the page where the web beacon is placed. Structural may use web beacons to improve your experience on the Site, including to provide you with content customized to your interests and to understand whether users read email messages and click on links contained within those messages so that the Site can deliver relevant content. Our web beacons may collect some contact information (for example, the email address associated with an email message that contains a web beacon).

6.3. Analytics Software.

We use analytics software to allow us to better understand the functionality of our Mobile Applications on your mobile devices. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded.

  1. No Guarantees

7.1. Factors Beyond Our Control.

While this Privacy Statement expresses Structural’s standards for protection of personally identifiable information, Structural is not in a position to guarantee that the standards will always be met. There may be factors beyond our control that may result in unintentional disclosure of data. We follow generally accepted industry standards to protect the User Information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your User Information, we cannot guarantee its absolute security and are not responsible for the theft, destruction, or inadvertent disclosure of your personally identifiable information.

7.2. Compromise or Breach.

In the unfortunate event that your “personally identifiable information” (as the term or similar terms are defined by any applicable law requiring notice upon a security breach) is compromised, we may notify you by email (at our sole and absolute discretion) to the last email address you have provided us in the most expedient time reasonable under the circumstances; provided, however, delays in notification may occur while we take necessary measures to determine the scope of the breach and restore reasonable integrity to the system as well as for the legitimate needs of law enforcement if notification would impede a criminal investigation.

  1. Your Choices & Obligations

8.1. Rights to Access, Correct, or Delete Your Information, and Closing Your Account

You have a right to (1) access, modify, correct, or delete your personal information controlled by Structural regarding your profile and (2) change or remove your content. Your organization provides your first name, last name, and company email address as a requirement of our services agreement; other information that either you or your company provides can be modified, corrected or deleted. You can request or your information be deleted by contacting us at support@structural.com. However, we recommend you contact the person at your organization responsible for your Structural account prior to requesting the deletion of any data, as it may remove your ability to access our services, and will reduce the information available to your organization via our platform. You can request your personal information that is not viewable on your profile or readily accessible to you (if any) by contacting support@structural.com. If you or your employer terminate your employment, your information will generally be removed from the Service within 24 hours. We generally delete closed account information and will de-personalize any logs or other backup information through the deletion process within 30 days of account closure, except as noted below.

Please note: If you ask us to delete your account, we will use commercially reasonable efforts to remove your data from our servers. Despite such removal, portions of your data may remain on our production and back-up servers indefinitely. Information you have shared with others (for example, through profile updates, announcements, or polls) or that others have copied may also remain visible after you have closed your account or deleted the information from your own profile. In addition, you may not be able to access, correct, or eliminate any information about you that other Users copied or exported out of our Services, because this information may not be in our control.

Please note: Information you have shared with others (for example, through profile updates, announcements, or polls) or that others have copied may also remain visible after you have closed your account or deleted the information from your own profile. In addition, you may not be able to access, correct, or eliminate any information about you that other Users copied or exported out of our Services, because this information may not be in our control.

8.2. Data Retention

We retain the personal information you provide while your account is in existence or as needed to provide you services. We may retain your personal information even after you have closed your account if retention is reasonably necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes between Users, prevent fraud and abuse, or enforce this Privacy Policy and our User Agreement. We may retain personal information, for a limited period of time, if requested by law enforcement. Our Customer Service may retain information for as long as is necessary to provide support-related reporting and trend analysis only, but we generally delete or de-personalize closed account data consistent with Section 3.1.

  1. Important Information

9.1. Minimum Age

As described in Section 2.1 of the User Agreement, persons must be of Minimum Age to use Structural.

9.2. Changes to this Privacy Policy

We may change this Privacy Policy from time to time. We reserve the right, at our discretion, to make changes to this Privacy Policy from time to time, so please review it frequently. You may review updates to our Terms of Service and Privacy Policy at any time via links on https://structural.com/privacy/. You agree to accept electronic communications and/or postings of revised versions of this Privacy Policy on https://structural.com/privacy/ and agree that such electronic communications or postings constitute notice to you of the revised version of this Privacy Policy. If we make significant changes in the way we treat your personal information, or to the Privacy Policy, we will provide notice to you on the Services or by some other means, such as email. Please review the changes carefully. If you agree to the changes, simply continue to use our Services. If you object to any of the changes to our terms and you no longer wish to use our Services, you may close your account(s). Unless stated otherwise, our current Privacy Policy applies to all information that we have about you and your account. Using our Services after a notice of changes has been communicated to you or published on our Services shall constitute consent to the changed terms or practices.

9.3. Security

We have implemented security safeguards designed to protect the personal information that you provide in accordance with industry standards. Access to your data on our Services is password-protected. We also offer secure https access to the Structural.ai website. To protect any data you store on our servers, we also regularly monitor our system for possible vulnerabilities and attacks, and we use a tier-one secured-access data center. However, since the Internet is not a 100% secure environment, we cannot ensure or warrant the security of any information that you transmit to us. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. It is your responsibility to protect the security of your login information. Please note that emails, instant messaging, and similar means of communication with other Users are not encrypted, and we strongly advise you not to communicate any confidential information through these means. Please help keep your account safe by using a strong password.

  1. European Economic Area

If you are accessing the Site while in the European Economic Area, please review our GDPR notice available here.

 

How To Contact Us

If you have questions or comments about this Privacy Policy, please contact us online (support@structural.com) or by physical mail at:

Structural, Inc.

Attn: Privacy Policy Issues

370 Wabasha Street N, Suite 660

St. Paul, MN 55102