Studio:31 cares deeply about the privacy of its visitors and users, and is fully committed to protect their personal information and use it properly in compliance with data privacy laws. This policy describes how we may collect and use personal information, and the rights and choices available to our visitors and users regarding such information.
We strongly urge you to read this policy and make sure you fully understand it, before you access or use any of our services.
1. Please read carefully!
2. What information do we collect?
2.1. Visitor and User Information
We collect two types of information regarding our Visitors and Users:
Un-identified and non-identifiable information pertaining to a Visitor or un-identified User, which may be made available to us, or collected automatically via his/her use of the Services (“Non-personal Information”). Such Non-personal Information does not enable us to identify the Visitor or User from whom it was collected. The Non-personal Information collected by us mainly consists of technical and aggregated usage information, such as Visitors’ and Users’ browsing and ‘click-stream’ activity on the Services, session heatmaps and scrolls, non-identifying information regarding the Visitor’s or User’s device, operating system, internet browser, screen resolution, language and keyboard settings, internet service provider, referring/exit pages, date/time stamps, etc.
Individually identifiable information, namely information that identifies an individual or may with reasonable efforts cause the identification of an individual, or may be of private or sensitive nature (“Personal Information”). The Personal Information collected by us mainly consists of contact details (e.g., e-mail address or phone number), billing details (name, physical billing address, payment method and transaction details), which are only collected from Users with Paid Services, details regarding a browsing or usage session (IP address, Geo-location and/or device unique identifier), details regarding connected third party accounts (such as the e-mail or username for a connected PayPal, Google or Facebook account), or official company registration documents), correspondences (including those made through or uploaded to our Services), and any other Personal Information provided to us by Visitors and/or Users through their access to and/or use of the Services. For the avoidance of doubt, any Non-personal Information that is connected or linked to Personal Information (for example, in order to improve the Services we offer) is deemed and treated by us as Personal Information, as long as such connection or linkage exists.
2.2. Users Information
We may also collect similar information pertaining to visitors and users of our websites or services (users), solely for and on our Users’ behalf (as further described in section 6 below).
2.3. Studio:31 Jobs Applicant Information
We also collect information that is provided to us by Studio:31 jobs candidates (“Applicants”), when they apply to any of the open positions published at www.S31uk .com, by e-mail or otherwise (as further described in Section 7 below).
3. How do we collect such information?
There are two main methods we use:
We collect information through your use of the Services. When you visit or use our Services, including when you browse the Website or any User Website, register a User Account, edit your User Website and upload information and content, and/or download and use any Studio:31 Apps and/or Mobile Apps, we are aware of it and will usually gather, collect and record such uses, sessions and related information, either independently or with the help of third-party services as detailed in Section 8 below, including through the use of “cookies” and other tracking technologies, as further detailed in Section 9 below.
We collect information which you provide us voluntarily. For example, we collect the Personal Information you provide us when you register to our Services; when you sign in to our Services via third party services such as Facebook or Google; when you submit or upload such Personal Information as you use any of our Services; and/or when you contact us directly by any communication channel (e.g., Studio:31 ’s emails).
We also collect information from third party sources as described in Section 8 below.
4. Why do we collect such information?
We collect such Non-personal and Personal Information for the following purposes:
To provide and operate the Services;
To further develop, customize and improve our Services, based on Visitors’ and Users’ common or personal preferences, experiences and difficulties;
To provide our Users with ongoing customer assistance;
To be able to contact our Visitors and Users with general or personalized service-related notices and promotional messages (as further detailed in Section 10 below);
To facilitate, events and promotions, monitor performance;
To create aggregated statistical data and other aggregated and/or inferred Non-personal Information, which we or our business partners may use to provide and improve our respective services;
To enhance our data security and fraud prevention capabilities;
To consider Applicants’ candidacy for working at Studio:31 (as further detailed in Section 7below); and
To comply with any applicable laws and regulations.
We will only use your Personal Information for the purposes set out in Section 4 where we are satisfied that:
our use of your Personal Information is necessary to perform a contract or take steps to enter into a contract with you, or
our use of your Personal Information is necessary to comply with a relevant legal or regulatory obligation that we have, or
our use of your Personal Information is necessary to support legitimate interests that we have as a business (for example, to maintain and improve our Services by identifying user trends and the effectiveness of Studio:31 campaigns and identifying technical issues), provided it is conducted at all times in a way that is proportionate, and that respects your privacy rights.
5. Where do we store your information?
5.1. Studio:31 Visitors’, Studio:31 Users’ and Users Personal Information may be maintained, processed and stored by Studio:31 and our authorized affiliates and service providers as necessary for the proper delivery of our Services and/or as may be required by law (as further explained below).
Studio:31 Jobs Applicants Information will be maintained, processed and stored as necessary, in secured cloud storage provided by our Third Party Services.
Studio:31 Ltd. is based in UK, which is considered by the European Commission to be offering an adequate level of protection for the Personal Information of EU Member State residents.
Studio:31 affiliates and service providers that store or process your Personal Information through Studio:31 ’s website are each contractually committed to keep it protected and secured, in accordance with industry standards and regardless of any lesser legal requirements which may apply in their jurisdiction.
Upon request Studio:31 will provide you with information about whether we hold any of your Personal Information. You may access, correct, or request deletion of your Personal Information by following the instructions provided in these Help Center articles: “GDPR: Retrieving Your Studio:31 Account Data” or “GDPR: Permanently Deleting Your Studio:31 Account. We will respond to your request within a timeframe imposed by local laws or a reasonable timeframe.
Please note that permanently deleting your Studio:31 account erases all of your information from Studio:31 's databases. After completing this process, you can no longer use any of your Studio:31 Services, your User Account and all its data will be removed permanently, and Studio:31 will not be able to restore your account or retrieve your data in the future. If you contact Studio:31 in the future, the system will not recognize your account and will not be able to locate the deleted account.
6. Users information
We may collect, store and process certain Non-personal and Personal Information of Users (Users Information), solely on our behalf and at their direction.
For such purposes, Studio:31 and Services Provider serves and shall be considered as a “Processor” and not as the “Controller” (as both such capitalized terms are defined in the European Union General Data Protection Regulation) of such Users-of-Users Information. The Users controlling and operating such User Websites shall be considered as the “Controllers” of such Users-of-Users Information, and are responsible for complying with all laws and regulations that may apply to the collection and control of such Users-of-Users Information, including all privacy and data protection laws of all relevant jurisdictions.
We cannot provide legal advice to Users,
If you are a visitor, user or customer, please read the following:
We no direct relationship with the individual users whose Personal Information we process. If you are a visitor, user or customer of any of our services, and would like to make any requests or queries regarding your Personal Information, please contact us directly. For example, if you wish to access, correct, amend, or delete inaccurate information processed by us or our Service Providers, please direct your query to the relevant us (who is the “Controller” of such data). If requested to remove any Users Personal Information, we will respond to such request within thirty (30) days. Unless otherwise instructed by our users, we will retain Users Personal Information for the period set forth in Section 13 below.
7. Studio:31 Careers applications
Studio:31 welcomes all qualified Applicants to apply to any of the open positions published at https://www.s31uk.com, by sending us their contact details and CV (“Applicants Information”) via the relevant Position Application Form on our Website, or through any other means provided by us.
We understand that privacy and discreetness are crucial to our Applicants, and are committed to keep Applicants Information private and use it solely for Studio:31’s internal recruitment purposes (including for identifying Applicants, evaluating their applications, making hiring and employment decisions, and contacting Applicants by phone or in writing).
Please note that Studio:31 may retain Applicants Information submitted to it for no longer than two years after the applied position has been filled or closed. This is done so we can re-consider Applicants for other positions and opportunities at Studio:31; so we can use their Applicants Information as reference for future applications submitted by them; and if the Applicant is hired, for additional employment and business purposes related to his/her work at Studio:31 .
If you previously submitted your Applicants Information to Studio:31, and now wish to access it, update it or have it deleted from Studio:31’s systems, please contact us at firstname.lastname@example.org.
8. Sharing personal information with third parties
Studio:31 may share your Personal Information with third parties (or otherwise allow them access to it) only in the following manners and instances:
8.1. Third Party Services:
Studio:31 has partnered with a number of selected service providers, whose services and solutions complement, facilitate and enhance our own. These include hosting, email and server co-location services, communications and content delivery networks (CDNs), data and cyber security services, billing and payment processing services, domain name registrars, fraud detection and prevention services, web analytics, e-mail distribution and monitoring services, session recording and remote access services, performance measurement, data optimization and marketing services, content providers, and our legal and financial advisors (collectively, “Third Party Service(s)”).
Such Third Party Services may receive or otherwise have access to our Visitors’ and Users’ Personal Information and/or Users Personal Information, in its entirety or in part – depending on each of their particular roles and purposes in facilitating and enhancing our Services and business, and may only use it for such purposes.
Studio:31 is accountable for Personal Information that it receives under the Privacy Shield and subsequently transfers to a third party as described above. In particular, Studio:31 remains responsible and liable as mentioned above if third-party agents that it engages to process the Personal Information on its behalf do so in a manner consistent with Studio:31 Principles.
8.2. Law Enforcement, Legal Requests, and Duties:
Where permitted by local data protection laws, Studio:31 may disclose or otherwise allow others access to your Personal Information pursuant to a legal request, such as a subpoena, legal proceedings, search warrant or court order, or in compliance with applicable laws, if we have good faith belief that the law requires us to do so, with or without notice to you.
8.3. Protecting Rights and Safety:
Studio:31 may share your Personal Information with others if we believe in good faith that this will help protect the rights, property or personal safety of Studio:31 , any of our Users, or any member of the general public, with or without notice to you.
8.4. Social Media Features and Framed Pages:
Our Services include certain Social Media features and widgets, single sign on features, such as the “Facebook Connect” or “Google Sign-in”, the “Facebook Like” button, the “Share this” button or other interactive mini-programs (“Social Media Features”).These Social Media Features may collect information such as your IP address or which page you are visiting on our Website, and may set a cookie to enable them to function properly. Social Media Features are either hosted by a third party or hosted directly on our Services. Your interactions with these third parties’ Social Media Features are governed by their policies and not ours.
In addition, our Services may enable you to share your Personal Information with third parties directly, such as via page framing techniques to serve content to or from Third Party Services or other parties, while preserving the look and feel of our Website and Services (“Frames”). Please be aware that if you choose to interact or share any Personal Information via such Frames, you are in fact providing it to these third parties and not to us, and such interactions and sharing too are governed by such third parties’ policies and not ours.
8.5. Studio:31 Subsidiaries and Affiliated Companies:
Your Personal Information in manners other than as described above, pursuant to your explicit approval, or if we are legally obligated to do so. Moreover, Studio:31 may transfer, share, disclose or otherwise use Non-personal Information in its sole discretion and without the need for further approval.
We may share the information of our visitors, users and their users-of-users with various third parties, including certain service providers, law enforcement officials and application developers.
The information may be shared solely in accordance with this policy.
Studio:31, together with its marketing, analytics and technology partners, uses certain monitoring and tracking technologies (such as cookies, beacons, pixels, tags and scripts). These technologies are used in order to maintain, provide and improve our Services on an ongoing basis, and in order to provide our Visitors, our Users with a better experience. For example, thanks to these technologies, we are able to maintain and keep track of our Visitor’s and Users’ preferences and authenticated sessions, to better secure our Services, to identify technical issues, user trends and effectiveness of campaigns, and to monitor and improve the overall performance of our Services.
Cookies: In order for some of these technologies to work properly, a small data file (“cookie”) must be downloaded and stored on your device. By default, we use several persistent cookies for purposes of session and user authentication, security, keeping the User’s preferences (e.g., regarding default language and settings), connection stability (e.g., for uploading media, using e-Commerce features, etc.), monitoring performance of our services and marketing campaigns, and generally providing and improving our services.
If you want to delete or block any cookies, please refer to the help and support area on your internet browser for instructions on how to locate the file or directory that stores cookies. Information on deleting or controlling cookies is also available at www.aboutcookies.org.uk
(note that this website is not provided by Studio:31 , and we, therefore, cannot ensure its accuracy, completeness or availability).
Please note that deleting our cookies or disabling future cookies or tracking technologies may prevent you from accessing certain areas or features of our Services, or may otherwise adversely affect your user experience.
Clear Gifs: We and certain Third Party Services may employ a software technology called “clear gifs” (a.k.a. Web Beacons/Web Bugs), which enables them and us to improve our Services by measuring their effectiveness and performance. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, however are not stored on your device, but instead embedded within our Services.
Flash and HTML5: We and certain Third Party Services may also employ certain tracking technologies known as “Flash cookies” and “HTML5”, mainly for advertising purposes. Various browsers may offer their own management tools for removing or blocking such technologies. Additional information about managing Flash cookies is available here.
(Please note that this website is not provided by Studio:31 , and we therefore cannot ensure its accuracy, completeness or availability).
User Data Supplementation: We may receive information about you from other sources, including publicly available databases or third parties from whom we have purchased data, and combine this data with information we already have about you. This helps us to update, expand and analyse our records, identify new customers, and provide products and Services that may be of interest to you. Where we obtain your Personal Information from these third parties, we ensure that such parties are contractually committed to inform you that your Personal Information will be disclosed to us and we take steps to ensure the accuracy of your Personal Information before using it. If you provide us personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us.
“Do Not Track” Signals: Please note that we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application.
10. Communications from Studio:31
10.1. Promotional Messages:
We may use your Personal Information to send you promotional content and messages by e-mail, text messages, direct text messages, marketing calls and similar forms of communication from Studio:31 or our partners (acting on Studio:31’s behalf) through such means.
If you do not wish to receive such promotional messages or calls, you may notify Studio:31 at any time or follow the “unsubscribe” or STOP instructions contained in the promotional communications you receive.
We take steps to limit the promotional content we send you to a reasonable and proportionate level, and to send you information which we believe may be of interest or relevance to you, based on your information.
11. Your rights in relation to your personal information
It is imperative that you have control over your Personal Information. That’s why Studio:31 is taking steps to enable you to access, receive a copy of, update, amend, delete, or limit the use of your Personal Information.
Before disclosing the requested Personal Information, we may ask you for additional information in order to confirm your identity and for security purposes. We reserve the right to charge a fee where permitted by law (e.g., if your request is unfounded or excessive).
If you are a Studio:31 Visitor or User, and you wish to receive a copy, access and/or request us to make corrections to the Personal Information that you have stored with us or wish to request a list of what Personal Information (if any) pertaining to you we disclosed to third parties for direct marketing purposes,
We will make all reasonable efforts to honour your request promptly (unless we require further information from you in order to fulfil your request), subject to legal and other permissible considerations.
12. Questions and Complaints
Our team will investigate the complaint and determine whether a breach has occurred and what action, if any, to take.
We take every privacy complaint seriously and will make all reasonable efforts to resolve your complaint promptly. Our target response time is 30 days.
We expect our procedures will deal fairly and promptly with your complaint. However, if you remain dissatisfied.
13. Data Retention
We may continue to retain such Personal Information even after our services/business has been completed and/or cease to use any particular Services, as reasonably necessary to comply with our legal obligations, to resolve disputes regarding our Users, prevent fraud and abuse, enforce our agreements and/or protect our legitimate interests.
We maintain a data retention policy which we apply to information in our care. Where your Personal Information is no longer required we will ensure it is securely deleted.
Studio:31 has implemented security measures designed to protect the Personal Information you share with us, including physical, electronic and procedural measures. Among other things, we offer HTTPS secure access to most areas on our Services; the transmission of sensitive payment information (such as a credit card number) through our designated purchase forms is protected by an industry standard SSL/TLS encrypted connection. We also regularly monitor our systems for possible vulnerabilities and attacks, and regularly seek new ways and Third Party Services for further enhancing the security of our Services and protection of our Visitors’ and Users’ privacy.
Regardless of the measures and efforts taken by Studio:31, we cannot and do not guarantee the absolute protection and security of your Personal Information, your Users Information or any other User Content upload, published or otherwise shared by Studio:31 or anyone else.
We therefore encourage you to avoid providing us or anyone with any sensitive information of which you believe its disclosure could cause you substantial or irreparable harm. Furthermore, because certain areas on our Services are less secure than others (for example, if you set your Support forum ticket to be “Public” instead of “Private”, or if you browse to a non-SSL page), and since e-mail and instant messaging are not recognized as secure forms of communications, we request and encourage you not to share any Personal Information on any of these areas or via any of these methods.
15. Public forums and user content
Our Services offer publicly accessible communities; please be aware that any information you provide in any such areas may be read, collected, and used by others who access them. To request removal of your Personal Information, feel free to contact us at: office@S31uk.com. In some cases, we may not be able to remove your Personal Information from such areas. For example, if you use a third party application to post a comment (e.g., the Facebook social plugin application) while logged in to your related profile with such third party, you must login into such application or contact its provider if you want to remove the Personal Information you posted on that platform.
In any event, we advise against posting any information (or use any posting means to post information) you don’t wish to publicize on these platforms.
If you upload any content or post it on third party website and provide it in any other way as part of the use of any Service, you do so at your own risk.
We have put adequate security measures in place to protect your Personal Information. However, we cannot control the actions of other Users or members of the public who may access your user content, and are not responsible for the circumvention of any privacy settings or security measures you or we may have placed on your User Website. You understand and acknowledge that, even after its removal by you or us, copies of User Content may remain viewable in cached and archived pages or if any third parties have copied or stored such User Content. To clarify, we advise against uploading or posting any information you do not wish to be public.
16. Contacting us