Last updated: October 26th, 2022
Setori Incorporated (“Setori” or “us”, “our”, “we”) respects your right to privacy. Your ability to make informed choices about the uses of your information is important to us.
This Privacy Notice details how we collect, use and store information and data that we receive. If you have any comments or questions about our privacy policies, please contact us at firstname.lastname@example.org.
This Privacy Notice shall govern all privacy aspects of our websites, including but not limited to https://www.setori.ai/ (the “Site”) and the use of our software development productivity analytics solution (the “Solution”, and together with the foregoing, the “Services”). We may update this Privacy Notice from time to time, and we encourage you to review it periodically.
Please also review the Terms of Service of the Site and Solution (together, the “Terms”). Terms capitalized but not defined herein have the meaning given to them in the applicable Terms. As used in this Privacy Notice, “Personal Data” means information that can be directly associated with a specific person or entity such as a name, address, date of birth, or e-mail address.
A Note on Legal Bases.
Certain jurisdictions do not allow the processing of personal data unless a legal basis has been established. Under the EU’s General Data Protection Regulation (GDPR), the possible legal bases include: where you give your consent, where processing is necessary to perform a contract with you, where processing is necessary to fulfill our legal obligations, or where we have a legitimate business interest to process your personal data. Where we are a controller, we only collect and process data where we have established a legal basis. Below you can find more details about specific legal bases.
Notice to California Residents.
If you are a resident of the State of California, some additional terms and rights may apply to you, as detailed below in the “California Privacy Notice”.
1. Types of Information We Collect.
1.1 Data from persons who visit our Sites, https://www.setori.ai/ including without limitation and any other site governed by this Privacy Notice (“Site Data”). The Site will record certain information automatically, such as your IP address, mobile device or computer, operating system and browser, and geo-location. In addition, we collect any information you provide when you contact us for any reason via our site interface, such as your name, email, address, and other contact information.
1.2 Data collected when we process information in the context of providing services to our customers, including customers that use our Services free of charge (together “Customers”). This is data concerning individuals, including Customer’s personnel and service providers collected when Customers and/or their personnel and/or service providers use the Services (“Customer Data”). Customer Data includes data regarding how systems and code are used, accessed, developed, tested and deployed by employees and service providers of our Customers using our Services. Additionally, this data includes names, emails, and account profiles on development systems such as Git providers, project management and messaging tools may be processed. For the avoidance of doubt, while Setori processes the Customer’s code, Setori does not store the code of the Customer, and deletes it after initial processing. Our processing of Customer Data on behalf of Customers who are located in the EU is subject to the provisions of our Data Processing Agreement, or to specific Data Processing Agreements signed with such customers.
1.3 Data concerning individuals who access our Services through various means of access, including but not limited to browsers, mobile apps, and APIs (“Access Data”). Access Data can include information that is used for your identification or authentication, or to login to our various tools and services, such as names and email addresses, as well as profiles and account information from third party services such as source code and project management tools, and metadata of a user’s activity on such third party services.
You are not required by law to provide us with any of the information described herein, but by using the Services you agree to provide us with such information.
2. Specific Information We Collect.
2.1 Registration Data: In order to access some of our Services, you may first need to create an account. When creating an account, you will be asked to provide information in order to verify your identity. This information may include your name and email address, information from third party providers through whom you access our Services, and any other information we deem reasonably necessary to properly verify your identity.
How We Use this Data: We use your registration data to provide you access to our Services, save your preferences, improve the usability of our Services, protect the security of our Services, prevent fraud, and to address any issues that arise. We use your contact details to communicate with you. We also use your contact details to send you newsletters or promotional materials relating to our products and services. For more information about our Communications and how you can control your preferences, see the Our Communications section below.
Legal Basis: When we process your registration data to provide you with our Services, we do so on the basis of performing a contract with you, in this case our Terms of Service. When we process your registration data we do so in order to maintain the Services, including to prevent fraud, protect the security of and/or address issues with the Services, we do so on the basis of our legitimate interest to maintain our assets. When we use your contact details to send you newsletters and promotional materials relating to our services, we do so based on your consent, and/or our legitimate interest to market our products and services.
2.2 Contact Data: If you contact us for any reason, we collect any Personal Data you provide, such as your email address and the content of your message. When you sign up for newsletters or email lists we collect your name and email address. We may also collect additional information about the company you work for, including without limitation, its name, size, and location, and your role in the company.
If you apply for a job with us, we, or a third party operating on our behalf, collect the information you provide as part of your application and during the course of the application process. This may include your name, contact details, resume, recommendations, and any other information we may request or that you choose to share with us.
From time to time, we hold special events in which we may invite you to participate. If you register for an event, we will collect personal data provided as part of the registration process, such as your name, contact details, and any other information we may request.
If you have signed up for our newsletters and/or if you have contacted us regarding our Services we may send you newsletters or other promotional materials. We try to limit direct marketing to a reasonable and proportionate level and only send you communications which we believe may be of interest to you. Note that we may need to contact you about administrative or service-related issues as part of providing the services to you. This is not direct marketing and even if you opt-out of direct marketing, you will continue to receive these messages
How we use this data: We use this Personal Data to respond to your inquiry, to provide you with newsletters and to provide you with promotional or informational materials matching the interest you have expressed in your sign up request. If you choose to register for one of our special events, we will use the data you provided us for event planning and logistical purposes, to contact you with updates or to ask for your feedback regarding the event, to improve our events, products and services, and for marketing purposes.
Legal Basis: Responding to your inquiry and providing newsletters, where you have requested this is based on performance of a contract with you. When we use your Personal Data to send you promotional or informational materials, this is based on your consent to receive such promotional material. You may withdraw your consent at any point, including by emailing us at email@example.com or by following the “unsubscribe” link in any messages. Note that we may need to contact you about administrative or service-related issues as part of providing the services to you. This is not direct marketing and even if you withdraw your consent to receipt of direct marketing, you will continue to receive these messages.
2.3 Automatically Collected Data: When you use the Services, we automatically collect information about your computer or mobile device. This includes non-Personal Data such as your operating system, and Personal Data such as your IP address, the location associated with your IP addresses, device ID, browsing history and any information regarding your viewing or usage history of the Services. This data is collected through cookies and similar technologies. You can change your browser setting in order to manage which cookies are placed. For more information and how to adjust your preferences, please see the Cookies and Similar Technologies section below.
We may also use social plugins, such as the Facebook plugin, which will allow social media platforms to link Personal Data collected through our Services with Personal Data in your social media profile. This combined data may be used to serve you with advertising or customized content on the applicable social media platform. We recommend you routinely review the privacy notices and preference settings that are available to you on any social media platforms.
How we use this data: We use this data to review how users use our Services, to develop new products or services and improve current content, products, and services, to prevent fraud, protect the security of our Services, and address any problems with the Services. This data is often used in an aggregated and non-specific analytical manner. We also use this data in order to provide you with customized content and targeted offers related to our Services
Legal Basis: Reviewing, developing, and improving our products and services, as well as fraud prevention and security uses are based on our legitimate interests to manage our business. Similar, using this data to provide you with customized content relating to our Services is also based on our legitimate interest.
2.4 Statistical Information and Analytics: We want to understand how people are using our Services so that we can make improvements, understand user needs, and tailor our services for users. To do this, we use certain third-party analytics tools that help us gather and compile statistical information. One of the third-party analytics tools we use is “Google Analytics”. For more information about how Google collects information and how you can control such use at https://policies.google.com/technologies/partner-sites. We can also anonymize and aggregate data which we can then share with our business partners.
3. Sharing the Personal Data We Collect.
We share your information, including Personal Data, as follows:
3.1 Customers. If you use our Services in connection with a company that is our Customer, that Customer may have access to information about your use of the Services.
3.2 Service Providers and Subcontractors. We disclose information, including Personal Data we collect from and/or about you, to our trusted service providers and subcontractors, who have agreed to confidentiality restrictions and who use such information solely on our behalf in order to: (1) help us provide you with Services; and (2) to assist us in our direct marketing activities described above.
3.3 Business Transfers. In case of any merger or sale of our company or its assets, including in case of liquidation, we may disclose your Personal Data as part of such transaction or during the negotiations leading up to it. In such case, your Personal Data shall continue being subject to this Privacy Notice.
3.4 Law Enforcement Related Disclosure. We may share your Personal Data with third parties: (i) if we believe in good faith that disclosure is appropriate to protect our or a third party’s rights, property or safety (including the enforcement of the Terms and this Privacy Notice); (ii) when required for compliance with any law, regulation, subpoena, court order or other law enforcement related issues, agencies and/or authorities.
4. International Transfer.
We are an international business and we transfer your data to various countries, including the US, where we are located. When we share Personal Data with third parties as described above, these third parties may also be located in countries other than your own. We will ensure that these third parties will be subject to written agreements ensuring the same level of privacy and data protection as set forth in this Privacy Notice.
We have implemented and maintain appropriate technical and organization security measures, policies and procedures designed to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to Personal Data appropriate to the nature of such data. However, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security. You are responsible for the security of the devices you use and for keeping your credentials protected.
6. Your Rights - How to Access and Limit our Use of Certain Personal Data.
Depending on the applicable law, you may have certain rights relating to the Personal Data that we collect about you. If you are in the EU, certain additional rights may apply as detailed below.
6.1 Right of Access. You have a right to know what Personal Data we collect about you. Subject to applicable law, we may charge a fee for providing this information. If we are not able to provide you with all of the information you request, we will do our best to explain to you why.
6.2 Right to Correct Personal Data. Subject to certain limitations, you may request that we update, complete, correct or delete inaccurate, incomplete, or outdated Personal Data.
6.3 Direct Marketing Opt Out. You can change your mind at any time about your election to receive marketing communications from us and/or having your Personal Data processed for direct marketing purposes. If you do, please notify us by email at firstname.lastname@example.org. It may take a few days for us to update our records before any opt out is effective.
7. Data Retention.
7.1 Subject to applicable law, we retain Personal Data as necessary for the purposes set forth above. We may delete information from our systems without notice to you once we deem it is no longer necessary for these purposes. Retention by any of our service providers may vary in accordance with their retention policies.
7.2 In some circumstances, we may store your Personal Data for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax, audit, accounting requirements and so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings.
7.3 Please Contact Us if you would like details regarding the retention periods for different types of your Personal Data.
8. Cookies and Similar Technologies.
8.1 What are Cookies? When we use the term “cookie” we are referring to technologies that get stored locally on your browser or device and which help us identify you and collect information about you. These may be traditional cookies, web beacons, pixel tags, or similar.
8.1.1 Some cookies (session cookies) will only be stored until you leave the Services and some (persistent cookies) will remain for longer periods or until you delete them. For example, persistent cookies may be used to help save your settings across visits
8.1.2 First-party cookies are placed by us, while third-party cookies may be placed by a third party. We use both first- and third-party cookies.
Cookie Consent. When using the Services, you shall be notified of the use of and placement of cookies on your device and will be asked to agree to placement of cookies.
Type of Cookie
These cookies are necessary in order to allow the Services to work correctly. They enable you to access & navigate the Services and utilize different capabilities and features of the Services These cookies cannot be disabled.
These cookies remember your settings and preferences and the choices you make (such as language or regional preferences) in order to help us personalize your experience and offer you enhanced functionality and content.
These cookies can help us identify and prevent security risks. They may be used to store your session information to prevent others from tampering with your login credentials.
Performance & Analytics
These cookies can help us collect information to help us understand how you use our Services, for example whether you have viewed messages or specific pages, which features are popular, and how long you spent on each page. This helps us improve the usability and performance of our Services.
Additionally, cookies and web beacons may be placed in messages we send in order to track your interaction with such emails.
8.3 How to Adjust Your Preferences. You can adjust your preferences through your browser’s settings. You can configure your settings to refuse all cookies and you can delete existing cookies at any time. Note that some features may not work properly if cookies are disabled or removed.
We do not knowingly collect Personal Data from children under the age of sixteen (16). In the event that you become aware that an individual under the age of sixteen (16) has registered to our Services or subscribed to our marketing lists or otherwise provided Personal Data without parental permission, please advise us immediately.
10. Changes to the Privacy Notice.
We may update this Privacy Notice from time to time to keep it up to date with legal requirements and the way we operate our business, and we will place any updates on this webpage. Please come back to this page every now and then to make sure you are familiar with the latest version. If we make material changes to this Privacy Notice, we will seek to inform you by notice on our Site and/or other communication channels.
11. Contact information.
If you have any comments or questions if you wish to exercise any of your legal rights, you can contact us by emailing email@example.com.
Information for EU Individuals
If you are an individual located in the European Union, some additional terms and rights may apply to you.
1 . Controllers and Processors.
1.1 Setori Incorporated is the data controller of your Personal Data as described in this Privacy Notice.
1.2 When we process information in the context of providing services to our customers (“Customers”), such as information about each Customer’s personnel and service providers, the applicable Customer serves as a controller of the personnel and service providers’ Personal Data and Company serves as a processor on its behalf.
2. International Transfers.
Whenever we transfer your Personal Data out of the European Economic Area (“EEA“), including to third parties, and when required under applicable law, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
2.1 We will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission.
2.2 Where we use certain service providers not located in countries with an adequate level of protection as determined by the European Commission, we may use specific contracts approved by the European Commission which give Personal Data the same protection it has in the EEA.
2.3 If you would like further information on the specific mechanism used by us when transferring your Personal Data out of the EEA, please Contact Us.
3. Your Rights.
In addition to the rights described in Section 6 above, you may have certain additional rights in relation to the Personal Data that we or other controllers hold about you. If you want to exercise any of these rights with respect to Personal Data held by other controllers, please contact the applicable controller (such as the relevant Customer) directly. You can also request that we contact all independent controllers. We may ask for reasonable evidence to verify your identity before we can comply with any request.
3.1 Deletion of Personal Data (“Right to Be Forgotten”). You have a right to request that we delete your Personal Data if either: (i) it is no longer needed for the purpose for which it was collected, (ii) our processing was based on your consent and you have withdrawn your consent, (iii) you have exercised your Right to Object (see below), (iv) processing was unlawful, or (iv) we are required to erase it for compliance with a legal obligation. To ensure that we do not collect any additional Personal Data, you should also uninstall any of our software you have installed on your devices, , terminate your account with us, and clear our cookies from any device where you have used our Services. We may retain certain Personal Data (including following your request to delete) as permitted by applicable law.
3.2 Right to Restrict Processing. You can ask us to limit the processing of your Personal Data if either: (i) you have contested its accuracy and wish us to limit processing until this is verified; (ii) the processing is unlawful, but you do not want us to erase the Personal Data; (iii) it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise, or defend of a legal claim; (iv) you have exercised your Right to Object (below) and we are in the process of verifying our legitimate basis for processing. We may continue to use your Personal Data after a restriction request under certain circumstances.
3.3 Right to Data Portability. If the processing is based on your consent or performance of a contract with you and processing is being carried out by automated means, you may be entitled to (request that we) provide you or another party with a copy of the Personal Data you provided to us in a structured, commonly-used, and machine-readable format.
3.4 Withdrawal of Consent. If our processing of your Personal Data is based upon your consent, you may withdraw your consent.
3.5 Right to Object. If processing is based on our legitimate interest, you may object to such processing where you believe your fundamental rights and freedoms outweigh our legitimate interests. If you object, we have an opportunity to demonstrate the validity of our legitimate interest.
3.6 Right to Lodge a Complaint with Your Local Supervisory Authority. You may have the right to submit a complaint to the relevant supervisory data protection authority if you have any concerns about how we are processing your Personal Data, though we ask that as a courtesy you please attempt to resolve any issues with us first.
California Privacy Notice
This California Privacy Notice (“Privacy Notice“) describes how we collect, share, and store personal information about California consumers who use our Services, as well as the choices they have with respect to that information. This Privacy Notice supplements and forms an integral part of our general rivacy notice, to which this Privacy Notice is attached. If not otherwise defined herein, capitalized terms have the meaning given to them in our General Privacy Notice. Please read the General Privacy Notice for additional terms, which may apply to you.
“Personal Information” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, or as otherwise may be defined by applicable law.
Personal Information We Collect and Why
It is your choice whether to provide us with certain Personal Information. However, if you refuse to do so, we may not be able to register you to the Site, and/or you may not be able to use our Services.
Information We Collect from You Directly:
We have collected the following information directly from you in the preceding 12 months and for the following purposes when you used the Services:
- Register for an Account. We collect identifiers such as your name and email address when you register for an account. This information may also include information from third party providers through whom you access our Services, such as Google, Github, Slack, or others, and any other information we deem reasonably necessary to properly verify your identity. We use this information to manage your relationship with us. We use this information to suggest other products or services you might be interested in.
- Sign up for our mailing list or newsletter, apply for a job or register for events. We collect identifiers such as your name and email address, location, affiliated company, role etc. when you sign up for our mailing list, apply for a job or register for events. We use this information to provide you with emails related to promotions, product launches, and service information as well as in order to respond to your inquiries or requests. You can unsubscribe at any time from these emails by clicking the unsubscribe button on the bottom of any such emails.
- Order products or services. We collect identifiers such as your name, email address, mailing address, and telephone number. We use this information to process transactions and to provide the goods or services to you.
- Contact us. If you contact us for technical support for assistance with our services or products, we collect your identifiers such as your name and email address, and any other personal information you choose to provide in such support requests. We use this information to respond to your queries and provide support or technical assistance that you request.
Additional uses: We may also use the Personal information detailed above as permitted by any applicable laws, including, to (i) comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons; (ii) cooperate with law enforcement agencies concerning conduct or activity that we reasonably and in good faith believe may violate applicable law; and (iii) exercise or defend legal claims.
Information We Collect from You Automatically:
We have collected the following information from you automatically in the preceding 12 months and for the following purposes when you used the Services:
- When you use our Services. We automatically collect identifiers such as your IP address, your location information, and your internet and other electronic network activity such as usage data about your browsing actions and patterns related to our Services. We also collect the type of device and operating system and technical data about your equipment. We and third parties on our behalf collect this data by using the following and similar technologies:
- Customer Data: We collect data regarding how our customers’ systems and code are used, planned, accessed and developed by employees and service providers of such Customer. Additionally, names, emails and Git provider profiles may be processed.
- Access Data: Data concerning individuals who access our Services through various means of access, including but not limited to browsers, mobile apps, and APIs. Access Data can include information that is used for your identification or authentication, or to login to our various tools and services, such as names and email addresses, as well as profiles and account information from third party services such as source code and project management tools, and metadata of a user’s activity on such third party services.
- Site Cookies. The Services may utilize “cookies”.
- Web beacons. We use web beacons to collect how you view and interact with emails from us, including which links you click on. We use this information to find out more about users including demographic information and usage patterns for more accurate reporting and to improve the effectiveness of our marketing.
Information We Collect from Third Parties about You:
We have collected the following information from third parties about you in the preceding 12 months and for the following purposes when you used the Services:
- If you apply for a job with us, we, or a third party operating on our behalf, collect the information you provide as part of your application and during the course of the application process. This may include your name, contact details, resume, recommendations, and any other information we may request or that you choose to share with us.
How We Share Your Information
Disclosures of Personal Information for a Business or Commercial Purpose within Preceding 12 Months:
We have disclosed the following categories of Personal Information for the following business or commercial purpose in the preceding 12 months:
- We have disclosed your personal identifiers and internet or other electronic network activity to data analytics providers, operating systems, and other third parties to help us perform services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, providing email communications, providing delivery services, and hosting our site.
- We have disclosed your personal identifiers and internet or other electronic network information to data analytics providers to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and to identify and repair errors that impair functionality of our site.
- We have disclosed your personal identifiers and internet or other electronic network information to advertising networks for auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impression.
- We have disclosed your personal identifiers and internet or other electronic network information with ad networks for short-term transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction.
- We have disclosed your personal identifiers and internet or other electronic network information to data analytics providers and operating systems to help us undertake activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.
- We have disclosed your personal identifiers and internet or other electronic network information to data analytics providers and operating systems to undertake internal research for technological development and demonstration.
Sales of Personal Information within Preceding 12 Months:
We have not sold Personal Information to any third parties in the preceding 12 months
We may also use the Personal Information detailed above as required or permitted by any applicable laws, including, to (i) comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons; (ii) cooperate with law enforcement agencies concerning conduct or activity that we reasonably and in good faith believe may violate applicable law; and (iii) exercise or defend legal claims.
Additionally, we may use the Personal Information detailed above (i) in a deidentified manner, which does not reasonably identify you and cannot reasonably be linked to you; or (ii) as aggregate consumer information, which does not contain any individual consumer identities and is not linked or reasonably linkable to you or your household.
Your Rights – How to Access and Limit Our Use of Certain Personal Information
Subject to certain exemptions, you have certain rights in relation to the Personal Information that we have collected about you, as detailed below. In accordance with applicable law, we may ask for reasonable evidence to verify your identity before we comply with certain of your requests, as detailed below:
- Right of access. You have the right to request that we disclose to you any or all of the following in respect of the 12-month period preceding your request:
(i) the specific pieces of Personal Information that we have collected about you;
(ii) the categories of Personal Information we have collected about you;
(iii) the categories of sources from which we collected the Personal Information about you;
(iv) the categories of third parties with whom we share Personal Information about you;
(v) if applicable, the categories of Personal Information about you we have sold and the categories of third parties to whom we have sold such Personal Information;
(vi) the categories of Personal Information about you we have disclosed for a business purpose and the categories of third parties to whom we have disclosed such Personal Information; and
(vii) our business or commercial purpose(s) for collecting or selling your Personal Information.
To request any of the information detailed above, please submit a verifiable request to us by contacting us at firstname.lastname@example.org. You may only request to exercise your right of access twice within a 12-month period.
- Right to delete. Subject to certain exceptions, you have the right to request that we and any of our service providers delete Personal Information about you collected by us. To request the deletion of your Personal Information, please submit a verifiable request to us by contacting us at email@example.com.
- Right to opt-out of the sale of Personal Information: If we start selling your Personal Information in the future, we will provide information on our webpage which will allow you to opt-out.
- Right to non-discrimination for exercising your consumer privacy rights. You have the right not to be discriminated against by us for exercising any of your consumer privacy rights, such as, not being denied any goods or services or charged different prices or rates.
How to exercise your California privacy rights
- Submitting requests through an authorized agent:
An authorized agent may exercise requests on your behalf. In order to exercise your right to know or right to delete through an agent, we may ask for reasonable evidence to verify your identity and the agent’s identity, and written authorization permitting the agent to act on your behalf before complying with your request. In order to submit a request to opt-out of the sale of your Personal Information through an agent, we may ask for written authorization permitting the authorized agent to act on your behalf before complying with your request. We reserve the right to deny the request of any agent that does not provide proof that they have been authorized to act on behalf of the applicable consumer in accordance with applicable law.
- Submitting a verifiable request:
In order to exercise your right to know or right to delete you must submit a request containing sufficient information that allows us to reasonably verify you are the person about whom we collected the applicable Personal Information or an authorized agent of such person, which may include a form of official identification. Any requests made through your password protected account will be verified through our existing authentication procedures for such account.
- We do not knowingly sell the Personal Information of California residents under 16 years of age.
Comments and Questions
If you have any comments or questions about this Privacy Notice or our privacy practices, or if you wish to exercise any of your legal rights as set out herein, please contact us using the details set out below:
Title: Setori Privacy