PRIVACY & COOKIES POLICY

I.DEFINITIONS

1. Whenever in this privacy policy reference is made to:

1.1. Administrator” – it shall mean Creoox AG (address: Landstrasse 97, 9494 Schaan, Liechtenstein, e-mail address: feedback@structool.com);

1.2. Administrator’s Cookies” – it shall mean the Cookies placed by the Administrator, connected with rendering electronic services by the Administrator by means of the Website;

1.3. Cookies” – it shall mean electronic data, in particular small text files, saved and stored on the devices used by the User to browse the Website;

1.4. Device” – it shall mean the electronic device by means of which the User is accessing the Website;

1.5. External Cookies” – it shall mean the Cookies placed by the Administrator’s partners through the Website;

1.6. Policy” – it shall mean the present privacy & cookies policy;

1.7. Service” – it shall mean a service rendered electronically by the Administrator, consisting in enabling access to the Website by means of an ICT system used by the User;

1.8. User” – it shall mean an entity for whom or which (in accordance with the Terms of Service and the provisions of law) the Services may be rendered or with whom (or which) an agreement on rendering the Services may be concluded;

1.9. Website” – it shall mean the website and the application available at the address: www.structool.com , consisting inter alia of a graphic-interface-based design application hosted and made available as a software-as-a-service.

II.THE SUBJECT OF THE POLICY

2. This Policy determines:

2.1. the rules of processing personal data by the Administrator; and

2.2. the rules of storing and accessing the information on User’s Devices by means of Cookies, for the aim of execution of the electronic services demanded by the User and rendered by the Administrator.

III.PERSONAL DATA PROTECTION

3.1. The Administrator attaches particular importance to ensuring the privacy of the Users. In order to respect the Polish act of 29th August 1997 on personal data protection, he carefully chooses and applies proper technical and organizational means to ensure due protection of processed data. In particular the Administrator protects the data against processing it in breach of the legal regulations in force. The Administrator permanently controls the processing of the data and limits the access to the data to the possibly widest extent, by giving appropriate authorisations for processing only when it is necessary to correctly manage and use the Website. Within the framework of the Personal Data Security Policy and the IT System Management Instruction that have been implemented by the Administrator, the Administrator informs on the following rules regarding protection of the personal data of the Users.

3.2. The Users’ personal data is processed in accordance with the Polish act of 29th August 1997 on personal data protection.

3.3. The Users’ personal data is processed on the basis of Users’ consents and on the basis of statutory authorisations permitting to process the personal data in order to realize and settle the rendered services, as well as in order to achieve other legally justified aims realized by the Administrator and the receivers of the data, with the reservation that the processing does not infringe Users’ rights and freedoms.

3.4. Submitting any personal data is voluntary, nevertheless submitting certain personal data is a condition of using the Website.

3.5. The Administrator shall process the Users’ personal data in order to:

3.5.1. render the Services for the Users;

3.5.2. execute the legally permissible activities in the fields of marketing and promotion.

3.6.T he Users’ data may be made accessible to the entities entitled to it on the basis of the legal regulations in force, in particular the appropriate state authorities.

3.7. The Administrator does not process any sensitive personal data of the Users.

3.8. Each User is entitled to:

3.8.1. correct, supplement, update and rectify his personal data;

3.8.2. demand the removal of his personal data;

3.8.3. raise objections against processing his personal data.

3.9. With respect to the aims referred to in point 10. the User may send a written request or an e‑mail containing a request to the Administrator’s address indicated in point 1.1.

3.10. The Users’ data shall be stored no longer than it is necessary for the realization the aim of its processing, and shall be subsequently erased.

3.11. The Administrator uses the IP addresses collected during internet connections. It is done for technical aims, related to the administration of the Website. Furthermore, the IP addresses are used to collect general statistical data.

IV.GENERAL REMARKS ON COOKIES

4.1. The Website applies the Cookies. The information collected by means of the Cookies allows to adjust the services and the content to individual needs and preferences of the Users, as well as it is used only to draw up general statistics concerning usage of the Website. Disabling the option enabling to save Cookies by changing the settings of the web browser generally does not prevent using the Website.

4.2. The Cookies applied by the Administrator are not dangerous for the User’s Device. In particular it is not possible to transfer any viruses or other malicious software this way. The Cookies enable identification of the software used by the User and make it possible to adjust the Website individually to each User. The Cookies usually contain the name of the domain of their origin, the time of storing them on the Device, as well as the value assigned to them.

4.3. The Administrator applies two types of Cookies:

4.3.1. the Session Cookies: they are stored on User’s Device until the browser’s session is ended. The saved information is then permanently erased from the Device’s memory. The mechanism of the Session Cookies does not allow to collect any personal data or any confidential information from the User’s Device;

4.3.2. the Persistent Cookies: they are stored on User’s Device and stay there until they are erased. Ending browser’s session or turning the Device off does not lead to erasing them from the User’s Device. The mechanism of the Persistent Cookies does not allow to collect any personal data or any confidential information from the User’s Device.

4.4. The User has the option of reducing or disabling the Cookies’ access to his Device. In the event of using this option, using of the Website shall be possible, with the exception of the functions that require Cookies per se.

V.AIMS OF COOKIES’ APPLICATION

5.1. The Administrator uses the Administrator’s Cookies for the following aims:

5.1.1. configuration of the Website, i.e.:

5.1.1.1. adjusting the content of the Website to the User’s preferences and to optimize using of the Website;

5.1.1.2. recognition of the User’s Device and its localization, as well as respective viewing of internet advertisements adjusted to User’s individual needs;

5.1.1.3. saving the preferences chosen by the User;

5.1.1.4. saving the history of the sites visited within the Website in order to recommend the content;

5.1.1.5. the font size, the look of the site etc.

5.1.2. authentication of the User within the Website and ensuring User’s session within the Website, i.e.:

5.1.2.1. correct configuration of chosen functions of the Website, enabling in particular the verification of authenticity of browser’s session;

5.1.2.2. optimisation and improvement of efficiency of the services rendered by the Administrator

5.1.3. realization of the procedures necessary for full functionality of the internet sites, i.e.:

5.1.3.1. adjustment of the content of the sites within the Website to the User’s preferences and optimisation of using the internet sites within the Website. In particular these files enable to recognise the general parameters of the User’s Device and properly view the Website in a way adjusted to User’s individual needs;

5.1.3.2. correct service of the partner programme, enabling in particular the verification of the sources of Users’ redirection to the Website.

5.1.4. saving the User’s location – i.e. proper configuration of chosen functions of the Website, enabling in particular to adjust the delivered information to the User, including his location;

5.1.5. analysis and research, as well as the audit of viewership – creating anonymous statistics, which help to understand the way the Users use the Website;

5.1.6. rendering the advertising services – i.e. adjusting the advertisements (inter alia of services and products of third parties) presented via the Website;

5.1.7. ensuring the safety and reliability of the Website.

5.2. The Administrator uses the External Cookies for the following aims:

5.2.1. presenting, within the Website, of the multimedia content downloaded from the external internet sites:

5.2.2. collection of general and anonymous statistical data via analytical tools:

5.2.3. presenting the advertisements adjusted to the User’s preferences with a use of internet advertising:

5.2.4. using interactive functions for the aim of popularization of the Website by means of social media:

5.3. The User may individually and at any time change the preferences regarding Cookies, by defining the conditions of storing them and of accessing the User’s Device by the Cookies. The changes of the preferences referred to in the previous sentence may be done by the User through modifying the browser’s settings or through configuration of the service. The said preferences may be changed in particular in a way blocking automatic servicing of Cookies in the settings of the browser or informing on each case of placing Cookies on User’s Device. The detailed information on the possibilities and ways of servicing Cookies are available in the settings of the software (the browser).

5.4. The User may at any time delete the Cookies by using the functions available within his browser.

5.5. Restrictions of using the Cookies may influence certain functionalities available within the Website.