Sitero Privacy Policy
Last Updated: 24 November 2022
Overview
Sitero will collect information through its websites or other media that can identify you (if provided by you or by your institution), such as your name, address, phone number, e-mail address, company name and position. Sitero may use this information to respond to your requests for information, products or services. Sitero may also collect information that will usually not allow us to directly identify you, such as information gathered through “cookies” (see below).
When you contact Sitero to request or to access information, you are asked to provide your personal information. By providing your personal information to Sitero via its websites, you agree to the terms of this Privacy Policy and to receive communications from Sitero
Sitero takes the privacy of your personal information very seriously and will use your information only in accordance with the terms of this Privacy Policy.
The information you provide to us will be available to Sitero, its subsidiaries and third parties working with or on behalf of Sitero. Access to your information and the equipment processing it, is at all times restricted to appropriate staff. Except as set forth in this Privacy Policy, Sitero will not trade, sell, release, share or transfer your personal information for use by any business outside the Sitero organization without your consent, or in a form other than what was disclosed to you at the time the information was collected, unless permitted or required by law
In jurisdictions with data protection and privacy laws, and where contractual commitments require, Sitero ensures that individuals can exercise all relevant informational rights with respect to their personal information collected by Sitero via its websites, including, but not limited to, the right of access and correction, to withdraw consent at any time, object to data processing, request data deletion, restrict aspects of data processing, and request transmission of provided personal information in a common digital format (e.g., pdf) to themselves or another organization.
This privacy notice is intended for:
- users of SITERO products and services (excluding research subjects);
- visitors to SITERO and SITERO-owned websites;
- users of SITERO systems and applications;
- members of the general public who are interested in contacting or are being contacted by SITERO; and
- any individual who has received this notice and to whom the other notices in this Privacy Centre do not apply.
If you have questions or concerns regarding this Privacy Policy, you may contact Sitero via the Contact Information at the end of this document.
Information We Collect
We understand that privacy is important to you. We are committed to treating your personal information with care and integrity
Sitero may also collect information that will usually not allow us to directly identify you, such as information gathered through “cookies” (see below).
Sitero collects information from faculty, staff, employees, students and/or general users including name and one or more specific contact methods so that people can be reached. This contact information can include phone/cell/pager numbers, email addresses, etc. It is up to individual client institution policy to determine what personal information is to be provided by their employees or affiliates. Sitero only stores this information for use by authorized individuals within a given client institution and Sitero in no way uses this information for its own purposes. Sitero applications can be used by the client institution to store any type of documentation, including but not limited to institutional policies, research protocols, etc. Control over access to such data resides with the client institution application administrator.
Sitero reserves the right to disclose all information collected when required by law or to respond to judicial process.
Cookies
When you use our sites, Sitero will assign cookie files (“cookies”) to you, which are a small amount of information we send to your web browser. Cookies enable the computers operating our websites to differentiate between visitors and to track the patterns of activities engaged in by different visitors. By tracking such activities, the computers operating our websites can recognize a visitor and customize certain features for that visitor. We may also use aggregated, non-identifiable information regarding persons who visit our site in order to learn more about the use of the site and how we can improve it
You may be able to modify your browser preferences to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose not to accept cookies, you may not be able to use those functions of the websites that require registration.
We may also receive IP addresses in the normal course of the operation of our website. An IP address is a number assigned to you by your Internet service provider so you can access the Internet. Although we do receive IP addresses, we do not use them to identify you personally or disclose them to others
When you interact with the Sitero SaaS we strive to make that experience easy and effective. To this end, we utilize cookies, when possible, with our application. Cookies are files that web browsers place on a computer’s hard drive and are used subsequently by the web application that put them there to know what data was saved in the cookie. Cookies can be set to either expire at the end of your browser session (session cookies) or to remain until some expiration date in the future (persistent cookies).
When you login to the Sitero Mentor application, you have an option to save your Institution ID as a cookie. If you choose to do this, our web application server sends a persistent cookie to your browser (in this case, to tell us what Institution ID you will be using each time you login). If your web browser is configured so that it will not accept cookies, you will need to enter the Institution ID each time you attempt to login unless you are using your institution’s single sign-on system.
Sitero web applications maintain your unique user session by means of session cookies. Web applications are inherently stateless – there is no connection that is maintained between the client browser and the server application. Each time a user clicks on a link or a button in our application, data is sent back to our server, processed by our application and a response page is sent back to the user’s browser. The way our application knows which user is making which request and where they are in the application is by storing data in variables within the user session on the application server, and a session ID is used to identify the unique session. This session ID is stored in a session cookie if your web browser is configured to accept cookies. If not, the session ID is automatically sent via the URL.
All cookies used by Sitero are encrypted via Secure Socket Layer (SSL) technology to ensure security as this data is transmitted between the application server and your browser.
Do-Not-Track Signals and Similar Mechanisms
Some web browsers transmit “do-not-track” signals to websites. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. We currently do not take action in response to these signals.
Server Logs
Web servers maintain log files that show each request and response processed by the server. These log entries contain data including the URL requested and the IP address of the machine making the request. Both the Sitero web applications and the Sitero website store this log information and we use it for the purposes of auditing, analyzing usage and making sure that no requests are being made from suspect locations.
Auditing
The ability to audit activity within its web applications is a necessary function to ensure compliance with a variety of government regulations and client policies. The Sitero applications store information such as when individual’s login and logout of the application, who made specific changes to data and when, who approved changes and when, etc. All information in every transaction is recorded for audit purposes. This information is accessible to authorized individuals only within a given client institution and is not otherwise made available to users outside of that institution.
How We Use Collected Information
Information collected from the Sitero website is only used to facilitate the dialog between Sitero and either current or prospective clients. This information is not shared with outside entities unless otherwise required by law.
We use your personal information for the purposes we have described below in this Privacy Notice, or for purposes which are reasonably compatible with the ones described. We will not, use it for other purposes without your permission, unless we have a legal right or obligation to do so
To manage our relationship with you.
We will use your personal information:
- To respond to your requests;
- To improve our level of service;
- To provide our products and services to you;
- To promote our products and services;
- To manage your account, if necessary;
- To provide you with information when you request it, or when we believe it may be of interest to you;
- To invite you to provide your views on our products and services, participate in research or attend events;
- To consider your application for employment;
- To perform analytics and understand your preferences;
- To provide access where required to our sites and facilities.
- To gain insights and feedback on our products and services in order to correct or improve them, by analyzing information from external sources such as Google, Facebook and Twitter (and others);
- For our own administrative and quality assurance purposes; and
- For other purposes that may be detailed on a website or mobile application which will be described at the time the information is collected.
- To manage and improve our processes and our business operations.
We will use your personal information to:
- Manage our network and information systems security;
- Manage our workforce effectively; and
- Prepare and perform management reporting and analysis, including analytics and metrics.
Security
Both the Sitero website and the Sitero SaaS have security measures in place to help protect against the loss, misuse, and alteration of the data under our control. When our website or web applications are accessed, Secure Socket Layer (SSL) technology protects information using both server authentication and data encryption to help ensure that data is safe, secure, and available only to you. Sitero also implements an advanced security method based on dynamic data and encoded session identifications, and hosts both the website and web applications in secure server environments that use firewalls and other advanced technology to prevent interference or access from outside intruders. Finally, Sitero provides unique user names and passwords that must be entered each time a client logs on to the SaaS. These safeguards help prevent unauthorized access, maintain data accuracy and ensure the appropriate use of data.
Information About Children’s Privacy
Our services are not directed to children and we do not knowingly collect any personal information from minors under the age of 13 years.
Responsibility Regarding Websites That We Do Not Own Or Control
From time to time, we may provide links to websites or mobile applications that are not owned or controlled by us. Our Privacy Notice does not cover them. Please read the privacy notices on those websites and mobile applications if you would like to find out how they collect, use and share your personal information.
Additional Information For California Consumers
This section applies solely California consumers (California residents), and explains your rights under the California Consumer Privacy Act (CCPA)
Sale of Personal information
In the preceding twelve (12) months, Sitero has not sold personal information
Access to specific information and data portability Rights
You have the right to request that Sitero disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive your request and confirm your identity, we will disclose to you the information requested, including:
- The categories of personal information we collected about you
- The categories of sources of the personal information we collected about you
- Our business purpose for collecting that personal information
- The categories of third parties with whom we share that personal information
- The specific pieces of personal information we collected
- Information about any sales of your personal information
Deletion request Rights
You have the right to request that Sitero delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive your request and confirm your identity, we will delete your personal information from our records, unless an exception applies. If an exception applies, you will be notified that the data will not be deleted, along with specific information about the basis for the exception.
Exercising Access, Data Portability and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a request Via Contact Information at the end of this document
Only you, or if you are a California resident, a person registered with the California Secretary of State that you authorize to act on your behalf, may make a request related to your personal information. You may also make a request on behalf of your minor child
We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the personal information subject to the request. For your protection, and to protect the privacy of others, we may need to verify your identity before completing what you have asked us to do. We may need to request additional personal information from you, such as home address, email address and government issued ID, in order to protect against fraudulent or spoofed requests
As part of our verification process, we may request that you provide us with proof that you have been authorized by the California resident on whose behalf you are making the request, which may include signed permission provided by such California resident.
You may only make a request for access or data portability twice within a 12-month period. Your request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative
- Describe your request with sufficient detail to allows us to properly understand, evaluate, and respond to it
- Provide a means to contact you
We will only use personal information provided in a CCPA request to verify the requestor’s identity or authority to make the request
Response timing
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing
Fee
We do not charge a fee to process or respond to your CCPA request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request
Service Providers and Third-Party Terms: Cross Border Data Transfer
Sitero is a global corporation and has developed global data protection practices designed to assure personally identifiable information is appropriately protected and transfer of personal data is within Sitero subsidiaries and is governed by the data processing agreements based on the Standard Contractual Clauses.
Opt-Out Policy
Sitero offers its clients and prospects a means to choose how we may use information provided. If, at any time after registering for information or ordering the SaaS, you change your mind about receiving information from us, send us a request specifying your new choice via the Contact Information at the end of this document.
Accessing and Changing Your Information
You can review the personal information you provided us and make any desired changes to such information at any time by logging in to your account on the Sitero SaaS or by contacting us directly via the Contact Information at the end of this document.
Notification Of Changes
We reserve the right to modify this privacy statement at any time with effect for the future, in particular to adapt it to a further development of the website or the implementation of new technologies, so please review it frequently.
Contact Information
If you have any questions or comments about this Notice, the ways in which Sitero collects and uses your information described above, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us by:
- Sending an email to privacy@sitero.com , Attn: Privacy
- Calling us at +1 (747) 666-0894; Monday through Friday between the hours of 7am and 7pm ET
- Write us at Sitero LLC, 3648 Grand Ave, Miami, FL 33133
