# Privacy Policy In addition to this Privacy Policy, Straion also has a [Terms of Service](/content/terms-of-service/index.html) ## 1. Introduction The protection and privacy of personal data is very important to Straion FlexCo ("Straion", "we" or "us"). With this privacy policy (the "Privacy Policy") we inform you how we handle and process your personal data when you access our website, use our Straion Services or otherwise interact with us. In addition, we explain your rights and available options. Straion currently provides its services exclusively as Software-as-a-Service (SaaS) and plans to offer an optional on-premise deployment in the future. On-premise deployment means the software runs on the customer's own hardware; Straion will have only limited access as agreed in the contract and will not store customer source code or personal data from the on-premise environment on Straion systems, except where strictly necessary for support and only on the Customer's documented instructions. Terms not defined otherwise herein have the meaning set forth in our General Terms and Conditions available under [www.straion.com/legal/terms-of-service/](/content/legal/terms-of-service/index.html) ("Terms"). ### Personal Data Personal data means any information relating to an identified or identifiable natural person (data subject). A natural person is identifiable if they can be identified directly or indirectly, in particular by reference to an identifier such as name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. ### Disclaimer The Straion Services are not directed to individuals under the age of 16 years and are intended exclusively for use by business customers and their authorized representatives acting in the course of their trade, business or profession (B2B). We do not offer the Straion Services to consumers acting for purely private purposes. We do not knowingly collect personal information from individuals under the age of 16 years. When registering for the Straion Services, users must confirm that they are at least 18 years old and that they are acting on behalf of a business customer. If we become aware that an individual under the age of 16 years or a consumer using the Straion Services for private purposes has provided us with personal data, we will take steps to delete such information. If you become aware that an individual under the age of 16 years has provided us with personal data, please contact our support services. ## 2. Application of this Privacy Policy ### 2.1 When does this Privacy Policy apply? We process personal data from you in different ways: - **From you as a Website Visitor.** We process personal data (such as IP address, name, email address or contact information) you share with us when accessing our website or when interacting with us - either as a visitor, Customer or potential customer of our Straion Services. - **From you as a Customer of our Straion Services.** Our Straion Services are made available to our customers subject to our Terms, and can be accessed via multiple channels: - By signing up directly on our website - By entering into a custom contract or order form - Through third-party marketplaces, such as Azure, AWS, GCP, Claude, GitHub Marketplace In order to use the Straion Services, you - either directly or as an employee or other representative of our business customer and designated by our business customer - are required to provide personal data during the signup or contractual process. We process personal data of you as our Customer and when interacting with us as a Customer or prospective Customer of our Straion Services. - **From you as an employee of our business partner.** We work with many business partners, as described below. To work with these partners, we collect business contact information and other related data from relevant employees of those business partners. When we process such data we are a data controller. We process your data in compliance with the GDPR and this Privacy Policy. ### 2.2 When does this Privacy Policy not apply? This Privacy Policy does not apply when we process personal data on behalf of our Customer: Personal Data included in Customer Content. A customer of our Straion Services can upload and manage a variety of content, such as texts, images, videos or other files to and via our Straion Services. Typically, this is content not intended for publication but Customer Content may contain personal data. We process this personal data according to the contract with our Customer. In this context, Straion is a data processor and not the controller. Straion will only process such data pursuant to our agreement. ## 3. How do we protect your personal data? ### General Protection of your data is extremely important to us. We use physical, technical and organizational safeguards designed to protect your information and strive to protect your data in the best possible way. All measures comply with Art 32 GDPR. ### Technical and organizational measures We use appropriate technical and organizational security measures to protect your data against manipulation, loss, destruction and unauthorized access or use, in accordance with Art 32 GDPR. These measures include, where appropriate, encryption, pseudonymization, access controls, and regular reviews of our security practices. ### Reviews We conduct thorough screenings and reviews of our systems, services and infrastructure taking into account security and compliance best practices, current risks, threats, vulnerabilities, technology, and changes in applicable legal requirements. ### Trainings Our staff has the obligation to secrecy in compliance with applicable law and undergoes regular training on data protection and confidentiality. Training includes GDPR obligations such as data subject rights and breach notification procedures. ## 4. Personal Data We Process ### 4.1 Website Our websites are made available to every internet user. We collect certain data when you visit our website and process data you, as a visitor, provide to us when accessing our website ([www.straion.com](/content/site-root.html)). #### Data we collect automatically from our website - **Internet or other electronic network activity information - Log Files & Usage Information** Data processed. When you visit our website for information purposes we collect data about your access to our servers on which our website is stored for retrieval via the Internet (so-called server log files). This access data includes: - Requested content, the name of the website accessed - File, date and time of access/request - GMT time zone difference - access status / HTTP status code - Amount of data transferred - Message about successful retrieval - browser type, version and language version - operating system - Referrer URL (the previously visited page) - IP address - the requesting provider - performance numbers such as latencies and caching - Source of the data. Website visitors. We process this data based on our legitimate interests (Art. 6(1)(f) GDPR) in monitoring and improving our website and services. For necessary cookies and similar technologies, processing is based on consent (Art. 6(1)(a) GDPR). ### 4.2 Customers We collect and process the following personal data when you are a customer of our Straion Services, interact with us and access the Straion Services via straion.app. #### Data you as our Customer of the Straion Services share directly with us - **Account Information** Data Processed. When you directly signup within our Straion Services, we will require you to enter your first name, last name, email address and a password. Straion creates user profiles including first name, last name, email address and profile picture. Passwords are not visible to Straion. - **Your Communications & Feedback** Data Processed. The Straion Services may also include customer support, where you may choose to submit information regarding a problem you are experiencing with the Straion Service. The specific personal information requested will vary based on the purpose of the support. - **Financial & Payment Information** Data Processed. If you choose to purchase products or services from us, we collect your name, contact information, and your payment information (which may include your credit card provider and expiration date, and other related billing information). - **Contact Information** Data Processed. When you contact us or request information about our products or services, we may collect your first name, last name, email address, country, phone number and other contact details to fulfill your request. ### 4.3 Data we collect automatically from our Straion Services - **Internet or other electronic network activity information - Log Files & Usage Information** Data processed. When you access our app we collect data about your access to our servers on which our app is stored for retrieval via the Internet (so-called server log files). This access data includes: - Requested content, the name of the website accessed - File, date and time of access/request - GMT time zone difference - access status / HTTP status code - Amount of data transferred - Message about successful retrieval - browser type, version and language version - operating system - Referrer URL (the previously visited page) - IP address - the requesting provider - performance numbers such as latencies and caching - information about how you use the Straion Services (e.g. which features are used, frequency of use, click paths, error messages), where such information is linked to your account or device. ## 5. How we share Data ### 5.1 Introduction We do not sell, rent, or share your personal data for money or anything else of value, and have not done so within the last 12 months. However, we do work together with other companies, contractors and service providers who help us run our business and operate our Straion Services. These companies provide services to help us deliver the Straion Services to you, provide you with customer support, process credit card payments, manage and contact you and other (potential) customers, provide marketing support, and otherwise improve our products and services. All data sharing is based on GDPR-compliant agreements with our processors (Art. 28 GDPR) and limited to the necessary purpose. ### 5.2 Disclosure of Personal Data We may disclose (and have done so in the last 12 months) your personal data to the following categories of third parties: #### Corporate Affiliates We disclose personal information to our affiliates and with their respective officers, directors, employees, accountants, attorneys and agents. Affiliates will only use the information as described in this notice. #### Acquisitions and Similar Transactions We may transfer any information we collect under this privacy policy in connection with any merger, reorganization, sale of company assets, dissolution, financing, or acquisition of all or a portion of the Straion businesses to another company or other similar event. In such cases, data we process of you may be part of the assets transferred in connection with the due diligence for any such transaction. ## 6. Your Rights In accordance with privacy laws, you as a data subject may assert the following data protection rights against us, where we are controller: - Right to withdraw consent: You may withdraw any consent you have given us at any time. - Right to be informed: You have the right to be informed about the personal data we process about you. - Right of access: You have the right to obtain access to the personal data and information we have collected about you. - Right to rectification: You have the right to request that inaccurate or incomplete personal data be corrected. - Right to erasure: You have the right to request the deletion of the data we hold about you. - Right to restriction of processing: You have the right to request restriction of processing under Art. 18 GDPR. - Right to data portability: You have the right to receive your personal data in a structured, commonly used and machine-readable format.