Privacy Policy

Privacy Policy

Last updated: Dec 21, 2023

This Privacy Policy describes the ways Sutro Labs Inc. (“Census”) collects, uses, and discloses information about you through Census’s websites and services (the “Services”). In this Privacy Policy “you” refers to individuals who use Census’s Services. By using the Services, you consent to the processing of your information described in this Privacy Policy.

Information Collected

Census collects and holds two types of data, in two different ways: information about Census users & visitors, and potentially sensitive customer data that users choose to sync across services they connect to Census.

1. Customer Data

Census uses a secure connection to access customer data sources and always limits its queries to what is strictly necessary to synchronize data selected by users. When Census copies data from a source to a destination, Census retains a temporary cache of the data that is fetched. This data is encrypted and stored by Census for a maximum of 14 days. Some optional features require caching this data indefinitely (until users disable them).

2. Information About Census Users

Census collects information from individuals who visit Census’s web site(s) (“Visitors”) and individuals who register to use the Services (“Customers”).

When requesting information about the Services or registering to use the Services, Census may require you to provide Census with personal contact information, such as name, company name, address, phone number, and email address. All information you provide to Census that can be directly or indirectly identified used to identify you is referred to as “Personal Data”.

In addition to the information you provide, when you use the Services Census may also collect information through our automatic data collection tools, which may include web beacons, cookies, embedded web links, and other commonly used information-gathering tools (“Data Tools”). These tools collect certain standard information that your browser sends to the Services such as your browser type and language, access times, and the address of the website from which you arrived at a Census website. They may also collect information about your Internet Protocol (IP) address, clickstream behavior (i.e. the pages you view, the links you click, and other actions you take in connection with the Services) and product information. Census may also use some of these Data Tools in emails sent from Census and therefore may collect information using these tools when you open the email or click on a link contained in the email.

Census may also contract with third-party advertising networks that collect non-personally identifiable information and Personal Data through Census’s web site and emails and on third-party web sites. Ad networks follow your online activities over time by collecting usage data through Data Tools. They use this information to provide advertisements about products and services tailored to your interests. You may see these advertisements on other web sites. This process also helps us manage and track the effectiveness of Census’s marketing efforts. You may opt out of display advertising partners’ targeted advertising using the following links: http://www.aboutads.info/choices, http://www.networkadvertising.org/choices and http://www.youronlinechoices.eu, if located in the European Union.

Census tracks your use of the Services over time. Census does not track you across third-party websites and therefore Census does not respond to Do Not Track signals in these circumstances. However, some third-party sites do keep track of your browsing activities when they serve you content. If you are visiting such sites, many browsers will allow you to set Do Not Track signals so that third parties know that you do not want to be tracked.

Use of Personal Data Collected

Census uses Personal Data to perform the Services requested, including:

• To respond to your requests for information, products, or services, and to provide customer service and support.
• To administer your account if you are a Customer.
• To enable your access and use of the Services.
• To send you technical notices, updates, security alerts, and support and administrative messages.
• To inform you about Census products and services.
• For legal compliance, such as to enforce Census’s legal rights, to comply in good faith with applicable laws, and to protect users of the Services.
• For other general business purposes, such as to provide, operate, maintain, make modifications to and improve the Services, and for marketing, advertising, research and development.
• For other purposes about which Census notifies you.

Sharing of Information Collected

1. Customer Data

We use a small set of cloud service providers to process Customer Data and to help us improve and protect our Services. These third parties will access your information only to perform tasks on our behalf in compliance with this Privacy Policy, and we’ll remain responsible for their handling of your information per our instructions. For a listed of trusted third parties that we use to process your Customer Data, please see https://getcensus.com/list-of-subprocessors

2. Personal Data

Census does not share, sell, rent, or trade Personal Data with third parties for their promotional purposes.

Census may share Personal Data with: (a) Census’s subsidiaries and affiliated companies; (b) subcontractors and other third party service providers; (c) auditors or advisers of our business processes; and (d) potential purchasers or investors in the company.

Census reserves the right to use or disclose Personal Data if necessary to (a) comply with lawful requests by public authorities, including to meet national security or law enforcement requirements; (b) protect and defend Census’s rights or property of those of its users; (c) act in an emergency to protect someone’s safety; or (d) investigate any violation or potential violation of the law, this Privacy Policy, applicable Services license restrictions, any other agreements between you and Census or other activity that is illegal or may expose Census to legal liability.

Census may share Personal Data with any company that acquires its company or assets. That company will possess the Personal Data collected by Census and will assume the rights and obligations regarding Personal Data as described in this Privacy Policy.

Census may share Personal Data if you provide prior consent to do so.

Where do we Process Your Information

We transfer, process, and store your personal information in the United States. To the extent we import Customer Data from the European Economic Area, Switzerland and UK to the United States, we will do so pursuant to Data Privacy Framework.

Data Privacy Framework (DPF)

Census complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Census has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. Census has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Census commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU and UK and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF should first contact Census at: privacy@getcensus.com. 

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Census commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) and the Gibraltar Regulatory Authority (GRA) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF. Individuals have the possibility, under certain conditions, to invoke binding arbitration for complaints regarding DPF compliance not resolved by any of the other DPF mechanisms. See Annex I of the DPF Principles for additional information: https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf?tabset-35584=2.

Census has responsibility for the processing of personal information it receives under the DPF Principles and subsequently transfers to a third party acting as an agent on its behalf. Census shall remain liable under the DPF Principles if its agent processes such personal information in a manner inconsistent with the DPF Principles, unless Census proves that it is not responsible for the event giving rise to the damage.

The Federal Trade Commission has jurisdiction over Census’s compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF). Census may disclose personal information in response to lawful requests by US public authorities, including to meet national security or law enforcement requirements.

Correcting and Updating Your Information

If you are a resident of a country that provides you with the right to request a copy of the Personal Data Census holds about you and/or to correct any inaccuracies within such data, and Census is required by applicable laws to respond to such requests, then you may address such requests to the contact information provided in the “Contact Us” section below. Census will use reasonable efforts to supply, correct or delete information that we hold about you or to advise you if we are not required by applicable laws to comply with such requests.

Customers may update or change their registration information by logging in to their accounts at https://getcensus.com. Requests to access, change, or delete your information will be handled within 30 days.

Customers cannot opt out of receiving transactional emails related to their account with Census or the Services.

Security

Census is hosted on Amazon Web Services and uses industry-standard security protocols to protect Personal Data. Personal Data is stored on private servers in a protected security group. All connections between the end user and our servers are encrypted with SSL, and server software is kept continuously up to date with the latest security patches.

Amendment of this Privacy Policy

Census may change this Privacy Policy at any time by posting a new version on Census’s website. Census will also notify Customers and users of any changes through Services account(s), email or by other means. The new version will become effective on the date it is posted, which will be listed at the top of the page as the new Effective Date. If a user disagrees with any changes to this Privacy Policy then their only remedy is to cease using the Services.

Minimum Age

The Services are not directed to, nor intended to be used by, individuals under the age of 13. Census does not knowingly collect personal information from individuals under the age of 13. If you become aware that an individual under the age of 13 has provided us with personal information, please contact us immediately as described below. If we become aware that an individual under the age of 13 has provided us with personal information, we will take steps to delete such information.

Your Privacy Rights

You may withdraw your consent to process your personal information at any time. If you do so, you may be unable to use some of the Services. You may “opt out” of receiving marketing or promotional communications from us by following the instructions in those communications. If you opt out, we may still send you non-promotional service emails, such as essential communications about your account or our ongoing business relations.
You can contact us directly at privacy@getcensus.com to exercise your privacy rights.

Individuals in the US

Some states grant you certain rights and control over your information. Those rights may include:

• Information about You: You may ask for us to state what categories of personal information about you we have, and the categories of sources from which we collect your personal information.
• Correct Your Information: You may log into your account, if you have one with any of our Services, to correct the information stored in your profile. You may also contact us to help you correct your information.
• Receive a Copy of Your Data: You may request the categories and specific pieces of information (if any) we have about you, the categories of personal information that we have disclosed about you for a business purpose, and the categories of third parties with which we have shared personal information.
• Delete Your Data: You may request that we delete the personal information we have collected from you.
• Profiling: You may opt out of our ability to create a profile of you for marketing or advertising purposes. Where you have created an account with us or where we have created a customer profile based on your transactional history with us, we may be limited in how we can manage your data and you may be asked if you wish to delete your data instead.
• Do Not Sell: You may opt out of our sale(s) of your personal information, as “sale” is defined by data privacy laws. Please see above for more information.
• Non-Discrimination: State law may prohibit discrimination against you for exercising your privacy rights.
• Do Not Share for Targeted Advertising: You may opt out of targeted advertising. For more information on how to do so, please see below.

Opting out of the sale or sharing of your personal information. We do not sell your personal information for money. However, we partner with a variety of companies, including ad networks, to improve the Services and to share personal information used to market services to you by these third parties. These transfers can be deemed a sale under some data privacy laws.
You may opt out of the sale of your personal information or the sharing to a third party for targeted advertising by clicking on the “Do Not Sell or Share My Personal Information” link on our Services contacting us using the methods above.

Verification Process and Required Information. All requests must be verified. In certain circumstances, we may decline a request to exercise the right to know and/or right to deletion, particularly where we are unable to verify your identity. If we cannot verify your identity based on the information provided, a request for a copy of your data will be treated as a request for information and if we cannot verify your identity, a request to delete personal information may be treated as a request to opt-out of the sale of personal information.
If you wish to appeal a decision regarding your rights, please contact us at privacy@getcensus.com.

Authorized Agent. You may designate an authorized agent to make a request on your behalf. An Authorized Agent must have written documentation of their authority to act on your behalf, such as a Power of Attorney.

Individuals in Europe

If you are in the EEA, UK or Switzerland, you have the following rights:

• Access. You have the right to request a copy of the personal data we are processing about you. For your own privacy and security, at our discretion we may require you to prove your identity before providing the requested information.
• Rectification. You have the right to have incomplete or inaccurate personal data that we process about you rectified.
• Deletion. You have the right to request that we delete personal data that we process about you, except we are not obliged to do so if we need to retain such data in order to comply with a legal obligation or to establish, exercise or defend legal claims.
• Restriction. You have the right to restrict our processing of your personal data where you believe such data to be inaccurate; our processing is unlawful; or that we no longer need to process such data for a particular purpose unless we are not able to delete the data due to a legal or other obligation or because you do not wish for us to delete it.
• Portability. You have the right to obtain personal data we hold about you, in a structured, electronic format, and to transmit such data to another data controller, where this is (a) personal data which you have provided to us, and (b) if we are processing that data on the basis of your consent or to perform a contract with you.
• Objection. Where the legal justification for our processing of your personal data is our legitimate interest, you have the right to object to such processing on grounds relating to your particular situation. We will abide by your request unless we have compelling legitimate grounds for the processing which override your interests and rights, or if we need to continue to process the data for the establishment, exercise or defense of a legal claim.
• Withdrawing Consent. If you have consented to our processing of your personal data, you have the right to withdraw your consent at any time, free of charge. This includes cases where you wish to opt out from marketing messages that you receive from us.
• Lodging a Complaint. If you believe that we have not complied with applicable data protection laws you have the right to lodge a complaint with the local data protection authority. The EU Commission provides a list of supervisory authorities here: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm. The UK Information Commissioner’s Office can be contacted at https://ico.org.uk/global/contact-us/.

Contact Us

If you have any questions about this Privacy Policy, please contact us at privacy@getcensus.com