Privacy Policy

Document Owner: Head of Legal

Effective Date: February 28, 2023

This Stairwell Privacy Policy (“Privacy Policy”) describes the ways in which Stairwell, Inc. and its affiliates (collectively, “we” or “Stairwell”) collect, use, maintain, and disclose information from users of the website stairwell.com (our “Website”), participants or attendees of events we sponsor or attend, prospective customers, or others for whose information we are acting as a data controller, whether through use of our products and performance of our products or services (“Offerings”) or otherwise.

For purposes of this Privacy Policy, the terms “user,” “customer,” “you,” and “your” are meant to refer to the individuals about whom we may collect personal information and any reference to “Stairwell,” “we,” “us” or the “Company” is a reference to Stairwell, Inc. and its affiliates.

Our Website and Offerings are not directed at children and Stairwell does not knowingly collect or sell personal information from individuals under the age of 16. If you believe we might have any information from or about a child under the age of 16, please contact us by using the information in section 10 below.

1. Personal Information That Stairwell Collects or Receives and How That Information Is Obtained
Stairwell may collect or receive different types of information about you, including information by which you may be personally identified, such as name, postal address, email address, telephone number; information about your internet connection, the equipment you use to access our Website, and usage details; technical unique identifiers and authentication credentials; or other information you choose to provide to Stairwell.

This information may be collected by us when you:

Visit our Website or any other websites that display or link to this Privacy Policy;
Visit our branded social media pages;
Visit our offices;
Receive communications from us or otherwise communicate with us, including but not limited to emails, phone calls, texts or faxes;
Use our products and services where we act as a controller of your personal information;
Register for, attend or take part in our events, webinars, programs, trainings, certifications or contests;
Act as or work for a service provider or supplier to Stairwell, to the extent Stairwell acts as a controller with respect to your personal information;
Are employed by a customer of our products and services where your information has been shared with us in our capacity as a controller (for example, during the contracting process);
Authorize a third party to share your personal information with us for marketing purposes or any other purpose;
Interact with us or provide us with your personal information at a live, in-person event;
Participate in a Stairwell community such as that focused on open source development; or
Participate in surveys, research or other similar data collection facilitated by us.

1.1. The Website and Offerings
The Website provides Internet-based access for users to learn about Stairwell and its Offerings and to communicate with Stairwell. Stairwell also provides Internet-based access to our Offerings. When an individual uses the Website or our Offerings, Stairwell gathers information, some of which may be considered to be personal information.

Our websites and services may contain links to other websites, applications, platforms and services maintained by third parties. The information practices of these third parties, including the social media platforms that host our branded social media pages, are governed by their privacy statements, which you should review to better understand their privacy practices.

If you communicate with Stairwell by telephone or through our chat feature on our website, you consent that Stairwell may monitor or record the call or record those interactions. This is done for reasons such as maintaining the integrity of your account, providing effective and timely service, and the improvement of our services.

If you provide us, our service providers, or our affiliates with any information relating to other individuals, you represent that you have the authority to do so, and where required, have obtained the necessary consent, and acknowledge that it may be used in accordance with this Privacy Policy. If you believe that your personal information has been provided to us improperly, or want to exercise your rights relating to your personal information, please contact us by using the information in section 10 below.

1.2. In-Person and Virtual Events
If you register to attend an in-person or virtual event sponsored or attended by Stairwell personnel or download one of our available knowledge resources (such as white papers, research reports, etc.), we may receive information about you, including your, name, phone number, business email address, company name, country, and any other information you elect to provide. We use this information consistent with the purpose for which you provided it, such as to contact you about Stairwell’s Offerings, company news, updates, and other Stairwell-related information. We may associate personal information that you provide to us, including email addresses, with information collected about you through other means such as cookies, web beacons, social media plugins, and third-party sources. This will help us better tailor content delivered to you through a variety of means, including online advertisements. We include unsubscribe instructions at the bottom of each email if at any time you would like to unsubscribe from receiving future emails from us.

Please note that opting out of marketing communications does not opt you out of receiving important business communications related to your current relationship with us, such as communications about your subscriptions or event registrations, service announcements or security information.

If you want your phone number to be added to our internal Do-Not-Call telemarketing register, please contact us by using the information in section 10 below. Please include your first name, last name, company and the phone number you wish to add to our Do-Not-Call register.

Alternatively, you can always let us know during a telemarketing call that you do not want to be called again for marketing purposes.

If you attend a Stairwell-hosted event or agree to be recorded in a telephone or virtual meeting, we may record some or all of that event or meeting. For events, we may document the event in various ways, such as by taking photos at the event, interviewing you at the event, or recording your participation in a live question-and-answer or other interactive sessions. We use this information for business and marketing purposes, including to enhance our Offerings and your customer or user experience.

1.3. Personal Information Acquired from Third-Party Sources
In some circumstances, we may also collect, or our partners may provide us with, publicly available information that you have published or that has been made available online, which may contain your personal information. The way in which our partners collect this is detailed in their own privacy policies, available on their websites.

We may receive personal information about you from third party sources where those parties have indicated that they have your consent or are otherwise legally permitted or required to disclose your personal information to Stairwell. For example, we may be provided with information about individuals interested in our Offerings, joining our company, or when using third party authentication options to sign-up for or log-in to our Offerings.

1.3.1. Advertising
The personal information we collect from other sources for the purposes of tailored advertising includes identifiers, professional or employment-related information, education information, commercial information, visual information, internet activity information, and inferences about preferences and behaviors. We, collect this from third party providers of business contact information, including mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), IP addresses, social media profiles, LinkedIn URLs and custom profiles for purposes of targeted advertising, delivering relevant email content, event promotion and profiling, determining eligibility and verifying contact information. This helps us update, expand, and analyze our records, identify new customers, and create more tailored advertising to provide services that may be of interest to you.

1.4. Cookies and Information-Gathering Tools
We use common information-gathering tools, such as tools for collecting data, cookies, web beacons, pixels, and similar technologies to collect information that may contain personal information as you navigate our websites, our Offerings, or interact with emails we have sent to you. For more information about Stairwell’s use of cookies and how to opt-out, please refer to Stairwell’s Cookie Notice in section 13 below.

2. How Stairwell Uses Personal Information
We collect and process your personal information (including, where legally permissible, special categories of personal information) for a variety of purposes, including but not limited to the following purposes and relying on the following legal bases:

Purpose	Description	Legal Basis
Websites and Social Media Branded Pages
Providing our websites (including our social media pages).	We process your personal information to operate and administer our websites and to provide you with the content you access and request.	Our legitimate interest in providing online content to our customers and prospective customers regarding our service offering and related information.
Improving our websites.	We process your personal information to analyze overall trends and help us improve the user experience on our websites.	Our legitimate interest in providing a relevant and well-functioning website for the benefit of our website visitors.
Promoting the security of our websites.	We process your personal information by tracking use of our websites and verifying and investigating activity.	Our legitimate interest in promoting the safety and security of our websites and in protecting our rights and the rights of others.
Displaying personalized advertisements and content.	We process your personal information to conduct market research, advertise to you, provide personalized information about us on and off our websites and to provide other personalized content based upon your activities and interests.	Our legitimate interest in advertising our products and services or, where necessary, to the extent you have provided your prior consent. Please see section 7, to learn how you can control the processing of your personal information by Stairwell for personalized advertising purposes.
Events
Managing event registrations and attendance.	We process your personal information to plan and host events or webinars for which you have registered or that you attend, including sending related communications to you.	Performance of a contract or where we receive your consent.
Communications
Sending communications.	We process your personal information to send you marketing information, product recommendations and other non-transactional communications (e.g., marketing newsletters, telemarketing calls, SMS or push notifications, information about our products, news or events) about us, our affiliates and partners.	Our legitimate interest in conducting direct marketing or where you have provided your prior consent (please see sections 1.2 and 7 below to learn how you can control the processing of your personal information by Stairwell for marketing purposes).
Recording phone calls.	We process your personal information, including recording phone calls (in accordance with applicable laws) for training, quality assurance, and administration purposes. If required under applicable law, we will give you the option to object to a call being recorded.	Consent or our legitimate interest in maintaining the high quality of our phone calls with users.
Handling contact and user support requests.	We process your personal information, if you fill out a “Contact Me” web form or request user support, or if you contact us by other means including but not limited to via phone.	Necessary for the performance of a contract or our legitimate interest in fulfilling your requests and communicating with you.
Stairwell Products and Services
Providing our services.	We process your personal information to perform our contract with you for the provision of our services, including support services, and to satisfy our obligations under the applicable terms of use.	Necessary for the performance of a contract or our legitimate interest to provide, support, and administer our services.
Optimizing the performance of the services.	We process your personal information to optimize or improve the performance of the services.	Legitimate interest to ensure that the service is performing in line with customer expectations.
Managing our customer and user accounts.	We process your personal information (including usage data) to manage customer and user accounts generally, such as billing, customer correspondence and customer relationship management.	Necessary for the performance of a contract or our legitimate interest in the management of customer and user accounts.
Managing usage and licensing compliance.	We process your personal information (including usage data) to assess and manage usage and licensing compliance with the applicable terms of use of our services.	Necessary for the performance of a contract or our legitimate interest in managing the provision of our services to customers.
Preparing internal reports and business modeling.	We process your personal information (including usage data) for internal reporting and business modeling purposes (e.g., forecasting, revenue, capacity planning, product strategy, etc.).	Our legitimate interest in the management of our business operations.
Maintaining our security.	We process your personal information (including your usage data) for the purposes of maintaining Stairwell’s own security, including investigating, detecting and preventing suspicious activity, fraud and cybercrime that may affect Stairwell or its services.	Our legitimate interest in promoting the safety and security of Stairwell generally and to protect our rights and the rights of others.
Managing compensation for employees.	We process your personal information (including your usage data) for the purposes of determining compensation for Stairwell employees, such as commission.	Necessary for the performance of a contract with an employee or our legitimate interest in fairly compensating our employees.
Undertaking financial reporting.	We process your personal information (including your usage data) for the purposes of financial reporting.	Our legitimate interest in meeting our obligations associated with the reporting of our finances.
Aggregating data.	We process your personal information (including your usage data) for the purposes of aggregating this information to ensure that it is no longer identifying.	Our legitimate interest in minimizing the amount of personal information processed as part of the noted processing activity.
Webinars, Programs, Trainings, Certifications and Contests
Managing, and participating in, webinars, contests, programs, training, certifications or promotions.	We process your personal information if you register for a webinar, contest, promotion, training, certification or a program. Some webinars, contests, programs, trainings, certifications and promotions have additional rules containing information about how we will process your personal information.	Necessary for the performance of a contract or where we seek your consent.
Other Data Collection
Managing payments.	If you have provided financial information to us, we process your personal information to verify that information and to collect payments to the extent that doing so is necessary to complete a transaction and perform our contract with you.	Necessary for the performance of a contract.
Administering surveys and conducting research.	We process your personal information (including, where legally permitted, special categories of personal information) in order to meet the goals set out in surveys or research as well as to analyze our compliance with internal policies.	Consent or explicit consent (if required under applicable law) or our legitimate interest in conducting the survey or research based on its stated goals (where no special categories of personal information are in scope).
Complying with legal obligations.	We process your personal information (including usage data) when cooperating with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws to the extent this requires the processing or disclosure of personal information to protect our rights.	Legal obligation or our legitimate interest in protecting against misuse or abuse of our websites or services, protecting personal property or safety, pursuing remedies available to us and limiting our damages, complying with judicial proceedings, court orders or legal processes, responding to lawful requests, or for auditing purposes.

If we need to collect and process personal information by law, or under a contract we have entered into with you, and you fail to provide the required personal information when requested, we may not be able to perform our contract with you.

3. With Whom Stairwell Shares Personal Information
We may share your personal information as follows:

Service providers: With our contracted service providers, who provide services such as IT and system administration and hosting, credit card processing, research and analytics, marketing, customer support and data enrichment for the purposes and pursuant to the legal bases described above in section 2;
Event sponsors: If you attend an event or webinar organized by us, or download or access an asset on our website, we may share your personal information with sponsors of the event or asset. If required by applicable law, you may consent to such sharing via the registration. In these circumstances, your information will be subject to the sponsors’ privacy statements. If you do not wish for your information to be shared, you may choose to not opt-in via event/webinar registration, or you can opt-out in accordance with section 7 below;
Customers with whom you are affiliated: If you use our services as an affiliate or authorized user, we may share your personal information with your affiliated customer responsible for your access to the services to the extent this is necessary for verifying accounts and activity, investigating suspicious activity, or enforcing our terms and policies;
Contest and promotion sponsors: With sponsors of contests or promotions for which you register in order to fulfill the contest or promotion;
Third party networks and websites: With third-party social media networks, advertising networks and websites, so that Stairwell can market and advertise on third party platforms and websites;
Partners and resellers: We may disclose personal information, such as contact information, business details, and content interest and activity details, to our partners and resellers for business purposes, such as to carry out our business or for joint marketing efforts to reach our customers and prospective customers. In many cases, you intentionally disclose your details by providing your information to these sponsors through consent via a registration form.
Professional advisers: In individual instances, we may share your personal information with professional advisers acting as service providers, processors, or joint controllers – including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance and accounting services, and to the extent we are legally obliged to share or have a legitimate interest in sharing your personal information;
Third parties involved in a corporate transaction: If we are involved in a merger, reorganization, dissolution or other fundamental corporate change, or sell a website or business unit, or if all or a portion of our business, assets or stock are acquired by a third party. In accordance with applicable laws, we will use reasonable efforts to notify you of any transfer of personal information to an unaffiliated third party.

We may also share aggregated usage data with Stairwell’s service providers for the purpose of helping Stairwell in such analysis and improvements. Additionally, Stairwell may share usage data on an aggregate basis in the normal course of operating our business; for example, we may share information publicly to show trends about the general use of our Offerings.

For more information on the recipients of your personal information, please contact us by using the information in section 10 below.

4. Where Stairwell Stores Personal Information
Your personal information may be collected, transferred to and stored by us in the United States and Canada and by our affiliates and third-parties disclosed in section 3, above, that are based in other countries.

Therefore, your personal information may be processed outside your country or jurisdiction, including in places that are not subject to an adequacy decision by the European Commission or your local legislature or regulator, and that may not provide for the same level of data protection. We ensure that the recipient of your personal information offers an adequate level of protection and security, for instance by entering into the appropriate back-to-back agreements and, if required, standard contractual clauses or an alternative mechanism for the transfer of data as approved by the European Commission (Art. 46 GDPR) or other applicable regulators or legislators. Where required by applicable law, we will only share, transfer or store your personal information outside of your jurisdiction with your prior consent.

5. Stairwell’s Offerings and Personal Information
To the extent that Stairwell collects personal information through its Offerings, Stairwell generally collects that information under the authority and direction of its customers, which are typically corporate entities. If not stated otherwise in this Privacy Policy or in a separate disclosure, we process such personal information as a processor on behalf of our customer (and its affiliates) who is the controller of the personal information. We are not responsible for and have no control over the privacy and data security practices of our customers, which may differ from those explained in this Privacy Policy. Stairwell typically has no direct relationship or contact with an individual whose personal information it may collect or receive from a corporate customer and subsequently analyze and use. Consequently, If your data has been submitted to us in our role as a processor by or on behalf of a Stairwell customer and you wish to exercise any rights you may have under applicable data protection laws, please inquire with them directly. If you wish to make your request directly to us, please provide us the name of the Stairwell customer who submitted your data to us. We will refer your request to that customer and will support them as needed in responding to your request within a reasonable timeframe. Regardless, the use of the information collected through our Offerings is limited to the purpose of providing the Offerings for which our customers have engaged Stairwell or as otherwise outlined in our agreements. We do not use any personal information collected through our Offerings to contact or market products or services to individuals. We also do not provide any personal information obtained through the Offerings to third parties for the purpose of allowing them to contact or market products or services to individuals.

6. How Long Stairwell Retains Personal Information
We may retain your personal information for a period of time consistent with the original purpose of collection (see section 2 above) or as long as required to fulfill our legal obligations. We determine the appropriate retention period for personal information on the basis of the amount, nature, and sensitivity of the personal information being processed, the potential risk of harm from unauthorized use or disclosure of the personal information, whether we can achieve the purposes of the processing through other means, and on the basis of applicable legal requirements (such as applicable statutes of limitation).

After expiry of the applicable retention periods, your personal information will be deleted. If there is any data that we are unable, for technical reasons, to delete entirely from our systems, we will implement appropriate measures to prevent any further use of such data. We may retain a copy of your information solely as necessary for the tracking “unsubscribe” or “do not contact” requests.

For more information on data retention periods, please contact us by using the information in section 10 below.

7. How You Can Exercise Your Rights in Personal Information
You may have certain rights relating to your personal information, subject to local data protection laws. Depending on the applicable laws these rights may include the right to:

Access your personal information held by us;
Know more about how we process your personal information;
Rectify inaccurate personal information and, taking into account the purpose of processing the personal information, ensure it is complete;
Erase or delete your personal information;
Restrict our processing of your personal information;
Transfer your personal information to another controller, to the extent possible;
Object to any processing of your personal information;
Opt out of certain disclosures of your personal information to third parties;
Know what categories of personal information are shared for delivering advertisements on non-Stairwell websites, applications, and services and the categories of recipients of such personal information;
Opt out of the sharing of your personal information for delivering advertisements on non-Stairwell websites, applications, and services;
If you’re under the age of 16, or such other applicable age of consent for privacy purposes in relevant individual jurisdictions, opt in to certain disclosures of your personal information to third parties;
Not be subject to a decision based solely on automated processing, including profiling, which produces legal effects (“Automated Decision-Making”);
Withdraw your consent at any time (to the extent we base processing on consent), without affecting the lawfulness of the processing based on such consent before its withdrawal; and
Not be discriminated against for exercising your rights as described above.
Where we process your personal information for direct marketing purposes or share it with third parties for their own direct marketing purposes, you can exercise your right to object at any time to such processing without having to provide any specific reason for such objection.

Please note that Automated Decision-Making currently does not take place on our websites or in our services.

To exercise your rights, please contact us by using the information in section 10 below. Your personal information may be processed in responding to these rights. We try to respond to all legitimate requests within one month unless otherwise required by law, and will contact you if we need additional information from you in order to honor your request or verify your identity. Occasionally it may take us longer than a month, taking into account the complexity and number of requests we receive. If you are an employee of a Stairwell customer, we recommend you contact your employer’s system administrator for assistance in correcting or updating your information.

Some registered users may update their user settings, profiles, organization settings and event registrations by logging into their accounts and editing their settings or profiles.

To update your billing information, discontinue your account or request return or deletion of your personal information and other information associated with your account, please contact us by reaching out to your primary point of contact or by using the information in section 10 below.

If you feel that Stairwell has not addressed your concerns in a satisfactory manner, you may have the right to complain to a data protection authority about Stairwell’s collection and use of your personal information.

8. How Stairwell Secures Personal Information
We take appropriate precautions including organizational, technical, and physical measures to help safeguard against accidental or unlawful destruction, loss, alteration, and unauthorized disclosure of, or access to, the personal information we process or use.

While we follow generally accepted standards to protect personal information, no method of storage or transmission is 100% secure. You are solely responsible for protecting your password, limiting access to your devices and signing out of websites after your sessions. More information about our security practices may be found at https://stairwell.com/security-statement/. If you have any questions about the security of our websites, please contact us by using the information in section 10 below.

9. How Stairwell Makes Changes to This Privacy Policy
We will update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, and other factors. If we do, we will update the “effective date” at the top. If we make a material update, we may provide you with notice prior to the update taking effect, such as by posting a notice on our website or by contacting you directly, or where required under applicable law and feasible, seek your consent to these changes.

We encourage you to periodically review this Privacy Policy to stay informed about our collection, processing and sharing of your personal information.

10. How to Contact Stairwell about Your Personal Information
To exercise your rights regarding your personal information, or if you have questions regarding this Privacy Policy or our privacy practices please email us at [email protected] or write to us at:

Stairwell, Inc.
ATTN: Legal
883 N. Shoreline Boulevard, C200
Mountain View, CA 94043

When you contact us, please indicate in which country and/or state you reside.

11. State Privacy Rights
State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information.

Colorado, Connecticut, Virginia, and Utah each provide their state residents with rights to:

Confirm whether we process their personal information
Access and delete certain personal information
Data portability
Opt-out of personal data processing for targeted advertising and sales

Colorado, Connecticut, and Virginia also provide their state residents with rights to:

Correct inaccuracies in their personal information, taking into account the information’s nature and the purpose of processing.
Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.

To exercise any of these rights, please contact us by using the information in section 10 above.

Nevada provides its residents with a limited right to opt-out of certain personal information sales. Residents who wish to exercise this sale opt-out right may submit a request to the address set forth in section 10 above; however, please know we do not currently sell data triggering that statute’s opt-out requirements.

If you are a California resident, you may have certain rights in addition to those described above. The California Consumer Privacy Act (as amended by the California Privacy Rights Act) (“CCPA”) requires businesses to disclose whether they sell or share Personal Data (as used in this Section, “Personal Data” is as defined in the CCPA). We may share Personal Data (in the form of identifiers and internet activity information) with third party advertisers for purposes of targeting advertisements on non-Stairwell websites, applications and services. In addition, we may allow third parties to collect Personal Data from our sites or services if those third parties are authorized service providers who have agreed to our contractual limitations as to their retention, use, and disclosure of such Personal Data, or if you use Stairwell sites or services to interact with third parties or direct us to disclose your Personal Data to third parties.

California law requires that we detail the categories of Personal Data that we disclose for certain “business purposes,” such as to service providers that assist us with securing our services or marketing our products, and to such other entities as described in sections 2 and 3 of this Privacy Policy. We disclose the following categories of Personal Data for our business purposes:

Identifiers;
Commercial information;
Internet activity information;
Financial information;
Professional and employment-related information;
Education information;
Geolocation data;
Audio and visual data;
In limited circumstances where allowed by law, information that may be protected characteristics under California or United States law; and
Inferences drawn from any of the above information categories.

California law grants state residents certain rights, including the rights to know and access specific types of Personal Data, to learn how we process Personal Data, to request deletion of Personal Data, to request correction of Personal Data, to opt-out of sharing your Personal Data for third party advertising purposes, and not to be denied goods or services for exercising these rights.

If you are a California resident under the age of 18 and have registered for an account with us, you may ask us to remove content or information that you have posted to our website(s). Please note that your request does not ensure complete or comprehensive removal of the content or information, because, for example, some of your content may have been reposted by another user.

For information on how to exercise your rights, please refer to section 10 of this Privacy Policy. If you are an authorized agent wishing to exercise rights on behalf of a California resident, please contact us using the information in section 10 of this Privacy Policy and provide us with a copy of the consumer’s written authorization designating you as their agent.

If you would like to opt-out of shares using your cookie identifiers, turn on a Global Privacy Control in your web browser or browser extension. Please see the California Privacy Protection Agency’s website at https://oag.ca.gov/privacy/ccpa for more information on valid Global Privacy Controls. If you would like to opt-out of shares using other identifiers (like email address), please refer to section 10 of this Privacy Policy.

We may need to verify your identity and place of residence before completing your rights request.

Below are certain metrics for requests we received from all individuals (including California residents) between January 1, 2022 and December 31, 2022.

	Requests Submitted	Requests Fulfilled in Whole or in Part*	Average Days to Respond	Median Days to Complete a Request**
Requests for Access to Personal Data	0	0	N/A	N/A
Requests to Delete Personal Data	0	0	N/A	N/A
Objections to Processing Personal Data	0	0	N/A	N/A

* Requests may be unable to be completed due to factors like the inability to verify the resident’s identity or lack of response.

** Time to complete a request may depend in part on receipt of information from the person making the request, such as information to verify the person’s identity or information about the action requested.

12. Protections for Residents of the European Economic Area, United Kingdom, and Switzerland
If you are a resident of the European Economic Area, United Kingdom, or Switzerland and where Stairwell is a data controller, your data protection rights are as follows:

If you wish to access, correct, update, or request deletion of your personal information, you can do so at any time.
You can object to processing of your personal information, ask us to restrict processing of your personal data or request portability of your personal information.
You have the right to opt-out of marketing communications we send to you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing emails we send to you. To opt out of other forms of marketing, please contact us using the contact details in Section 10.
If Stairwell has collected and currently processes your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than your consent.
You have the right to complain to a data protection authority about Stairwell’s collection and use of your personal information.

Stairwell responds to verifiable requests received from individuals who wish to exercise their data protection rights in accordance with applicable data protection laws. When contacting us, please provide us with detailed information about the personal information you are requesting we correct, update, amend, or remove, and the timeframe and manner in which you believe we came to collect your personal information. If we obtained your personal information from a customer or third party acting on your behalf, you should contact the company or person you provided your information to. If you would no longer like to be contacted by one of our customers or would like to have your personal information corrected, updated, amended, or removed, please contact the customer who is acting as a data controller with respect to your personal information.

13. Cookie Notice
This Stairwell Cookie Notice describes the different types of cookies used in connection with the Website. You may be presented with the option to agree to the use of certain cookies prior to browsing the Website. In doing so, you can reject the use of cookies except for those deemed necessary for the website or otherwise designed in a manner that is permissible under applicable law.

A cookie is a small text file that is stored on a user’s computer to remember your webpage actions or preferences over time. Cookies don’t read or modify data on the user’s computer. Cookies help provide a user with a better and faster online experience. When you visit a website for the first time, your internet browser will download and place cookies on your device. The next time you access the same website from the same device, the website will recognize that you have visited before, and in some cases adapt the content to your prior visits. This allows the website experience to be tailored to your personal interests and preferences.

A web beacon is a small graphic file that is placed on the web page the user visits and is often used to help deliver cookies and gather usage and performance data.

13.1. Why Does Stairwell Use Cookies?
Why does Stairwell use cookies?

To Allow the Website and Web Portals to Function Properly: Cookies perform different functions that help us make your online experience smoother and more interactive. Especially if you are using the same device and the same browser as you did when you visited our website previously.
Some cookies are essential to maintain and operate the Website and web portals. They allow us to provide you with consistent access to services and functionalities, consistent and updated information, and a seamless online experience.
To Help Us Improve Our Website and Web Portals: Cookies help us improve our Website and web portals by analyzing how visitors interact with them. We use that information to determine what is popular and what else visitors may find useful. That information allows us to understand how visitors use our website to make them better and enhance the web experience, and to display content most relevant to individual users.
To Customize a User’s Web Experience on Our Websites and Web Portals: Cookies also help us understand how you use and interact with our websites and web portals. They can be used to remember your preferences and user ID when you visit our websites. If we know your settings and preferences we can provide a more personalized user experience by helping you navigate more efficiently to relevant pages, remember your personal preferences, and modify content based on those preferences to provide more personalized content (based on preferences or geography, for example).

In addition to the above uses of cookies, web beacons, and other tracking technologies, we also use third-party service providers to help us implement and utilize cookies, web beacons, and other tracking technologies to analyze the data they collect. In some cases, we link the information gathered by cookies, web beacons, and other tracking technologies to a user’s personal information. We may also use cookies, web beacons, tracking technologies, and the personal information they collect to tailor our Websites, Web Portal, and communications so they are more relevant to a user’s interests. Additionally, cookies enable tailored content such as relevant advertisements to be provided on partner websites.

Most web browsers support cookies, and users can control the use of cookies at the individual browser level. Please note, if you choose to disable cookies all content will remain visible; however, it may limit your use of certain features or functions on the Stairwell website.

First-party cookies are cookies deployed by Stairwell on the Website. Third-party cookies are related to content from other websites that may deploy their own cookies, and that are set by an entity other than Stairwell.

If you decide to reject cookies, we will no longer use cookies other than those listed as “necessary.” Rejecting the use of functional cookies will result in decreased functionality of Stairwell’s website, and may impact your ability to take advantage of certain website features.

We cannot delete third-party cookies. In order to delete third-party cookies, you must do so through your browser settings.

We and our third-party partners use Local Storage (HTML5) to provide certain features on the Stairwell website, to display advertising based on your web browsing activities, and to store content information and preferences. Various web browsers may offer their own management tools for removing HTML5.

We use cookies and other tracking technologies for the following purposes:

13.1.1. Strictly Necessary Cookies
These cookies are necessary for the website to function and cannot be switched off in our systems. This includes diagnostic functions such as identifying 404 errors and monitoring page load speed. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.

Cookie ID	Domain	Description
__cfruid	.events.stairwell.com	This cookie identifies trusted web traffic.
cf_use_ob	stairwell.com	This cookie improves page load times and disallows security restrictions based on the visitor’s IP address.
JSESSIONID	.nr-data.net	This cookie is a session identifier to allow us to monitor session counts for an application.
cookieyes-consent	.stairwell.com	This cookie remembers a user’s consent preferences so that their preferences are respected on the subsequent visits to the site.

13.1.2. Functional Cookies

Cookie ID	Domain	Description
__cf_bm	.zoominfo.com	This cookie protects our website against bots.
ln_or	.stairwell.com	This cookie helps us determine whether certain analytics can be carried out on a specific domain.
lang	.ads.linkedin.com	This cookie is used to remember a user’s language setting.
__hssrc	.stairwell.com	This cookie tracks a single session.
lidc	.linkedin.com	This cookie is used to facilitate data center selection.
li_gc	.linkedin.com	This cookie stores a user’s consent regarding using cookies for non-essential purposes.
messagesUtk	.stairwell.com	This cookie allows us to recognize visitors who chat with us via the tools on the website.
__hssc	.stairwell.com	This cookie helps us keep track of a user’s sessions.

13.1.3. Analytics Cookies
These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.

Cookie ID	Domain	Description
AnalyticsSyncHistory	.linkedin.com	This cookie stores information about syncs with other cookies.
_ga	.stairwell.com	This cookie calculates visitor, session, and campaign data and also keeps track of the site usage for the site analytics report. The cookie stores information anonymously and assigns a randomly generated number to recognize unique visitors.
_gid	.stairwell.com	This cookie stores information on how visitors use a website, while also creating an analytics report of the website’s performance.
_gat_gtag_UA_180646454_1	.stairwell.com	This cookie allows us to distinguish between users.
_ga_TW84GPPQZ8	.stairwell.com	This cookie is installed by Google Analytics. Used to persist session state.
__hstc	.stairwell.com	This cookie helps us track visitors’ sessions.
hubspotutk	.stairwell.com	This cookie helps us deduplicate contacts when a form is submitted.
_cfuvid	.zoominfo.com	This cookie helps us distinguish between individual users who share the same IP address.
bscookie	.www.linkedin.com	This cookie stores performed actions on the website.
bcookie	.linkedin.com	This cookie is used to recognize a browser ID.
UserMatchHistory	.linkedin.com	This cookie is used for LinkedIn Ads ID syncing.
visitorId	.ws.zoominfo.com	This cookie identifies a user.

Version	Date	Description	Author	Approved by
2.0.0	2023.01.31	Extension of document to address ISO/IEC 27701 requirements	Head of Legal	VP, Finance & Operations
1.0.0	2021.09.21	First version	COO	CEO