Steerio | Privacy Statement

Privacy Policy

Ockham Technologies SAS (“Ockham Technologies“) offers tools and platform commercialised as “Steerio” which provide the means to measure and increase project work performance by giving team members a voice within their project. Ockham Technologies understands the importance of protecting personal information. For this reason, Ockham Technologies strives to have business procedures and security safeguards in place to protect personal information under its control.

Application and Scope

This Privacy Policy (“Policy“) is intended to establish responsible and transparent practices for the management of personal information and to satisfy the relevant and applicable legal requirements. This Policy sets out the standards, responsibilities and obligations of Ockham Technologies in respect of any personal information collected, accessed or processed by Steerio in the course of its business operations and specifies the obligations of Ockham Technologies that arise from Ockham Technologies Terms of Service (available at (the “Terms”) entered into between Ockham Technologies and its corporate customers (each, a “Customer”), whereby Ockham Technologies might handle or have access to personal information.

This Policy also governs personal information collected about Steerio’s website users and explains how Ockham Technologies uses and discloses personal information collected from people who visit its website and otherwise interact with Steerio through and its sister websites provided by Ockham Technologies (for example, (collectively, the "website" or platform). It also explains how Ockham Technologies uses cookies and similar technologies.

International Compliance

Ockham Technologies complies with: (i) data protection laws applicable to Ockham Technologies; and (ii) applicable industry standards concerning data protection, confidentiality or information security. Ockham Technologies has global operations and therefore, in some cases, information managed by Ockham Technologies may be transferred, processed and stored to other countries, although at all times, Ockham Technologies will ensure that personal information is protected by confidentiality and security procedures and protections that are, at a minimum, equivalent to those employed by Ockham Technologies itself.

Ockham Technologies complies with this Policy and is in adequation with protection of personal information according to the European Commission Decision of 20 December 2001 pursuant to Directive 95/46/EC of the European Parliament and the Council.

Ockham Technologies also complies with the General Data Protection Regulation (Regulation (EU) 2016/679).

Definition of Personal Information

Personal information is defined as “any information about an identifiable individual”. This may include, for example, email addresses and contact details and any similar information provided to Ockham Technologies (through the Steerio platform) in the course of its business operations, or which Ockham Technologies may receive from business inquiries. Personal information that is aggregated and cannot be associated with an identifiable individual is not considered to be personal information.

Collection and Use of Personal Information through the Services

When providing services, Ockham Technologies through the Steerio platform only processes personal information in accordance with the Terms and applicable laws. Ockham Technologies generally uses personal information from or about its Customers and Users (as defined in the Terms), (hereinafter referred to as “Customer Personal Information”) for the following purposes:

  • to create, establish and administer Customer’s account, to respond to Customer’s inquiries related to its account and to contact Customer about Ockham Technologies’ services or account-related matters;

  • to provide services, including to provide Customer and its Users with access and use of the Steerio platform and customer support;

  • to measure and analyze User behavior in order to, among others, monitor, maintain and improve Steerio’s services or features and to create new services or features;

  • to personalise or customise the experience when using the services;

  • to meet legal and regulatory requirements and to allow Ockham Technologies to meet contractual requirements relating to the services provided to Customer;

  • to conduct surveys on the quality of Steerio’s services or to collect feedbacks on the services; and

  • to provide Customer with offers for additional products and services that Ockham Technologies believes may be of interest to Customer. Ockham Technologies through the Steerio platform may also use information provided by Customers and Users to create de-identified data aggregated for benchmarking or marketing purposes.

Unless required or authorized by law, Ockham Technologies will not use Customer Personal Information for any other or new purpose without obtaining prior consent.

Collection and Use of Personal Information through the Website

Ockham Technologies generally collects and uses personal information from or about its website users as follows:

  1. Information provided by users. In many cases, Ockham Technologies through Steerio collects personal information directly from users when they visit or use the website. For instance, Ockham Technologies may collect the following types of information:

    • Inquiries and Requests for a Trial or Service. Ockham Technologies may collect users’ name, contact information, e-mail address and any other information provided when users make an inquiry or contact Ockham Technologies through the website, when users sign up to receive Steerio’s newsletter or when users submit a request or an order for an Steerio trial or service. Ockham Technologies will only use this information to process and answer users’ request or to manage Ockham Technologies as well as Steerio platform everyday business needs in connection with such request.

    • Personalization of Website. When users visit the website, they may, from time to time, be invited to provide information such as user’s title to help Ockham Technologies personalise or customise the users experience when using the website.

  2. Technical information. When users visit the website, Ockham Technologies may collect, using electronic means such as cookies, technical information. This information may include information about visits to the website, including the IP address of the users’ computer and which browser was used to view the website, the users’ operating system, resolution of screen, location, language settings in browsers, the site the user came from, keywords searched (if arriving from a search engine), the number of page views, information entered, advertisements seen, etc. This data is used to measure and improve the effectiveness of the website or enhance the experience for users. While most of the time this information is depersonalized, if this information relates to an identifiable individual, Ockham Technologies will treat this information as personal information. Ockham Technologies may also, without limitations, collect and use the following type of information when users visit and/or interact with Ockham Technologies / Steerio on the website:

    • Google Analytics Ockham Technologies uses Google Analytics which allows it to see information on user website activities including, but not limited to, page views, source and time spent on our website. This information is depersonalized and is displayed as numbers, meaning that it cannot be tracked back to individuals. Users may opt-out of Ockham Technologies’s use of Google Analytics by visiting the Google Analytics opt-out page.

    • Mixpanel: Ockham Technologies uses Mixpanel which allows it to see information on user website activities including, but not limited to, page visits, interactions with the platform. However, this information is depersonalized. Users may not opt-out of Ockham Technologies’ use of Mixpanel.

    • Hotjar: Ockham Technologies uses Hotjar which allows it to see information on user website activities including, but not limited to, page visits and usage of the interface. This information is depersonalized. Users may not opt-out of Ockham Technologies’ use of Hotjar.

    • HubSpot: Ockham Technologies uses HubSpot which allows it to see information on user website activities including, but not limited to, page views, source and time spent on our website. However, this information is not depersonalized and users may not opt-out of Ockham Technologies’ use of HubSpot.

    • Google AdWords: Ockham Technologies might use Google AdWords Remarketing to advertise Steerio across the Internet and to advertise on third party websites (including Google) to previous visitors to the website. AdWords remarketing will display ads to users based on what parts of the Steerio website they have viewed by placing a cookie on the users’ web browser. It could mean that Ockham Technologies advertises Steerio to previous visitors who haven’t completed a task on the site or this could be in the form of an advertisement on the Google search results page, or a site in the Google Display Network. This cookie does not in any way identify the user or give access to the users’ computer or mobile device. The cookie is only used to indicate to other websites that the user has visited a particular page on the website, so that they may show the user ads relating to that page. If users do not wish to participate in Google AdWords Remarketing, they can opt out by visiting Google’s Ads Preferences Manager.

    • Interest-based Advertising. Ockham Technologies may also allow a limited number of trusted third parties to install cookies on users’ hard drive from the website. The website may include third-party advertising and links to other websites which may be used to generate personalized advertisements. Personalized ads, sometimes referred to as interest-based or behavioral ads, are ads based upon information about users, such as page views on the website, information requests or purchases on the website. Ockham Technologies does not provide any personal information to advertisers or to third party sites that display interest-based ads on the website. However, advertisers and other third-parties (including the ad networks, ad-serving companies, and other service providers they may use) may assume that users who interact with or click on a personalized ad or content displayed on the website are part of the group that the ad or content is directed towards.

    • Advertisers or ad companies working on their behalf sometimes use technology to serve the ads that appear on the website directly to users’ browser. They may also use cookies to measure the effectiveness of their ads and to personalize ad content. Ockham Technologies does not have access to or control over cookies or other features that advertisers and third party sites may use, and the information practices of these advertisers and third party websites are not covered by this Policy. Please contact them directly for more information about their privacy practices.

  3. Choice with Cookies. Users can block the use of cookies by activating the settings in their browser. The “Help” feature on most browsers will tell users how to prevent their browser from accepting new cookies, how to have the browser notify the users when they receive a new cookie, or how to disable cookies altogether. If users choose to withhold consent, or subsequently block cookies, they may not be able to access all or part of the content of the website. Additionally, users can disable or delete similar data used by browser add-ons, by changing the add-on’s settings or visiting the website of its manufacturer.

  4. Privacy Policies of other Websites. This Policy only addresses the use and disclosure of information by Ockham Technologies. Other websites that may be accessible through the website have their own privacy policies and data collection, use and disclosure practices.

  5. Personal Information from other Sources. Ockham Technologies may obtain from third parties additional personal information about a website user if such user gave permission to those third parties to share its information.

Sharing of Personal Information

Ockham Technologies will not sell, rent or trade personal information to any third party. However, Ockham Technologies may share personal information when authorized and/or required by law or as follows:

  1. Service providers. Ockham Technologies may grant access to personal information to third party service providers in connection with the performance or the improvement of its website and services. Before sharing any personal information with any of its third party service providers, Ockham Technologies will ensure that the third party maintains reasonable data management practices for maintaining the confidentiality and security of personal information and preventing unauthorized access.

  2. As permitted or required by law. Ockham Technologies may disclose personal information as required by applicable law or by proper legal or governmental authority. Ockham Technologies may also disclose information to its accountants, auditors, agents and lawyers in connection with the enforcement or protection of its legal rights. Ockham Technologies may also release certain personal information when it has reasonable grounds to believe that such release is reasonably necessary to protect the rights, property and safety of others and itself, in accordance with or as authorized by law. In the event Ockham Technologies receives a governmental or other regulatory request for any Customer Personal Information, it agrees to immediately notify Customer in order that Customer shall have the option to defend such action. Ockham Technologies shall reasonably cooperate with Customer in such defense.

  3. Business transaction. Ockham Technologies may disclose personal information to a third party in connection with a sale or transfer of business or assets, an amalgamation, re-organization or financing of parts of our business. However, in the event the transaction is completed, personal information will remain protected by applicable data protection laws. In the event the transaction is not completed, Ockham Technologies will require the other party not to use or disclose the personal information received in any manner whatsoever and to delete such information.

Security of Personal Information

Ockham Technologies will store and process the personal information in a manner consistent with industry security standards, and as long as necessary for the purposes described in this Policy, unless a longer retention is required by law. Ockham Technologies has implemented technical, organizational and administrative systems, policies, and procedures to help ensure the security, integrity and confidentiality of personal information and to mitigate the risk of unauthorized access to or use of personal information, including (i) appropriate administrative, technical and physical safeguards and other security measures designed to ensure the security and confidentiality of the personal information it manages; (ii) a security design intended to prevent any compromise of its own information systems, computer networks or data files by unauthorized users, viruses or malicious computer programs; (iii) appropriate internal practices including, but not limited to, encryption of data in transit; using appropriate firewall and antivirus software; maintaining these countermeasures, operating systems and other applications with up-to-date virus definitions and security patches so as to avoid any adverse impact to the personal information that it manages; appropriate logging and alerts to monitor access controls and to assure data integrity and confidentiality; permitting only authorized users access to systems and applications; and (iv) all persons with authorized access to personal information must have a genuine business need-to-know prior to access (“Security Program”).

Training and Supervision

Ockham Technologies maintains adequate training programs to ensure that its employees and any others acting on its behalf are aware of and adhere to its Security Program. Ockham Technologies shall exercise necessary and appropriate supervision over its relevant employees to maintain appropriate confidentiality and security of the personal information it manages.

Data Incidents involving Customer Personal Information

Ockham Technologies shall, if any legal requirement to do so, promptly notify Customer of any reasonably suspected or actual loss of data or breach or compromise of its Security Program which has or may result in the loss or unauthorized access, disclosure, use or acquisition of Customer Personal Information (including hard copy records) or otherwise presents a potential threat to such information (“Data Incident”). While the initial notice may be in summary form, a comprehensive written notice may be given to Customer in the timeframe legally required. The notice shall summarize in reasonable detail the nature and scope of the Data Incident (including each data element type) and the corrective action already taken or to be taken by Ockham Technologies. Ockham Technologies shall promptly take all necessary and advisable corrective actions, and shall cooperate fully with Customer in all reasonable efforts to mitigate the adverse effects of Data Incident and to prevent its recurrence.

How to Contact Us

Any questions or complaints regarding this Policy or Ockham Technologies handling of personal information can be addressed by sending an email to:

Change of Privacy Policy

Ockham Technologies will review and update its policies and procedures as required to keep current with rules and regulations, new technologies, standards and customer concerns. This Policy may therefore change from time to time.

This Policy was last updated on February 14, 2018.