Legal

Terms of Service

These Terms of Service are a contract between you and SEG Study in Europe OÜ. By using the SEG Study in Europe website (“Site”) and any services accessible from the SEG Study in Europe Site (collectively, the “Services”), you are agreeing to be bound by the following Terms of Service. If a user violates any of the terms outlined below, we reserve the right to cancel accounts or bar access to accounts without notice. If you do not agree to these terms, please do not use our Services.

Your Account

  • You must be a human. Accounts registered by “bots” or other automated methods are not permitted.
  • You must be 13 years of age or older.
  • You must provide a valid email address, along with any other information required by SEG Study in Europe during the registration process.
  • You are responsible for maintaining the security of your account and password. SEG Study in Europe will not be liable for any loss or damage from your failure to comply with this security obligation. Personally identifiable information submitted by you shall be subject to our Privacy Policy.
  • One person or legal entity may not maintain more than one free account.
  • You may not use the SEG Study in Europe Site for any illegal or unauthorized purpose. You must not, in the use of the SEG Study in Europe Site, violate any laws in your jurisdiction (including but not limited to copyright laws).

Payments, Refunds, Upgrading and Downgrading

Unless otherwise arranged with a SEG Study in Europe representative, a valid credit card is required for payments. Free accounts are not required to provide a credit card number. The SEG Study in Europe Service is billed in accordance with our pricing schedule or as indicated in the invoice. Full refunds or partial refunds shall be made in the event that we are unable to provide the service paid for due to force majure. In order to treat everyone equally, no exceptions will be made.

All fees are exclusive of all taxes, levies, or duties imposed by taxing authorities, and you shall be responsible for payment of all such taxes, levies, or duties, excluding only European Union Value Added Taxes (VAT). You agree to pay for any such taxes that might be applicable to your use of the SEG Study in Europe Site and payments made by you herein.

Violation of these Terms of Service

SEG Study in Europe reserves the right to investigate and prosecute violations of any of these Terms of Service to the fullest extent of the law. SEG Study in Europe may involve and cooperate with law enforcement authorities in prosecuting users who violate the Terms of Service. You acknowledge that SEG Study in Europe has no obligation to prescreen or monitor your access to or use of the SEG Study in Europe Site or any information, materials or other content provided or made available through the SEG Study in Europe Site, but has the right to do so. You hereby agree that SEG Study in Europe may, in the exercise of SEG Study in Europe’s sole discretion, remove or delete any entries, information, materials or other content that violates these Terms of Service or that is otherwise objectionable.

Cancellation

You are solely responsible for properly canceling your Account. To do so, the account owner must send an email to [email protected] with “Account Cancellation” in the subject line. Any cancellation of your Account will result in the deactivation or deletion of your Account or your access to your Account, and the forfeiture and relinquishment of all Content in your Account. This information cannot be recovered from SEG Study in Europe once your account is canceled. Please be aware that SEG Study in Europe may for a time retain residual information in our backup and/or archival copies of our database. We will make reasonable commercial efforts to delete your information as soon as possible after you communicate that intention to us.

Cancellations will take effect within 5 working days of submitting a cancellation request. If you change your mind within this period, send an email to [email protected] with “Account Reactivation” in the subject line. After this grace period, your account will be permanently deleted with no possibility of recovery.

Termination

SEG Study in Europe reserves the right to terminate any Accounts that do not have an email verification for sixty (60) days or accounts that are beyond reasonable doubt no longer in use. SEG Study in Europe, in its sole discretion, has the right to suspend or terminate your Account if you breach these Terms of Service. SEG Study in Europe may refuse to provide you any current or future use of the SEG Study in Europe Site, or any other SEG Study in Europe service. Any termination of your Account will result in the deactivation or deletion of your Account, denied access to your Account, and the forfeiture and relinquishment of all Content in your Account. This information cannot be recovered from SEG Study in Europe once your Account is terminated; however SEG Study in Europe may for a time retain residual information in our backup and/or archival copies of our database.

Modifications to the SEG Study in Europe Site and Prices

SEG Study in Europe reserves the right at any time and from time to time to modify or discontinue, temporarily or permanently, the SEG Study in Europe Site (or any part thereof) with or without notice.

Prices of all SEG Study in Europe services, including but not limited to Personal Advisor Service fees, are subject to change. If the price does change, we will make reasonable efforts to notify you in advance.

SEG Study in Europe shall not be liable to you or to any third party for any modification, price change, suspension or discontinuance of the SEG Study in Europe Services.

We reserve the right, in our sole discretion, to change, modify, add to, supplement or delete any portion of these Terms of Service at any time, effective with or without prior notice; provided, however, that we will use reasonable efforts to provide you with notification of any material changes (as determined in our sole discretion) by email.

If any future changes to these Terms of Service are unacceptable to you or cause you to no longer be in compliance, you must immediately stop using the SEG Study in Europe Service. Your continued use of the SEG Study in Europe Service following any revision to this Agreement constitutes your complete acceptance of any and all such changes. Any new features that augment or enhance the current SEG Study in Europe Service, including the release of new tools and resources, will be subject to these Terms of Service.

Copyright and Content Ownership

We claim no intellectual property rights over the content submitted or created exclusively in your SEG Study in Europe account. Any content that is yours remains yours.

These Terms do not grant us any licenses or rights to your content except for the limited rights needed for us to provide the Services to you.

The look and feel of the SEG Study in Europe Site is © 2018 SEG Study in Europe OÜ. all rights reserved. You may not duplicate, copy, or reuse any portion of the code or visual design elements without express written permission.

Indemnification

You agree to indemnify and hold SEG Study in Europe, its parents, subsidiaries, affiliates, officers, partners and employees, harmless from any claim or demand, including reasonable attorneys’ fees, made by any third party due to or arising out of your use of the Services, use of your account by any third party, the violation of the terms of use by you, or the infringement by you, or any third party using your account, of any intellectual property or other right of any person or entity.

Limitation of Liability

UNDER NO CIRCUMSTANCES, INCLUDING, BUT NOT LIMITED TO, NEGLIGENCE, SHALL SEG STUDY IN EUROPE OR ITS AFFILIATES, CONTRACTORS, EMPLOYEES, AGENTS, OR THIRD-PARTY PARTNERS OR SUPPLIERS, BE LIABLE TO YOU FOR ANY LOST PROFITS OR SPECIAL, INDIRECT, INCIDENTAL, CONSEQUENTIAL, OR EXEMPLARY DAMAGES THAT RESULT FROM OR RELATE TO THE SERVICES, INCLUDING YOUR USE THEREOF, OR ANY OTHER INTERACTIONS WITH SEG STUDY IN EUROPE, EVEN IF SEG STUDY IN EUROPE OR A SEG STUDY IN EUROPE AUTHORIZED REPRESENTATIVE HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. IN NO EVENT SHALL SEG STUDY IN EUROPE’S OR ITS AFFILIATES, CONTRACTORS, EMPLOYEES, AGENTS, OR THIRD-PARTY PARTNERS OR SUPPLIERS’ TOTAL LIABILITY TO YOU FOR ALL DAMAGES, LOSSES, AND CAUSES OF ACTION ARISING OUT OF OR RELATING TO THIS AGREEMENT OR YOUR USE OF THE SITE OR SERVICES EXCEED EITHER THE AMOUNT OF FEES PAID BY YOU TO SEG STUDY IN EUROPE FOR THE SERVICES IN THE SIX (6) MONTH PERIOD PRECEDING THE EVENTS THAT GIVE RISE TO THE APPLICABLE CLAIM OR FIFTY EUROS, WHICHEVER IS GREATER.

Disclaimer

THE SERVICES, SEG STUDY IN EUROPE SITE AND ITS CONTENTS ARE PROVIDED “AS IS” AND “AS AVAILABLE” WITHOUT ANY WARRANTY OR REPRESENTATIONS OF ANY KIND, WHETHER EXPRESSED OR IMPLIED. SEG STUDY IN EUROPE IS A DISTRIBUTOR AND NOT A PUBLISHER OF THE CONTENT SUPPLIED BY THIRD PARTIES; AS SUCH, SEG STUDY IN EUROPE EXERCISES LIMITED EDITORIAL CONTROL OVER SUCH CONTENT AND MAKES NO WARRANTY OR REPRESENTATION AS TO THE ACCURACY, RELIABILITY OR CURRENCY OF ANY INFORMATION, CONTENT, SERVICE OR MERCHANDISE PROVIDED THROUGH OR ACCESSIBLE VIA THE SITE. WITHOUT LIMITING THE FOREGOING, SEG STUDY IN EUROPE SPECIFICALLY DISCLAIMS ALL WARRANTIES AND REPRESENTATIONS AS THE PUBLISHER OF ANY CONTENT TRANSMITTED ON OR IN CONNECTION WITH THE SITE OR ON SITES THAT MAY APPEAR AS LINKS ON THE SITE, OR THE SERVICES, INCLUDING WITHOUT LIMITATION ANY WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE OR NON-INFRINGEMENT OF THIRD PARTY RIGHTS. NO ORAL ADVICE OR WRITTEN INFORMATION GIVEN BY SEG STUDY IN EUROPE NOR ANY OF ITS AFFILIATES, EMPLOYEES, OFFICERS, DIRECTORS, AGENTS, OR THE LIKE SHALL CREATE A WARRANTY. PRICE AND AVAILABILITY INFORMATION IS SUBJECT TO CHANGE WITHOUT NOTICE.

Publicity

You grantSEG Study in Europe the right to use your company name and logo as a reference for marketing or promotional purposes on our website and in other public or private communications, subject to your standard trademark usage guidelines as provided to us from time-to-time. If you don’t want to be listed, you may send an email to [email protected] declining to be used as a reference.

Jurisdiction

These Terms of Service will be governed by and construed in accordance with the federal laws of Estonia and the European Union, without giving effect to its conflict of law provisions or your actual state or country of residence. If for any reason a court of competent jurisdiction finds any provision or portion of the Terms of Service to be unenforceable, the remainder of the Terms of Service will continue in full force and effect. Any waiver of any provision of the Terms of Service will be effective only if in writing and signed by an authorized representative of SEG Study in Europe.

Privacy Policy

SEG Study in Europe is committed to protecting the privacy of all its users.

In order to ensure that our customers and users are fully informed of our data handling policies and their rights pertaining to this data, we maintain this page which details our practices around information collected through the SEG Study in Europe platform.

Last updated: 2018-04-01

Overview

Our approach to data security and privacy includes but is not limited to:

Kinds of Information We Collect

SEG Study in Europe processes four different categories of data, which reflect the different levels of sensitivity in context. However, there are several common traits about how we handle the data, regardless of type:

  • We never sell this data to third parties. In limited cases, we provide it to third-party services for usage strictly within the SEG Study in Europe product or business; for example, to provide analytics graphs on the SEG Study in Europe dashboard.
  • All data is subject to the protections of the General Data Protection Regulation, in the case it originates from the European Union.

Type 1: End-user PII

This is the most sensitive type of data that SEG Study in Europe collects. Examples:

  • Any user profile data passed to SEG Study in Europe by the customer, using the SDK function
  • Browser information that is collected by default in the SEG Study in Europe SDK (e.g., OS, device type, browser language, user agent)
  • Browsing history data that is collected by default in the SEG Study in Europe SDK (e.g., current page URL, current page title)

We reiterate that like all data we collect, end-user PII is never sold to third parties.

Customers may opt out of browser and browser history information by contacting SEG Study in Europe support.

This data is used in the targeting and customization of SEG Study in Europe content.

Type 2: End-user SEG Study in Europe Data

This data pertains to how end users are interacting with SEG Study in Europe content; for example, whether a flow was shown to a given user, whether a user has clicked away a tooltip, etc. This category also includes user responses to in-SEG Study in Europe forms or surveys.

Though this category usually does not contain PII, we caution that form or survey responses may add PII to this data.

End-user SEG Study in Europe data is provided to service providers for usage within the SEG Study in Europe platform. Customers may also configure SEG Study in Europe to send this data upstream to other services via Segment.

Data in this category is used in the targeting and customization of SEG Study in Europe content, as well as displaying analytics on the SEG Study in Europe dashboard.

It is this data stream which is available for CSV download on the SEG Study in Europe dashboard.

Type 3: Customer PII

Customer PII is collected by the SEG Study in Europe dashboard, for example the name and email address of each of a customer’s team members who are authorized to use the SEG Study in Europe platform.

SEG Study in Europe does not store financial data about customers (e.g., credit card information), choosing instead to employ a dedicated payments processor.

Data of this type is used mainly in the SEG Study in Europe dashboard and editor, and within the SEG Study in Europe business.

Type 4: Customer Aggregate Data

This category includes customer-wide statistics such as active user count, number of SEG Study in Europe flows shown, how many SEG Study in Europe flows are published at a time, etc.

This data does not contain PII.

Data in this category is used mainly in the SEG Study in Europe dashboard and editor, customer emails, and within the SEG Study in Europe business.

Security and Compliance

GDPR

The European Union General Data Protection Regulation (GDPR) is a law that regulates the transfer of personal data out of the European Union, that takes effect May 2018. The GDPR enumerates the rights of end users with regards to data collected about them, including the right to view, delete, and/or cease collecting this data.

Compliance with the GDPR is a practical requirement of any data service like SEG Study in Europe with end users in the European Union. Further, it is the moral duty of data processors to protect the privacy rights of their users.

SEG Study in Europe is fully and proudly compliant with the GDPR.

More information is available in our Legal section below.

PCI Data Security Standard

SEG Study in Europe is fully compliant with the PCI Data Security Standard, which regulates the handling and retention of payment data. SEG Study in Europe does not handle customer payment data directly, instead using a fully PCI DSS compliant payments processor. SEG Study in Europe is not intended for the handling of end-user payment information.

Encryption

SEG Study in Europe is committed to the privacy of information as it passes over the network, as well as to preventing unauthorized access to customer or end-user data. We use industry-leading encryption to protect all external traffic in transit (via HTTPS/TLS) and at rest (using AES-256 and an automated key rotation system).

Data Retention

End-user and customer data in the SEG Study in Europe platform is retained indefinitely by default. In the case that customers or individuals request the deletion of their data, SEG Study in Europe will perform this deletion within seven working days.

Requests for data deletion may be addressed to [email protected].

Legal

GDPR and Privacy Shield

Part of SEG Study in Europe’ GDPR compliance strategy is adherence to the EU-US and Swiss-US Privacy Shield Frameworks as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. SEG Study in Europe has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://privacyshield.gov/.

For any GDPR or Privacy Shield-related inquiries, please contact [email protected].

In compliance with the Privacy Shield Principles, SEG Study in Europe commits to resolve complaints about our collection or use of your personal information.  EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield compliance should first contact SEG Study in Europe.  SEG Study in Europe has further committed to cooperate with the EU and Swiss data protection authorities (DPAs) and comply with any advice given by the DPAs pertaining to compliance with the Privacy Shield Principles, including remedial and compensatory measures for non-compliance.   Under certain conditions, more fully described on the Privacy Shield website (https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint), individuals may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

SEG Study in Europe is subject to the investigatory and enforcement powers of the US Federal Trade Commission with regards to GDPR-related and other matters.

Law Enforcement

SEG Study in Europe will comply with any lawful request by public authorities, including to meet national security or law enforcement requirements.

Transfer of Ownership

If SEG Study in Europe merges with or is acquired by another company, the protections in this privacy policy may be subject to change.

We use the information you provide about yourself when placing an order only to complete that order and to provide fantastic customer service during the term of your service. We do not share this information with outside parties without your permission.

Although SEG Study in Europe owns the data storage, databases and the SEG Study in Europe site, you retain all rights to your content. We will also not utilize your content in our databases to compete with you, to advertise or market to your clients, or to contact your clients for any other means of profit.

Finally, we never use or share the personally identifiable information provided to us online in ways unrelated to the ones described above without also providing you an opportunity to opt-out or otherwise prohibit such unrelated uses, except under the following circumstances:

  • If it becomes necessary to share information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of the Terms of Service, or as otherwise required by law.
  • If SEG Study in Europe is acquired by or merged with another company. In this event, SEG Study in Europe will notify you before information about you is transferred and becomes subject to a different privacy policy.

End User Customer Data

SEG Study in Europe will collect End User Customer Data necessary to provide the service to you. “End User Customer Data” means information about your customers, which includes any information you elect to send to SEG Study in Europe in your implementation as well as general information including but not limited to browser information and IP address.

We do not sell, share or disclose any End User Customer Data with any third party, except if SEG Study in Europe is acquired by or merged with another company.

Questions?

Please don’t hesitate to contact us at [email protected].

Overview

The SEG Study in Europe Platform consists of a web application that delivers content to customer applications, and a software development kit (SDK) that serves that content. Our data is stored in secure environments, completely managed by first-class cloud vendors like Amazon and Google.

 

Architecture

The SEG Study in Europe Platform is designed for redundancy and the expectation that failures will happen. Our web application is hosted separately from our APIs, which are also separate from our databases.

 

Backups

Application backups are performed nightly. All backup data is encrypted. Please see our Terms of Service for more information about retained backups.

 

Security

SEG Study in Europe employees are responsible for the security of all data that may come to them, regardless of format. SEG Study in Europe maintains ongoing training programs to inform all employees of these requirements. Within SEG Study in Europe, only authorized employees have access to customer data. When accessing customer data, each employee must authenticate with their individual authentication credentials.Customers are responsible for securing their login information and end-user privacy.The SEG Study in Europe engineering team monitors system health and integrity from our headquarters in Boston, Massachusetts. Information about system uptime is publicly available at http://status.appcues.com or by emailing [email protected].While SEG Study in Europe has not undergone a 3rd-party security audit, we hold ourselves to security controls from the SOC-2 framework and have chosen our cloud hosting providers that are SOC-compliant.

 

Privacy

SEG Study in Europe is committed to protecting your personal information. For more details, please see our Privacy Statement.

 

Reporting Issues

At SEG Study in Europe we take any reports of vulnerabilities seriously. If you encounter a security issue with any of our software or services, please report it to [email protected]. We have an internal SLA for responding to such issues, and are committed to responding and fixing any issues promptly.

Please note that it is against our Terms of Service to run automated security scanning tools against our system without prior approval. If you are interested in providing such a service, please contact us at [email protected].