Safe Harbor Privacy Policy

Effective Date: August 26, 2014

Textura understands that privacy is an important concern, and Textura strives to collect, use and disclose Personal Information in a manner consistent with the laws of the countries in which Textura and its affiliates and subsidiaries do business.  This Textura Safe Harbor Privacy Policy (the “Safe Harbor Privacy Policy”) sets forth the privacy principles that Textura follows with respect to Personal Information transferred from the European Economic Area (“EEA”) (which includes the twenty-seven member states of the European Union (EU) plus Ireland, Liechtenstein and Norway) to the United States. 

Textura adheres to the principles set forth in the U.S.-EU Safe Harbor Framework and the Safe Harbor Frequently Asked Questions (the “Safe Harbor Principles”) as set forth by the U.S. Department of Commerce.  To learn more about the Safe Harbor program, please visit: http://www.export.gov/safeharbor/.

This Safe Harbor Privacy Policy supplements the Textura Privacy Policy.  If any conflict exists or arises between the policies in this Safe Harbor Privacy Policy and the Safe Harbor Principles, the Safe Harbor Principles shall govern.

SCOPE

This Safe Harbor Privacy Policy applies to all Personal Information, in any format, collected in and transferred from countries in the EEA to Textura in the United States, including manually processed data and Employee Information.
 

DEFINITIONS

For purposes of this Safe Harbor Privacy Policy, the following definitions shall apply:

“Agent” means any third party that processes Personal Information pursuant to the instructions of, and solely for the benefit of, Textura, or to which Textura discloses Personal Information for processing on Textura’s behalf.  Examples of Agents that Textura may use include customer support providers, payment processing providers (such as banks), IT providers, credit card processors, and providers that assist Textura in managing and maintaining data relating to employees.

“Employee Information” means Personal Information of individuals employed in the EEA by Textura or affiliates or subsidiaries of Textura.

“Personal Information” means any information that identifies or could be used to identify an individual. Personal Information does not include anonymized information, aggregate information (to the extent an individual’s identity cannot reasonably be derived from such information), or publicly available information that has not been combined with non-public Personal Information.

“Sensitive Personal Information” means Personal Information that reveals a natural person’s race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, or that concerns a natural person’s sex life or health.

“Textura” means Textura Corporation, its successors, subsidiaries, divisions and groups in the United States.

Contact Information

Questions, concerns, or complaints concerning the collection and use of Personal Information by Textura pursuant of this Safe Harbor Privacy Policy should be submitted by mail or electronic mail as follows:
Textura Legal Department
Textura Corporation
1405 Lake Cook Road
Deerfield, IL 60015