Supplemental EEA+ Privacy Notice

Effective January 1, 2020

The data protection laws of the European Economic Area (EEA), the United Kingdom and Switzerland (collectively, the “EEA+”), including the General Data Protection Regulation (“GDPR”), require us, STRIVR Labs, Inc., to provide additional and different information about our data processing practices to data subjects in the EEA+.

1. Scope

If you are located in the EEA, the United Kingdom or Switzerland, and access our website (the “Site”) or our products, software, and services (the “Products”; the Site and Products collectively, the “Services”), this Supplemental EEA+ Privacy Notice applies to you.

2. Who Is the Data Controller?

STRIVR Labs, Inc. is the data controller. Our address is 90 Middlefield Road, Menlo Park, California, USA, 94025. Our phone number is (650) 656-9987. Our email address is privacy@strivr.com.

3. What Are Our Legal Bases for Processing Personal Data?

We rely on the following legal bases to process your personal data, as appropriate:

We have set out below the specific legal bases on which we rely for each of the purposes for which we use or disclose your personal data. We have also identified what our legitimate interests are where appropriate.

Purpose of Use or Disclosure Legal Basis and Legitimate Interest
To create and maintain your account, and process and deliver your orders
  • Contract Performance Legal Basis based on our Terms of Use, master services agreement, terms of sale, or other applicable contract.
  • If the processing of your personal data is necessary for us to collect amounts owed to us, the basis is Legitimate Interest Legal Basis.
To manage our relationship with you which will include:
  1. Providing you with customer service
  2. Responding to any specific comments or questions you may have
  3. Communicating with you in relation to your account, including asking you to leave a review or take a survey
  • If the processing relates to a product or service you have ordered, registered for or otherwise contracted for, the basis is Contract Performance Legal Basis based on the applicable contract.
  • If we are legally obligated to respond to your request or inquiry, the basis is Obligations Legal Basis.
  • In all other cases, Legitimate Interest Legal Basis, including to maintain the quality of our customer service, keep our records updated, and understand how customers use our products and services so that we can improve them for you and others.
To provide, maintain, monitor, secure, debug, customize and optimize our Services, and develop and improve our products and services.
  • If the processing is necessary to comply with an applicable contractual obligation with you > Contract Performance Legal Basis per the applicable contract.
  • If the processing is necessary to comply with an applicable legal obligation, such as under data security laws, Legal Obligations Legal Basis.
  • In all other cases, the basis is Legitimate Interest Legal Basis, including as necessary to run our business, provide administration and IT services, maintain network security, and prevent fraud.
To understand what may be of interest to you, deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you, in accordance with applicable law.
  • We process your personal data and contact you for direct marketing purposes on the Consent Legal Basis as required by applicable law.
  • In all other cases, the basis is Legitimate Interests Legal Basis as necessary to understand how customers use our products and services, to develop and improve them for you and others, to remain a competitive business, and to inform our marketing strategy.
To comply with legal obligations that apply to us, monitor and ensure compliance with our terms, and defend our legal interests in the event of a potential dispute
  • If necessary to protect vital interests of a natural person, the basis is Vital Interests Justification.
  • If necessary to comply with applicable laws, the basis is Legal Obligations Legal Basis per applicable laws.
  • In all other applicable cases, the basis is Legitimate Interest Legal Basis to prevent fraud, danger or other unlawful conduct, and to defend our legitimate legal interests.
Disclose your personal data to our service providers (i.e., processors) as necessary to achieve the above purposes
  • The lawful bases listed above apply to any disclosure necessary to further the corresponding purpose.
Disclose your personal data to a prospective or actual purchaser or seller in the context of a merger, acquisition or other reorganization or sale of our business or assets.
  • If the confidential processing of your personal data is necessary for us to evaluate or execute such a transaction while protecting our trade secrets or sensitive business information and your privacy interests to do not override such interests, the basis is Legitimate Interest Legal Basis based on the pursuit of such legitimate interests.
  • Otherwise, we will obtain your consent and rely on the Consent Legal Basis.
Disclose your personal data to courts, law enforcement or regulatory authorities as permitted or required by applicable law.
  • If necessary to protect vital interests of a natural person, the basis is Vital Interests Justification.
  • If necessary to comply with applicable laws, the basis is Legal Obligations Legal Basis per applicable laws.
  • In all other applicable cases, the basis is Legitimate Interest Legal Basis to prevent fraud, danger or other unlawful conduct, and to defend our legitimate legal interests.

4. How Do We Protect Personal Data in the Context of International Data Transfers?

We may transfer your personal data to service providers and business partners outside of the EEA. Some of these recipients may be located in countries for which the European Commission has issued adequacy decisions. In each case, the transfer is thereby recognized as providing an adequate level of data protection from a European data protection law perspective (GDPR Art. 45).

By entering into appropriate data transfer agreements based on Standard Contractual Clauses (2010/87/EU and/or 2004/915/EC) as referred to in GDPR Art. 46(5) or other adequate means, we have established that such recipients will provide an adequate level of data protection and that appropriate technical and organizational security measures are in place to protect personal data against accidental or unlawful destruction, loss or alteration, unauthorized disclosure or access, and against all other unlawful forms of processing.

You can ask for a copy of such appropriate data transfer agreements by contacting us using the contact details above.

5. Your Rights

Subject to applicable law, you have the right to:

To exercise these rights, please contact us using the contact details above.

6. Your Choices

You are not required to provide personal data to us but if you do not provide any personal data to us, you may not be able to use our website or we may not be able to authenticate and assist you with your orders, inquiries or requests. Certain types of personal data which we collect from you are integral to the provision of our products and services. When we collect this information from you through an electronic form, we typically mark the field with an asterisk. In the event that you do not provide us with such information, we generally will not be able to provide you with our products and services.

You can use our website and order products and services from us without consenting to our processing of your personal data for marketing and promotional purposes; the consequence is that our website and marketing activities will be less tailored to you and you may miss out on relevant offers and promotions.