Privacy Policy

Last Updated: April 7, 2020

In this Privacy Notice, we, Strivr Labs, Inc., (“we” or “Strivr”) describe how we use personal information that we collect from you when you use this website or any of our websites (the “Site”) or our products, software, and services (the “Products”; the Site and Products collectively, the “Services”).

If you are located in the European Economic Area (“EEA”), the United Kingdom and Switzerland (collectively, “EEA+”), please also see our Supplemental EEA+ Privacy Notice.

If you are a resident of California, please also see our Supplemental CCPA Privacy Notice.

If you have a visual disability, you may be able to use a screen reader or other text-to-speech or text-to-Braille tool to review the contents of this online Privacy Notice.

For your convenience, this Site or our Services may contain links to a number of other websites. The privacy policies and procedures described here do not apply to those sites; we suggest contacting those sites directly for information on their data collection and distribution policies.

1. CONSENT

This section regarding consent does not apply if you are based in the EEA+. If you access or use our Services or otherwise actively provide us with your personal information, you agree that we may collect, use and process your personal information as outlined in this Privacy Notice and as permitted by applicable laws. If you do not agree to the terms of this Privacy Notice, please do not use our Services or provide us with any personal information. 

2. WHAT TYPES OF INFORMATION DO WE COLLECT?

We may collect, use, store and transfer the following information to provide, improve and protect our Services.

If you visit or interact with our Services, fill in forms on the Site, interact with our Services, or correspond with us by phone, e-mail, or otherwise, we collect personal information about you, including the following:

We use cookies and related technologies such as pixel tags and web beacons to collect certain types of the Technical and Usage Data described above as permitted by applicable law. Cookies are small files we transfer to your device through your web browser when you use our Services to enable our systems to recognize your device and provide features based on who you are. For more information about how we use cookies and related technologies, please see our Cookies Policy.

3. HOW DO WE USE YOUR PERSONAL INFORMATION?

We use the following categories of personal information for the following purposes:

4. To Whom Do We Disclose Your Personal Information?

We may share information as discussed below, but we won’t sell it to advertisers or third parties.

5. How Do We Protect Your Personal Information?

We have implemented measures and procedures intended to protect the privacy of individuals and ensure that data protection is integral to all processing activities. Such measures may include adhering to the principle of data minimization (e.g., not keeping data for longer than is necessary), employing pseudonymization and de-identification measures, implementing cyber security measures, and maintaining a company-wide written information security policy.

6. Your Rights

Under applicable laws, you may have rights to access, update, rectify, port or erase certain personal information that we have about you or restrict or object to certain activities in which we engage with respect to your personal information. To submit a request to exercise any such rights, please contact us at privacy@Strivr.com and clearly describe your request. If you have such rights and your request complies with the requirements under applicable laws, we will give effect to your rights as required by law.

If you are located in the EEA+, please also see our Supplemental EEA+ Privacy Notice.
If you are a resident of California, please also see our Supplemental CCPA Privacy Policy.

7. Privacy Shield

7.1 Privacy Shield Framework. Strivr complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. Strivr 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 Notice 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://www.privacyshield.gov/.  

7.2 Third Party Controller Opt Out. Except as permitted or required by applicable law and in accordance with Strivr’s role as a controller or processor, Strivr provides users with an opportunity to opt out of sharing their personal information with third-party controllers. Strivr requires third-party controllers to whom it discloses the personal information of users to contractually agree to (a) only process the personal information for limited and specified purposes consistent with the consent provided by the user, (b) provide the same level of protection for personal information as is required by the Privacy Shield Principles, and (c) notify Strivr and cease processing personal information (or take other reasonable and appropriate remedial steps) if the third-party controller determines that it cannot meet its obligation to provide the same level of protection for personal information as is required by the Privacy Shield Principles.

7.3 Third Party Disclosures. Strivr may disclose personal information to trusted third parties as indicated in this Privacy Notice without offering an opportunity to opt out. Strivr requires that its agents and service providers that have access to personal information within the scope of this Privacy Notice provide the same level of protection as required by the Privacy Shield Principles. We ensure that our agents process personal information received under the Privacy Shield in a manner consistent with our obligations under the Privacy Shield Principles, unless we prove that we are not responsible for the event giving rise to the damage.

7.4 Lawful Requests. We may also need to disclose personal information in response to lawful requests by public authorities, for law enforcement or national security reasons, or when such action is necessary to comply with a judicial proceeding or court order, or when otherwise required by law. We do not offer an opportunity to opt out from this category of disclosure.

7.5 Complaint Resolution. In compliance with the Privacy Shield Principles, Strivr commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Strivr at privacy@Strivr.com.

Strivr has further committed to refer unresolved Privacy Shield complaints to the JAMS Privacy Shield Program, an alternative dispute resolution provider in the United States. If you do not receive timely acknowledgement of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint. The services of JAMS are provided at no cost to you.

A binding arbitration option may also be available to you in order to address residual complaints not resolved by any other means. Strivr is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.

8. Children’s Privacy

This Site and our Services are not directed to persons under 13. If you become aware that your child has provided us with personal information without your consent, please contact us. We do not knowingly collect personal information from children under 13. If we become aware that a child under 13 has provided personal information, we take steps to remove such information and terminate the child’s account.

9. Modifications

If we change, modify, add or remove portions of this Privacy Notice, we will provide you with notice of such updates as required by applicable law and upload the updated Privacy Notice to our Site. You should check our Site regularly to see any recent changes we may have made.

10. Contact Us

Have questions or concerns about our Site, Products or Privacy Notice? Contact us at Strivr:

Strivr
90 Middlefield Road
Menlo Park, CA 94025
(650) 656-9987
privacy@strivr.com