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. Any reference to a linked site or any specific third party product or service by name does not constitute or imply its endorsement by us, and you assume all risk with respect to such use.
1. Your data
We may collect, use, store and transfer the following information to provide, improve and protect our Services.
- personal information is the personal information you give us may include your name, title, company, mailing address, email address, phone number, password, resume information, feedback and any other information you choose to provide to us when using the Services;
- technical data is data such as your internet protocol (IP) address, your login data, the web page you visited before visiting our Site, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Site;
- usage data is data that tells us how you use our Site, Products, or Services;
- marketing and communication data is data that tells us your preferences in receiving marketing from us and our third parties and your communication preferences; and
- sensitive personal data such as your race or ethnicity, your political opinions, religious beliefs, membership in a trade union, physical or mental health condition, sexual orientation, or criminal offenses. We do not ask for any sensitive personal information and request that you omit any such information in any communications with us. If you send us sensitive personal information, we will delete it unless you provide your specific consent to having us include it your account, as it will be processed with the rest of your personal information.
2. How we use your data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
The ways we plan to use your personal data are as follows:
- Products. We collect feedback in order to improve our Products and our Site.
- Usage. We also use your data, especially usage data and technical data, including the actions you take in your account (such as Site visits, page interaction information, and search history), to evaluate and improve our Site and our Products.
- Marketing. We may also use your data to provide you with information about goods or services we feel may interest you. If you do not want us to use your data in this way, select the “unsubscribe” link in any e-mail communication from us.
3. Sharing your data
We may share information as discussed below, but we won’t sell it to advertisers or third parties.
3.2 Other applications and third-party links. The Site or Services may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy policies. When you leave our Site or Services, we encourage you to read the privacy policies of every website you visit. Please remember that their use of your personal information will be governed by their privacy policies and terms.
4. Protecting your data
We only process personal data where we have a legal basis for doing so. We review the personal data we hold on a regular basis to ensure it is being lawfully processed.
Before transferring personal data to any third party (e.g. suppliers, partners and back office support), we establish that there is a legal reason for making the transfer, which may include your consent.
We will only retain your personal data for as long as necessary to fulfill the purposes for which we collected it, including satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data, and whether we can achieve those purposes through other means, and the applicable legal requirements.
We have implemented measures and procedures that adequately protect the privacy of individuals and ensure that data protection is integral to all processing activities. This includes implementing measures which may include:
- Data minimization (e.g. not keeping data for longer than is necessary);
- Cyber security; and
- A data security policy.
5. Individuals in the European Union
5.1 Your Rights. If you are an individual in the European Union, you have certain rights with respect to the access, correction, restriction, and erasure of your personal information stored on our platform at any time. You can exercise any of these rights at any time by contacting us at Strivr. Your rights include the following:
- Accessing your data. Upon request and if available, we shall provide any information relating to your data and our processing of your data in a concise, transparent, intelligible, and easily accessible form using clear and plain language. The information shall be provided in writing or by other means, including, where appropriate, by electronic means within 30 days of a written request.
- Correcting your data. You have the right to ask us to rectify any inaccurate or incomplete personal data on our platform. If we have given your personal data to any third parties, we will notify those third parties that Strivr has received a request to rectify your personal data, unless doing so proves impossible or involves disproportionate effort. Those third parties should also rectify the personal data they hold – however, we are not in a position to audit those third parties to ensure that such rectification has occurred.
- Erasing your data. You can ask us to erase your personal data stored on our platform. If we receive a request to erase your data, we will ask you if you want your personal data to be removed entirely or if you want to be kept on a list of individuals who do not want to be contacted in the future (for a specified period or otherwise). We cannot keep a record of individuals whose data we have erased so if we come into possession of your personal data again at a later date, you may be contacted again by us and such contact is not a violation of your right of erasure.
- Restricting the use of your data. We only process your personal data where we have the legal basis for doing so. You have the right to ask us to suspend or otherwise restrict the processing of your personal data where:
- You challenge the accuracy of the personal data;
- The processing is unlawful but you do not want us to erase it;
- We no longer need the personal data for the purposes of the processing, but you want us to hold it as you need it to establish, exercise, or defend legal claims; or
- You have objected to our use of your data, but we need to verify whether we have legitimate grounds to use it.
5.2 Third parties. If we have given the personal data to any third parties, we will tell those third parties that we have received a request to restrict the use of your personal data, unless this proves impossible or involves a disproportionate effort. Those third parties should also rectify the personal data they hold – however, we will not be in a position to audit those third parties to ensure that the rectification has occurred.
5.3 Withdrawing your consent. Where we are relying on consent to process your personal data (for example consent to receive marketing) you have the right to withdraw your consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you.
6. Individuals outside of the European Union
6.1 Accessing Account Information. We will provide you with the means to ensure that personally identifiable information in your web account file is correct and current. You may review this information by sending an email to Strivr: firstname.lastname@example.org.
6.2 Record of Data Transfer. Strivr will provide the right to request and receive, once a year and free of charge, information about third parties to whom we have disclosed certain types of personal information (if any) about you for our direct marketing purposes in the prior calendar year, and a description of the categories of personal information shared. To make such a request, please send an email to Strivr and please include the phrase “Personal Information Privacy Request” in the subject line, the domain name of the website you are inquiring about, along with your name, address, and email address. At our option, we may respond to such requests by providing instructions about how our users can exercise their options to prevent our disclosure of personal information to third parties for their direct marketing purposes.
6.4 California Consumer Privacy Act of 2018 (CCPA). You have the right to request, twice a year and free of charge, certain information about parties to whom we have disclosed or sold your personal information in the prior calendar year and a description of the categories of personal information shared. Additionally, upon request, twice a year and free of charge, we shall provide to you any information relating to your personal information and our processing of your personal information in a concise, transparent, intelligible, and easily accessible form using clear and plain language. The information shall be provided in writing or by other means within 45 days of a written request. To make such a request, please send an email to Strivr at email@example.com and please include the phrase “Personal Information Privacy Request” in the subject line, the domain name of the website you are inquiring about, along with your name, address and email address. You can also ask us to erase your personal data stored on our platform. If we receive a request to erase your data, we will ask you if you want your personal information to be removed entirely or if you want to be kept on a list of individuals who do not want to be contacted in the future (for a specified period or otherwise). We cannot keep a record of individuals whose personal information we have erased so if we come into possession of your personal information again at a later date, you may be contacted again by us. Strivr has collected, will collect, and has disclosed the personal information described in the categories above during the last year for business purposes; however, Strivr does not sell your personal information. If you exercise your rights under the CCPA, Strivr will not discriminate against you.
7. Storing and transferring your data
The Site and Services are controlled by Strivr from its offices in the United States. Strivr may store and use information in the United States, Brazil, and other jurisdictions; any personal data provided to Strivr will be transmitted to or within those jurisdictions. Strivr also may transfer information and personal data to other jurisdictions to facilitate Strivr’s third party processors’ access to and/or processing of information and/or personal data.
Strivr makes no representation that materials on this Site or Services are appropriate or available for use in other locations, and access to them from territories where their contents are illegal is prohibited. Those who choose to access this Site from other locations do so on their own initiative and are responsible for compliance with applicable local laws.
8. Privacy Shield
8.2 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.
8.4 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.
8.5 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 firstname.lastname@example.org.
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.
9. 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.
90 Middlefield Road
Menlo Park, CA 94025