Privacy Policy

Last Updated: September 12, 2019

STRIVR LABS, INC. (“Strivr”) is committed to protecting and respecting your privacy and ensuring that your personal information is processed fairly and lawfully in line with all relevant privacy legislation. The purpose of this Privacy Policy is to set out the principles governing our use of personal information that we may obtain about you through this website (the “Site”) and your use of our products, software, and services (the “Products”; the Site and Products collectively, the “Services”). By using the Services, you agree to our use of the personal information that we obtain about you. 

Please read this Privacy Policy carefully. We may change our Privacy Policy from time to time. We therefore ask you to check it occasionally to ensure that you are aware of the most recent version that will apply each time you access this Site. If a revision meaningfully reduces your rights, we will notify you. BY USING THIS SITE, YOU AGREE TO THIS PRIVACY STATEMENT. IF YOU DO NOT AGREE TO THIS PRIVACY STATEMENT, DO NOT USE THIS SITE OR OUR SERVICES.

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.

1.1 Data we collect and process. You may give us personal information by visiting or interacting with the Services, filling in forms on the Site, interacting with our Services, or by corresponding with us by phone, e-mail, or otherwise. This personal information includes the following data which are referred to in this Privacy Policy as ‘your data’, ‘your personal data’ or ‘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:

The ways we plan to use your personal data are as follows:

3. Sharing your data

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

3.1 Others working for Strivr. Strivr uses trusted third parties (i.e. IT services, analytics services, etc.) to help us provide, improve, protect, and promote our Site and our Products. These third parties will access your information only to perform tasks on our behalf in compliance with this Privacy Policy, and we’ll remain responsible for their handling of your information per our instructions.

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:

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:

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: privacy@strivr.com.

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.

6.3 California Online Privacy Protection Act. As required by the California Online Privacy Protection Act (“California Act”) and the California Business and Professions Code, this Privacy Policy identifies the categories of personally identifiable information (as that term is defined above and in the California Act) that we collect through our Site or Services about individual consumers who use or visit our Site or Services and the categories of third-party persons or entities with whom such personally identifiable information may be shared. See more about the California Act at http://consumercal.org/california-online-privacy-protection-act-caloppa/#sthash.0FdRbT51.dpuf.

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 privacy@strivr.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

8.1 Privacy Shield Framework. Strivr complies with the EU-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 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 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://www.privacyshield.gov/

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.

8.3 Third Party Disclosures. Strivr may disclose personal information to trusted third parties as indicated in this Privacy Policy 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 Policy 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.

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 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.

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.

10. Privacy Policy changes

This Privacy Policy may be changed from time to time, consistent with the requirements of the Privacy Shield program. You can determine when this Policy was last revised by referring to the “last updated” indication at the top of this page. Any changes to our Policy will become effective upon our posting of the revised Policy on the Site.

11. Contact

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

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