Privacy policy

Strivr Privacy Notice

This Privacy Notice describes how STRIVR Labs, Inc. ("STRIVR", "we" or "us") collects, uses, shares, and otherwise processes individually identifiable information ("Personal Information") that we collect from you when you visit our websites or purchase our products, software, including both the Strivr Platform and WorkWise, or services (collectively "Services"). STRIVR does not independently process Personal Information of users of STRIVR products ("Users"). STRIVR sells business to business only, and Users are employees or affiliates of STRIVR's customer ("Customer"). STRIVR may process certain User Personal Information, but this is done at the direction or on behalf of a Customer, and Customer's Privacy Notice would apply. Personal Information about our employees, contractors, and other STRIVR temporary workers are addressed through internal company policies and procedures and are outside the scope of this Privacy Notice.

1. Categories of Personal Information Collected and Purposes of Collection

We may collect the following categories of Personal Information when you interact with us via our Services. We may collect this Personal Information directly from you, or from third-party partners, applications, and advertising networks.

We rely on several legal grounds to process Personal Information, depending on the type of information, source, and purpose, including, without limitation: (a) as necessary to perform a transaction; (b) as necessary to comply with a legal obligation; (c) consent; and (d) as necessary for legitimate interests. You are not required to provide all the Personal Information identified in this Privacy Notice to use our Services or to interact with us, but certain functionality may not be available or we may not be able to respond to your request, perform a transaction with you, or provide you with marketing that we believe you would find valuable if you do not provide the requested Personal Information.

We will not use your Personal Information for a purpose that is materially different from the purpose for which it was originally collected unless we provide notice of such additional processing.

2. Sharing of Personal Information

We may share your Personal Information, as permitted by applicable law, with trusted service providers like Square to help us provide Services; we may also share your Personal Information with service providers like Mixpanel who help us improve our Services by providing analytics, like AutoO who protect you, us, and other Users by providing security safeguards like access permissions, and promote our products and Services.  We may also share data with Oculus and Android when you use their respective devices to initiate and provide the Services.

We may also share your Personal Information, as permitted by law, with (i) business partners and others as part of a business reorganization, including a merger, acquisition, sale or similar transaction; (ii) our auditors and advisors; (iii) others when required to comply with a subpoena, court order, legal process, or governmental request; and (iv) others to establish or protect our legal rights, property, or safety, or the rights, property, or safety of others, or to defend against legal claims. We do not sell or share your personal information with other third parties, other than as described in this section.

3. Marketing Choices

You have control regarding our use of your Personal Information for directing marketing. If you no longer wish to receive any marketing communications, remain on a mailing list to which you previously subscribed, or receive any other marketing communication, you can choose to not receive such communications at any time. Please follow the unsubscribe link in the relevant communication, customize your communications in our Preference Center, or contact us as detailed below.

4. Cookies 

We use and allow certain trusted partners to use cookies, web beacons, and similar tracking technologies (collectively, "Cookies") in our Services. Cookies are small amounts of data that are stored on your browser, device, communication, or the page you are viewing. This information might be about you, your preferences or your device and is mostly used to make the Services work as you expect it to. The information does not usually directly identify you, but it can give you a more personalized web experience. Some Cookies are deleted once you close your browser, while other Cookies are retained even after you close your browser so that you can be recognized when you return to a website. For more information about how we use Cookies and related technologies, please see our Cookies Policy.

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. However, no security measure can guarantee against compromise. You also have an important role in protecting your Personal Information. You should not share your username and password with anyone, and you should not re-use passwords across more than one website. If you have any reason to believe that your username or password has been compromised, please contact us as detailed below.

6. Data Subject Rights

Depending on your place of residence, you may have certain rights related to the collection and processing of your Personal Information. The rights vary but may include:

• Right to know whether, and for what purposes and from what source, we collect, process, and share your Personal Information.
• Right to access, modify, or correct your Personal Information.
• Where processing of Personal Information is based on consent, the right to withdraw your consent to such processing. 
• Right to opt-out of the sale or share of your Personal Information. However, we note that we have not and do not sell or share your Personal Information, except as permitted by law and described in Section 2 of this Notice.
• Right to object to decisions based on profiling or automated decision-making that produce legal or similarly significant effects on you. Note that we do not use automated decision-making without human intervention, including profiling, in a way that produces legal effects concerning you or otherwise significantly affects you.
• Right to restrict the processing and disclosure of your Personal Information or object to processing and disclosure of your Personal Information. We generally rely on the following legal bases for processing Personal Information: (i) for our legitimate interest or (ii) for performance of a task in the public interest.
• Right to data portability, which means that you can request that we provide certain Personal Information about you in a machine-readable format.
• Right to deletion, erasure, or the right to be forgotten, which means that you can request deletion or removal of certain Personal Information we process about you. Users of WorkWise on Meta Quest have the right to deletion, erasure, or the right to be forgotten, which means that you can request deletion or removal of certain Personal Information we process about you — regardless of location.

• Right to appeal the decisions we make regarding the processing of your Personal Information. You may exercise this right by replying to the correspondence you receive from us, or by contacting us at the address listed at the end of this Privacy Notice.
• Right to lodge a complaint with a regulator located in the jurisdiction of your residence, place of work, or where an alleged violation of law occurred.

You may exercise these rights, to the extent they apply to you, by contacting us as outlined at the end of this Privacy Notice. Note, however, that we may request certain reasonable additional information, that may include Personal Information, to help us authenticate your identity, your request, and to clarify or understand the scope of the request. We will respond to a valid request relating to your rights within one month of receipt, or within three months where a request is complex or challenging. We will not discriminate against you by offering you different pricing or products, or by providing you with a different level or quality of products, based solely upon this request. You may also have the option of designating an authorized agent to exercise your rights on your behalf.‍

7. Cross-Border Data Transfers and Onward Transfers to Third Parties

We transfer Personal Information to various jurisdictions as necessary for the purposes described above, including to jurisdictions that may not provide the same level of data protection as your home country. We provide appropriate protections for cross-border transfers as required by law for international data transfers. With respect to transfers originating from the European Economic Area ("EEA"), we implement standard contractual clauses approved by the European Commission, and other appropriate solutions, such as adhering to the EU-U.S. Data Privacy Framework ("EU-U.S. DPF"), the UK Extension of the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework ("Swiss-U.S. DPF"), collectively, “DPF”, to address cross-border transfers as required by applicable law. Where required by such laws, you may request a copy of the suitable mechanisms we have in place by contacting us as detailed below.

In sharing Personal Information with third party service providers, as outlined in Section 2 “Sharing of Personal Information,” we adhere to the DPF Principles of “Accountability for Onward Transfers,” “Notice,” and “Choice.” Specifically, when transferring Personal Information to third parties service providers, we ensure the establishment of appropriate agreements. These agreements mandate that third party service providers must handle Personal Information only for defined, specific purposes and in ways that align with our DPF obligations. Should we become aware of any third-party service provider using or disclosing Personal Information contrary to this Policy, we will take effective actions to stop such misuse. Our responsibility and liability under the Data Privacy Framework Principles persist if a third party that we engage mishandles Personal Information in violation of the DPF Principles, except in instances where we can demonstrate that we were not at fault for the event leading to damages.     

If STRIVR is unable to resolve your concern regarding your personal information received by STRIVR under the DPF, you have the right to direct your unresolved concern to JAMS, an independent dispute resolution service based in the United States, to provide recourse at no charge to you. To seek recourse for an unresolved concern, visit JAMS' DPF Dispute Resolution page. If JAMS is unable to resolve your concern, you may have the right to invoke binding arbitration under certain conditions. To learn more about this option, visit the DPF’s "How to Submit a Complaint" page.

8. Children's Privacy

We do not knowingly collect or share the Personal Information of individuals under 16 years old nor are the Services directed to individuals under 16 years old. If you become aware that someone under 16 has provided us Personal Information without proper consent, please contact us so that we can take steps to remove this information.

9. Third-Party Sites

Our websites 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 or practices. We encourage you to read the privacy notices and policies of every website you visit.

10. Data Retention

We retain the Personal Information described above only for the period necessary to fulfill the purposes outlined in this Privacy Notice and as otherwise needed to address regulatory and legal rights and obligations.

11. STRIVR’s Participation in the EU-U.S., UK Extension, and Swiss-U.S. Data Privacy Frameworks

STRIVR participates in and complies with the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”), the UK Extension of the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (“Swiss-U.S. DPF”), collectively, “DPF”, as set forth by the U.S. Department of Commerce regarding the collection, use and retention of Personal Information from European Union member countries, the United Kingdom, and Switzerland. STRIVR’s participation in the DPF subjects it to the investigatory and enforcement power of the Federal Trade Commission.

As a DPF participant, STRIVR is committed to and has certified to the U.S. Department of Commerce that it adheres to: (i) the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of Personal Information received from the European Union; (ii) the UK Extension to the EU-US DPF with regard to the processing of Personal Information received from the United Kingdom; and (iii) the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of Personal Information received from Switzerland.  If there is any conflict between the terms in this Privacy Notice and the EU-U.S. DPF Principles and the UK-EU DPF or Swiss-U.S. DPF Principles, the Principles shall govern.  To learn more about the DPF program, and to view our certification, please visit https://www.dataprivacyframework.gov/. Please note the following:

• STRIVR may disclose Personal Information received in reliance on the DPF in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
• You have the right to request access to Personal Information received by STRIVR in reliance on the DPF, and to exercise choice in limiting STRIVR use and disclosure of such information. If you are interested in exercising your rights and choices, please contact STRIVR at the address, phone number or email address below or update your preferences via the cookie banner on our website.

STRIVR’s privacy practices are provided in this Privacy Statement. STRIVR encourages you to contact us at any time as specified in the Contact Us section below with questions, concerns or complaints about our privacy practices and participation in the DPF. You may also refer a complaint to your local data protection authority and STRIVR will work with them to resolve your concern.

If STRIVR is unable to resolve your concern regarding your Personal Information received by STRIVR under the DPF, you have the right to direct your unresolved concern to JAMS, an independent dispute resolution service based in the United States, to provide recourse at no charge to you. To seek recourse for an unresolved concern, visit JAMS' DPF Dispute Resolution page. If JAMS is unable to resolve your concern, you may have the right to invoke binding arbitration under certain conditions. To learn more about this option, visit the DPF’s "How to Submit a Complaint" page.

Please note that the foregoing processes apply only to the resolution of disputes regarding Personal Information received by STRIVR under the DPF. All other disputes that you may have with STRIVR, or any agents, representatives, agencies, officers, directors, or employees, must be resolved in accordance with the terms and conditions of any applicable websites, mobile apps, email newsletters, email subscriptions or other digital properties owned or controlled by STRIVR. For more information about the DPF program, and to view STRIVR’s certification, please visit the DPF website.

12. Changes to this Privacy Notice

We may update this Privacy Notice from time to time as our Services and privacy practices change, or as required by law. The effective date of our Privacy Notice is posted above, and we encourage you to visit our websites periodically to stay informed about our privacy practices. We will post the updated version of the Privacy Notice on our websites and ask for your consent to the changes if legally required.

13. Contact Us

If you would like to exercise any rights you may have, as detailed above or you have questions or concerns about this Privacy Notice, contact us at: 

• ‍Mailing address: 1600 Wyatt Drive, Suite 6, Santa Clara, CA 95054‍
• Phone: (650) 656-9987‍
• Email: privacy@strivr.com