- Information We Collect
- How We Use Information We Collect
- Our Legal Basis for Collecting Personal Data
- Information We Share
- Your Failure to Provide Personal Data
- Our Retention of Your Personal Data
- Your Choices and Accessing, Updating or Deleting Your Personal Data
- Third Party Links
- International Transfer
- How We Protect Personal Data
- Direct Marketing and “Do Not Track” Signals
- Stratifyd Partners
- How to Contact Us
Irrespective of which country you live in, you authorize us to transfer, store, and use your information in the United States, and any other country where we operate. In some of these countries, the privacy and data protection laws and rules regarding when government authorities may access data may vary from those in the country where you live. Learn more about our data transfer operations in the “International Transfer” section below. If you do not agree to the transfer, storage and use of your information in the United States, and any other country where we operate, please do not use the Sites or Services.
Information We Collect
We collect information, including personal data, to provide better services to all our Users. We use the term “Personal Data” to refer to any information that identifies or can be used to identify you. Common examples of Personal Data include: full name, email address, digital identity, such as a login name or handle, information about your device, and certain metadata.
“Sensitive Personal Data” refers to a smaller subset of Personal Data which is considered more sensitive to the individual, such as race and ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, genetic or biometric information, physical or mental health information, medical insurance data, or sexual orientation.
When you use our Services, we collect Personal Data in the following ways:
1. Information You Give to Us
As you evaluate whether Stratifyd is the right solution for your company, you may choose to provide us with Personal Data about yourself, including your name, company name, phone number, and email address by completing forms on our website, such as when you request to schedule a demo. You may also choose to provide us with employment and education information when you apply for a job at Stratifyd via our Site.
In some instances, you may elect to provide us with location and address information. You may also provide us with Personal Data about yourself when you report a problem or have a question about our services.
The Sites offer interactive and social features that permit you to submit content and communicate with us. You may provide Personal Data to us when you post information in these interactive and social features. Please note that your postings in these areas of the Sites may be publicly accessible or accessible to other Users.
2. Information We Obtain from Your Use of Our Services
We collect certain information automatically, such as your operating system version, browser type, and internet service provider. We also collect information about your interaction with the Services, such as creating or logging into your account, or opening or interacting with the Services on Your mobile device. When you use our Site, we automatically collect and store this information in service logs. This includes: details of how you used our Site; Internet protocol address; cookies that uniquely identify your browser, the referring web page and pages visited. We may also collect and process information about your actual location. The information we collect automatically is statistical data and may or may not include Personal Data, but we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties.
3. Cookies and Similar Technologies
We and our partners use various technologies to collect and store information when you visit one of our services, and this may include using cookies or similar technologies to identify your browser or device. We also use these technologies to collect and store information when you interact with services from our partners, such as advertising services. Our third party advertising and analytics partners include Google, [Others] and similar partners.
The technologies we use for this automatic data collection may include:
Web Beacons. Pages of our services or our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count Users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
Clickstream Data. Clickstream data is information collected by our computers when you request Web pages from the Sites. Clickstream data may include information such as the page served, the time spent viewing the page, source of the request, type of browser making the request, the preceding page viewed and similar information. Clickstream data permits us to analyze how visitors arrive at the Sites, what type of content is popular, what type of visitors in the aggregate are interested in particular kinds of content on the Sites.
How We Use Information We Collect
We use your Personal Data in ways that are compatible with the purposes for which it was collected or authorized by you, including for the following purposes:
- To present, operate or improve the Site and Services, including analysis of Site activity;
- To inform you about Services and products available from Stratifyd;
- To authorize access to our Sites and Services;
- To provide, maintain, administer or expand the Services, performing business analyses, or for other internal purposes to support, improve or enhance our business, the Services, and other products and services we offer;
- To offer and administer programs;
- To customize or tailor your experience of the Services;
- To administer content, promotion, sweepstakes, surveys, voting polls or other Site features;
- To communicate about, and administer your participation in, special programs, surveys, contests, online campaigns, online programs, sweepstakes, and other offers or promotions, and to deliver pertinent emails;
- To improve our Site and Services;
- To secure our Services, including to authenticate Users;
- To use statistical information that we collect in any way permitted by law, including from third parties in connection with their commercial and marketing efforts;
- To respond to and support Users regarding their use of the Sites and Services;
- To comply with all applicable legal requirements;
- To perform data analysis and testing;
- To resolve disputes;
- To otherwise fulfill the purpose for which the information was provided.
We use the information we collect from our Sites to provide, maintain, and improve them, to develop new services, and to protect our company and our Users.
We use information collected from cookies and other technologies, to improve your User experience and the overall quality of our services. For example, by saving your language preferences, we’ll be able to have our services appear in the language you prefer. We may use your Personal Data to see which web pages you visit at our Site, which web site you visited before coming to our Site, and where you go after you leave our Site. We can then develop statistics that help us understand how our visitors use our Site and how to improve it. We may also use the information we obtain about you in other ways for which we provide specific notice at the time of collection.
Our Legal Basis for Collecting Personal Data
Whenever we collect Personal Data from you, we may do so on the following legal bases:
- Your consent to such collection and use;
- Out of necessity for the performance of an agreement between us and you, such as your agreement to use our Services or your request for Services;
- Our legitimate business interest, including but not limited to the following circumstances where collecting or using Personal Data is necessary for:
Intra-organization transfers for administrative purposes;
- Product development and enhancement, where the processing enables Stratifyd to enhance, modify, personalize, or otherwise improve our services and communications for the benefit of our Users, and to better understand how people interact with our Sites;
- Communications and marketing, including processing data for direct marketing purposes, and subject to your opt-in for these purposes, and to determine the effectiveness of our promotional campaigns and advertising;
- Fraud detection and prevention;
- Enhancement of our cybersecurity, including improving the security of our network and information systems; and
- General business operations and diligence;
Provided that, in each circumstance, we will weigh the necessity of our processing for the purpose against your privacy and confidentiality interests, including taking into account your reasonable expectations, the impact of processing, and any safeguards which are or could be put in place. In all circumstances, we will limit such processing for our legitimate business interest to what is necessary for its purposes.
Information We Share
We do not share personal data with companies, organizations and individuals outside of Stratifyd unless one of the following circumstances applies:
With your consent. We will share Personal Data with companies, organizations or individuals outside of Stratifyd when we have your consent to do so.
Enterprise Accounts. Your employer or your organization may offer you access to our Services. We will share Personal Data with your employer or organization. Your employer or organization can review and manage your use of such enterprise Services.
For Legal Reasons. We will share Personal Data with companies, organizations or individuals outside of Stratifyd if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:
- meet any applicable law, regulation, legal process or enforceable governmental request.
- detect, prevent, or otherwise address fraud, security or technical issues.
- protect against harm to the rights, property or safety of Stratifyd, our Users or the public as required or permitted by law.
We attempt to notify Users about legal demands for their Personal Data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.
Business Transfers. If we establish a new related entity, are acquired by or merged with another organization, or if substantially all of our assets are transferred to another organization, Personal Data about our Users is often a transferred business asset. In the event that Stratifyd itself or substantially all of our assets are acquired, Personal Data about our Users may be one of the transferred assets.
Non-Personal and Aggregate Site Use Information. Stratifyd may compile and share your information in aggregated form (i.e., in a manner that would not personally identify you) or in de-identified form so that it cannot reasonably be used to identify an individual (“De-Identified Information”). We may disclose such De-Identified Information publicly and to third parties, or to Stratifyd Partners under agreement with us.
Your Failure to Provide Personal Data
Your provision of Personal Data is required in order to use certain parts of our services and our programs. If you fail to provide such Personal Data, you may not be able to access and use our Services and/or our programs, or parts of our Services and/or our programs.
Our Retention of Your Personal Data
We may retain your Personal Data for a period of time consistent with the original purpose for collection. For example, we keep your Personal Data for no longer than reasonably necessary for your use of our programs and Services and for a reasonable period of time afterward. We also may retain your Personal Data during the period of time needed for us to pursue our legitimate business interests, conduct audits, comply with our legal obligations, resolve disputes and enforce our agreements.
Your Choices and Accessing, Updating or Deleting Your Personal Data
Whenever you use our Services, we aim to provide you with choices about how we use your Personal Data. We also aim to provide you with access to your Personal Data. If that information is wrong, we strive to give you ways to update it quickly or to delete it – unless we have to keep that information for legitimate business or legal purposes. Subject to applicable law, you may obtain a copy of personal information we maintain about you or you may update or correct inaccuracies in that information by contacting us. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to the information. In addition, if you believe that personal information we maintain about you is inaccurate, subject to applicable law, you may have the right to request that we correct or amend the information by contacting us as indicated in the How to Contact Us section below.
Your Rights With Respect to Personal Data
Some data protection laws, including the European Union’s General Data Protection Regulation (“GDPR”), corresponding legislation in the United Kingdom, and some U.S. state laws, provide you with certain rights in connection with Personal Data you have shared with us. If you are resident in the European Economic Area, you may have the following rights:
- The right of access. You have the right to request a copy of your Personal Data which we hold about you.
- The right of correction: You have the right to request correction or changes of your Personal Data if it is found to be inaccurate or out of date.
- The right to be forgotten: You have the right to request us, at any time, to delete your Personal Data from our servers and to erase your Personal Data when it is no longer necessary for us to retain such data. Note, however, that deletion of your Personal Data will likely impact your ability to use our services.
- The right to object (opt-out): You have the right to opt-out of certain uses of your Personal Data at any time.
- The right to data portability: You have the right to a “portable” copy of your Personal Data that you have submitted to us. Generally, this means your right to request that we move, copy or transmit your Personal Data stored on our servers / IT environment to another service provider’s servers / IT environment.
- The right to refuse to be subjected to automated decision making, including profiling: You have the right not to be subject to a decision and insist on human intervention if the decision is based on automated processing and produces a legal effect or a similarly significant effect on you.
- The right to lodge a complaint with a supervisory authority.
You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you need further assistance regarding your rights, please contact us using the contact information provided below and we will consider your request in accordance with applicable law. To make these requests, you may contact us using the contact information below, and we will consider your request in accordance with applicable laws. For your protection, we may need to verify your identity before responding to your request, such as verifying that the email address from which you send the request matches your email address that we have on file. If we no longer need to process Personal Data about you in order to provide our Services or our Sites, we will not maintain, acquire or process additional information in order to identify you for the purpose of responding to your request.
In some cases our ability to uphold these rights for you may depend upon our obligations to process personal information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.
Changing or Deleting Your Information
You may update or correct information about yourself by making changes to your profile by emailing us at firstname.lastname@example.org. If you completely delete all such information, then your account may become deactivated. We may retain an archived copy of your records as required by law, to comply with our legal obligations, to resolve disputes, to enforce our agreements or for other legitimate business purposes.
We may contact you to request that you update your Personal Data on a regular basis to ensure its integrity for the purposes of ongoing data management.
Our Opt-in/Opt-out Policy
At any time, you can follow a link provided in offers, newsletters or other email messages (except for e-commerce confirmation or service notice emails) received from us or a Stratifyd Partner to unsubscribe from the service.
Your Ad Choices
As described above, we or third party partners may place or recognize a unique cookie on your browser when you visit our Sites for the purpose of serving you targeted advertising (also referred to as “online behavioral advertising” or “interest-based advertising”). You may find more information about entities involved in online advertising and additional choices you may make, including opt-out of having your information used for internet-based advertising, through the Network Advertising Initiative (“NAI”) at the NAI Service, and the Digital Advertising Alliance (the “DAA”) at the DAA consumer choice service. Stratifyd is a participant in the online industry’s self-regulatory program administered by the DAA and has agreed to adhere to the DAA’s principles applicable to interest-based ads.
The tools provided at the DAA opt-out page and the NAI opt-out page are provided by third parties, not Stratifyd. Stratifyd does not control or operate these tools or the choices that advertisers and others provide through these tools.
Third Party Links
The Sites may contain links to webpages operated by parties other than Stratifyd. We do not control such websites and are not responsible for their contents or the privacy policies or other practices of such websites. Our inclusion of links to such websites does not imply any endorsement of the material on such websites or any association with their operators. Further, it is up to the User to take precautions to ensure that whatever links the User selects or software the User downloads (whether from this Site or other websites) is free of such items as viruses, worms, trojan horses, defects and other items of a destructive nature. These websites and services may have their own privacy policies, which the User will be subject to upon linking to the third party's website. Stratifyd strongly recommends that each User review the third party's terms and policies.
We are committed to complying with applicable laws, regulations and mandatory government standards regarding the protection of Personal Data.
If we transfer your Personal Data out of your jurisdiction, we will implement suitable safeguards and rely on legally-provided mechanisms to lawfully transfer data across borders to ensure that your Personal Data is protected.
EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield
With respect to Personal Data received or transferred pursuant to the Privacy Shield Frameworks, Stratifyd is subject to the regulatory and enforcement powers of the U.S. Federal Trade Commission.
Pursuant to the Privacy Shield Frameworks, EU, UK and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also may correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to email@example.com. If requested to remove data, we will respond within a reasonable timeframe.
We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to firstname.lastname@example.org.
In certain situations, we may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. Stratifyd’s accountability for Personal Data that it receives in the United States under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Stratifyd remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the Personal Data on its behalf do so in a manner inconsistent with the Principles, unless Stratifyd proves that it is not responsible for the event giving rise to the damage.
In compliance with the Privacy Shield Principles, Stratifyd commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union, United Kingdom and Swiss individuals with Privacy Shield inquiries or complaints should first contact Stratifyd by email at email@example.com or via post at:
Stratifyd has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you.
If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at .
How We Protect Personal Data
Stratifyd maintains administrative, technical and physical safeguards designed to protect the User's Personal Data and information against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. We implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, taking into account technological reality, cost, the scope, context and purposes of processing weighted against the severity and likelihood that the processing could threaten individual rights and freedoms. For example, we restrict access to personal information to Stratifyd employees, contractors, business partners and agents who need to know that information in order to operate, develop or improve our services. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations. We use commercially reasonable security measures such as encryption, firewalls, and Secure Socket Layer software (SSL) or hypertext transfer protocol secure (HTTPS) to protect Personal Data.
If Stratifyd collects account information for payment or credit, Stratifyd will use the information only to complete the task for which the account information was offered.
The Site is not intended for use by children. We do not intentionally gather Personal Data about visitors who are under the age of 16. If a child has provided us with Personal Data, a parent or guardian of that child may contact us to have the information deleted from our records. If you believe that we might have any information from a child under age 16 in the applicable jurisdiction, please contact us at firstname.lastname@example.org. If we learn that we have inadvertently collected the personal information of a child under 16, or equivalent minimum age depending on jurisdiction, we will take steps to delete the information as soon as possible.
Direct Marketing and “Do Not Track” Signals
Stratifyd does not track its users over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals. However, some third party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your browser may include controls to block and delete cookies, web beacons and similar technologies, to allow you to opt out of data collection through those technologies.
California residents are entitled to contact us to request information about whether we have disclosed Personal Data to third parties for the third parties’ direct marketing purposes. Under the California “Shine the Light” law, California residents may opt-out of our disclosure of Personal Data to third parties for their direct marketing purposes. You may choose to opt-out of the sharing of your Personal Data with third parties for marketing purposes at any time by submitting a request to email@example.com. California users may request further information about our compliance with this law by contacting us at firstname.lastname@example.org or by writing to us at the address listed in the “How to Contact Us” section.
Stratifyd Partner Information. We collect information about individuals within our Stratifyd Partners organization (“Partner Information”). Partner Information may include information related to the Partner’s account, name, work e-mail address, work phone number, job title or similar kinds of information. We use Partner Information to support the Partner account, maintain our business relationship with the Partner, respond to Partner inquiries, or perform accounting functions. Stratifyd Partners may update personal information and password by logging into the Stratifyd Platform and updating their account. Stratifyd Partners may contact Stratifyd support in order to delete their Personal Data. In some cases, we may not be able to delete Partner Information, and in such cases we will tell you why.
Information about our Partners’ Contacts. We collect information about any contacts, such as employees, customers, and others, that may be uploaded into the Stratifyd Platform (“Information about our Partners’ Contacts”). Information about our Partner’s Contacts may include name, e-mail address, phone number, job title, or similar kinds of information. We use Information about our Partner’s Contacts for the purposes of providing Services to such contacts. Stratifyd Partners may update or delete Information about their contacts in the Stratifyd Platform. Stratifyd Partners may also contact Stratifyd support in order to update and delete such information. In some cases, we may not be able to delete such information, and in such cases we will tell you why.
Archival Information. We collect communications information for archival purposes on behalf of, and as directed by, our Stratifyd Partners. This information may include emails, texts, websites, social media messages or posts, and other forms of data or electronic communications (“Archival Information”). Archival Information includes data about our Stratifyd Partners and the third parties they correspond with. We do not control or monitor the information our Stratifyd Partners collect and store through our services, or their privacy practices or policies. It is our Partner’s obligation to obtain all necessary consents and to comply with all applicable laws with respect to the Partner’s communications and use of our services. Our Partner’s privacy policies or practices apply to Archival Information, the purposes for which the Partner collects Archival Information, how the Partner may use Archival Information and what choices the individual may have with respect to Archival Information. Individuals must contact the applicable Partner in order to correct, amend, or delete their information, or to opt out of any collection, uses or disclosure of their information by our Partner.
Automatically Collected Information. We collect information automatically about how our Stratifyd Partners use our services (“Automatically Collected Information”). We do this via data collection technologies such as cookies, web beacons, gifs or other tracking technologies. We collect this information in order to monitor, support and improve our services or to provide Stratifyd Partners with certain customized features. We may use Automatically Collected Information to tell us how our Stratifyd Partners use our services, to improve our services or develop new products, services or features. We may combine this information with other information we collect.
We will retain Partner Information we process on behalf of our Stratifyd Partners for as long as needed to provide services to our Partner, or for the period of time requested by a particular Partner.