This “Privacy Policy” describes the privacy practices of Strety Holdings, Inc. and our subsidiaries and affiliates (collectively, “Strety,” “we,” “us” or “our”) in connection with the strety.com website and any other website or application which posts or links to this Privacy Policy (collectively, the “Service”).  

This Privacy Policy does not apply to information that we process on behalf of our business customers (such as businesses and other organizations) while providing the Strety platform to them. Our use of information that we process on behalf of our business customers may be governed by our agreements with such customers. If you have concerns regarding your personal information that we process on behalf of a business customer, please direct your concerns to that enterprise customer.

Strety’s customers may have their own policies regarding the collection, use and disclosure of their employees’ personal information, and Strety is not responsible for our customers’ handling of such information. Strety’s handling of our customers’ employee data may be governed by service agreements with our employer-customers. To learn about how a particular customer handles personal information, we encourage you to read the customer’s privacy statement or contact the customer directly.

WHAT WE COLLECT

Information you give us. Personal information that you may provide through the Service or otherwise includes:

• Contact information, such as your‎ name, email address, employer, title and manager;
• Profile information, such as username, password, employer, and start date;
• Transaction information, such as information about payments from you and other details of services you have purchased from us;
• Marketing information, such as your preferences for receiving communications about us, and details about how you engage with our communications;

• User-generated content data, such as photos, images, tasks, KPIs, comments, questions, messages, works of authorship, and other content or information that you generate, transmit, or otherwise make available on the Service, as well as associated metadata. Metadata includes information on how, when, where and by whom a piece of content was collected and how that content has been formatted or edited. Metadata also includes information that users can add or can have added to their content, such as keywords, geographical or location information, and other similar data; and

• Other information that you choose to provide but is not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

• Information from third party sources.We may combine personal information about you from other sources. We may add this to information we get from this Site. Third-party services that you use to log into, or otherwise link to, your Service account, such as Microsoft. This data may include your username, profile picture and other information associated with your account on that third-party service that is made available to us based on your account settings on that service.

Information collected automatically. We, our service providers, and our business partners may automatically log the following information about you, your computer or mobile device, and your activity over time on the Site and other online services:

• Device data, such as your computer or mobile device operating system type and version number, manufacturer and model, browser type, screen resolution, IP address, unique identifiers, and general location information such as city or town.
• Usage data, such as the website you visited before browsing to the Site, pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.

• Communication interaction data such as your interactions with our email, text or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.

Some of our automatic collection is facilitated by:

• Cookies, which are text files stored on a visitor’s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently and remembering your preferences, enabling functionality and helping us understand user activity and patterns.
• Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications.
• Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

• Chat technologies, such as those provided by Intercom that employ cookies and software code to operate the chat features that you can use to communicate with us through the Service. Intercom and other third parties may access and use information about webpages visited on our website, your IP address, your general geographic information (e.g., city, state), and other personal information you share through online chats for the purposes described in this Privacy Policy.

USE OF PERSONAL INFORMATION

We use your personal information for the following purposes or as otherwise described to you at the time of collection:

Service delivery. We use your personal information to:

• provide, operate, maintain, and improve the Service;
• communicate with you regarding the Service, including by sending you Service announcements, technical notices, updates, security alerts, and support and administrative messages;
• process your Service transactions and any related payments;
• understand your needs and interests, and personalize your experience with the Service; and
• provide support for the Service and respond to your requests, questions and feedback.

Service operation. We use your personal information to:

• provide, operate, maintain and improve the Service;
• understand your needs and interests, and personalize your experience with the Service; and
• provide support for the Service and respond to your requests, questions and feedback.

Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Service and our business and develop other products and services. As part of these activities, we may create aggregated, de-identified or other anonymous data from personal information we collect. We may make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.  

Marketing. We may collect and use your personal information for marketing purposes:

• Direct marketing. If you request information from us, use the Service or participate in our surveys, promotions or events, we may send you Strety-related marketing communications as permitted by law but will provide you with the ability to opt out.

Compliance and protection. We may use your personal information to:

• protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
• audit our internal processes for compliance with legal and contractual requirements and internal policies;
• enforce our Terms of Use;
• protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft; and
• comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities.

Cookies and similar technologies. In addition to the other uses included in this section, we may use the cookies and similar technologies described above for the following purposes:

• Technical operation. To allow the technical operation of the Service, such as by remembering your selections and preferences as you navigate the site, and whether you are logged in when you visit password protected areas of the Service.
• Functionality. To enhance the performance and functionality of our services.
• Analytics. To help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails. For example, we use Google Analytics for this purpose. You can learn more about Google Analytics and how to prevent the use of Google Analytics relating to your use of our sites here: https://tools.google.com/dlpage/gaoptout?hl=en.

Other purposes with your consent. In some cases we will ask for your consent to collect, use or share your personal information for other purposes.

SHARING OF PERSONAL INFORMATION

We may share your personal information with the following parties and as otherwise described in this Privacy Policy or at the time of collection:

• Service providers. We may employ companies and individuals to help provide the Service on our behalf or help us operate our business (such as IT, customer support, hosting, website analytics, email delivery, marketing and advertising, research, event management). Payment processors.  Any payment card information you use to make a purchase on the Service is collected and processed directly by our payment processor, Stripe, and we never physically receive or store your full payment card information. Stripe commits to complying with the Payment Card Industry Data Security Standard (PCI-DSS) and using industry standard security. Stripe may use your payment information in accordance with its own Privacy Policy here: https://stripe.com/privacy.
• Linked third-party services. If you log into the Service with, or otherwise link your Service account to a third-party service, we may share your personal information with that third-party service. The third party’s use of the shared information will be governed by its privacy policy and the settings associated with your account with the third-party service.
• Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services they render to us.
• Compliance and protection. We may disclose your personal information as we believe appropriate to government or law enforcement officials or private parties (a) for the compliance and protection purposes described above; (b) as required by law, lawful requests or legal process, such as to respond to subpoenas or requests from government authorities; (c) where permitted by law in connection with any legal investigation; and (d) to prosecute or defend legal claims.
• Business Transfers. We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business deal (or potential business deal) such as a merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy, in which case we will make reasonable efforts to require the recipient to honor this Privacy Policy.
• Other users. Your profile and other user-generated content data (except for messages) may be visible to other users of the Service. For example, other users of the Service may have access to your information if you chose to make your profile or other personal information available to them through the Service, such as when you provide comments or share other content. This information can be seen, collected and used by others, including being cached, copied, screen captured or stored elsewhere by others, and we are not responsible for any such use of this information.

INFORMATION CHOICES

Access or update your information. You may send requests about accessing or updating your personal information to privacy@strety.com or our postal address provided in the “Contact Us” section below.

Delete or close your account. If you wish to request to close your account, please contact us. Marketing communications. You may opt out of our marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email. You may continue to receive service-related and other non-marketing emails.

Cookies. Most browsers let you remove and/or stop accepting cookies from the websites you visit. To do this, follow the instructions in your browser’s settings. Many browsers accept cookies by default until you change your settings. If you do not accept cookies, however, you may not be able to use all functionality of the Service and our website may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit http://www.allaboutcookies.org.

Blocking images/clear gifs: Most browsers and devices allow you to configure your device to prevent images from loading. To do this, follow the instructions in your particular browser or device settings.

Linked third-party platforms. If you choose to connect to the Service through your social media account or other third-party platform, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Choosing not to share your personal information. Where we are required by law to collect your personal information, or where we need your personal information in order to provide the Service to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with our services. We will tell you what information you must provide to receive the Service by designating it as required at the time of collection or through other appropriate means.

CALIFORNIA RESIDENTS 

If you are a California resident, then you also have certain rights under California law.  You may exercise these rights by contacting us as set forth in the “Contact Us” section. 

Sharing and Selling 

Under California law, “Share” is defined to include sharing, renting, releasing, disclosing, disseminating, or making available personal information to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration, and a “Sale” is defined broadly to include the selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating the personal information of a consumer to another business or third party for anything of value.   

Strety does not Share or Sell your personal information as a matter of course; however, it is possible that it may do so in the future (e.g., as part of an acquisition).  If you are a California resident and would like to opt-out of the Sharing or Sale of your personal information to our sponsors, partners, and other third parties, you may.  Once you make an opt-out request, we will wait at least twelve months before asking you to reauthorize.   

Right to Limit 

Under California law, some personal information you may provide to us may be considered “sensitive” personal information. You may, at any time, direct us (and our service providers) to limit our use and disclosure of your “sensitive” personal information to only those uses which are necessary to perform the Services, or for any other lawful purpose. Once you exercise this right, we will not use or disclose your sensitive personal information for any other purposes without your express consent unless permitted by applicable law. However, we may continue to use or disclose your personal information that is not considered “sensitive” as set forth in this Privacy Policy. 

Right to Know and Modify; Data Portability.  

California law requires that we provide you with specific categories of data that we have collected about you in the last twelve months, including: (i) the categories of personal information we have collected about you; (ii) the categories of sources from which the personal information is collected; (iii) the business or commercial purpose for collecting your personal information; (iv) the categories of third parties with whom we have shared your personal information; and (v) the specific pieces of personal information we have collected about you.  If there are inaccuracies in the data and personal information we retain about you, you have the right to request that these inaccuracies be corrected.  

The information requested will be delivered in a portable and readily useable format that allows you to transmit this information to another entity without hindrance. 

Right to Delete 

You have the right to request that we delete the personal information we have collected from you.  There are a number of exceptions, however, where we would retain your personal information even if you request that it be deleted.  These exceptions include, for example, if we need to retain the information to comply with applicable law, provide you with a good or service, or preserve the security of our systems.   

When you contact us to exercise your rights under this section, we may request identity verification.  Only you, or someone legally authorized to act on your behalf, may exercise these rights, except that a parent may also exercise some of these rights on behalf of their child.  Your request must be described with sufficient detail to allows us to properly understand, evaluate, and respond to it. 

Please note that you may be limited in the number of times that you may exercise certain of these rights each year, subject to applicable law. 

Refusal of Requests 

 To the extent permitted by California law, we may refuse to disclose to you personal information that we have collected about you under the following circumstances, among others: 

• We cannot verify your request; 

• The request is manifestly unfounded or excessive, or we have already provided personal information to you more than twice in a 12-month period; 

• We cannot disclose certain sensitive information, such as your social security number, financial account number, or account passwords, although we will disclose whether we have collected that type of information; 

• If disclosure would restrict our ability to comply with legal obligations, exercise legal claims or rights, or defend legal claims; and/or 

• If the personal information consists of certain medical information, consumer credit reporting information, or other types of information that is exempt from disclosure under California law. 

OTHER STATE LAW PROVISIONS 

If you are a resident of Virginia, Colorado, Connecticut, Tennessee, Texas, Montana, beginning on January 1, 2025, Iowa, and beginning on January 1, 2026, Indiana, applicable law requires us to receive your opt-in consent before processing any “sensitive data”, which includes (1) personal information revealing racial or ethnic origin, religious beliefs, mental or physical health diagnosis, sexual orientation, or citizenship or immigration status; (2) the processing of genetic or biometric data for the purpose of uniquely identifying a natural person; (3) personal information collected from a known child; or (4) precise geolocation data. We will ask for your opt-in consent before processing your sensitive data in connection with the Service. If you opt-in and change your mind, you may opt-out by contacting us as set forth in the “Contact Us” section. 

It is possible that your state or jurisdiction provides that you have other rights that are the same as or similar to the rights for California residents described above.  If this is the case, you may exercise these rights using the process set forth for California residents. 

RIGHTS OF RESIDENTS OF THE UK AND EUROPEAN ECONOMIC AREA 

 If your personal data has been collected in connection with our activities in the UK or European Economic Area, you have the following rights: 

Withdrawal of Consent: If consent is the lawful basis of our processing, you have the right to withdraw any consent that you have provided to us to process your personal data. 

Access: You have the right to access your personal data. 

Rectification: You have the right to rectify inaccurate personal data. 

Erasure: You have the right to have your personal data erased if it is no longer necessary for the purposes for which it was processed, you have withdrawn your consent to, or object to, its processing and there is no other legitimate grounds for processing it or you believe that it has been unlawfully processed. 

Restriction: You have the right to have the processing of your personal data restricted if you contest its accuracy, if its processing is unlawful, if we no longer need it but you need it preserved for purposes of a legal claim, or if you have objected to its processing and are awaiting verification of our legitimate grounds for processing it.  

Data Portability: You have the right to have certain personal data you provide to us transferred to another company in a machine-readable format. 

Objection: You have the right to let us know that you object to the further use or disclosure of your personal data for certain purposes. 

In order to exercise any of these rights, or for more information, you may contact us as set forth in the “Contact Us” section.  Please note that these rights are subject to certain preconditions and qualifications under applicable law. 

SECURITY

The security of your personal information important to us. We take a number of organizational, technical and physical measures designed to protect the personal information we collect, both during transmission and once we receive it. However, no security safeguards are 100% secure and we cannot guarantee the security of your information.

Authorized User Support Access

At Strety, we value the privacy and security of our users' data. Our administrative team may, under specific circumstances, masquerade as a user in your Strety Organization through our admin application designed to allow our team to troubleshoot issues, provide user support, and ensure the smooth operation of our platform.

Conditions for Authorized User Support Access:

• Support and Troubleshooting: Authorized user support access is limited to scenarios where we need to support, troubleshoot or resolve issues reported by users.
• Minimal Access: Our team will generally access only the information and system settings that we believe are necessary to resolve the issue at hand. Access is restricted to authorized Strety personnel who have undergone certain security training.

INTERNATIONAL DATA TRANSFERS

We are headquartered in the United States and therefore store your personal information on web servers and systems in the United States. 

THIRD PARTY SITES AND SERVICES

The Service may contain links to other websites and services operated by third parties, such as social media platforms, advertising services and other websites and applications. These links are not an endorsement of, or representation that we are affiliated with, any third party. We do not control third party websites, applications or services, and are not responsible for their actions. Other websites and services follow different rules regarding their collection, use and disclosure of your personal information. We encourage you to read their privacy policies to learn more.

CHILDREN

The Service is not directed at, and Strety does not knowingly acquire or receive personal information from, children under the age of 13. If we learn that any user of the Service is under the age of 13, we will take appropriate steps to delete that individual’s personal information and restrict that individual from future access to the Service.

CONTACT US

Please direct any comments or questions about this Privacy Policy or privacy practices to privacy@strety.com.

CHANGES TO THIS PRIVACY POLICY

We reserve the right to modify this Privacy Policy. If we make any changes, we will change the Last Updated date above. We encourage you to periodically review this page for the latest information on our privacy practices.

Any modifications to this Privacy Policy will be effective upon our posting of the new policy and/or upon implementation of the new changes in the Service (or as otherwise indicated at the time of posting). In all cases, your continued use of the Service after the posting of any updated Privacy Policy indicates your acceptance of the update.