Strativity Group, LLC
401 Hackensack Avenue, 8th Floor
Hackensack, NJ 07601
Strativity has further committed to refer unresolved privacy complaints under the EU-US and Swiss-US 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.
Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.
Investigatory and Enforcement Powers of the Federal Trade Commission
Strativity is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
Personal Data That We Collect
We are in the consulting business, and we generally would collect personal data about an individual either in the course of administering our relationship with our clients, in the course of executing our consulting engagements, or through the Website in connection with the promotion of our services.
If you are a client or work for a client, we likely have collected various contact, business, and in some cases financial information about you in the course of administering our relationship with you or your employer. In those cases, our legal basis for the collection and processing of the information is our legitimate interest to perform our obligations under our contract with you or the company for which you work.
In connection with the execution of our consulting engagements, we sometimes collect personal data about specific employees, customers, or prospects of our client from that client. This information might include name, job title, email address and other contact information, and demographic information. In these cases, our legal basis for the collection and processing of the information is our legitimate interest to perform our obligations under our contract with our client. We also conduct a certain survey and other research activities, and in connection with these activities we collect personal data, such a name or contact information, directly from a survey respondent. Our legal basis for collection and processing of respondent-supplied personal data is consent; we do not collect personal data without the affirmative consent of the research participant. Consent can be withdrawn at any time.
The Website also collects personal data from you that you specifically and voluntarily provide to us as you use the Website. Such information might include your name, company affiliation, job title, email address, country of residence as well as other types of information. You may choose to provide such information to us in order to subscribe for newsletters or to access other products or services provided by us and our business partners. If you choose to purchase any products or services through the Website, you may also be asked to provide us with your payment information as a condition to such purchase. If you contact us, for example by sending us an email, we may retain copies of your correspondence (including your email address). In these cases, our legal basis for collection and processing of your personal data is consent; we do not collect personal data without the affirmative consent of the research participant. Consent can be withdrawn at any time.
As you navigate through the Website, we may also collect standard internet log information, including your IP address, operating system, browser type, language, access times and referring website addresses through service providers such as Google Analytics and Google Advertising. We may collect this information to enhance the Website, facilitate improved navigation and personalize advertising, which includes remarketing, demographic and location targeting. For these purposes, we (or our services providers) may also obtain information about your general internet usage by using cookies.
Pages of the Website may contain electronic images known as web beacons that permit us to count users who have visited those pages and for other related website statistics. Web beacons are not used to access your personal information on the Website and are only used to compile aggregated statistics concerning use of the Website. Currently, our systems do not respond to browser do-not-track signals, and we do not treat such do-not-track signals as “do not sell” signals under CCPA (as defined below).
How We Use Your Personal Data
Depending on how we obtain your personal data (as described above), we may either be considered a “controller” or a “processor” under applicable law as to that data. If we are the processor, we will process the data in accordance with the instructions provided to us by the controller of that data.
We may use information that we collect about you or that you provide to us, including any personal data, in the following ways:
- To present the Website and its contents in a suitable and effective manner.
- To provide you with information, products or services that you request from us.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
- To notify you about changes to our service.
- To allow you to participate in interactive features of our service, when you choose to do so.
- In any other way we may describe when you provide the information.
We do not rent, sell or give this personal data to any third party for the purpose of directly marketing any products or services, or otherwise make any use of this data. We do not “sell” personal data as defined under the California Consumer Privacy Act (“CCPA”), and have not done so in the preceding 12 months. We also do not “sell” (as defined in CCPA) personal information of persons under 16 without affirmative authorization, or otherwise.
In cases of onward transfer to third parties of data of EU and Swiss individuals received pursuant to the EU-US and the Swiss-US Privacy Shield, Strativity is potentially liable.
In all cases, we will take reasonable steps to ensure the personal data is accurate, complete, current and relevant and being used only for the intended purposes. We will not process personal data in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by the individual.
Disclosure of Your Information
We may disclose personal data that we receive or collect about you (as described above) to contractors and service providers we use to support our business. In these cases, we require the third party to follow all of the same privacy protection regulations as followed by us.
In the event of a merger, acquisition, or any form of sale of some or all of Strativity’s assets, personal data held by us about our clients will be among the assets transferred to the buyer.
|Category of consumer personal information collected (non-HR)||Source from which collected||Purposes for which collected||Categories of third parties with whom shared|
|Name and contact information – website visitor||Supplied by person himself/herself||Marketing of our own services||Technology infrastructure vendors|
|Name and contact information – client officer||Supplied by person himself/herself||Administration of business||Technology infrastructure vendors|
|Systems details – visitors to Websites (IP/device ID, browser settings, similar)||The computer or device of the person himself/herself||Internal analytics; improvement of Website experience||Technology infrastructure vendors|
All information may also be shared among our affiliated group of companies solely for administrative and operations purposes.
Additional Rights as to Your Personal Data
If you would like further information about these rights or would like to exercise any of them, including to opt out of the “sale” of your information as defined in the CCPA, please write to us at LRW Group, 1900 Ave of the Stars, 16th Floor, Los Angeles, CA 90067 USA, Attn: Privacy Officer, email us at privacy@LRWGroup.com, call us at (800) 591-6538, or submit your question or request at https://LRWGroup.com/YourDataYourRights/.
By law, as well as for your protection, if you request that we take certain actions as to personal data we have about you, we are required to take certain steps to verify your identity. If we are not able to verify your identity, we may not be able to respond to your request. To verify your identity, we request, at point of submission of your request, that you supply your basic contact information, as well as certain other non-personally identifiable information (e.g., information relating to your last interaction with us, such as subject matter and type of study), and we endeavor to match at least two pieces of this information with information in our possession. In addition, as to those rights permitted by law to be exercisable by an authorized agent on your behalf, in addition to verifying your identity as described above, we require the agent to also supply written authorization from you to act on your behalf, except where restricted by law.
Children Under the Age of 13
The Website is not intended for children under 13 years of age. It is our policy not to knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on the Website. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information.
Retention of Personal Data
We keep personal data for no longer than necessary for the purposes for which the personal data is collected or processed. The length of time we retain personal data for depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights.
We maintain physical, electronic and procedural security measures to help safeguard client and personal data which are consistent with industry standards and practice and in compliance with applicable law. Third parties that provide us with support or services and that may also receive client or personal data are required by us to maintain security measures similar to ours with respect to such information. We will take reasonable precaution, consistent with industry standards and practice, to protect personal data from loss, misuse, unauthorized access, disclosure, alteration, and destruction.
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