Updated: September 9. 2018.
II. Transparency Notice–What Information We Collect and How We Use It
The types of information we may collect (directly from you or from Third Party-sources) and our privacy practices depend on the nature of the relationship you have with Stirista and the requirements of applicable law. Below are some of the ways we collect information and how we use it.
1. Information Stirista Collects
If you are a Customer (or an employee or agent of a Customer) with an account, we collect certain information (“Collected Information”) from you when you sign up for our Services, such as your name, email address, mailing address, and phone number. If you are a User, we collect certain, limited, anonymized information about the unique application identifiers, application installations, and mobile devices you use, which is provided by our Customers through their subscription to our Services. We also collect information about the online activity of each Customer or Visitor on the site, such as pages viewed, time spent on a page, configuration of a Customer’s or Visitor’s landing page, or settings used. We also automatically collect information about the device used by each Customer or Visitor who accesses the Site or Services, such as: operating system, hardware version, device settings, IP address, time zone, language setting, referring URL, browser, cookie information, click path, general geographic information, and Internet Service Provider.
2. Information from Third-Party Sources
Stirista may collect information about you from Third-Party sources to supplement information provided by you, including Internet Protocol addresses, cookies, navigational data, and advertisements clicked. This supplemental information allows us to verify information that you have provided to Stirista and to enhance our ability to provide you with information about our business, products, and Services. Stirista’s agreements with these Third Party-sources typically limit how the Company may use this supplemental information.
3. How Stirista Uses Collected Information
Depending on how you interact with Stirista, we and our Third Party-service providers may also use Collected Information in a variety of ways, including:
· Providing Information and Services You Requested. Stirista may use the Collected Information to fulfill requests for programs, Services, or information that you may request, including information about potential or future Services, including to: (a) generally manage your information and accounts; (b) respond to questions, comments, and requests; and (c) provide access to certain areas and features of the Services;.
· Marketing Products and Services. Stirista may use the Collected Information to provide you with materials about offers, products and services offered by us, or by our Customers. Stirista may provide you with these materials by mobile application notification, postal mail, or email, as permitted by applicable law. Such uses include: (a) to tailor content, advertisements, and offers; (b) to notify you about offers, products, and services that may be of interest to you; (c) to provide Services to you; (d) for other purposes disclosed at the time that you provide Collected Information; or (e) otherwise with your consent. If you do not wish us to use your Collected Information for marketing purposes, you may contact us at any time to opt out of the use of your Collected Information for such purposes, as further described below.
· Research and Development. Stirista may use your Collected Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and Services or develop new products, processes and services.
· Anonymous and Aggregated Data. Including as discussed below, Stirista may use and share your anonymized or aggregated information within the Stirista group of companies or with Third Parties for research, analytics, and any other legally permissible purposes.
· Other Uses. Stirista may use your Collected Information for other purposes disclosed to you at the time you provide Collected Information or with your consent.
4. Social Media
Generally, online social media resources (“SMR”) are interactive tools that enable individuals to collaborate and share information with others. Social media resources include, but are not limited to, social networks, discussion boards, bulletin boards, blogs, wikis, and referral functions to share web site content and tools with a friend or colleague.
5. Direct Mail and Email Marketing
Visitors who provide us with Collected Information, or whose Collected Information we obtain from Third Parties, may receive periodic emails, newsletters, or mailings from us with information on Stirista or our business partners’ products and Services or upcoming special offers/events we believe may be of interest. We offer the option to decline these communications at no cost to the individual by following the instructions below.
6. All Internet Users – Cookies, Pixel Tags/Web Beacons, Analytics Information, and Interest-Based Advertising
Like many other websites, Stirista or its business partners may employ a cookie, or small piece of computer code that enables Web servers to “identify” visitors, each time a Visitor initiates a session on the Company’s Sites. A cookie is set in order to identify visitors; tailor our Sites to you; measure and research the effectiveness of our Sites’ features, offerings, and advertisements; and authenticate users for registered Services. Cookies can only access Collected Information that you have provided on our Sites and cannot be accessed by other sites. Visitors also have the ability to delete cookie files from their own hard drive at any time by clicking on the Privacy or History tab typically found on the Settings or Options menu in your internet browser. However, please also be advised that cookies may be necessary to provide access to much of the content and many of the features of Stirista’s Sites.
Pixel Tags/Web Beacons
Stirista may use “pixel tags,” also known as “web beacons,” which are small graphic files that allow us to monitor the use of our Sites. A pixel tag can collect information such as the Internet Protocol (“IP”) address of the computer that downloaded the page on which the tag appears; the URL of the page on which the pixel tag appears; the time the page containing the pixel tag was viewed; the browser type and language; the device type; geographic location; and the identification number of any cookie on the computer previously placed by that server. When corresponding with you via HTML capable email, we or our Third Party-service providers may use “format sensing” technology, which allows pixel tags to let us know whether you received and opened our email.
We may also use Google Analytics and Google Analytics Demographics and Interest Reporting to collect information regarding visitor behavior and visitor demographics on some of our Sites, and to develop website content. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout. Stirista also uses its own Platform to provide analytics internally and to Customers as mentioned above.
Through our Sites, Stirista may in the future allow Third-Party advertising partners to set tracking tools (e.g., cookies) to collect anonymous Collected Information regarding your activities (e.g., your IP address, page(s) visited, time of day). We may also share such de-identified information we have collected with Third-Party advertising partners and our Customers. These advertising partners and Customers may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit non-Stirista related websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising.”
7. Mobile Devices
Stirista may provide websites, applications, and online resources that are specifically designed to be compatible and used on mobile devices. Stirista will collect certain information that your mobile device sends when you use such websites, applications, or online resources, like a device identifier, location, language, user settings, and the operating system of your device.
8. Anonymous and Aggregated Information
Stirista may use your Collected Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access the Sites or other online Services, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. Anonymized or aggregated information is not Collected Information, and Stirista may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within Stirista, with Customers, and with Third Parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
III. Choice and Opt-Out
Where you have consented to Stirista’s Processing of your Collected Information, you may withdraw that consent at any time and opt out by following the instructions below. Additionally, before we use Collected Information for any new purpose not originally authorized by you, we will provide information regarding the new purpose and give you the opportunity to opt-out. Note that, due to the nature of the Services, you may have to provide the email or other identifying value that is associated with your Collected Information in order for Stirista to segregate out the use and retention of such Collected Information.
Prior to disclosing Collected Data to a Third Party or Customer for a purpose other than its original purpose or the purpose authorized subsequently by the individual, Stirista will endeavor to obtain each individual’s explicit consent (opt-in). Where consent of the individual for the Processing of Collected Information is otherwise required by law or contract, Stirista will comply with the law or contract.
10. Email Communications
11. “Do Not Track”
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. At this time, there is no general agreement on how companies like Stirista should interpret DNT signals. Therefore, Stirista does not recognize or respond to browser-initiated DNT signals, whether that signal is received on a computer or a mobile device. For information about “do-not-track,” visit http://www.allaboutdnt.org.
IV. Onward Transfer
12. Information We Share
Stirista may share Collected Information with our service providers that we have retained to perform Services on our behalf including (i) provision of IT and related Services; (ii) provision of information and Services you have requested; and (iii) customer service activities.
Stirista has executed appropriate contracts with our service providers that prohibit service providers from using or sharing your Collected Information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.
Information Disclosed for Our Protection and the Protection of Others
We may disclose information about you: (i) if we are required to do so by law, court order or legal process; (ii) in response to lawful requests by public authorities, including to meet national security or law enforcement requirements; (iii) under the discovery process in litigation; (iv) to enforce Stirista policies or contracts; (v) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vi) if we, in good faith, believe that disclosure is otherwise necessary or advisable.
In addition, from time to time, server logs may be reviewed for security purposes – e.g., to detect unauthorized activity on the Services. In such cases, server log data containing Collected Information may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.
Information Disclosed in Connection with Business Transactions
13. Data Transfers
Stirista primarily stores Collected Information sent or collected via or by Stirista in the United States, in the cloud, our servers, the servers of our affiliates or the servers of our service providers. To facilitate the Company’s global operations, the Company may transfer, store and access such information from around the world. Your Collected Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to Stirista, you consent to the storage of your Collected Information in these locations.
V. Rights of Access, Rectification, Erasure and Restriction
14. Your Collected Information
15. Customer Data
As a data processor for our Customers, Stirista Processes data that may include Collected Information of Users (“Customer Data”). Stirista will not review, share, distribute or reference any such Customer Data except as provided in the agreements between us and our Customers, or as may be required by law. If Collected Information pertaining to you as an individual has been submitted to us by a Customer as Customer Data and you wish to exercise any rights you may have to access, correct, amend, or delete such data, please inquire with the relevant Customer directly. Because Stirista personnel have limited to no ability to access Customer Data, if you wish to make your request directly to Stirista, please provide the name of the relevant Stirista customer. We will refer your request to that Customer and will support them as needed in responding to your request within a reasonable timeframe.
The security of all Collected Information provided to Stirista is important to us, and Stirista takes reasonable steps designed to protect your Collected Information. Unfortunately, no data transmission over the Internet or storage of information can be guaranteed to be 100% secure. As a result, while Stirista strives to protect your Collected Information, we cannot ensure or warrant the security of information you transmit to Stirista. You are responsible for maintaining the secrecy of your own passwords. If you have reason to believe that your passwords or Collected Information is no longer secure, please promptly notify Company at firstname.lastname@example.org.
VIII. Redress and Accountability
Stirista will address your concerns and attempt to resolve any privacy issues in a timely manner.
IX. Other Rights and Important Information
16. Information Regarding Children
Due to the nature of Stirista’s business, Services are not marketed to minors. Stirista does not knowingly solicit or collect Collected Information from children under the age of 13 (and in certain jurisdictions under the age of 16). This applies to any Collected Information directly collected by us but does not apply to the Collected Information provided to us by Third Party services and organizations or from our Customers regarding Users (please refer to the terms of their respective Privacy Policies). If we learn that we have Collected Information from a child under the age of 13 (and in certain jurisdictions under the age of 16) in relation to the Services, we will promptly delete that information.
17. California Privacy Rights
California residents are allowed to request certain information regarding whether the operator of an online service discloses personally identifiable information (as defined in §1798.83 of the California Civil Code) about them to any third parties for the third parties’ direct marketing purposes. At this point, we do not collect any such PII. If technical capabilities change and provide us with the ability to associate the information that we collect about Users to a specific individual (and we choose to do so), we will comply with the requirements of Cal. Civ. Code §1798.83.
If you have questions about this provision, you may contact us as provided in the “Redress and Accountability” section. You may reach the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs by mail at 1625 North Market Blvd., Sacramento, CA 95834, or by telephone at (916) 445-1254 or (800) 952-5210.
18. Links to Third-Party Digital Properties
“Process” or “Processing” means any operation which is performed upon Collected Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
“Third Party” is any natural or legal person, public authority, agency, or body other than the Visitor, Stirista or Stirista’s agents.