Effective Date: March 12, 2020
2. INFORMATION WE COLLECT AND HOW WE USE IT
Required Information You Voluntarily Provide Us.
When you begin using the App, you will be required to provide us with various information that, on its own or in combination with other information, can used to identify you as an individual (“Personal Data”). To access the App, you will be required to provide us with your first and last name and your e-mail address. You will also be prompted to create a password.
The App integrates with Zoom, and in order to access the App, you must have a valid account with Zoom. By accessing and using the App, you grant Strive access to your Zoom account. By granting Strive access to your Zoom account, you understand and agree that Strive will have access to the Recordings, your Zoom ID User ID, and any Zoom meeting ID linked to the Meeting. You understand that the Recordings themselves could capture, either by audio or video, certain Personal Data, including, without limitation, your appearance, your voice, and any other Personal Data you chose to capture in the Recordings.
Optional Information You Voluntarily Provide Us.
In addition to the required information that you provide to Strive in order to use the App, there are various pieces of information you can, or may in the future be able to, choose to provide as part of your use of the App. For example, you may choose to provide us with various information about your current professional performance and learning goals, or certain Personal Data may be captured via audio or video on the Recordings, and thereafter made available to Strive through your use of the App. We use this information for the purpose of providing you with the core aspects of the App. For example, you may provide us with information that is necessary to provide the coaching services to you as part of the App in an effort to assist in your learning and professional development.
Further, now or in the future, we may allow you to provide us with access to additional information and data through integrations with third party goods and services.
The various categories of information in this subsection is, or may be, considered Personal Data, and is used for the purpose of providing you with the App’s functionality. While all of the information described here may not be required to use the App, some aspects of the App may not be available if you choose not to provide us with such information.
You may also choose to provide us with special categories of Personal Data, including, without limitation, Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data, health data, or data concerning a natural person's sex life or sexual orientation (collectively, “Special Information”). This type of Personal Data could be provided to Strive via the Recordings, or via any other form of communication you have with Strive. You are not required to provide us with your Special Information, but to the extent you choose to submit your Special Information, such information will only be used for the purposes of providing you our services in conjunction with the App. By agreeing to this Policy and by your use of the App, you explicitly consent to our collection and use of your Special Information.
Information Collected Automatically As You Use The App.
In addition to the information that you provide to us voluntarily, Strive may, now or in the future automatically collect information through the App about how you use and interact with the App and other similar activities in order to better understand our users and how they use the App, and to improve the App.
3. PURPOSES OF COLLECTION AND LEGAL BASES FOR USE
We use the Personal Data described above primarily for providing you with the core aspects of the App, namely to provide you with the Coaching Services.
However, we also use your Personal Data, or aggregated and/or anonymized Personal Data (but not Personal Data that can be used to identify users), for our own purposes of understanding our users and how they use the Service, as well as improving the Service over time. By using the Service, you consent to these additional uses.
The legal grounds for our processing your Personal Data for the purposes above are:
- first and foremost, you provided your consent by agreeing to this Policy, which you may withdraw at any time by emailing us at email@example.com;
- it is necessary for our contractual relationship;
- the processing is necessary for us to comply with our legal or regulatory obligations; and/or
- the processing is in our legitimate interest as a provider of the App (for example, to protect the security and integrity of our systems and to provide you with customer service and the core functionality of the App).
4. HOW WE SHARE YOUR INFORMATION
First of all, we do not sell or share your Personal Data with advertisers. We also do not share your Personal Data with other third parties except to the extent that it is in furtherance of the App, or when you choose to do so (as described below and in the Terms and Conditions for Meeting Metrics.
Information Shared By You Through The App.
You may, now or in the future, be able to choose to voluntarily share information collected through the App through email, or other means of communication.
Your Company may have access to your Personal Data. Strive acts at the direction of your Company with regards to sharing your Personal Data with your Company.
Our Personnel And Vendors.
To be able to effectively provide you with the App, and to improve the functionality of the App, we may disclose your Personal Data to our employees, contractors, agents, vendors, and other similar persons or entities, including without limitation the coaches that assist with the Coaching Services, to the extent that such persons or entities have a need-to-know such Personal Data in furtherance of the App and Coaching Services. Our third-party vendors (“Third-Party Vendors”) provide us with various types of services, including without limitation, hosting services, web application integration services, form and online survey creation services, marketing software services, e-mail services, customer relationship management software services, messaging software services, and data management software services. We may share your Personal Data, including Special Information, with our Third-Party Vendors.
Sale of Company or Assets.
In the event that we sell all or substantially all of our company or its assets, including the Personal Data collected through the App, we may transfer your information, upon reasonable notice to you, to the acquiring company.
Other Third Parties.
In addition to our practices described above, we may share your Personal Data if we have a good-faith belief that such action is necessary to (1) comply with the law (see the section below on “Government Requests”), (2) protect and defend the rights or property of Strive, or (3) prevent an emergency involving danger of death or serious physical injury to any person. We will only share your Personal Data for the foregoing reasons to the extent permitted by GDPR.
5. STORING YOUR INFORMATION
Duration of Storage of Personal Data.
We will store your Personal Data for as long as it is needed to provide the App and Coaching Services, however, we may not know if you have stopped using the App and Coaching Services so we encourage you to contact us if you are no longer using the App and Coaching Services. However, if required by applicable law, we may retain your Personal Data for such period as may be required by such law. To continue to provide an effective service, we may store non-Personal Data perpetually and may anonymize your Personal Data and store that anonymized information perpetually.
Additionally, as described in this Policy, we use third parties to provide the App and Coaching Services and do not have full control over their practices related to storage and retention of your Personal Data. However, we will work with such third parties to delete or modify your Personal Data to the extent required by GDPR and the European Commission’s model contracts for the transfer of personal data to third countries (i.e., the standard contractual clauses pursuant to Decision 2010/87/EU) (the “SCCs”).
We use reasonable efforts to secure your Personal Data and to attempt to prevent the loss, misuse, and alteration of the information that we obtain from you. For example, we require our personnel to sign confidentiality agreements that extend to your Personal Data; we informally review the privacy practices of new products and services that we integrate into our Service; and we restrict access to your Personal Data to individuals within and outside of Strive who need access to such information to provide the Service. In addition, we rely on the technical safeguards provided by the third party vendors we use to host, store, and process your Personal Data. However, you acknowledge and agree that loss, misuse, and alteration may occur despite our efforts to protect your Personal Data. We are not responsible to our users or to any third party due to any such loss, misuse, or alteration, except to the extent required by GDPR, the SCCs, or other applicable law.
6. YOUR CHOICES
In addition, if you wish to access, receive a copy of, change or delete the Personal Data we hold about you, you may contact us as described at the end of this Policy.
You may withdraw the consent granted in this Policy for us to use the Personal Data described in this Policy by contacting us as described at the end of this Policy. Please note that if you do so, it will not affect the lawfulness of the use of your Personal Data based on your prior consent.
In addition, you may contact us as described at the end of this Policy to request that we do not disclose your Personal Data to third parties (other than those that are acting as our agent to perform tasks on our behalf, such as data processors) or to request that your Personal Data not be used for a purpose that is materially different from the purposes for which it was originally collected or for purposes subsequently authorized by you.
Upon receipt of any of the above request(s), we will use reasonable efforts to reflect any changes you request in our databases to the full extent required by GDPR, the SCCs, or other applicable law.
If you are not happy with how we have attempted to resolve your complaint, you may contact the relevant data protection authority.
8. INTERNATIONAL VISITORS AND DATA TRANSFERS
The App is hosted in the United States and is intended for visitors located within the United States as well as users located outside of the United States. If you choose to use the App from the European Economic Area (“EEA”), Switzerland, or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your Personal Data outside of those regions to the United States for storage and processing. By providing any information, including Personal Data, on or to the App, you consent to such transfer, storage, and processing.
Information collected in the EEA may be transferred, stored and processed by us or third parties (as provided in this Policy) in the United States and other countries whose data protection laws may be different than the laws of your country. Whenever we transfer your Personal Data out of the EEA, we ensure a similar degree of protection is afforded to it by entering into SCCs with the relevant third party.
As described in this Policy, we may share Personal Data with third parties and may be required to disclose information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
9. GOVERNMENT REQUESTS
From time to time, we may receive requests from government agencies to obtain information about our users. In handling such government requests, we greatly value the privacy of your Personal Data. While we may be required to turn over user information at times, we will strive to require a search warrant or subpoena, to the extent that we can reasonably demand such warrant or subpoena, before we turn over Personal Data about you and we will also strive to notify users when we receive government requests about their data.
10. THIRD PARTY SERVICES AND PRACTICES ARE BEYOND OUR CONTROL
The App may utilize numerous third party services as part of the functionality of the App, such as hosting services, analytics providers, communications services, and other vendors; and we may share your Personal Data with third parties to the extent explained in this Policy. We have no control over such third parties, except to the extent required by GDPR and the SCCs. Thus, we make no guarantees about, and assume no responsibility for the information, services, or data/privacy practices of third parties, except to the extent required by GDPR and the SCCs. We encourage you to review the privacy practices of such third parties.
11. CHANGES TO THIS POLICY
12. CALIFORNIA PRIVACY STATEMENT
The following provision applies to users in the State of California. We do our best to keep your data accurate and up to date, to the extent that you provide us with the information we need to do so. If your data changes, then you are responsible for notifying us of those changes. Upon request, we will provide you with information about whether we hold, or process on behalf of a third party, any of your Personal Data.
We will retain your information for as long as needed to provide you with the App. We may also retain and use your information in order to comply with our legal obligations, resolve disputes, prevent abuse, and enforce our agreements.
As explained in this Policy, we share your Personal Data in order to provide and support the App.
13. PLEASE REACH OUT TO US WITH ANY QUESTIONS OR FEEDBACK
If you have any questions about this Policy or the App, please feel free to contact us by email at firstname.lastname@example.org.