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STRIVE TALENT PRIVACY POLICY FOR USERS PARTICIPATING IN LEARNING AND DEVELOPMENT PROGRAMS

Effective Date: July 29, 2019

1.         PURPOSE OF POLICY

We are committed to protecting your privacy as you use our service! We created this Privacy Policy for users Participating in Learning and Development Programs (“Policy”) to give you confidence as you visit and use the Strive website, service, and related services, which may include a web application, offline services, and/or other related services provided by us as described in the Terms and Conditions for users Participating in Learning and Development Programs (collectively, the “Service”). This Policy applies to Strive’s coaching service, but does not apply to Strive’s recruiting and job placement services, which are governed by a separate Privacy Policy, which can be found at https://www.strive.co/tos-privacy-policy. This Policy covers how we collect, use, store, and share your information when you use our Service. The provisions of our Terms and Conditions for users Participating in Learning and Development Programs  (https://www.strive.co/termsofservice) apply to this Policy as well. All references to “we”, “us”, “our”, “Strive Talent”, or “Strive” refer to Strive Talent Inc., a Delaware corporation. All references to “you”, “your”, or “user” refers to (1) the end-user of the Service which includes users who seek to use our learning and development software and the Service either in their individual capacity or in connection with user’s employment with the Employer, and (2) users, other than Marketing Recipients (as defined below), who transmit Personal Data (as defined below) through the Service but who do not become end-users of the Service. All references to “Employer”, “your Employer”, or “user’s Employer” refer to the user’s employer in such cases where Strive has entered into a contract with such employer to provide the Service to the employer’s personnel. For the sake of clarity, this Policy does not apply to the any Employer. Do not hesitate to contact us at hello@strive.co if you have any questions or want to discuss this Policy.

 

This Policy also describes our practices related to information of individuals with whom we communicate for marketing or promotional purposes but who may not otherwise be users of the Service (the “Marketing Recipients”). By using the Service and agreeing to this Policy, or by agreeing to this Policy as a Marketing Recipient, you consent to the privacy practices described in this Policy. And, additionally, you consent to the use of your Personal Data by your Employer (if applicable).

 

2.         INFORMATION WE COLLECT AND HOW WE USE IT

Required Information You Voluntarily Provide Us.

When you begin using the Service, 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 Service, you will be required to provide us with your first and last name, your e-mail address, and a password you create.

 

Personal Data We Collect from Marketing Recipients

In addition to the Personal Data we collect from users of the Service, we collect Personal Data from Marketing Recipients who are interested in learning more about our products and services. This Personal Data consists of basic contact information such as the Marketing Recipient’s name and email address. This Personal Data is collected by us when Marketing Recipients sign up for commercial emails from us via online or offline sign up forms, and through other means such as in-person events and meetings and from the Internet. For Marketing Recipients who are not otherwise users of the Service, we only use your Personal Data to send communications, including updates on promotions and events, relating to products and services offered by us and by third parties we work with that are related to the Service.

 

Optional Information You Voluntarily Provide Us.

In addition to the required information that you provide to Strive in order to use the Service, there are various pieces of information you can, or may in the future be able to, choose to provide through the Service. For example, you may choose to provide us with various information about your current professional performance and learning goals. We use this information for the purpose of providing you with the core aspects of the Service. For example, you may provide us with information that is necessary to provide the coaching services to you as part of the Service in an effort to assist in your learning and professional development.

 

We also may collect and store communications that occur through the Service or outside of the Service between you and Strive, and communications that occur through the Service.

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 Service’s functionality. While all of the information described here may not be required to use the Service, some aspects of the Service may not be available if you choose not to provide us with such information.

 

Special 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”). 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 the Service. By agreeing to this policy and by your use of the Service, you explicitly consent to our collection and use of your Special Information.

 

Information Collected Automatically As You Use The Service.

In addition to the information that you provide to us voluntarily, Strive may, now or in the future automatically collect information through the Service about how you use and interact with the Service and other similar activities in order to better understand our users and how they use the Service, and to improve the Service.

 

Cookies.

When you access the Strive website or other aspects of the Service, you may receive a message advising you that cookies and similar technologies are in use. By clicking "accept", closing the message, or continuing to browse or use the Service, you signify that you understand and agree to the use of these technologies, as described in this Policy. When you use the Service, we may send one or more cookies to your device. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the Service. We use these cookies for the purpose of better understanding how visitors interact and engage with the Service, and in some cases we may use this information to inform our communications with you. Please review your web browser settings to modify your cookie settings, to disable the use of cookies, or to delete cookies. Please note that if you delete, or choose not to accept, cookies from the Service, you may not be able to utilize the features of the Service to their fullest potential. In addition, please note that third parties such as advertisers or analytics providers may also use cookies and similar technologies while you are browsing or using the Service. We unfortunately have no control over such third parties’ use of these technologies.

 

Other Anonymous Data We Collect.

When you use and visit the Service, we may also use third-party services, such as Google Analytics and others, which use cookies to collect generic, anonymous information that does not identify you. We use this information to better understand how users interact with the Service and to improve your user experience while using the Service.

 

Do Not Track Signals.

We do not track you or collect your information across third party websites or online services. Thus, we do not receive Do-Not-Track signals, or other similar signals. To the extent that we do receive any such signals, we will not comply with them as it is not an aspect of the functionality of our Service.

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 Service, namely to provide you with the Strive Programs (as that term is defined in the Terms).

 

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 hello@strive.co;

  • 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 Services (for example, to protect the security and integrity of our systems and to provide you with customer service and the core functionality of the Service).

 

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 Service, or when you choose to do so (as described below and in the Terms and Conditions for users Participating in Learning and Development Programs ).

 

Information Shared By You Through The Service.

You may, now or in the future, be able to choose to voluntarily share information collected through the Service through email, or other means of communication.

 

Your Employer (as that term is defined in the Terms) may have access to your Personal Data. Strive acts at the direction of your Employer with regards to sharing your Personal Data with your Employer.

 

Our Personnel And Vendors.

To be able to effectively provide you with the Service, and to improve the functionality of the Service, 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 Service, to the extent that such persons or entities have a need-to-know such Personal Data in furtherance of the Service. 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 our Service, 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 Service, however, we may not know if you have stopped using the Service so we encourage you to contact us if you are no longer using the Service. 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 Service 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 EU-U.S. and Swiss-U.S. Privacy Shield Principles (“Privacy Shield”).

 

Security.

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, Privacy Shield, or other applicable law.

 

6.         YOUR CHOICES

You can change some of your Personal Data through the account settings provided on the Service. 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, Privacy Shield, 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. 

 

7.         INTERNATIONAL VISITORS AND DATA TRANSFERS

The Service 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 Service from the European Economic Area, 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 Service, you consent to such transfer, storage, and processing. 

 

Strive participates in, and complies with Privacy Shield regarding the collection, use, sharing, and retention of personal information from the European Economic Area and Switzerland. If there is any conflict between the terms in this Policy and Privacy Shield Principles, then Privacy Shield shall govern. Our participation in Privacy Shield applies to all Personal Data that is subject to this Policy and is received from the European Economic Area or Switzerland. We will comply with Privacy Shield in respect of such Personal Data.

 

To learn more about Privacy Shield, please visit: https://www.privacyshield.gov/. To view a list of companies that have certified that they adhere to Privacy Shield, please visit: https://www.privacyshield.gov/list.

 

As part of our participation in Privacy Shield, if you have a dispute with us about our adherence to Privacy Shield, we will seek to resolve it through JAMS, an independent alternative dispute resolution body based in the United States. You can learn more about JAMS at the following URL: https://www.jamsadr.com/.

 

In certain circumstances, you may have the right to invoke binding arbitration under Privacy Shield, as described in Annex I to the Privacy Shield Principles, which can be found at the following URL: https://www.privacyshield.gov/article?id=ANNEX-I-introduction.

 

Privacy Shield participants, such as Strive, are subject to the investigatory and enforcement powers of the US Federal Trade Commission and other authorized statutory bodies. Under certain circumstances, we may be liable for the transfer of personal data that we receive and subsequently transfers to a third party, as described in Privacy Shield.

 

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.

 

 

8.         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.

9.         THIRD PARTY SERVICES AND PRACTICES ARE BEYOND OUR CONTROL

Our Service may utilize numerous third party services as part of the functionality of the Service, 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 Privacy Shield. 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 Privacy Shield. We encourage you to review the privacy practices of such third parties.

 

10.       CHANGES TO THIS POLICY

Strive reserves the right to change this Policy from time to time, with or without notice to you. Any changes to this Privacy Policy will become effective on the “Effective Date” indicated above. If you continue to use the Service after the Effective Date, you consent to the new Policy. Strive will always have the latest Policy posted on the Service.

8.         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 our Services. 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 our Services.

9.         PLEASE REACH OUT TO US WITH ANY QUESTIONS OR FEEDBACK

If you have any questions about this Policy or our Service, please feel free to contact us by email at hello@strive.co.