EFFECTIVE JANUARY 1, 2020
The data protection laws of the European Economic Area (EEA), the United Kingdom and Switzerland (collectively, the “EEA+”), including the General Data Protection Regulation (“GDPR”), require us, STRIVR Labs, Inc., to provide additional and different information about our data processing practices to data subjects in the EEA+.
1. Scope
If you are located in the EEA, the United Kingdom or Switzerland, and access our website (the “Site”) or our products, software, and services (the “Products”; the Site and Products collectively, the “Services”), this Supplemental EEA+ Privacy Notice applies to you.
2. Who Is the Data Controller?
STRIVR Labs, Inc. is the data controller. Our address is 975 California Ave. Floor 2, Palo Alto, California, USA, 94304. Our phone number is (650) 656-9987. Our email address is privacy@strivr.com.
3. What Are Our Legal Bases for Processing Personal Data?
We rely on the following legal bases to process your personal data, as appropriate:
- The processing is necessary for us to perform a contract with you or take steps at your request prior to entering into a contract (“Contract Performance Legal Basis”);
- The processing is necessary for us to comply with an applicable legal obligation (“Legal Obligations Legal Basis”);
- The processing is necessary for us to realize a legitimate interest based on an assessment of that interest and your privacy and other fundamental interests (“Legitimate Interest Legal Basis”);
- The processing is performed according to your consent (“Consent Legal Basis”); and
- The processing is necessary to protect your vital interests or those of another natural person (“Vital Interests Legal Basis”).
We have set out below the specific legal bases on which we rely for each of the purposes for which we use or disclose your personal data. We have also identified what our legitimate interests are where appropriate.
4. How Do We Protect Personal Data in the Context of International Data Transfers?
We may transfer your personal data to service providers and business partners outside of the EEA. Some of these recipients may be located in countries for which the European Commission has issued adequacy decisions. In each case, the transfer is thereby recognized as providing an adequate level of data protection from a European data protection law perspective (GDPR Art. 45).By entering into appropriate data transfer agreements based on Standard Contractual Clauses (2010/87/EU and/or 2004/915/EC) as referred to in GDPR Art. 46(5) or other adequate means, we have established that such recipients will provide an adequate level of data protection and that appropriate technical and organizational security measures are in place to protect personal data against accidental or unlawful destruction, loss or alteration, unauthorized disclosure or access, and against all other unlawful forms of processing.You can ask for a copy of such appropriate data transfer agreements by contacting us using the contact details above.
5. Your Rights
Subject to applicable law, you have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and information about how it is processed.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no lawful reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.To exercise these rights, please contact us using the contact details above.
6. Your Choices
You are not required to provide personal data to us but if you do not provide any personal data to us, you may not be able to use our website or we may not be able to authenticate and assist you with your orders, inquiries or requests. Certain types of personal data which we collect from you are integral to the provision of our products and services. When we collect this information from you through an electronic form, we typically mark the field with an asterisk. In the event that you do not provide us with such information, we generally will not be able to provide you with our products and services.You can use our website and order products and services from us without consenting to our processing of your personal data for marketing and promotional purposes; the consequence is that our website and marketing activities will be less tailored to you and you may miss out on relevant offers and promotions.