Data Privacy Policies

Straive General Data Privacy / Protection Policy Statement
Straive™ is committed to ensure protection of personal information of its employees, customers, clients, and stakeholders, pursuant to the provisions of applicable Data Privacy/Protection Regulation in its operations globally. All such Regulations are strictly observed in the collection, processing, security, retention, and disposal, of any personal information entrusted to, and acquired by the company, during the course of its engagements.

Integrity and Accountability
Straive™ upholds the highest standard of work ethic, honesty, and exhibits transparency in any engagement which involves the collection, processing, security, retention, and disposal of personal information of the data subjects. The employees, internal stakeholders, and business partners, are responsible in complying with all the information security controls and policies related to Data Privacy/Protection; and are accountable for any action, and all its corresponding outcomes, in protecting the personal data of data subjects.

Security threats, breaches, incidents, or any act which may lead to the violation of any of the provisions in the Global Data Privacy/Protection (and or its corresponding SPi Global information security policies and procedure) are reported to the Gobal Data Protection Officer (dpo@straive.com), to the supervising authority, and to the data subject, as applicable.

Respect
Straive™ respects and honors the Rights of the Data Subjects, as follows:

• The right to be informed; that a data processor and/or controller should secure consent when gathering information directly from the data subject;
• The right of access to their personal data;
• The right to have inaccurate personal data rectified or completed when incomplete;
• right to data portability that allows them to move, copy or transfer personal data easily from one IT environment to another in a safe and secure way, without affecting its usability;
• The right to have personal data erased;
• The right to object to process personal data for the legal task, marketing purposes, scientific/historical research and statistics;
• The right to be informed relating to automated decision making and profiling; and
• The right to seek damages through a civil court against organizations that fail to protect their personal data.
• Further, Straive™ is committed to continuously:
• Implement organizational and technical controls to ensure that personal data are not compromised in all stages of the data lifecycle
• Educate its employees about their responsibilities in adherence to the company's policies and procedures relating to the protection of personal data; and provide awareness on the penalties resulting to personal data breach and non-compliance to the requirements of the Global Data Privacy/ Protection
• Encourage its employees to report any observed data privacy control issues
• At Straive™, we put a premium on privacy. To that end, we developed a Privacy Policy that covers how we collect, use, disclose, transfer, and store personal information from employees, our customers, business partners, providers, and from the public in general.
• It only takes a moment to familiarize yourself with our privacy practices, so please do. If you have questions, please contact us.

Data Privacy & Information Security
At Straive™, we take the security of your personal information very seriously. When your personal data is stored on any company-owned device, we use computer systems with limited access housed in facilities using logical and physical security measures adherent to governing data privacy regulations and information security standards.
We will work with you to keep your personal information accurate, complete, and up to date. Your personal information will be retained for the period necessary to fulfill the purposes outlined in this Privacy Policy. Our service-specific privacy summaries will also be considered as applicable to your relationship with Straive™ as customer, employee, applicant, investor, business partner, etc.
When assessing these periods Straive™ carefully examines the need to collect personal information at all and if we establish a relevant need we only retain it for the shortest possible period to realize the purpose of collection, unless a longer or different retention period is required by law.

Collection and Use of Personal Information
You may be asked to provide your personal information anytime you are in contact with Straive™ or any of our affiliated companies. Straive™ and its affiliates may share this information with each other and use it in accordance with this Privacy Policy. We may also combine it with other information to provide and improve our products, services, content, and advertising.
You are not required to provide the personal information that we have requested, but, if you decide not to do so, in many cases we will not be able to provide you with our products or services or respond to any queries you may have.
It is also important to note that when you post on an Straive™ forum, chat room, or social networking service, any personal information and content you share will be visible to other users and can be read, collected, or used by them. You are solely responsible for any personal information you choose to share or submit in these channels. For example, if you list your name and email address in a forum posting, that information will be considered public, and will be accessible to a lot of people.

What information are collected and how we use the information
We may process your personal information for the purposes described in this Privacy Policy with your consent, for compliance with a legal obligation to which Straive™ is subject or when we have assessed it is necessary for the purposes of the legitimate interests pursued by Straive™ or a third party to whom it may be necessary to disclose information.
The personal information we collect also allows us to keep you posted on Straive™'s latest product and service announcements, software and solutions updates, and upcoming events. If you don't want to be on our mailing list, you can opt out anytime by contacting our Corporate Communications team.
We also use personal information to help us create, develop, operate, deliver, and improve our products, services, content and advertising, as well as for loss prevention and anti-fraud purposes. Your personal information may also be used for account and network security purposes, including the protection of our services for the benefit of all customers. We limit our use of data for anti-fraud purposes to those which are strictly necessary and within our assessed legitimate interests. In some transactions, we may also validate the information you provided with publicly accessible sources.
We may use your personal information, including your date of birth, to verify your identity, assist with the identification of users, and to determine appropriate services. For example, we may use your date of birth to help us get a better understanding of the demographics of our applicants.
When you provide information such as your name, email address, country of residence, company you represent, industry and details, you authorize and enable us to respond to a general/business inquiry made by you or on behalf of a company that you represent. If you wish to be contacted by telephone, we may also collect your work phone number.
When you provide your resume and other personal details to apply online for a job at Straive™, we may use this information throughout the company or our affiliates and subsidiaries to consider you for employment, or to respond to your inquiry. We may also keep the information for future consideration of any suitable job opportunity that may arise.
You provide us information when subscribing and using any of our subscription services. This data may include your name, email address and the organization you represent. Our subscription center keeps track of your communication preferences (over email or phone) and areas of interest (such as receiving newsletters, thought leadership content and/or marketing collateral) that you may have either opted into or opted out of.
Email Communications: If you are a recipient of our marketing communications, we will track whenever you receive, open, click a link, or share an e-mail you receive from Straive™.
From time to time, we may use your personal information to send important notices, such as communications about changes to our terms, conditions, and policies.
We may also use your personal information for internal purposes such as auditing, data analysis, and research to improve our products, services, and customer communications.

Non-Personal Information
We also collect data in a form that does not, on its own, permit direct association with any specific individual. We may collect, use, transfer, or disclose non-personal information for any purpose. Here are some examples of non-personal information that we collect and how we may use it:
We may collect information such as occupation, language, zip code, area code, unique device identifier, referrer URL, location, and the time zone where an Straive™ product or publicly available link is used so that we can better understand customer behaviour and improve our products, services, and advertising.
We may collect information regarding customer activities on our website, and from our other products and services. This information may be aggregated or combined to help us provide more useful information to our customers and to understand which parts of our website, products, and services are of most interest. Aggregated data is considered nonpersonal information for the purposes of this Privacy Policy.
We may collect and store details of how you use our services, including search queries. This information may be used to improve the relevance of results provided by our services. Except in limited instances to ensure the quality of our services over the Internet, such information will not be associated with your IP address.
With your explicit consent, we may collect data about how you use your device and its applications to help app developers improve their apps.
If we do combine non-personal information with personal information, the combined information will be treated as personal information for as long as it remains combined. We might receive or validate information about you from other sources to ensure the accuracy and completeness of your profile.

Privacy Policy on Cookies and Other Straive™ Technologies
Our websites, online services, interactive applications, email messages, and advertisements may use cookies and other technologies such as pixel tags and web beacons. These technologies help us better understand user behaviour, tell us which parts of our websites people have visited. These also facilitate and measure the effectiveness of advertisements and web searches.
We treat information collected by cookies and other technologies as non-personal information. However, to the extent that Internet Protocol (IP) addresses or similar identifiers are considered personal information by local law, we also treat these identifiers as personal information. Similarly, to the extent that non-personal information is combined with personal information, we treat the combined information as personal information for the purposes of this Privacy Policy.
Straive™ and our partners may also use cookies and other smart technologies to remember personal information when you use our website, online services, and applications. Our only goal in these cases is to make your experience with Straive™ more convenient and personal.
Please know that we may gather some information automatically and store it in log files. This information includes Internet Protocol (IP) addresses, browser type and language, Internet service provider (ISP), referring and exit websites and applications, operating system, date/time stamp, and clickstream data.
We use this information to understand and analyse trends, to administer the site, to learn about user behavior on the site, to improve our product and services, and to gather demographic information about our user base as a whole. We may use this information in our marketing and advertising services.
In some of our email messages, we use a “click-through URL” linked to content on the Straive™ website. When customers click one of these URLs, they pass through a separate web server before arriving at the destination page on our website. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our customer communications. If you prefer not to be tracked in this way, you should not click text or graphic links in the email messages.
Pixel tags enable us to send email messages in a format customers can read, and they tell us whether mail has been opened. We may use this information to reduce or eliminate messages sent to customers.

Disclosure to Third Parties
At times Straive™ may make certain personal information available to strategic partners that work with Straive™ to provide products and services, or that help Straive™ market to customers. Personal information will only be shared by Straive™ to provide or improve our products, services and advertising; it will not be shared with third parties for their marketing purposes.

Service Providers
We also share personal information with companies who provide services such as information processing, fulfilling customer orders, delivering services, managing and enhancing customer data, providing customer service, assessing your interest in our products and services, and conducting customer research or satisfaction surveys. These companies are obligated to protect your information and may be located wherever Straive™ operates.

Legal Duty to Disclose
It may be necessary − by law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence − for Straive™ to disclose your personal information. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate.
Additionally, in the event of a reorganization, merger, or sale, we may transfer to the relevant third party any and all personal information we have collected.

The existence of Automated Decision-Making, Including Profiling
Straive™ does not make any decisions involving the use of algorithms or profiling that significantly affects you.

Access to Personal Information
You can help ensure that your contact information and preferences are accurate, complete, and up to date by contacting us directly. For other personal information we hold, we will provide you with access for any purpose – including requesting the correction of inaccurate data, or the deletion of the data if Straive™ is not required to retain it by law or for legitimate business purposes.
We may decline to process requests that are frivolous/vexatious, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law. We may also decline aspects of deletion or access requests if we believe doing so would undermine our legitimate use of data for anti-fraud and security purposes as described earlier.

Third Party Sites and Services
Straive™ websites, products, applications, and services may contain links to third-party websites, products, and services. Our products and services may also use or offer products or services from third parties.
Information collected by third parties, which may include such things as location data or contact details, is governed by their privacy practices. For your protection, we encourage you to learn about the privacy practices of those third parties.

International Users
All the information you provide may be transferred or accessed by entities around the world as described in this Privacy Policy. Personal information, relating to Straive™ services, regarding individuals who reside in a member state of the European Economic Area is controlled and/or processed in accordance with the EU General Data Protection Regulation for the international transfer of personal information collected in the European Economic Area. As applicable, within and among Straive™ companies, customers and providers, the EU model contract clauses are enforced to govern the transfer of covered data.

For users under the jurisdiction of the US Federal
Government, Straive™ companies respect the rights of the data subjects (consumers) pursuant to the California Consumer Privacy Act (CCPA) – the right to control of the personal information that we collect, process, and manage during the engagement; the right to delete personal information (with some exemptions); right to opt-out or in their personal information, and the right for non-discrimination for exercising the CCPA rights.
As a global company, we have several legal entities in different jurisdictions which are responsible for the personal information which they collect.
We also abide by the Asia-Pacific Economic Cooperation (APEC) Cross Border Privacy Rules System. The APEC CBPR system provides a framework for organizations to ensure protection of personal information transferred among participating APEC economies.

Children
We understand the importance of taking extra precautions to protect the privacy and safety of children using Straive™ products and services. Children under the age of 13, or equivalent minimum age in the relevant jurisdiction, are not permitted to create or provide their own personal information, unless their parent provided verifiable consent. If we learn that we have collected the personal information of a child under 13, or equivalent minimum age depending on jurisdiction, outside the above circumstances we will take steps to delete the information as soon as possible.
If at any time a parent needs to access, correct, or delete data associated with a child's data previously provided to Straive™, they may contact us directly.

Our Company-wide Commitment to Your Privacy
To make sure your personal information is secure, we communicate our privacy and security guidelines to Straive employees and strictly enforce privacy safeguards within the company.

Questions & Complaints
If you have any questions or concerns about Straive's Privacy Policy or data processing, or if you would like to make a complaint about a possible breach of local privacy laws, please contact us.
Straive™ responds to or resolves a privacy question or question about personal information received on priority. Where your issue may be more substantive in nature, more information may be sought from you. All such substantive contacts receive a response. If you are unsatisfied with the reply received, you may refer your complaint to the relevant regulator in your jurisdiction. If you ask us, we will endeavour to provide you with information about relevant complaint avenues which may be applicable to your circumstances.
The Straive™ Privacy Policy was updated in March 2021. Straive™ may update its Privacy Policy from time to time. When we change the policy in a material way, a notice will be posted on our website along with the updated Privacy Policy
For more details on Straive™'s Data Privacy/Protection Policy, contact the Data Privacy Officer directly via dpo@straive.com