Website Privacy Policy

Last Update: April 3, 2019

This Website Privacy Policy (“Privacy Policy”) covers the web sites (“Web Sites”) operated by StrategiCom, Inc. (“StrategiC
om” or “we” or “us” or “our”), including but not limited to www.strategicom.net.  This Privacy Policy describes the types of information that we collect, what we do with it, how we protect it, and if and when we disclose it to third parties.


This Privacy Policy is a part of and subject to the StrategiCom Terms of Service (“TOS”). Accordingly, when you enter into the TOS, you agree that you have read, understand, and agree that we can collect, use, and disclose your information in accordance with this Privacy Policy. If you do not agree or are not comfortable with any part of this Privacy Policy, you should not agree to the TOS (including this Privacy Policy) and you may not use the Web Sites.

Additional information about StrategiCom's Data Privacy and Data Security practices, including StrategiCom's commitments with regard to the General Data Protection Regulation (GDPR), can be found at the bottom of this page.

Information Gathering, Processing and Usage:

We receive, collect and store any information you enter on our website or provide us in any other way. In addition, we collect the Internet protocol (IP) address used to connect your computer to the Internet; login; e-mail address; password; computer and connection information and purchase history. We may use software tools to measure and collect session information, including page response times, length of visits to certain pages, page interaction information, and methods used to browse away from the page. We also collect personally identifiable information (including name, email, password, communications); payment details (including credit card information), comments, feedback, product reviews, recommendations, and personal profile.

When you conduct a transaction on our website, as part of the process, we collect personal information you give us such as your name, address and email address. Your personal information will be used for the specific reasons stated above only.



StrategiCom may disclose your Information to third parties under the following circumstances:

  • We collect such Non-personal and Personal Information for the following purposes:

  • To provide and operate the Services;

  • To provide our Users with ongoing customer assistance and technical support;

  • To be able to contact our Visitors and Users with general or personalized service-related notices and promotional messages;

  • To create aggregated statistical data and other aggregated and/or inferred Non-personal Information, which we or our business partners may use to provide and improve our respective services; 

  • To comply with any applicable laws and regulations.

Cookies


To enhance your experience on our Web Sites, many of our web pages use "cookies". Cookies are bits of electronic information that a web site can transfer to a visitor’s hard drive to help tailor and keep records of his or her visit.  Cookies are required to use most StrategiCom services.  You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access most of StrategiCom’s services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Web Sites.  If you proceed with using our Web Sites without deactivating cookies through your browser, you are deemed to have accepted our use of cookies.

Web Beacons


Pages of our services or our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Data Storage


Our company is hosted on the Wix.com platform. Wix.com provides us with the online platform that allows us to sell our products and services to you. Your data may be stored through Wix.com’s data storage, databases and the general Wix.com applications. They store your data on secure servers behind a firewall. 

All direct payment gateways offered by Wix.com and used by our company adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of credit card information by our store and its service providers.


Protecting Personal Information


We understand the importance of safeguarding your Information.  We employ administrative, physical, and electronic measures designed to protect your Information from unauthorized access.  We implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, taking into account technological reality, cost, the scope, context and purposes of processing weighted against the severity and likelihood that the processing could threaten individual rights and freedom.  Despite our efforts, we cannot guarantee the security of your Information. Accordingly, we assume no liability for any disclosure of data due to errors in transmission, unauthorized third-party access or other acts of third parties, or acts or omissions beyond our reasonable control.

Privacy Shield


Strategicom complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Information transferred from the European Union and the United Kingdom to the United States. StrategiCom has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.  If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/

As such:

  • We participate in Privacy Shield.

  • We collect only Personal Information provided by the individual or the individual’s employer, including but not limited to name, address and email.

  • StrategiCom is subject to the Principles of all personal data received from the EU in reliance on the Privacy Shield.

  • StrategiCom collects Personal Information for authentication and personalization of the user experience.

  • Other than to the Third-Party Service Providers referenced above, StrategiCom does not disclose any Personal Information to third parties.

  • StrategiCom's customers can view their personal data in their profile in the application.

  • All user accounts are password protected, and an individual's Personal Information is only available to that individual when logged in.

  • StrategiCom is subject to the investigatory and enforcement powers of the FTC.

  • StrategiCom understands the possibility, under certain conditions, for the individual to invoke binding arbitration.

  • StrategiCom is required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

  • StrategiCom is liable in cases of onward transfers to third parties.

In compliance with the Privacy Shield Principles, StrategiCom commits to resolve complaints about our collection or use of your Personal Information.  EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact StrategiCom at:

info@strategicom.net

StrategiCom has further committed to cooperate with EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU in the context of the employment relationship. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact the EU DPAs for more information or to file a complaint. The services of EU DPAs are provided at no cost to you.

Third Party Websites 


This Privacy Policy applies only to our Web Sites.  This Privacy Policy does not apply to any websites managed, maintained, and/or hosted by third parties not directly affiliated with StrategiCom that you may visit, e.g., via a link provided through the Web Sites or on a website maintained by any third party.  We do not control the privacy policies of other websites to which we may provide hyperlinks.  We cannot be responsible for the privacy practices or the content of such non-StrategiCom websites, and we do not control the practices of any of the third party websites or service providers to whose sites we link. We encourage you to learn more about the online privacy and data security policies of third party websites directly from such third parties, as their policies may differ from ours.

Children’s Privacy 


We are committed to protecting the privacy of children.  Our solutions are not intended for anyone under the age of 13. If you are under 13, do not use or provide any information on or through our solutions. If we learn we have collected or received Personal Data from a child under 13 without verification of parental consent, we will delete that information. If you are a parent or guardian or otherwise believe we might have any information from or about a child under 13, please contact us so that we can delete the child's information. Our services will never knowingly accept, collect, maintain or use any information from a child under the age of 13. If a child whom we know to be under the age of 13 sends Personal Data to us online, we will only use that information to respond directly to that child or notify parents.
 


Strategicom Data Privacy & Data Security Statement


This Data Privacy & Data Security Statement (the “Statement”), is provided by StrategiCom  (“StrategiCom”) to its Clients (each, a “Client”) and to users of StrategiCom’s Services affiliated with the Clients (“Users”). This Statement describes StrategiCom’s commitments with regard to data privacy and data security.   StrategiCom may update this Statement from time to time.  Updated versions will be published on StrategiCom’s website.

1. Definitions

  • “Authorized Persons” means StrategiCom’s employees, agents, and contractors that have a need to know or otherwise access User Data to enable StrategiCom to provide the Services.

  • “Controller” means a controller as defined under the GDPR.

  • “Data Protection Laws” means all international, federal, national and state privacy and data protection laws and regulations to the extent applicable to StrategiCom and the Services.

  • “Data Breach” means any loss or unauthorized access, acquisition, theft, destruction, disclosure or use of User Data that occurs while such User Data is in the possession of or under the control of StrategiCom.

  • “GDPR” means the EU General Data Protection Regulation 2016/679.

  • “Personal Data” means information relating to an identified or identifiable natural person.  An identifiable natural person is a natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

  • “Process” or “Processing” means any operation or set of operations that are performed upon User Data, whether or not by automatic means, such as collection, accessing, processing, use, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure, dissemination, transmittal, alignment or combination, blocking, erasure, destruction or otherwise used as set out in the applicable Data Protection Laws.

  • “Processor” means a processor as defined under the GDPR.

  • “Services” means StrategiCom’s services, solutions and products.

  • “Sub-Processor” shall mean an entity engaged by StrategiCom to assist it in Processing the User Data in fulfillment of its obligations with regard to the Services.

  • “Third Party” is any person or entity other than StrategiCom and Client and Client’s Users.

  • “User Data” means all data relating to a User that is (i) provided to StrategiCom by Client or User or (ii) otherwise obtained, accessed, developed, or produced by StrategiCom.  User Data may include Personal Data.

2. Data Privacy

  • 2.1. Compliance with Laws. StrategiCom is committed to complying with its obligations under all Data Protection Laws. For purposes of the GDPR, Client is considered the Controller and StrategiCom is its Processor; if Client is considered a Processor for purposes of the GDPR, then StrategiCom is considered its Sub-Processor.

  • 2.2. Distribution of User Data. Users should provide StrategiCom only with Personal Data that is requested by Strategicom or that is otherwise necessary for StrategiCom to provide the Services. StrategiCom is not responsible for any other Personal Data.  Client will not provide StrategiCom with Personal Data unless Client has obtained all required consents from Users.

  • 2.3. Limitations on Use of Personal Data. StrategiCom shall not Process User Data other than for the purposes specified by Users. StrategiCom shall not Process User Data for the benefit of any Third Party. StrategiCom shall access only the User Data that it needs to perform the Services (i.e., no more than necessary). StrategiCom will not store User Data longer than necessary to achieve the permitted purposes specified by User.

  • 2.4. Restrictions. Except with a User’s prior, written approval, on a case-by-case basis, StrategiCom will not: (a) use User Data other than as necessary for StrategiCom to provide the Services, (b) disclose, sell, assign, lease or otherwise provide User Data to Third Parties (other than to its affiliates or Sub-Processors) except to the extent required or permitted by Data Protection Laws, or (c) merge User Data with other data, modify or commercially exploit any User Data.

  • 2.5. Sensitive Personal Data. Clients and Users are advised never to provide StrategiCom with Sensitive Personal Data. “Sensitive Personal Data” means (a) information that reveals a natural person’s racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade-union membership, (b) information or data concerning a natural person’s health or sex life or sexual orientation; or (c) genetic data or biometric data about a natural person.

3. Sub-Processors

  • StrategiCom may engage Sub-Processors in connection with the provision of the Services, provided, however, that StrategiCom may not provide a Sub-Processor with access to User Data unless the Sub-Processor has: (i) a business need to know / access the relevant User Data, as necessary for the purposes of the Services; (ii) signed a written obligation of confidentiality or are under professional obligations of confidentiality; and (iii) implemented technical, operational, physical, and organization safeguards to protect User Data against accidental or unlawful destruction or alteration and unauthorized disclosure or access.

4. Data Subject Rights; Cooperation

  • StrategiCom shall use commercially reasonable efforts to cooperate and assist with a User’s exercise of his/her rights under applicable Data Protection Laws with respect to Personal Data Processed by StrategiCom, including, without limitation, the right to be forgotten, the right to data portability, and the right to access data under the GDPR.

5. Return or Destruction of User Data

  • Upon the written request of a User, StrategiCom will return User Data to the User in a commonly readable format or securely delete User Data as soon as reasonably practicable. However, if StrategiCom is required by law to retain User Data or if User Data is stored in a manner such that it cannot readily be returned or destroyed without affecting other data, then StrategiCom will continue to protect such User Data in accordance with this Statement and limit any use to the purposes of such retention.

6. Data Security

  • 6.1. Security Program Requirements. StrategiCom will maintain a security program that contains administrative, technical, and physical safeguards appropriate to the complexity, nature, and scope of its activities. StrategiCom’s security program shall be designed to protect the security and confidentiality of User Data against unlawful or accidental access to, or unauthorized processing, disclosure, destruction, damage or loss of User Data.  At a minimum, StrategiCom’s security program shall include: (a) limiting access of User Data to Authorized Persons; (b) implementing network, application, database, and platform security; (c) means for securing information transmission, storage, and disposal within StrategiCom’s possession or control; (d) means for encrypting User Data stored on media within StrategiCom’s possession or control by using modern acceptable cyphers and key lengths, including backup media; (e) means for encrypting User Data transmitted by StrategiCom over public or wireless networks by using modern acceptable cyphers and key lengths; and (f) means for keeping firewalls, routers, servers, personal computers, and all other resources current with appropriate security-specific system patches.

  • 6.2. Regular Reviews. StrategiCom shall ensure that its security measures are regularly reviewed and revised to address evolving threats and vulnerabilities.

7. Data Breach Procedures

  • 7.1. Notification. StrategiCom shall notify Client and any affected User of any Data Breach as soon as practicable and without undue delay after becoming aware of it.  Such notification shall at a minimum: (i) describe the nature of the Data Breach, the categories and numbers of Users concerned, and the categories and numbers of Personal Data records concerned; (ii) communicate the name and contact details of StrategiCom's data protection officer or other relevant contact from whom more information may be obtained; and (iii) describe the measures taken or proposed to be taken to address the Data Breach.

  • 7.2. Remedial Actions. In the event of a Data Breach for which StrategiCom is responsible, StrategiCom will use commercially reasonable efforts to: (a) remedy the Data Breach condition, investigate, document, restore the Services, and undertake required response activities; (b) provide regular status reports to Client on Data Breach response activities; (c) assist Client with the coordination of media, law enforcement, or other Data Breach notifications; and (d) assist and cooperate with Client in its Data Breach response efforts.

8. Cross-Border Transfers

  • 8.1. Location. StrategiCom systems and Strategicom’s Processing of User Data will occur within the following jurisdictions: United States of America and Ireland (the “Processing Jurisdictions”). Strategicom will not transfer any User Data outside of the Processing Jurisdictions except as directed by or with the consent of Client and/or User.

  • 8.2. Sub-Processors. Before providing User Data of a European citizen to Sub-Processors, StrategiCom will use commercially reasonable efforts to ensure that the Sub-Processors will either be certified under the EU-US Privacy Shield or that the Sub-Processors execute EU-prescribed Standard Contractual Clauses.

Privacy Policy Updates


This Privacy Policy may be updated periodically and without prior notice to reflect changes in our online information practices. We will post a prominent notice on this Web Site to notify you of any significant changes to our Privacy Policy and indicate at the bottom of the policy when it was most recently updated.

Questions
Any questions about this Privacy Policy should be addressed to our Help Desk at info@strategicom.com

Terms & Conditions

This website is owned and operated by StrategiCom. These Terms set forth the terms and conditions under which you may use our website and services as offered by us. This website offers visitors [description of what is offered on your website]. By accessing or using the website of our service, you approve that you have read, understood, and agree to be bound by these Terms.

© 2019 StrategiCom Inc. |  1676 Bryan Rd, Suite 107 | O' Fallon, MO 63368  |  info@strategicom.net