Privacy Policy

Webinar: FIND THE HIDDEN CATALYST IN YOUR DATA FOR RELATIONSHIP GROWTHHOME PRODUCTSCUSTOMER DATA PLATFORM LIFESTYLE SEGMENTATIONONBOARDING TOOLSCROSS-SELLING TOOLS PLANS CONSULTING ABOUTOUR STORYPARTNERSCONTACTBLOG LOG INSTRUM PLATFORM PRIVACY POLICYLAST UPDATED: JUNE 2022This Privacy Policy (also referred to as the “Privacy Policy” or “Agreement”) provides information on the collection, use, processing, and sharing (collectively referred to “processing” or “process”) of personal information by Strum Platform, Inc. (“Strum”, “we” or “us”) in connection with your (“you” or “Client”) use of Strum website (strumplatform.com), the Strum software platform, and our provision of our services to you (collectively, the “Services”); and social media pages that link to this Privacy Policy, and in the context of other offline sales and marketing activities. This Privacy Policy also explains the privacy rights you have in relation to these processing activities and the security practices that Strum employs when handling this information.As used in this Privacy Policy, “personal information” or “personal data” means information that relates to an identified individual or to an identifiable individual. For example, this could include among other things names, addresses, email addresses, business contact details, or information gathered through your use of our Services or via our websites. Personal information is also referred to as “information about you.” For more detail about the types of information about you that we may process, please refer to “Which Specific Pieces of Personal Information Do We Process” below.WHO IS RESPONSIBLE FOR YOUR PERSONAL INFORMATION?Strum is responsible for processing the personal information provided to it by you as described in this Privacy Policy, and in other documentation provided to you from time to time.  If Strum at any time determines that instructions provided by you for the processing of personal information infringes applicable data protection laws, Strum will inform you of such determination, and additional fees may apply.  PERSONAL INFORMATION SOURCES  Information Supplied by YouWe process the personal information you provide to us on behalf of your customers.We may also collect information supplied by you, including, for example:• When you register/subscribe to our Services.• When you posting material to the websites (user contributions to public areas of the website).• When you request further information from us.• When you report a problem with our Services.• When you enter contests/promotions via the websites.• In communications with us (email, text, etc.).• Via mobile/desktop applications.• Via interactions with third-party services we make available to users.• In response to surveys.• To fulfill transactions/orders.• Search queries conducted.Information Collected AutomaticallyInformation about you may be collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.  For more information, see “What Cookies and Similar Technologies Do We Use On Our Sites?” below.Information Collected by Third-PartiesWe may also collect personal information via third-party data sources such as Epsilon, Veritas, and Dun & Bradstreet.WHICH SPECIFIC PIECES OF PERSONAL INFORMATION DO WE PROCESS?We may process the following items of your personal information or the personal information of your customers, as applicable:• Name• Alias• Online identifier (e.g. social media handles)• IP address• Unique device IDs• Account name• Postal address• Street address• Email address• Telephone number• Social security number• Driver’s license number or state identification number• International ID number (e.g. passport number, other international governmental ID number)• Other unique personal identifier• Geolocation data• Family and lifestyle details• Racial/ethnic/color data• Trade union membership data• Citizenship status• Insurance policy number• Educational background• Current employer• Employment history• Bank account number• Credit card number• Debit card number• Other financial information• Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.• Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer's interaction with an internet website, application, or advertisement.• Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.WHY AND HOW DO WE USE PERSONAL INFORMATION?We may use personal information for the following business purposes:• to communicate and respond to your requests and inquiries to Strum;• for the performance of our Services;• for security and compliance;• to engage in transactions with customers, suppliers and business partners and to process orders for Strum products and services;• to analyze, develop, improve and optimize the use, function and performance of our sites and products and services;• to manage the security of our sites, networks and systems; and• to comply with applicable laws and regulations and to operate our business.We may use personal information for the following commercial purposes:• to market our products and services or related products and services, and to tailor our marketing and sales activities to your or your company’s interests.These purposes are described below in further detail.To communicate and respond to your requests and inquiries to StrumIf you get in touch with us (such as by submitting contact forms on our sites or sending an email or by visiting social media platforms), we process information about you to communicate with you and to respond to your requests or other inquiries. We can also process personal information to interact with you on third party social networks.Performance of the ServicesStrum may process personal information for the processing activities necessary to perform the Services, including for testing and applying new product or system versions, patches, updates and upgrades, and resolving bugs and other issues Client has reported to Strum.Security and ComplianceWe may process personal information for the following purposes:• to help keep our Services secure, including for security monitoring and identity management;• to investigate and prevent potential fraud or illegal activities involving our systems and networks, including to prevent cyber-attacks and to detect bots;• to administer our back-up disaster recovery plans and policies; and• to confirm compliance with licensing and other terms of use (license compliance monitoring).To engage in transactions with customers, suppliers and business partners and to process purchases of our products and servicesIf you place an order for our Services, or if you provide services to Strum, our employees, customers or partners as a supplier or business partner, Strum processes information about you and your customers to engage in and administer the relevant transactions (such as by sending invoices and making payments), administer your order, and help you get started and adopt our Services.To analyze, develop, improve and optimize the use, function and performance of our ServicesWe may process personal information in order to analyze, develop, improve and optimize the use, function and performance of our Services, including for quality assurance and training purposes, as well as for marketing and sales campaigns. In case our Services permit you to participate in interactive discussions, create a profile, post comments, opportunities or other content, or communicate directly with another user or otherwise engage in networking activities, Strum may process personal information when moderating these activities.To manage the security of our sites, networks and systemsWe may collect site use data for security and operations management to help keep our sites, networks and systems secure, or to investigate and prevent potential fraud, including ad fraud and cyber-attacks and to detect bots.To comply with applicable laws and regulations and to operate our businessIn some cases, we have to process personal information to comply with applicable laws and regulations. For example, to respond to a request from a regulator or to defend a legal claim. We may also process personal information in the performance and operation of our business, such as to conduct internal audits and investigations or for finance and accounting and archiving and insurance purposes.To market our products and services or related products and services and to tailor marketing and sales activitiesStrum may use information about you to notify you about new product releases and service developments, events, alerts, updates, prices, terms, special offers and associated campaigns and promotions (including via newsletters). Strum may also use personal information to advertise Strum’s products and services or related products and services, and also to have our distributors, resellers or partners notify you about our products or services or their related products or services (such as via joint sales or product promotions). We do our best to tailor your website visit, marketing experience and our communications to your expressed interests.FOR WHAT PERIOD DO WE RETAIN PERSONAL INFORMATIONStrum maintains personal information for the following retention periods:• Information we collect to engage in transactions with our customers, suppliers and business partners, and to process purchases of our products and services, will be retained for the duration of the transaction or services period, or longer as necessary for record retention and legal compliance purposes.• If you have registered for a Strum account, your account information will be retained for as long as you maintain an active account. Your account and account information will be deleted if you do not log in for six consecutive months. Strum retains records of that deletion for thirty days.• If you have registered for our newsletters and blogs, your subscription data will be retained for as long as you are subscribed to our distribution lists. WHEN AND HOW CAN WE SHARE YOUR PERSONAL INFORMATION?Within StrumOur employees are authorized to access personal information only to the extent necessary to serve the applicable purpose(s) and to perform their job functions.Sharing with third partiesWe may share personal information with the following third parties for a business purpose:• Subsidiaries and affiliates;• Third-party service providers (for example, credit card processing services, order fulfilment, analytics, event/campaign management, website management, information technology and related infrastructure provision, customer service, e-mail delivery, auditing, and other similar service providers) in order for those service providers to perform business functions on behalf of Strum, and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them;• Relevant third parties in the event of a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings);• As required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to government requests, including public and government authorities outside your country of residence, for national security and/or law enforcement purposes.We may share personal information with the following third parties for a commercial purpose:• To third parties to market their products or services to users if users have consented to these disclosures.When third parties are given access to personal information, we will take appropriate contractual, technical and organizational measures designed to ensure that personal information is processed only to the extent that such processing is necessary, consistent with this Privacy Policy, and in accordance with applicable law.HOW IS PERSONAL INFORMATION HANDLED GLOBALLY?No personal information is processed or transmitted outside of the United States.CALIFORNIA RESIDENTSCalifornia users may have additional rights, available here.NEVADA RESIDENTSStrum does not sell or license the personal information to third-parties for monetary consideration.  However, if you have any questions about the rights of Nevada users under this agreement, please contact us at: support@strumplatform.com SECURITY AND DATA BREACH MANAGEMENTHow Is Your personal information Secured?Strum has implemented appropriate technical, physical and organizational measures designed to protect personal information against accidental or unlawful destruction or accidental loss, damage, alteration, unauthorized disclosure or access as well as all other forms of unlawful processing (including, but not limited to, unnecessary collection) or further processing.Strum has implemented and will maintain technical and organizational measures designed to prevent accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal information. Strum employees are required to maintain the confidentiality of personal information. Employees' obligations include written confidentiality agreements, and compliance with company policies concerning protection of confidential information.All personal information is hosted in Microsoft Azure and is protected by Azure Active Directory security systems. See https://azure.microsoft.com/en-us/services/active-directory/security/ for more information.Incident Management and data breach notification.Strum promptly evaluates and responds to incidents that create suspicion of or indicate unauthorized access to or handling of personal information.If Strum becomes aware and determines that an incident involving personal information qualifies as a breach of security leading to the misappropriation or accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal information transmitted, stored or otherwise processed on Strum systems that compromises the security, confidentiality or integrity of such personal information, Strum will report such breach to Client without undue delay.As information regarding the breach is collected or otherwise reasonably becomes available to Strum and to the extent permitted by law, Strum will provide Client with additional relevant information concerning the breach reasonably known or available to Strum.WHAT COOKIES AND SIMILAR TECHNOLOGIES DO WE USE ON OUR SITES?Cookies and similar technologies (e.g., pixels tags and device identifiers) are used by Strum and our advertising technology partners to recognize you and/or your device(s) on, off and across different services and devices for the purposes specified in “Why And How Do We Use Your personal information?” above.When do we use cookies and similar technologies?Cookies are small text files that contain a string of characters and uniquely identify a browser on a device connected to the Internet. Any browser visiting our sites will receive cookies from us. We also place cookies in your browser when you visit non-Strum sites that host our plugins or tags.We use cookies and other technologies on all our sites to ensure the best possible and secure experience on our sites and to provide you with tailored information on products and services.Strum also uses cookies or similar technologies on its sites to collect online information such as your mobile device ID, IP address, and other information about your device, as well as behavioral data of your device usage on our sites (e.g. pages viewed, links clicked, documents downloaded). How can I manage my cookie preferences?If you do not want to receive cookies, you can change your browser settings on your computer or other device you are using to access our services. Most browsers also provide functionality that lets you review and erase cookies, including Strum cookies.WHAT ARE YOUR PRIVACY RIGHTS?Client controls access to the personal information of Client’s end users, and Client’s end users should direct any requests related to their personal information to Client.  Notwithstanding, Strum will provide reasonable assistance with requests from individuals to do any of the following: Opt-out of our use or sharing of your personal informationYou may withdraw consent you have previously provided for the processing of information about you, including for email marketing by Strum.Delete personal informationYou can ask us to erase or delete all or some of the information about you.Change or correct personal informationYou can edit some of the information about you by. You can also ask us to change, update or fix information about you in certain cases, particularly if it is inaccurate.Object to, or limit or restrict use of personal informationYou can ask us to stop using all or some of the information about you (for example, if we have no legal right to keep using it) or to limit our use of it (for example, if the information about you is inaccurate).Right to access and/or have your information provided to youYou can also ask us for a copy of information about you and can ask for a copy of information about you provided in machine readable form if you reside in California or other jurisdictions that provides you this right as a matter of law.Deletion after you cease using our ServicesExcept as otherwise specified in an order for Services or required by law, upon termination of Services or at Client’s request, Strum will delete Client’s production customer data located on Strum computers in a manner designed to ensure that they cannot reasonably be accessed or read, unless there is a legal obligation imposed on Strum preventing it from deleting all or part of the data. Client may consult with Client’s Strum services contact for additional information on data deletion prior to service completion.You can exercise any of the foregoing choices by contacting us at: support@strumplatform.com or by submitting an inquiry form.DO YOU COLLECT INFORMATION FROM CHILDREN?As a company focused on serving the needs of businesses, Strum's sites are not directed to minors and Strum does not promote or market its services to minors, except in very limited circumstances as part of specific educational outreach programs with parental permission. If you believe that we have mistakenly or unintentionally collected personal information of a minor through our sites without appropriate consent, please notify us through our inquiry form so that we may immediately delete the information from our servers and make any other necessary corrections. Additionally, please use this same form to request removal of content or information that was posted to our sites when the registered user was under the age of 18. Please note that such requests may not ensure complete or comprehensive removal of the content or information, as, for example, some of the content may have been reposted by another user.COMPLIANCE WITH PRIVACY LAWSBoth you and Strum may have legal obligations to protect the personal information processed herein.  Each of you (as client) and Strum represent and warrant as follows:Strum, and, to Strum's knowledge, all vendors, processors, or other third parties acting for or on behalf of Strum in connection with the processing of personal information or that otherwise have been authorized to have access to personal information in the possession or control of Strum, comply and at all times have complied, in all material respects with all of the following in the conduct of its business: (a) Privacy laws; (b) rules of self-regulatory organizations, including the Payment Card Industry Data Security Standard; (c) industry standards, guidelines, and best practices, including the National Institute of Standards and Technology (NIST) Cybersecurity Framework; and (d) all obligations or restrictions concerning the privacy, security, or processing of personal information under any contract to which Strum is a party or otherwise bound as of the date hereof.Client, and, to Client's knowledge, all vendors, processors, or other third parties acting for or on behalf of Client in connection with the processing of personal information or that otherwise have been authorized to have access to personal information in the possession or control of Client, comply and at all times have complied, in all material respects with all of the following in the conduct of its business: (a) Privacy laws; (b) rules of self-regulatory organizations, including the Payment Card Industry Data Security Standard; (c) industry standards, guidelines, and best practices, including the National Institute of Standards and Technology (NIST) Cybersecurity Framework; and (d) all obligations or restrictions concerning the privacy, security, or processing of personal information under any contract to which Client is a party or otherwise bound as of the date hereof.As used herein, “Privacy Laws” means all applicable laws, governmental orders, and binding guidance issued by any governmental authority concerning the privacy, security, or processing of personal information (including laws of jurisdictions where personal information was collected), including, as applicable, data breach notification laws, consumer protection laws, laws concerning requirements for website and mobile application privacy policies and practices, Social Security number protection laws, data security laws, and laws concerning email, text message, or telephone communications. Without limiting the foregoing, Privacy Laws include: the Federal Trade Commission Act, the Telephone Consumer Protection Act, the Telemarketing and Consumer Fraud and Abuse Prevention Act, the Controlling the Assault of Non-Solicited Pornography and Marketing Act of 2003, the Children’s Online Privacy Protection Act, the California Consumer Privacy Act of 2018, the Computer Fraud and Abuse Act, the Electronic Communications Privacy Act, the Fair Credit Reporting Act, the Fair and Accurate Credit Transaction Act, the Health Insurance Portability and Accountability Act of 1996, as amended and supplemented by the Health Information Technology for Economic and Clinical Health Act of the American Recovery and Reinvestment Act of 2009, the Gramm-Leach-Bliley Act, the Family Educational Rights and Privacy Act, the GDPR, and all other similar international, federal, state, provincial, and local laws.Note that if you are not providing personal information on behalf of a third-party, the foregoing will not apply to you.AUDIT RIGHTSTo the extent provided in Client’s order for Services, Client may at Client’s sole expense audit Strum’s compliance with the terms of this Privacy Policy by sending Strum a written request, including a detailed audit plan, at least six weeks in advance of the proposed audit date. Client and Strum will work cooperatively to agree on a final audit plan.The audit shall be conducted no more than once during a twelve-month period, during regular business hours, subject to Strum’s on-site policies and regulations, and may not unreasonably interfere with business activities. If Client would like to use a third party to conduct the audit, the third party auditor shall be mutually agreed to by the parties and the third-party auditor must execute a written confidentiality agreement acceptable to Strum. Upon completion of the audit, Client will provide Strum with a copy of the audit report, which is classified as confidential information under the terms of Client’s agreement with Strum.Strum will contribute to such audits by providing Client with the information and assistance reasonably necessary to conduct the audit, including any relevant records of processing activities applicable to the Services. If the requested audit scope is addressed in a SOC 2 or a similar audit report issued by a qualified third party auditor within the prior twelve months and Strum provides such report to Client confirming there are no known material changes in the controls audited, Client agrees to accept the findings presented in the third party audit report in lieu of requesting an audit of the same controls covered by the report. Additional audit terms may be included in Client’s order for Services.DISPUTE RESOLUTION OR FILING A COMPLAINTIf you have any complaints regarding our compliance with our privacy and security practices, please contact us first. We will investigate and attempt to resolve any complaints and disputes regarding our privacy practices.CHANGES TO THIS SERVICES PRIVACY POLICYThis Privacy Policy was last updated June 2022. However, the Privacy Policy can change over time, for example to comply with legal requirements or to meet changing business needs. The most up-to-date version can be found on this website: http://www.strumplatform.com/services-privacy-policy.html. In cases of material changes, we will also inform you in another appropriate way (for example via a pop-up notice or statement of changes on our website) prior to the changes becoming effective.CONTACT USWe may be reached at support@strumplatform.com HOME SCHEDULE DEMO CONTACT US STRUM AGENCYThe Strum Platform™ is a trademark of Strum Agency Inc. | © 2022By using this website, you agree to our use of cookies. We use cookies to provide you with a great experience and to help our website run effectively.OK