Last updated: January 25, 2019
Except for physical location information and tracking technologies (as described below), you do not have to give us any personal information to browse this Site. However, you may be asked to provide personal information to submit or request information from us, or to use the services offered through this Site. Once you provide us with your personal information, you are no longer anonymous to us. This information may include:
In order to access and use certain areas or features of the Site, you consent to our collection and use of your physical location information if you use the Site on a location-enabled device (including GPS, cellular, and Wi-Fi networks) or from your browser.
In order to access and use certain areas or features of the Site, you consent to our collection and use of certain information about your use of the Site through the use of tracking technologies or by other passive means. Your consent to our access and use of this “passively collected” information includes, but is not limited to, the domain name of the website that allowed you to navigate to the Site, search engines used, the internet protocol (IP) address used, the length of time spent on the Site, the pages you looked at on the Site, other webpages you visited before and after visiting the Site, the type of internet browser you have, the frequency of your visits to the Site, and other relevant statistics, including the following:
StrongKey complies with its obligations under applicable privacy laws by: keeping personal data up to date where needed based on the purposes for which the personal data is being processed; by not collecting or retaining excessive amounts of data; by ensuring that appropriate technical measures are in place that are designed to protect personal data from loss, alteration, misuse, unauthorized access and disclosure as it is transmitted, stored, or otherwise processed, and by using appropriate measures to securely destroy personal data when it is no longer needed by StrongKey.
Personal information collected through the Site may be used by us and our affiliates for purposes of:
We do not sell, rent, trade, or otherwise share personal information collected through the Site, except as described below:
You can always choose whether or not to provide information on the Site. However, if you choose not to disclose certain information, you may not be able to register as a user of the Site, which may limit your access to certain portions of the Site.
If at any time you decide that you no longer wish to receive notices from us regarding the Site, you may indicate this preference by contacting us at firstname.lastname@example.org.
Unless subject to an exemption under the GDPR, if your personal data is subject to the GDPR, you have the following rights with respect to your personal data:
If your personal data is subject to the GDPR, StrongKey will transfer personal data from the European Economic Area (EEA) to a location outside the EEA only when there has been a documented adequacy determination, or where StrongKey has confirmed adequate privacy protections. If StrongKey transfers personal data to a third party acting as an agent of StrongKey, we will also obligate the third party to have adequate privacy protections in place.
StrongKey may transfer personal data to and on behalf of clients and third parties with whom StrongKey has an existing service agreement or as part of our legal obligations, each of which shall be subject to StrongKey policies, and only to the extent necessary for purposes of legitimate interests pursued by the data controller (or by a third party).
Under the GDPR, data subjects have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is not based on the data subject’s explicit consent. We do not engage in automated decision making.
We employ reasonable security precautions to help protect against the loss, misuse, and alteration of personal information provided on or through the Site. These security measures include: Storing all passwords in hashed form, forced SSL encryption of all CMS communications, monitoring deployed on server (monitors critical files for changes as well as any failed user logins, any users added to the system, or any password changes, the starting or certain services and even attempted attacks), and Hubspot’s security protocols. However, no method of transmitting or storing data is completely secure. As a result, although we strive to protect personal information about you, we cannot guarantee the security of any information you transmit to us through or in connection with the Site. If you have reason to believe that personal information is no longer secure, please notify us immediately by contacting us in accordance with the last section below.
Children are not eligible to use the Site, and we ask that minors (children under the age of 16) not submit any personal information to us. If you are a minor, you can use the Site only in conjunction with your parents or guardians.
Under California’s “Shine the Light” law, California residents who provide personal information in obtaining products or services for personal, family, or household use are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g., requests made in 2018 will receive information regarding 2017 sharing activities).
To obtain this information on behalf of StrongKey, please send an email message to email@example.com with “Request for California Privacy Information” on the subject line and in the body of your message. We will provide the requested information to you at your e-mail address in response. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.
The Site is hosted in the United States. All matters relating to the Site are governed exclusively by the laws of the State of California in the United States of America and not the jurisdiction in which you are located. If you are located outside of the United States of America and you contact us, please be advised that any information you provide to us will be transferred to the United States of America and that by submitting information, you explicitly authorize such transfer.
If your personal data is subject to the GDPR, the data controller for the purposes of GDPR or other data protection laws applicable in Member states of the European Union and other provisions related to data protection is:
Any data subject may, at any time, contact us directly with any questions and suggestions concerning data protection. We encourage interested persons to raise any concerns about the collection, use, or processing of personal data using the contact information provided above. In the event of a privacy related issue or complaint, we will investigate and attempt to promptly resolve any complaints and disputes regarding use and disclosure of personal data.
For complaints that cannot be resolved, if your personal data is subject to the GDPR, we commit to cooperating with the panel established by the EU data protection authorities (DPAs) or the Swiss Federal Data Protection and Information Commissioner (FDPIC), as applicable, and comply with the advice given by the DPAs or FDPIC about personal data transferred from the EU or Switzerland.
In order to facilitate the handling of complaints, individuals in the EU can choose to contact their national DPA or use the form located at this link:
Individuals in Switzerland can contact the Swiss FDPIC by visiting:
This independent dispute resolution process is provided at no cost to the individual.