PRIVACY POLICY
Effective date: 09 March 2023
Introduction
www.strategicbusinessconnect.com (the “Platform”) provides services through Asentiv Marketing and Management Company LLC ("Company"; or "we).
We respect your privacy and are committed to protecting it through our compliance with this policy.
This policy covers how we process your personal data if you use our Platform or order any Services. In these instances, we are the controller of your personal data (which means we decide what information we collect and how it is used).
Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use the Platform. By accessing or using the Platform you agree to this Privacy Policy.
This policy may change from time to time. Your continued use of the platform after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.
1. INFORMATION WE COLLECT ABOUT YOU
Personal data means any information that does (or could be used to) identify a living person. In particular, the Platform may collect the following categories of information:
a) Personal data
This includes but is not limited to information such as name, country code, telephone or mobile number, email address, date of birth and demographic information and information relating to the business owned by you including business name, ownership, and logo, if you choose to be listed in the client directory.
b) Financial data
This includes but is not limited to information such as bank account and payment card details. You will be required to submit your credit card number and CVV to process payments through our payment gateway.
c) Internet or other similar network activity
This includes but is not limited to, browsing history, search history, information on your interaction with the platform or advertisement, address, your login data, browser type, and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Platform.
d) Marketing and communications data
This information includes but is not limited to preferences in receiving marketing from us and our third parties and your communication preferences.
e)Other information
This information includes but is not limited to general, aggregated, demographic, and non-personal information to improve our Platform, and any other information we consider necessary to enhance your experience on the Platform.
For example, the information you provide when you enter a promotion via our Platform or our social media channels or the comments or feedback you provide on the Platform. Any information you provide us, or that we may collect from you when you report a problem with the Platform or a record of correspondence in an event that you contact us.
f) Technical data
This information includes but is not limited to IP address, browser type and version, time zone setting and generic location, browser plug-in types and versions, operating system and platform, devices you use to access our Platform.
g) Usage Data
Information about how a user interacts with the Platform. This information includes but is not limited to, the number of times they visit a page or sections they tap on.
2. HOW DO WE COLLECT IT
We collect the information detailed above:
(a) directly from you when you provide it to us e.g., when you register on our Platform or while filling in forms on the Platform; or when you correspond with us, in which case we maintain records and copies of your correspondence (including email addresses) if you contact us;
(b) automatically as you navigate through the Platform including traffic data, location data, and other communication data. Information collected automatically may also include usage details, and details of your visit to the Platform. IP addresses and information are collected through cookies and other tracking technologies.
(c) third-party data: We may also collect data from third-party automated sources (via cookies, plugins and other similar technologies)
(d) via Google’s Application Programming Interface (API) Services to enable the use of certain Platform features (i.e., use of your Gmail account to calendar events from the Platform’s Coaching feature). The information collected and used with these API services includes personal data such as email addresses, calendar information, and first and last names. Your Google information is used by our system developers to provide or improve user-facing features that are prominent to your user experience.
(e) when you give us feedback to contact you.
3. HOW WE USE OR DISCLOSE YOUR PERSONAL DATA
We may use, or disclose the personal information collected for one or more of the following purposes:
(a) to fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about the Platform, we will use that personal information to respond to your inquiry;
(b) to provide Services and provide updates about the Services you have bought (eg. confirmation of order);
(c) to personnel providing technical and business-related services to the Platform (including but not limited to external consultants and freelancers) including the following:
(i) Kajabi, who hosts our Platform. Their privacy policy is available at https://kajabi.com/policies/privacy
(ii) Community box, a plug-in that assists us with data storage. Their privacy policy is available at https://www.communitybox.co/privacy-policy
(iii) Stripe : https://stripe.com/en-in/privacy
(iv) Keap : https://keap.com/legal/privacy-policy
(d) to comply with any court order, law, or legal process, including responding to any government or regulatory request.
(e) to provide, support, personalize, and develop the Platform;
(f) to create, maintain, customize, and secure your account with us;
(g) to provide you with support and to respond to your inquiries, including to investigate and to address your concerns and monitor and improve our
responses;
(h) to help maintain the safety, security, and integrity of the Platform;
(i) for testing, research, analysis, to develop and improve the Platform.
(j) carrying out our obligations arising from any contracts entered between you and another entity using our application or between you and us;
(k) to protect and defend ourselves against legal claims;
(l) respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
We do not sell personal information.
4. HOW WE STORE YOUR PERSONAL DATA
4.1 We use Kajabi and Community Box to store your data from the Platform.
4.2 We implement reasonable organizational level, physical, and technical security measures to help guard your data from any loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. However, no physical or electronic security system is impenetrable.
5. RETENTION OF PERSONAL DATA
5.1 We retain your personal information only for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information; the potential risk of harm from unauthorized use or disclosure of your personal information; the purposes for which we process your personal information and whether we can achieve those purposes through other means; and the applicable legal requirements. This period of retention of data will be anywhere between 6 months and upwards depending on the applicable law and the nature of the data and the factors listed above. In some circumstances, you may ask us to delete your information.
5.2 Keep in mind that, while our systems are designed to carry out our deletion practices upon deletion of accounts, we cannot promise that deletion will occur within a specific timeframe. There may be legal requirements to store your data and we may need to suspend those deletion practices if we receive a valid legal process asking us to preserve content or if we receive reports of abuse or other Terms of Service violations. Finally, we may also retain certain information in backup for a limited period of time or as required by law.
6. INTERNATIONAL DATA TRANSFERS
6.1 We are located and operate in the United Arab Emirates. However, our servers and service providers may be located in the United States, United Kingdom and/ or Europe. By submitting personal information to us, you understand that we may transfer your personal information to a country foreign to you. The laws that apply to the use and protection of personal information in other countries or jurisdictions in which we transfer or process personal information, may be different from the laws and protections in your country. These transfers may include transfers to our service
providers located in foreign jurisdictions. Whenever we engage a service provider, we require that its privacy and security standards adhere to our requirements and applicable privacy laws.
7. OUR LEGAL GROUNDS FOR PROCESSING YOUR PERSONAL INFORMATION
7.1 To the extent required by applicable law, we will collect your personal data with your consent, where required, and in accordance with our legitimate need to provide our Platform.
7.2 Under European data protection laws, our Platform is required to rely on one or more legal bases to collect, use, share, and otherwise process the information for a.) performing Services under this Privacy Policy and Terms of Use b.) Using your information to maintain your registration c.) for the intended purpose of use of the Platform.
7.3 Some of the basis for processing your data may include the following:
a) your consent, which is revocable at any time and in this regard, the type of data processed includes but is not limited to, cookies and similar technologies, verification of personal data like addresses, and marketing communication;
b) pursuant to a legal obligation, and in this regard, we may process any data and personal information requests, required to be processed under the applicable laws; and
c) vital interest, and in this regard, the type of data processed, includes but is not limited to, any data required to be preserved and shared to avoid harm to the general public.
8. HOW WE PROTECT YOUR PERSONAL INFORMATION
8.1 Personal information is maintained on our servers or those of our service providers and is accessible by authorized employees, representatives, and agents as necessary for the purposes described in this privacy policy.
8.2 We realize that individuals trust us to protect their personal information. We maintain reasonable and appropriate physical, electronic, and procedural safeguards designed to help protect your personal information. While we attempt to protect your personal information in our possession, no method of transmission over the internet, or security system is perfect, and we cannot promise that information about you will remain secure in all circumstances.
8.3 For your convenience, the Platform includes functionality that allows you to remain logged in so that you do not have to re-enter your password each time you want to access your account. If you choose to remain logged in, you should be aware that anyone with access to your device will be able to access and make changes to your account and may be able to make purchases through your account. For that reason, if you choose to remain logged in, we strongly recommend that you take appropriate steps (such as enabling the “Passcode Lock” security feature on your mobile device) to protect against unauthorized access to and use of your account. Please also notify us as soon as possible if you suspect any unauthorized use of your account or password.
9. YOUR DATA RIGHTS
9.1 We want you to be in control of your information, so we provide you with the following tools:
(a) The right to access: You have the right to request copies of your personal data. We may charge you a small fee for this service.
(b) The right to rectification: You have the right to request that we correct any information you believe is inaccurate. You also have the right to request that. We complete the information you believe is incomplete.
(c) The right to erasure: You have the right to request that we erase your personal data, under certain conditions.
(d) The right to restrict processing: You have the right to request that we restrict the processing of your personal data, under certain conditions.
(e) Correction/Rectification. The right to request correction of inaccurate personal information maintained by the business.
(f) The right to object to processing: You have the right to object to our processing of your personal data, under certain conditions. You may withdraw your consent to the processing of your information at any time by stopping to use the Platform.
(g) Object to Processing: Object, on grounds relating to your situation, to our processing of personal data concerning you which is (i) necessary for the performance of a task carried out in the public interest, (ii) carried out in the exercise of official authority vested in us, or (iii) processed by us on the basis of our legitimate interest. In this case, where applicable, we will no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights, and freedoms, or the processing serves to assert, exercise or defend legal claims.
(h) Non-Discrimination. The right not to be discriminated against for exercising any of the rights conferred at law.
(i) Complaints. The right to lodge a complaint with the appropriate governmental authority.
If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us.
10. CHILDREN’S DATA RIGHTS
10.1 This Company does not intend the Platform to be used by anyone under legal age as per the jurisdiction you reside in. In such cases, Platform does not knowingly collect personal information from anyone under the legal age. In addition, we may limit how we collect, use, and store some of the information of EU users between 13 and 16. In some cases, this means we will be unable to provide certain functionality to these users. If we need to rely on consent as a legal basis for processing your information and your country requires consent from a parent, we may require your parent’s consent before we collect and use that information. Make sure to read the entire policy to fully understand all the below terms related to your privacy.
11. AUTOMATIC DECISION-MAKING
11.1 If you are a resident of the EEA, you have the right to object to processing based solely on automated decision-making (which includes profiling), when that decision- making has a legal effect on you or otherwise significantly affects you.
11.2 We do not engage in fully automated decision-making that has a legal or otherwise significant effect using customer data.
12. MARKETING
12.1 Our company would like to send you information about our services of ours from time to time, that we think might interest you.
12.2 If you have agreed to receive marketing, you may always opt out at a later date.However, please note that you may miss out on important updates, sessions, or advisories and may not be able to enjoy the full benefits, functionality, and experience of the Platform, which may impact the value you derive from the Platform for your business.
12.3 We may collect and share some of this information directly with advertising partners, and in some cases through the use of cookies or other similar technologies (which you may consent to, depending on your location).
12.4 For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at
https://thenai.org/about-online-advertising/faq/?tab=2
12.5 If you no longer wish to be contacted for marketing purposes write us an email at [email protected]
13. COOKIES AND SIMILAR TECHNOLOGIES
13.1 We use two broad categories of cookies: (1) first-party cookies, served directly by us to your computer or mobile device, which we use to recognize your device when it revisits our Platform; and (2) third-party cookies, which are served by service providers or business partners on our client services, and can be used by such service providers or business partners to recognize your device when it visits other websites. Some technologies, plug-ins, and specific cookies are also used to collect the automatic data mentioned under this privacy policy and it may include:
(a) Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. 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 certain parts of the Platform. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to the Platform. These cookies include but are not limited to:
i. Essential Cookies: These cookies are essential to provide you with services available through our Platform and to enable you to use some of its features. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.
ii. Functionality Cookies: These cookies allow our Sites to remember the choices you make when you use our Sites. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-select your preferences every time you visit our Platform.
iii. Analytics and Performance Cookies: These cookies collect information about traffic to our Sites and about how individuals use our Sites.
(b) Flash Cookies. Certain features of the Platform may use locally stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on Flash cookies are not managed by the same browser settings as are used for browser cookies.
(c) Web Beacons. Pages of our Platform and 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 the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
13.2 How to manage cookies: You can set your browser not to accept cookies, and the above website tells you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result.
13.3 Do not track: Your browser settings may allow you to automatically transmit a "Do Not Track" signal to websites and online services you visit; however unless mandated by law and where it is required by us to do so as per the law, the website shall not alter its current practices when it receives a "Do Not Track" signal from a visitor's browser.
Most browsers automatically accept cookies, but you can choose whether or not to accept cookies through your browser controls, often found in your browser’s “Tools” or “Preferences” menu. More information on how to modify your browser settings or how to block, manage or filter cookies can be found in your browser’s help file or through such sites as: https://www.aboutcookies.org/
14. PRIVACY POLICIES OF OTHER WEBSITES
Our Website may contain links to other websites. Our Privacy Policy applies only to our website, so if you click on a link to another website, you should read their Privacy Policy.
15. CHANGES TO OUR PRIVACY POLICY
It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users' personal information, we will notify you. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Platform and this privacy policy to check for any changes.
16. CONTACT INFORMATION
To ask questions or comment about this privacy policy and our privacy practices, contact us at: [email protected]
