- Data Collection
- Data Uses
- Data Location
- Data Retention
- Data Security
- Data Sharing
- Cookies and Tracking Technologies
- Data Subject Rights
- Strattic Services
- Roles and Responsibilities
- Additional Information and Contact
1. Data Collection
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We collect your data when you use our Services or contact us, directly ourselves or via third-party services.
Such data may include: The data we process regarding our Prospects and Users is typically collected and generated through automatic means, directly from you, through your interaction with us or with our Services; or through third-party services, social media, analytics tools, events we organize or take part in, and other business initiatives.
- Contact information: contact details and interests, as well as any needs, preferences, attributes and insights relevant to our potential engagement;
- Direct interactions and communications with us: correspondence with us (e.g., for user experience, support and training purposes), as well as chats, surveys, feedbacks, calls and video recordings, transcriptions, and analyses thereof;
- Site usage information: connectivity, technical and aggregated usage data, user agent, IP addresses, device data (such as type, OS, device ID, browser version, locale and language settings used), approximate geolocation, activity, communication and performance logs, session recordings, issues and bugs, and the cookies and pixels installed or utilized on your device.
We may collect additional data from our Users, such as:
- Account information: e-mail address, name and, when applicable, hashed password or other information used for authentication and access control;
- Service usage information: license key, server’s software, version and IP address, MySQL version, PHP settings & version, WordPress version, WordPress debug mode, WordPress memory limit, WordPress max upload size, WordPress settings (permalink structure, multisite, language, theme, plugins), site URL.
2. Data Uses
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We use your data to provide you with our Services, to continually improve them, and to communicate with you.
Strattic processes the personal data described in Section 1 for the purposes listed below, as necessary for the performance of our Services (“Performance of Contract”); to comply with our legal and contractual obligations (“Legal Obligations”); and to support our legitimate interests in maintaining, improving and advertising our Services. These include understanding how our Services are used, and how our Services, campaigns and other activities are performing; gaining insights which help us dedicate our resources and efforts more efficiently; marketing, advertising and selling our Services; providing customer service and technical support; and protecting and securing our Services, ourselves and the organizations and individuals we engage with (“Legitimate Interests”).
Specifically, we use your data for the following purposes (and in reliance on the legal bases for processing noted next to them, as appropriate):
- To facilitate, operate, enhance and provide our Services (Performance of Contract; Legitimate Interests);
- To provide you with assistance and technical support services, to test and monitor the Services, or diagnose or fix technology problems, and to train our staff (Performance of Contract; Legitimate Interests);
- To personalize our Services, including by recognizing an individual and remembering their information when they return to our Services, and to provide further localization and personalization capabilities (Performance of Contract; Legitimate Interests);
- To gain a better understanding on how individuals use and interact with our Services, which content and data they have processed through our Services, and how we could improve their and others’ user experience and the value they can generate from using the Services, so we could continue improving our products, offerings and the overall performance of our Services, including through the utilization and optimization of Artificial Intelligence and Machine Learning capabilities (Legitimate Interests);
- To facilitate and optimize our marketing and advertising campaigns, ad management and sales operations, and to manage and deliver advertisements for our products and Services more effectively (Legitimate Interests; Consent);
- To contact you with general or personalized service-related messages, or with promotional messages, in accordance with Section 8 below, and to facilitate, sponsor and offer certain events and promotions (Performance of Contract; Legitimate Interests; Consent);
- To facilitate and optimize our marketing campaigns, ad management and sales operations, and to manage and deliver advertisements for our products and services more effectively, including on other websites and applications. Such activities allow us to highlight the benefits of using our Services, and thereby increase your engagement and overall satisfaction with our Services. This includes contextual, behavioral and interests-based advertising based on your activity, preferences or other data available to us or to our business partners (Legitimate Interests; Consent);
- To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity (Performance of Contract; Legitimate Interests);
- To create aggregated statistical data, inferred non-personal data, or anonymized or pseudonymized data (rendered non-personal), which we or our business partners may use to provide and improve our respective services, or for any other purpose (Legitimate Interests); and
- To comply with our legal, regulatory, compliance and contractual obligations (Legal Obligations).
3. Data Location
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We and our Service Providers will store your data in different locations worldwide.
We and our authorized Service Providers maintain, store and process personal data in the various locations we operate around the globe, including in Israel, the EU and the US, as reasonably necessary for the proper performance and delivery of our Services, or as may be required by law.
Strattic is headquartered in Israel, a jurisdiction which is recognized by the European Commission and the UK Information Commissioner’s Office (ICO) as offering an adequate level of protection for the personal data of UK and EEA residents. We transfer personal data from the EEA and the UK to Israel on this basis. For data transfers from the EEA or UK to countries which are not considered to be offering an adequate level of data protection, we and the relevant data exporters and importers have entered and intend to enter into Standard Contractual Clauses as approved by the European Commission and UK ICO. You can obtain a copy by contacting us as indicated in Section 12 below.
4. Data Retention
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We retain your personal data for as long as necessary to provide you with our Services; we do not retain your payment information.
We retain your personal data for as long as it is reasonably necessary to provide you with our Services and offerings and to maintain and expand our relationship; to comply with our legal and contractual obligations; or to protect ourselves from any potential disputes (e.g. as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with applicable laws and regulations.
Please note that except as required by applicable law or our specific agreements with you, we will not be obligated to retain your personal data for any particular period, and we are free to securely delete it or restrict access to it for any reason and at any time, with or without notice to you. If you have any questions about our data retention policy, please contact us by e-mail at email@example.com.
Please also note that we do not retain your payment information, it is transferred directly to the relevant Service Provider (as per Section 6 below). We only retain a token of such payment information (which cannot be used to reidentify it) and the chosen payment method, as it is required for your continuous payment of our Services subscriptions.
5. Data Security
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We will do our best to make sure your data is secured.
We and our Service Providers implement systems, applications and procedures to secure your personal data, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information. These measures provide sound industry-standard security, however, although we make efforts to protect your privacy and data, we cannot and do not guarantee the absolute protection and security of any personal data stored with us or with any third-parties.
6. Data Sharing
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We may share your data for different reasons, mainly in order to provide you with our Services, or if required by law.
Legal Compliance: in exceptional circumstances, we may disclose or allow government and law enforcement officials access to your personal data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations, with or without notice to you. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect our legitimate business interests, including the security or integrity of our products and Services.
Service Providers: we engage selected third-party companies and individuals to perform services complementary to our own. Such Service Providers include hosting and server co-location services, communications and content delivery networks (CDNs), internet service providers, operating systems and platform, data analytics services, marketing and advertising services, data and cyber security services, fraud detection and prevention services, billing and payment processing services, web analytics, e-mail and SMS distribution and monitoring services, session or activity recording services, remote access services, performance measurement, data optimization services, social and advertising networks, content providers, support and customer relation management systems; and our business, legal, financial and compliance advisors (collectively, “Service Providers“). These Service Providers may have access to your personal data, depending on each of their specific roles and purposes in facilitating, supporting and enhancing our Services, and may only use it for such purposes.
Account Administrators for Multi-Member Plans: User data may be shared with the administrator or other Users of the same account (if applicable). This means that the administrator of the account may have access, and will be able to monitor, process and analyze the personal data contained therein, as well as your use of the Services and communication with us.
Protecting Rights and Safety: we may share personal data with others if we believe in good faith that this will help protect the rights, property or personal safety of Strattic, our Users, our Prospects, or any members of the general public.
Additional Sharing: we may share your personal data in additional manners, pursuant to your request or explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal, non-identifiable and anonymous. We may transfer, share or otherwise use non-personal and non-identifiable data at our sole discretion and without the need for further approval.
7. Cookies and Tracking Technologies
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Cookies: cookies are small text files that are stored through the browser on your computer or mobile device (for example, Google Chrome or Safari) when you visit a website. Some cookies are removed when you close your browser session – these are the “session cookies”. Some last for longer periods and are called “persistent cookies”. We use both types of cookies to facilitate the use of the Services’ features and tools. Whilst we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application, you can manage your cookies preferences, including whether or not to accept them and how to remove them, through your browser settings. Please bear in mind that disabling cookies may complicate or even prevent you from using the Services. For more information regarding cookies, you may find the following websites useful: www.allaboutcookies.org, www.youronlinechoices.co.uk.
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We may contact you with service and promotional communications.
We engage in service and promotional communications, through social media, e-mail, phone, SMS and notifications.
Service Communications: we may contact you with important information regarding our Services. For example, we may send you notifications (through any of the means available to us) of changes or updates to our Services (such as billing issues, login attempts or password reset instructions, alerts and notifications concerning anomalies detected by our Services, etc.). You can control your communications and notifications in accordance with the instructions included in the communications sent to you. Please note that you will not be able to opt-out of receiving certain service communications which are integral to your use (like password resets or billing notices payment issues, login attempts or password reset instructions, etc.).
Notifications and Promotional Communications: we may also notify you about new features, additional offerings, events, webinars, special opportunities or any other information we think you will find valuable. We may provide such notices through any of the contact means available to us (e.g., SMS, phone, mobile or e-mail), through the Services, or through our marketing campaigns on any other sites or platforms. In order to control your notifications settings please follow the instructions included in the promotional communications sent to you. If you do not wish to receive such communication, you may also notify us by sending an e-mail to: firstname.lastname@example.org.
9. Data Subject Rights
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You may exercise your rights concerning your personal data, by contacting us or editing your user profile.
Individuals have rights concerning their personal data. If you wish to exercise your privacy rights under any applicable law, including the EU General Data Protection Regulation (GDPR), or the CCPA, such as – to the extent applicable – the right to know/request access (specific pieces of personal data collected; categories of personal data collected; categories of sources from whom the personal data was collected; purpose of collecting personal data; categories of third parties with whom we have shared personal data), rectification or erasure of your personal data held with Strattic, please log in to “My Account” and edit your user profile. If you wish to exercise your right to restrict or object to such personal data’s processing, to direct us not to sell your personal data to third parties now or in the future, or to port such personal data, or the right to equal services and prices (e.g. freedom from discrimination) (each to the extent available to you under the laws which apply to you) – please contact us by e-mail at: email@example.com. Please be advised that deleting your personal data stored with Strattic will adversely affect your use of our Services.
Please note that such rights are not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal data that we hold about you. In the event that we cannot accommodate your request, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
Please also note that we may require additional information, including certain personal data, in order to authenticate and process your request. Such additional information may be then retained by us for legal purposes (e.g., as proof of the identity of the person submitting the request), in accordance with Section 4 above. We may redact from the data which we will make available to you, any personal data related to others.
10. Strattic Services
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We may process personal data on our Users’ behalf, if you are their visitor or user, please contact them directly with any requests.
We may store personal data of visitors and users of our Users, as part of our Services (the “Users”).
If you are a visitor or user of our Users’ website, and you would like to make any requests or queries regarding data we process on their behalf, please contact them directly. For example, if you are a visitor or user of our User and you wish to access, correct, or delete data processed by Strattic on their behalf, please direct your request to the relevant User (who is the “data controller” of such data – per Section 11 below). Note that if you do contact us, we may share your communications with the relevant User.
11. Roles and Responsibilities
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We are the controllers of our Prospects and Users data; we are the processors of visitors and users’ data processed on our Users’ behalf.
Certain data protection laws and regulations, such as the GDPR or the CCPA typically distinguish between two main roles for parties processing personal data: the “data controller” (or under the CCPA, “business”), who determines the purposes and means of processing; and the “data processor” (or under the CCPA, “service provider”), who processes the data on behalf of the data controller. Below we explain how these roles apply to our Services, to the extent that such laws and regulations apply.
Strattic is the “data processor” of its Users’ visitors and users’ data, which we process on behalf of our Users, who are the “data controller” of such data. Such processing will be in accordance with a Data Processing Agreement (“DPA”). In these instances, our Service Providers processing such data will assume the role of “sub-processors”.
For the avoidance of doubt, each Strattic User is solely responsible for providing adequate notice to their visitors and users whose personal data may be processed – including sufficient reference to the processing of their personal data via the Services, and any other information necessary to comply with all applicable privacy and data protection laws; and to obtain all approvals and consents from such individuals as required under such laws.
12. Additional Information and Contact Details
Our Services are not designed to attract children under the age of 18: we do not knowingly collect personal data from children and do not wish to do so. If we learn that a person under the age of 18 is using the Services, we will attempt to prohibit and block such use and will make our best efforts to promptly delete any personal data stored with us with regard to such child. If you believe that we might have any such data, please contact us by e-mail at firstname.lastname@example.org.