Privacy Policy

Last updated 2021-07-28.

For the purposes of this Privacy Statement, Strengthology Insights LLC “Strengthology, we, us, and our” refer to Strengthology Insights LLC, 12650 North Beach Street, Suite 114-944, Keller, Texas, 76244, U.S.A.

This statement describes the types of information, including Personal Information, collected and processed through Strengthology websites and through the services delivered via Strengthology websites, and how Strengthology treats such information. For questions about this Privacy Statement or your Personal Information, please contact support@strengthologyinsights.com.

By using the term “Personal Information” in our Privacy Statement, we refer to information that you individually provide to Strengthology either directly or indirectly that on its own or in combination with other information, can be used to identify you or make you identifiable. Personal Information includes, for example, your name, your mailing address, your telephone number, your email address or other information that identifies you or makes you identifiable. This notice describes the personal data we collect, how it’s used and shared, and your choices regarding this data. We recommend that you read this along with our Terms of Service, which highlights our practices.

Information that by itself cannot be used to identify you or make you identifiable does not qualify as Personal Information.

I. INFORMATION COLLECTED BY STRENGTHOLOGY WEBSITES

Strengthology websites gather information in two ways: (1) indirectly (for example, through our site’s technology), and (2) directly (for example, when you, the site visitor, voluntarily provide information on various pages).

The information will be transferred to Strengthology Inc.’s servers located in the United States of America (“USA”).

1. Information Collected Indirectly

Strengthology indirectly collects a variety of information through your interaction with and use of Strengthology websites. This information may include, but is not limited to, browser and device information, data collected through automated electronic interactions, application usage data, content information based on your individual interests, demographic information, geographic or geo-location information, statistical and aggregated information (“Other Information”).

Statistical or aggregated information does not directly identify a specific person, but it may be derived from Personal Information. For example, we may aggregate Personal Information to calculate the percentage of users in a particular zip code.

If we combine Other Information with Personal Information, we will treat the combined information as Personal Information.

1.1 Strengthology Cookies

Some types of indirectly collected information are stored in “cookies.” Cookies are small files of electronic information that a website can transfer to a visitor’s hard drive to help that visitor while on the site. There are different types of cookies:

• Essential cookies are used to provide visitors with basic functions through our websites. Without these cookies, our websites will not work properly.
• Analytics cookies use statistics to collect information anonymously. This information helps us understand how our visitors use our websites.

The use of cookies is standard on the internet. Although most web browsers automatically accept cookies, the decision of whether to accept them is yours. You have the choice to accept or decline cookies by way of consent. You may adjust your browser settings to prevent the reception of cookies, or to provide notification whenever a cookie is sent to you. You may refuse the use of cookies by selecting the appropriate settings on your browser. However, please note that if you do this, you may not be able to access the full functionality of Strengthology websites. Cookies placed by Strengthology will expire when the user terminates the website session or after a reasonable period of inactivity.

1.1 a. Tracking Data

Website traffic volume and patterns, such as the number of visitors to a given website or page on a daily basis is typically referred to as Tracking Data. This type of indirectly collected information is gathered through various means, such as an IP address, which is a number that is automatically assigned to your computer whenever you are surfing the Web. Web servers, the computers that “serve up” Web pages, automatically identify your computer by its IP address. When you visit any Strengthology Websites, our servers log your computer’s IP address.

We operate on our behalf to collect information about your activity, or activity on devices associated with you. On our sites and applications we use cookies, flash cookies, pixels, tags, application program interfaces and web beacons.

Only designated administrators of Strengthology can access the Tracking Data gathered, and the information is used only for administrative and planning purposes to meet the needs of our users, such as to improve the content of the site and to customize the content and/or layout of the site for individuals or groups of users.

2. Information Collected Directly

Strengthology also collects Personal Information and other information that users voluntarily provide. It is entirely your decision to provide the requested information.

Strengthology keeps all information directly collected confidential, and will only use the information for the particular purpose stated at the point of collection. Strengthology will seek your specific permission for any additional use. You may choose to have this information removed at any time. Strengthology will never barter, trade, or sell access to your information without your specific consent.

2.1. User Account Data

When setting up an account on one of the Strengthology Websites (“User Account”), you may be asked to provide Personal Information including, but not limited to, your name, e-mail address, and your phone number. If you choose to purchase any products, services, access codes or other items for sale by Strengthology, you will be asked to provide payment details and your full address for billing purposes.

As a customer/user of Strengthology, we may obtain Personal Information about you when you register to use one of our websites or services/products or when you provide feedback about our products or services. The processing is necessary to perform the contract with you according to Article 6 (1) 1 lit. b) GDPR. As a customer/user, we will use your Personal Information, unless otherwise prohibited by law, for the following purposes:

• To provide you with the products and services you request.
• To communicate with you about your account or transactions with us and send you changes to our policies.
• To provide support including, but not limited to, product updates, product patches and fixes and other similar communications.

Furthermore, we will use your Personal Information for our legitimate interests according to Article 6 (1) 1 lit. f) GDPR to notify you about information about features on our site, new product releases and service developments and to advertise Strengthology’s products and services in accordance with this Privacy Statement.

Any User Account data will only be stored until you decide to terminate your User Account (see clause III.1. below). In case we are obliged to further store your Personal Information due to statutory retention requirements, your Personal Information will be barred for further use by Strengthology and only be stored until such retention periods expire.

2.2. Other Personal Information Provided Directly

Personal Information provided by you on Strengthology Websites, e.g. via contact forms, or via telephone will be stored in our service database and retained for the period necessary to fulfill our contractual obligations to you in accordance with Art. 6 (1) 1 lit. b) GDPR unless a longer retention period is required by law.

Strengthology takes the security of your personal information very seriously. If you or anyone else using Family Sharing log on a device that is owned by a third party, any information shared may be loaded on to that third-party device thereby disclosing such shared information.

II. DATA COLLECTION

Many Strengthology websites offer users the opportunity to participate in surveys or assessments via the internet. Strengthology will provide information about the purpose and process for each survey or assessment as part of the applicable survey or assessment.

1. Access to Your Survey or Assessment Results From Another User Account

Another online user may purchase access to a Strengthology survey or assessment for you. Please note that when participating in a survey or assessment, your results will also be accessible to the online user who purchased the Strengthology access. The data accessible to that account holder may include your name and your results. In addition, the account holder cannot modify, alter, or delete any of your results or User Account data.

2. Sharing Your Survey Results With Other People

After completion of the survey or assessment, you may have the opportunity to share your survey or assessment results via e-mail, or social networks. Please note that only your name and results will be displayed. By sharing your information from your User Account with any social media service, you are authorizing us to share information we collect from and about you with the social media service provider, other users, and your network of contacts on the social media service, and you understand that the social media service’s use of the shared information will be governed by the social media service’s privacy policy. If you do not want your Personal Information shared in this way, please do not connect your Strengthology information to a social media service provider.

III. GENERAL INFORMATION ON COLLECTION AND PROCESSING OF INFORMATION

1. Correcting and Changing User Information and Preferences; Deletion of User Accounts

If you have given your consent in accordance with Article 6 (1) 1 lit. a) GDPR to receiving e-mail communications from Strengthology but wish to withdraw your consent and discontinue this service, you may do so at any time by contacting us (see also below clause III.8. “Your rights”). In addition, as a registered user, you can change your settings within your User Account under “PROFILE” by updating your “Contact” settings.

You also have the option at all times to have your User Account deleted for any of the Strengthology websites or to request a revision of your user information at any time. To do so, please contact us.

To stop receiving newsletters or marketing communications, please contact us at support@strengthologyinsights.com.

2. Information Security

Strengthology employees understand the need for user privacy, and we maintain reasonable and appropriate security procedures to protect your information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into due account the risks involved in the processing and the nature of the Personal Information. Strengthology has appointed a Privacy Policy Administrator to monitor privacy practices. Access to user data is strictly limited to specific individuals who are trained to respect user privacy. The access given to these employees is restricted to their need for such information for business purposes.

3. Third-Party Information Storage

We provide Personal Information to our affiliates and other trusted businesses or persons to process it for us, based on our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures. For example, we use service providers for data storage. Any vendor or agent that we retain is not allowed to use Personal Information they receive from us for any other purpose than to perform the contracted services we have contracted them to perform. Like Strengthology, they will never barter, trade, or sell access to your information.

4. Children and Privacy

Strengthology encourages parents and guardians to spend time with their children online and to be fully familiar with the sites visited by their children. Strengthology sites do not contain content that is generally considered unsuitable for children. Strengthology's policy aims to comply with requirements of the U.S. Children's Online Privacy Proection Act (“COPPA”) for more information about COPPA please visit OnGuard Online.

5. Links to Other Sites

Strengthology websites may contain links to sites owned and/or operated by other organizations, and the privacy policies of those sites may differ from that of Strengthology. These sites may collect data and make use of it in ways that Strengthology does not. We encourage you to review the privacy policies posted on all third-party sites.

6. Location of Data Collection and Processing and Storage

In personally accessing Strengthology websites, you may be submitting Personal Information and survey or assessment results that Strengthology will use for business purposes that are consistent with this Privacy Statement. As a worldwide organization, Strengthology collects information that may be processed internationally throughout Strengthology offices worldwide. Your information may be processed in the United States or any other country in which Strengthology maintains facilities including any Strengthology subsidiary.

Strengthology keeps Personal Information gathered and processed for the purposes described in this Privacy Statement for as long as there is a business purpose.

7. Your Rights

You have the right to access the Personal Information that we hold about you and to correct, update, amend, suppress, delete or otherwise modify any Personal Information where it is inaccurate. When updating your Personal Information, we may ask you to verify your identity before we can act upon your request.

You may also, if governed by the General Data Protection Regulations, object to the use or processing of your Personal Information or withdraw consent to use your Personal Information at any time.

Under the General Data Protection Regulations, regarding the processing of your Personal Information, you have the following rights:

• the right to require free of charge (i) information whether your Personal Information is retained and (ii) access to and/or (iii) duplicates of the Personal Information retained. However, if the request affects the rights and freedoms of others or is manifestly unfounded or excessive, we reserve the right to charge a reasonable fee (taking into account the administrative costs of providing the information or communication or taking the action requested) or refuse to act on the request;
• the right to request proper rectification, removal or restriction of your Personal Information;
• where processing of your Personal Information is either based on your consent or necessary for the performance of a contract with you and processing is carried out by automated means, the right to receive the Personal Information concerning you in a structured, commonly used and machine-readable format or to have your Personal Information transmitted directly to another company, where technically feasible (data portability);
• where the processing of your Personal Information is based on your consent, the right to withdraw your consent at any time without impact to data processing activities that have taken place before such withdrawal or to any other existing legal justification of the processing activity in question; the right not to be subject to any automatic individual decisions which produces legal effects on you or similarly significantly affects you and
• the right to take legal actions in relation to any breach of your rights regarding the processing of the Personal Information, as well as to lodge complaints before the competent data protection regulators.

To exercise the rights referred to above, please contact us at support@strengthologyinsights.com.

As far as we process your Personal Information on the basis of our legitimate interests pursuant to Art. 6 1) lit. f) GDPR, you may object to processing at any time. You may find the detailed description of our processing activities and the legal basis in the sections before. If you object we will no longer process your Personal Information unless there are compelling and prevailing legitimate grounds for the processing or the data is necessary for the establishment, exercise or defense of legal claims. If you object to such processing, we ask you to state the grounds of your objection in order for us to examine the processing of your Personal Information and decide whether to adjust the processing accordingly.

Please note that the processing of your Personal Information may involve advertising activities as described above. If you do not want that we process your Personal Information for direct marketing activities, you can object free of charge at any time via e-mail support@strengthologyinsights.com.

Strengthology will obtain your consent before sharing your Personal Information with any third party that is not acting as an agent or vendor to perform tasks on our behalf or to use the information for a purpose materially different from the purpose for which it was initially collected or subsequently authorized by you. An exception to this will be (among others) where Strengthology’s processing of Personal Information is necessary for compliance with a legal obligation under the applicable law.

8. Sensitive Information

For processing of your sensitive information (e.g. medical information, Personal Information revealing ethnic or racial origin, political opinions, religious or philosophical beliefs, trade union membership, the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or a natural’s person sex life or sexual orientation), we will obtain your explicit consent.

Strengthology is among others not required to obtain explicit consent with respect to sensitive information where the processing is (a) necessary to protect the vital interests of the data subject or another natural person where the data subject is physically or legally incapable of giving consent; (b) necessary for the establishment, exercise or defense of legal claims or whenever courts are acting in their judicial capacity; (c) necessary to carry out Strengthology’s obligations in the field of employment law in so far as it is authorized by European Union or Member State Law or a collective agreement pursuant to Member State Law providing for appropriate safeguards for the fundamental rights and the interests of the data subject; or (d) related to information that is manifestly made public by the individual.

9. Dispute Resolution

If you have any complaints regarding our compliance with this Policy, you should first contact us. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Information in accordance with this Policy.

This Agreement and any disputes arising out of or related heroto, will be governed exclusively by the applicable governing law below, based on the laws of the primary jurisdiction in which we are located. For U.S. Federal Government, this Agreement shall be controlled and construed under the laws of the United States of America. The courts located in the applicable venue below will have exclusive jurisdiction to adjudicate any dispute arising out or or relating to the Agreement or its formation, interpretation or enforcement. Each party hereby consents and submits to the exclusive jurisdiction of such courts.

With respect to human resources data, Strengthology will cooperate and comply with the EU DPA’s and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with the advice given by such authorities with respect to human resources data transferred from the EU and Switzerland in the context of the employment relationship. If you do not receive timely acknowledgment of your complaint from Strengthology, or if we have not addressed your complaint to your satisfaction, you may contact the EU DPA’s for more information or to file a complaint. The services of the EU DPA’s are provided at no cost to you.

Strengthology is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

10. Strengthology Privacy Notice for California Residents

This Privacy Notice for California Residents supplements the information contained in Strengthology’s Privacy Policy and applies solely to all visitors, users and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.

INFORMATION WE COLLECT

The Strengthology website (the “Site”) collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”).

In particular, the Site has collected the following categories of personal information from its consumers within the past 12 months:

Category	Examples	Collected
A. Identifiers	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number or other similar identifiers.	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	YES
C. Protected classification characteristics under California or federal law	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	YES
D. Commercial information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	YES
E. Biometric information	Genetic, physiological, behavioural, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints and voiceprints; iris or retina scans; keystroke, gait or other physical patterns; and sleep, health or exercise data.	NO
F. Internet or other similar network activity	Browsing history, search history, information on a consumer’s interaction with a website, application or advertisement.	YES
G. Geolocation data	Physical location or movements.	YES
H. Sensory data	Audio, electronic, visual, thermal, olfactory or similar information.	NO
I. Professional or employment-related information	Current or past job history or performance evaluations.	YES
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))	Education records directly related to a student, maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information or student disciplinary records.	NO
K. Inferences drawn from other personal information	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behaviour, attitudes, intelligence, abilities and aptitudes.	YES

Personal information does not include:

• Publicly available information from government records
• Deidentified or aggregated consumer information
• Information excluded from the CCPA’s scope such as:
  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994

Strengthology obtains the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, from forms you complete or products and services you purchase.
• Indirectly from you. For example, from observing your actions on our Site.

USE OF PERSONAL INFORMATION

We may use or disclose the personal information we collect for one or more of the following business purposes:

• 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 our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
• To provide, support, personalize and develop our Site, products and services.
• To create, maintain, customize and secure your account with us.
• To process your requests, purchases, transactions, and payments and prevent transactional fraud.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To personalize your Site experience.
• For testing, research, analysis and product development, including to develop and improve our Site, products and services.
• To respond to law enforcement requests and as required by applicable law, court order or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.

Strengthology will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated or incompatible purposes without providing you notice.

SHARING PERSONAL INFORMATION

Strengthology may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

We share your personal information with the following categories of third parties:

• Subsidiaries and affiliates
• Contractors and service providers

DISCLOSURES OF PERSONAL INFORMATION FOR A BUSINESS PURPOSE

In the preceding 12 months, Strengthology has disclosed the following categories of personal information for a business purpose to one or more of the parties identified above:

Category A: Identifiers

Category B: California Customer Records personal information categories

Category D: Commercial information

Category F: Internet or other similar network activity

Category G: Geolocation data

YOUR RIGHTS AND CHOICES

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

ACCESS TO SPECIFIC INFORMATION AND DATA PORTABILITY RIGHTS

You have the right to request that Strengthology disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability and Deletion Rights), we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).

DELETION REQUEST RIGHTS

You have the right to request that Strengthology delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
6. Engage in public or peer-reviewed scientific, historical or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

EXERCISING ACCESS, DATA PORTABILITY AND DELETION RIGHTS

To exercise the access, data portability and deletion rights described above, please submit a verifiable consumer request to us by contacting us at support@strengthologyinsights.com.

Only you, or a person registered with the California Secretary of State who you authorize to act on your behalf, may make a verifiable consumer request related to your personal information.

You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice in a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

VERFICATION OF IDENTITY

Strengthology’s Client Support Team is tasked with verifying a person’s identity prior to taking any action on an individual’s account with Strengthology. Our Client Support Team will endeavor to use information that you have previously provided in order to verify your identity.

Strengthology may request any of the following information in order to verify your identity:

• first and last name
• email address or username
• security questions and answers
• access code
• purchase order number
• other uniquely identifiable variables
• unique numeric code sent to the individual’s verified email address

RESPONSE TIMING AND FORMAT

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account.

If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

11. Policy Updates

This Privacy Statement is Strengthology’s promise to its websites users and Users with a registered User Account. Additional information that is particular to specific Strengthology sites may exist, and updates to this policy may be posted. For these reasons, we suggest that users who may have specific concerns about the information being gathered and use of that information regularly view the Privacy Statement on each site. Strengthology reserves the right to change the policy on use of information collected at any time.

12. Additional Questions or Comments

If you have any inquiries, complaints, access requests and any other questions or comments regarding Strengthology’s Privacy Policy, please contact us. Strengthology will respond to you within 30 days of receiving a complaint.