Strategy Payments

Effective: January 2016

This Privacy Policy governs the manner in which Strategy, LLC. (“Strategy”) collects, uses, maintains and discloses information collected from users (each, a “User”) of its strategynewmedia.com website and any derivative or affiliated websites on which this Privacy Policy is posted (collectively, the “Website”).  Strategy reserves the right, at its discretion, to change, modify, add or remove portions of this Privacy Policy at any time by posting such changes to this page.  You understand that you have the affirmative obligation to check this Privacy Policy periodically for changes, and you hereby agree to periodically review this Privacy Policy for such changes.  The continued use of the Website following the posting of changes to this Privacy Policy constitutes an acceptance of those changes.

Privacy

Strategy believes that every User should know how Strategy utilizes the information collected from Users.  The Website is not directed at children under 13 years of age, and Strategy does not knowingly collect personally identifiable information from children under 13 years of age online.  Please note that the Website may contain links to other websites.  These linked sites may not be operated or controlled by Strategy.  Strategy is not responsible for the privacy practices of these or any other websites, and you access these websites entirely at your own risk.  Strategy recommends that you review the privacy practices of any other websites that you choose to visit.

Strategy is based, and this website is hosted, in the United States of America.  If User is from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law and User is registering an account on the Website, visiting the Website, purchasing products or services from Strategy or the Website, or otherwise using the Website, please note that any personally identifiable information that User provides to Strategy will be transferred to the United States.  Any such personally identifiable information provided will be processed and stored in the United States by Strategy or a service provider acting on its behalf.  By providing your personally identifiable information, User hereby specifically and expressly consents to such transfer and processing and the uses and disclosures set forth herein.

The Information Strategy Collects

Users browsing the Website without registering an account or affirmatively providing personally identifiable information to Strategy do so anonymously.  Otherwise, Strategy may collect personally identifiable information from Users in a variety of ways.  Personally identifiable information may include, without limitation, (i) contact data (such as a User’s name, mailing and e-mail addresses); (ii) demographic data (such as a User’s zip code, age and income); (iii) financial information collected to process purchases made from Strategy via the Website or otherwise (such as credit card, debit card or other payment information); and (iv) other information requested during the account registration process. If a User communicates with Strategy by e-mail or otherwise interacts with Strategy or uses the features on the Website, any information provided in such communications may be collected by Strategy.  Strategy may also collect information about how Users use the Website, for example, by tracking the number of unique views received by the pages of the Website, or the domains and IP addresses from which Users originate.  While not all of the information that Strategy collects from Users is personally identifiable, it may be associated with personally identifiable information that Users provide Strategy through the Website or otherwise.

Strategy may use “cookies” or “web beacons” to track how Users use the Website.  A cookie is a piece of software that a web server can store on Users’ PCs and use to identify Users should they visit the Website again.  Users may adjust their web browser software if they do not wish to accept cookies.

How Strategy Uses Information

Strategy may use personally identifiable information collected through the Website for the specific purposes for which the information was collected, to process purchases and sales of products or services offered via the Website, to contact Users regarding products and services offered by Strategy, its parent, subsidiary and other related companies and its trusted affiliates, independent contractors and business partners, and otherwise to enhance Users’ experience with Strategy and such affiliates, independent contractors and business partners.  Strategy may also use information collected through the Website for research regarding the effectiveness of the Website and the business planning, marketing, advertising and sales efforts of Strategy, its trusted affiliates, independent contractors and business partners

Disclosure of Information

Strategy may disclose personally identifiable information collected from Users to its parent, subsidiary and other related companies, trusted affiliates, independent contractors and business partners who will use the information for the purposes outlined above, as necessary to provide the services offered by Strategy and to provide the Website itself, and for the specific purposes for which the information was collected.  Strategy may disclose personally identifiable information at the request of law enforcement or governmental agencies or in response to subpoenas, court orders or other legal process, to establish, protect or exercise Strategy’s legal or other rights or to defend against a legal claim or as otherwise required or allowed by law.  Strategy may disclose personally identifiable information in order to protect the rights, property or safety of a User or any other person.  Strategy may disclose personally identifiable information to investigate or prevent a violation by User of any contractual or other relationship with Strategy or the perpetration of any illegal or harmful activity.  Strategy may also disclose aggregate, anonymous data based on information collected from Users to investors and potential partners.  Finally, Strategy may disclose or transfer personally identifiable information collected from Users in connection with or in contemplation of a sale of its assets or business or a merger, consolidation or other reorganization of its business.

Security of Information

Information about Users that is maintained on Strategy’s systems is protected using industry standard security measures.  However, no security measures are perfect or impenetrable, and Strategy cannot guarantee that the information submitted to, maintained on or transmitted from its systems will be completely secure.  Strategy is not responsible for the circumvention of any privacy settings or security measures relating to the Website by any Users or third parties.

Correcting, Updating, Accessing or Removing Personal Information

If a User’s personally identifiable information changes, or if a User no longer desires to receive non-account specific information from Strategy, Strategy will endeavor to provide a way to correct, update and/or remove that User’s previously-provided personal data.  This can be done by emailing a request to Strategy at social@strategynewmedia.com. Additionally, you may request access to the personally identifiable information as collected by Strategy by sending a request to Strategy as set forth above.  Please note that in certain circumstances, Strategy may not be able to completely remove a User’s information from its systems.  For example, Strategy may retain a User’s personal information for legitimate business purposes, if it may be necessary to prevent fraud or future abuse, for account recovery purposes, if required by law or as retained in Strategy’s data backup systems or cached or archived pages.  All retained personally identifiable information will continue to be subject to the terms of the Privacy Policy to which the User has previously agreed.

Contacting Strategy

If you have any questions or comments about this Privacy Policy, you may contact Strategy via e-mail at social@strategynewmedia.com or call our office at 913.440.0672.