Our privacy policy is reviewed at regular intervals to ensure it meets the current statutory requirements.
This policy covers the Stratilo website. By using Stratilo websites, interacting with the company and using the Services, you are agreeing to this privacy policy.
For the purposes of this Privacy Policy, Stratilo is a brand owned by CBHQ Media Ltd (a UK registered company (14449712) with the registered office at 6 Company Road, Barnstaple, EX31 3FZ, UK) is the data controller “Stratilo”.
Our cookie policy is detailed here.
General Policy
Customer Data
Content and information submitted by users to the Services is referred to in this policy as “Customer Data”. As further explained below, Customer Data is controlled by the organization or other third party that created the account (the “Customer”). Where Stratilo collects or processes Customer Data, it does so on behalf of the Customer.
If you join an account and create a user profile, you are a “user,” as further described in the Terms of Service. If you are using the Services by invitation of a Customer, whether that Customer is your employer, another organization, or an individual, that Customer determines its own policies regarding storage, access, modification, deletion, sharing, and retention of Customer Data which may apply to your use of the Services. Please check with the Customer about the policies and settings it has in place.
Stratilo employees or contractors only access Customer Data at the request of Customer in order to provide support.
Customer Data is retained until a Hard Delete is requested by the Customer or deemed valid for purging based on the Stratilo data purging policies.
Customer Feedback
As part of providing Services to the Customer, Stratilo collects customer feedback and customer details (name, email, social media, telephone) on behalf of the Customer and serves as a processor of that data for the Customer.
For the purposes of GDPR, we are a data processor of customer feedback on behalf of our clients. If you wish to exercise your data subject rights, you’ll need to contact the client who is the data controller. If you make a request of us in relation to this, we will redirect your request to the client and let you know we have done so.
Billing Information
Billing information is collected in order to fulfil the contract of providing Services to the Customer. The collected billing information includes credit card details, billing address, and billing contact. According to UK law, we are obliged to retain these details for a period of 6 years.
The billing information is processed by Stripe Inc., which process the data in the US. The data is transferred to the US under the Standard Contractual Clauses.
Personal Information
Application
When creating a user account with the Services, you’ll be asked to provide your email and name. These are required in order to set up a unique account and for the transactional emails within the Services. Your email will also be used to help onboard you to the Services and provide you with information about the Services. All of the emails can be opted out of by clicking on the link in the email.
Your email and name is also used with our in-application tracking for the legitimate interest of improving the Service. This tracking is used to identify issues, bugs and help us improve the product. We retain the information until you delete your account.
We also use your email and name for providing the legitimate interest of technical and sales support. We retain this information indefinitely. You can object to the processing of this information by contacting support@stratilo.com.
Website
We use data processors to manage the delivery of resources. Those processors are based in the US, and are covered by Standard Contract Clauses.
Other Information
Pseudo-anonymised usage data
We use analytics services to produce aggregate and pseudo-anonymised usage data on the usage of the application and websites. This data is used to help us resolve issues and improve the website and Services to provide you with the best experience possible. As part of this tracking, we capture details on your device (device type, OS type & version, browser type & version) and location (city, country).
3rd party information
We use data enrichers to enrich the data about you to help us provide better sales and support. The enriched data includes job title, information about your company.
Children’s information
Our Services are not directed to children under 16. Our clients can use our Services to collect customer feedback from children on their products or services which can include children’s personal information. It is up to our clients to ensure they have the appropriate lawful basis for collecting and processing that data.
If you feel that a child’s data is being processed without an appropriate lawful basis, you should contact the company or organization that collected the data in the first place with your concerns. You may contact us and we will redirect your enquiry to the company or organization concerned as required by the GDPR.
Data Security
We care about the trust you place in us in providing us with your company and personal information. While no one can guarantee 100% security, we have in place various methods of securing your data including:
- Encryption-in-rest and in-transit
- Minimization of personal data collected to what is required to deliver the Services and websites
- Usage of firewalls, regular vulnerability scans, and intrusion detection
Your Individual Data Rights
You have various rights over your personal information. Those rights are:
- Being informed about data collected and how it is processed
- Access to the data we have on you
- Being able to correct and update the data we have on you
- Erasure of the data we have on you
- Restricting of the processing of the data we have on you
- Being able to move the data we have on you to another service
- Knowledge of what automated decision-making and/or profiling we do with your personal information
There are circumstances when your data rights can be overridden, such as in the case of billing information which is required to be maintained for 6 years under UK law.
We don’t do any automated decision-making or profiling.
We provide you with information about the data collected and how it is processed via this privacy policy and the privacy notices displayed when we collect the data.
You can access and update (rectify) the Personal Information we have on you by logging into the Service. If you wish to rectify information in other services please email support@stratilo.com.
You can erase the data we have on you by closing and deleting your Service account. This will also anonymize the tracking data we have collected in the process of using the Service.
Your Company Data Rights
You own the copyrights, IP, and other similar rights to the Company Data entered into the Service.
If you wish to close your company account with us you can request to cancel the subscription within the app.
Tracking and Targeted Advertising
We may allow service providers and other third parties to use cookies and other tracking technologies to track your browsing activity over time and across our Site and third party websites. We may also partner with a third party ad network to either display advertising on our Site, to manage our advertising on other sites, or to provide you targeted advertisements based upon your interests on our Site or on third party sites.
We will update our cookie policy of details on advertising/targeting cookies if they are implemented.
You may opt out of having your personal information used for targeted ads by clicking here or if you are in the European Union, here, but you may still receive untargeted ads.
Other companies’ use of their tracking technologies is subject to their own privacy policies. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to do not track or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
In some of our communications, we use tracking means, such as a “click-through URL” linked to content on the Site. We track this data to help us measure the effectiveness of our customer communications.
Disclosure
We will not disclose Customer Data or Personal Information to any government, except as necessary to comply with the law or a valid and binding order of a law enforcement agency (such as a subpoena or court order).
If a law enforcement agency sends us a demand for Customer Data or Personal Information, we will attempt to redirect the law enforcement agency to request that data directly from Customer or Individual. As part of this effort, we may provide Customer or Individual’s basic contact information to the law enforcement agency.
If compelled to disclose Customer Data or Personal Information to a law enforcement agency, then we will give Customer or Individual reasonable Notice of the demand to allow the Customer or Individual to seek a protective order or other appropriate remedy unless we are legally prohibited from doing so.
Change of Ownership or other Business Transaction
In the event that CBHQ Media Ltd enters into a business transition, such as a merger, acquisition, or the sale of all or part of its assets (a “Business Transition”), users’ data (including personally identifiable information and non-personally identifiable information associated with the Stratilo services) will likely be part of the assets transferred.
Supervisory Authority
For the purposes of the GDPR legislation our Supervisory Authority is the UK’s Information Commissioner’s Office. If you wish to lodge a complaint about your data subject rights or the lawfulness of processing, you can do so by contacting the ICO.
Changes to this Privacy Policy
Stratilo may change this Privacy Policy from time to time. Laws, regulations and industry standards evolve, which may make those changes necessary, or we may make changes to our business. We will post the changes to this page and encourage you to review our Privacy Policy to stay informed.
If we make changes that materially alter your privacy rights, Stratilo will provide additional notice, such as via email or through the Services. If you disagree with the changes to this Privacy Policy, you should deactivate your Services account. Contact the Customer if you wish to request the removal of Personal Data under their control.
You understand and agree that if you use the Stratilo services after the effective date of the updated Privacy Policy, Stratilo will consider your use as acceptance of the updated Privacy Policy.
Learn more
If you have any further queries or concerns, please contact us at support@stratilo.com.