DATA PRIVACY POLICY

This Data Privacy Policy describes how StratusLIVE collects, uses and discloses information, and what choices you have with respect to the information.

When we refer to “StratusLIVE”, we mean the StratusLIVE entity that acts as the controller or processor of your information, as explained in more detail in the “Identifying the Data Controller and Processor” section below.

Table of Contents:

• Applicability of this Data Privacy Policy
• Information We Collect and Receive
• How We Use Information
• Data Retention
• How We Share and Disclose Information
• Security
• Age Limitations
• Changes to this Data Privacy Policy
• International Data Transfers
• Data Protection Officer
• Identifying the Data Controller and Processor
• Your Rights
• California Privacy Rights
• Data Protection Authority
• Contacting StratusLIVE
• Data Request Policy

Applicability Of This Data Privacy Policy

This Data Privacy Policy applies to StratusLIVE’s online business applications and online portals for constituents, donors, customers (whether not-for-profit, government or for-profit) and partners, including the associated StratusLIVE mobile, browser and desktop applications (collectively, the “Services”), StratusLIVE.com and other StratusLIVE websites (collectively, the “Websites”) and other interactions (StratusLIVE online customer support site) you may have with StratusLIVE. If you do not agree with the terms, do not access or use the Services, Websites or any other aspect of StratusLIVE’s business.

This Data Privacy Policy does not apply to any Third Party applications or software that integrate with the Services through the StratusLIVE platform (“Third Party Services”), or any other Third Party products, services or businesses. In addition, a separate agreement governs delivery, access and use of the Services (the “Subscription Agreement Terms of Use and Conditions”), including the processing of any messages, files or other content submitted through Services accounts (collectively, “Customer Data”). The organization (e.g., your employer or another entity or person) that entered into the Subscription Agreement Terms of Use and Conditions (“Customer”) controls its instance of the Services (its “Instance”) and any associated Customer Data. If you have any questions about specific Instance settings and privacy practices, please contact the Customer whose Instance you use. If you have received an invitation to join an Instance but have not yet created an account, you should request assistance from the Customer that sent the invitation.

Information We Collect And Receive

StratusLIVE may collect and receive Customer Data and other information and data (“Other Information”) in a variety of ways:

• Customer Data. Customers or individuals granted access to an Instance by a Customer (“Authorized Users”) routinely submit Customer Data to StratusLIVE when using the Services.
• Other Information. StratusLIVE also collects, generates and/or receives Other Information:

1. Instance and Account Information. To create or update an Instance account, you or your Customer (e.g., your employer) supply StratusLIVE with an email address, phone number, password, domain and/or similar account details. In addition, Customers that purchase a paid version of the Services provide StratusLIVE (or its payment processors) with billing details such as credit card information, banking information and/or a billing address.
2. Usage Information.

• Services Metadata. When an Authorized User interacts with the Services, metadata is generated that provides additional context about the way Authorized Users work. For example, StratusLIVE logs the Instances, channels, people, features, content and links you view or interact with, the types of files shared, and what Third Party Services are used (if any).
• Log data. As with most websites and technology services delivered over the Internet, our servers automatically collect information when you access or use our Websites or Services and record it in log files. This log data may include the Internet Protocol (IP) address, the address of the web page visited before using the Website or Services, browser type and settings, the date and time the Services were used, information about browser configuration and plugins, language preferences and cookie data.
• Device information. StratusLIVE collects information about devices accessing the Services, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and crash data. Whether we collect some or all of this Other Information often depends on the type of device used and its settings.
• Location information. We receive information from you, your Customer and other third-parties that helps us approximate your location. We may, for example, use a business address submitted by your employer, or an IP address received from your browser or device to determine approximate location. StratusLIVE may also collect location information from devices in accordance with the consent process provided by your device.

3. Cookie Information. StratusLIVE uses cookies and similar technologies in our Websites and Services to help us collect Other Information. The Websites and Services may also include cookies and similar tracking technologies of third parties, which may collect Other Information about you via the Websites and Services and across other websites and online services.

A browser cookie is a small text file that contains pieces of data stored on your device to help websites and mobile apps remember things about you. Other technologies, including Web storage and identifiers associated with your device, may be used for similar purposes. In this policy, we say “cookies” to refer to these technologies.

How We Use Cookies:  StratusLIVE uses cookies to provide the best experience for users of its sites and services. These cookies are required to protect your account data, improve the user experience, keep our services secure, and provide users a more personalized experience. The cookies we use generally fall into one of the following categories:

Please note that third parties (including, for example, partners and nonprofit customers) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

Except for Necessary cookies (see in above table), all cookies will expire when web session has ended.

4. Third Party Services. A Customer can choose to permit or restrict Third Party Services for its Instance. Typically, Third Party Services are software that integrate with our Services, and a Customer can permit its Authorized Users to enable and disable these integrations for its Instance. StratusLIVE may also develop and offer StratusLIVE applications that connect the Services with a Third Party Service. Once enabled, the provider of a Third Party Service may share certain information with StratusLIVE. For example, if a cloud storage application is enabled to permit files to be imported to an Instance, we may receive the user name and email address of Authorized Users, along with additional information that the application has elected to make available to StratusLIVE to facilitate the integration. Authorized Users should check the privacy settings and notices in these Third Party Services to understand what data may be disclosed to StratusLIVE. When a Third Party Service is enabled, StratusLIVE is authorized to connect and access Other Information made available to StratusLIVE in accordance with our agreement with the Third Party Provider and any permission(s) granted by Customer (including, by its Authorized User(s)). Except where required for integration and explicitly supplied in the application, we do not receive or store passwords for Third Party Services when connecting them to the Services.

5. Contact Information. In accordance with the consent process provided by your device, any contact information that an Authorized User chooses to import (such as an address book from a device) is collected when using the Services

6. Third Party Data. StratusLIVE may receive data about organizations, industries, lists of companies that are customers, Website visitors, marketing campaigns and other matters related to our business from parent corporation(s), affiliates and subsidiaries, our partners, or others that we use to make our own information better or more useful. This data may be combined with Other Information we collect and might include aggregate-level data, such as which IP addresses correspond to zip codes or countries. Or it might be more specific: for example, how well an online marketing or email campaign performed.

7. Additional Information Provided to StratusLIVE. We also receive Other Information when submitted to our Websites or in other ways, such as if you participate in a focus group, contest, activity or event, apply for a job, enroll in a certification program or other educational program hosted by StratusLIVE or a vendor, request support, interact with our social media accounts or otherwise communicate with StratusLIVE.

Generally, no one is under a statutory or contractual obligation to provide any Customer Data or Other Information (collectively, “Information”). However, certain Information is collected automatically and, if some Information, such as Instance setup details, is not provided, we may be unable to provide the Services.

How We Use Information

Customer Data will be used by StratusLIVE in accordance with Customer’s instructions, including any applicable terms in the Subscription Agreement Terms of Use and Conditions and Customer’s use of Services functionality, and as required by applicable law. StratusLIVE is a processor of Customer Data and Customer is the controller. Customer may, for example, use the Services to grant and remove access to an Instance, assign roles and configure settings, access, modify, export, share and remove Customer Data and otherwise apply its policies to the Services.

StratusLIVE uses Other Information in furtherance of our legitimate interests in operating our Services, Websites and business. More specifically, StratusLIVE uses Other Information:

• To provide, update, maintain and protect our Services, Websites and business. This includes use of Other Information to support delivery of the Services under a Subscription Agreement Terms of Use and Conditions, prevent or address service errors, security or technical issues, analyze and monitor usage, trends and other activities, or at an Authorized User’s request.
• As required by applicable law, legal process or regulation.
• To communicate with you by responding to your requests, comments and questions. If you contact us, we may use your Other Information to respond.
• To develop and provide search, learning and productivity tools and additional features. StratusLIVE tries to make the Services as useful as possible for specific Instances and Authorized Users. For example, we may improve search functionality by using Other Information to help determine and rank the relevance of content, channels or expertise to an Authorized User, make Services or Third Party Service suggestions based on historical use and predictive models, identify organizational trends and insights, to customize a Services experience, or create new productivity features and products.
• To send emails and other communications. We may send you service, technical and other administrative emails, messages, and other types of communications. We may also contact you to inform you about changes in our Services, our Services offerings, and important Services-related notices, such as security and fraud notices. These communications are considered part of the Services and you may not opt out of them. In addition, we sometimes send emails about new product features, promotional communications or other news about StratusLIVE. These are marketing messages so you can control whether you receive them. If you have additional questions about a message you have received from StratusLIVE please reach out through the contact mechanisms described below.
• For billing, account management and other administrative matters. StratusLIVE may need to contact you for invoicing, account management, and similar reasons and we use account data to administer accounts and keep track of billing and payments.
• To investigate and help prevent security issues and abuse.

If Information is aggregated or de-identified so that it is no longer reasonably associated with an identified or identifiable natural person, StratusLIVE may use it for any business purpose. To the extent Information is associated with an identified or identifiable natural person and is protected as personal data under applicable data protection law, it is referred to in this Data Privacy Policy as “Personal Data.”

Data Retention

StratusLIVE will retain Customer Data in accordance with a Customer’s instructions, including any applicable terms in the Subscription Agreement Terms of Use and Conditions and Customer’s use of Services functionality, and as required by applicable law. Depending on the Services plan, Customer may be able to customize its retention settings and apply those customized settings at the Instance level, channel level or other level. Customer may also apply different settings to messages, files or other types of Customer Data. The deletion of Customer Data and other use of the Services by Customer may result in the deletion and/or de-identification of certain associated Other Information. StratusLIVE may retain Other Information pertaining to you for as long as necessary for the purposes described in this Data Privacy Policy. This may include keeping your Other Information after you have deactivated your account for the period of time needed for StratusLIVE to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes, and enforce our agreements.

How We Share And Disclose Information

This section describes how StratusLIVE may share and disclose Information. Customers determine their own policies and practices for the sharing and disclosure of Information, and StratusLIVE does not control how they or any other third parties choose to share or disclose Information.

• Customer’s Instructions. StratusLIVE will solely share and disclose Customer Data in accordance with a Customer’s instructions, including any applicable terms in the Subscription Agreement Terms of Use and Conditions and Customer’s use of Services functionality, and in compliance with applicable law and legal process.
• Displaying the Services. When an Authorized User submits Other Information, it may be displayed to other Authorized Users in the same or connected Instances. For example, an Authorized User’s email address may be displayed with their Instance profile.
• Collaborating with Others. The Services provide different ways for Authorized Users working in independent Instances to collaborate, such as StratusLIVE messaging or email interoperability. Other Information, such as an Authorized User’s profile Information, may be shared, subject to the policies and practices of the other Instance(s).
• Customer Access. Owners, administrators, Authorized Users, and other Customer representatives and personnel may be able to access, modify, or restrict access to Other Information. This may include, for example, your employer using Service features to export logs of Instance activity or accessing or modifying your profile details.
• Third Party Service Providers and Partners. We may engage third party companies or individuals as service providers or business partners to process Other Information and support our business. These third parties may, for example, provide virtual computing and storage services, or we may share business information to develop strategic partnerships with Third Party Service providers to support our common customers.
• Third Party Services. Customer may enable or permit Authorized Users to enable Third Party Services. We require each Third Party Service to disclose all permissions for information access in the Services, but we do not guarantee that they do so. When enabled, StratusLIVE may share Other Information with Third Party Services. Third Party Services are not owned or controlled by StratusLIVE and third parties that have been granted access to Other Information may have their own policies and practices for its collection, use, and sharing. Please check the permissions, privacy settings, and notices for these Third Party Services or contact the provider for any questions.
• Corporate Affiliates. StratusLIVE may share Other Information with its corporate affiliates, parents and/or subsidiaries.
• During a Change to StratusLIVE’s Business. If StratusLIVE engages in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of StratusLIVE’s assets or stock, financing, public offering of securities, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities, some or all Other Information may be shared or transferred, subject to standard confidentiality arrangements.
• Aggregated or De-identified Data. We may disclose or use aggregated or de-identified Other Information for any purpose. For example, we may share aggregated or de-identified Other Information with prospects or partners for business or research purposes, such as telling a prospective StratusLIVE customer the average amount of time spent within a typical Instance.
• To Comply with Laws. If we receive a request for information, we may disclose Other Information if we reasonably believe disclosure is in accordance with or required by any applicable law, regulation, or legal process. Please see the Data Request Policy to understand how StratusLIVE responds to requests to disclose data from government agencies and other sources.
• To enforce our rights, prevent fraud, and for safety. To protect and defend the rights, property, or safety of StratusLIVE or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or security issues.
• With Consent. StratusLIVE may share Other Information with third parties when we have consent to do so.

Security

StratusLIVE takes security of data very seriously. StratusLIVE works hard to protect Other Information you provide from loss, misuse, and unauthorized access or disclosure. These steps take into account the sensitivity of the Other Information we collect, process and store, and the current state of technology. Given the nature of communications and information processing technology, StratusLIVE cannot guarantee that Information during transmission through the Internet or while stored on our systems or otherwise in our care will be absolutely safe from intrusion by others. When you click a link to a Third Party site, you will be leaving our site and we don’t control or endorse what is on Third Party sites.

Age Limitations

To the extent prohibited by applicable law, StratusLIVE does not allow use of our Services and Websites by anyone younger than 16 years old. If you learn that anyone younger than 16 has unlawfully provided us with personal data, please contact us and we will take steps to delete such information.

Changes To This Data Privacy Policy

StratusLIVE may change this Data 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 services or business. We will post the changes to this page and encourage you to review our Data Privacy Policy to stay informed. If we make changes that materially alter your privacy rights, StratusLIVE will provide additional notice, such as via email or through the Services. If you disagree with the changes to this Data Privacy Policy, you should deactivate your Services account. Contact the Customer if you wish to request the removal of Personal Data under their control.

International Data Transfers

StratusLIVE does not transfer your Personal Data to countries other than the one in which you live.

Data Protection Officer

To communicate with our Data Protection Officer, please email legal@StratusLIVE.com.

Identifying The Data Controller And Processor

Data protection law in certain jurisdictions differentiates between the “controller” and “processor” of information. In general, Customer is the controller of Customer Data. In general, StratusLIVE is the processor of Customer Data and the controller of Other Information. StratusLIVE, LLC, a U.S.-based limited liability company based in Chesapeake, Virginia is the controller of Other Information and a processor of Customer Data relating to Authorized Users who use Instances established for Customers in the U.S. and Canada.

Your Rights

Individuals located in certain countries, including the European Economic Area and the United Kingdom, have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, you may have the right to request access to Information, as well as to seek to update, delete or correct this Information. You can usually do this using the settings and tools provided in your Services account. If you cannot use the settings and tools, contact the Customer who controls your Instance for additional access and assistance. Or, you may contact the StratusLIVE online customer support site (https://Zendesk.stratuslive.com).

To the extent that StratusLIVE’s processing of your Personal Data is subject to the General Data Protection Regulation (or applicable laws covering the processing of Personal Data in the United Kingdom), StratusLIVE relies on its legitimate interests, described above, to process your data. StratusLIVE may also process Other Information that constitutes your Personal Data for direct marketing purposes, and you have a right to object to StratusLIVE’s use of your Personal Data for this purpose at any time.

Your California Privacy Rights

This section provides additional details about the personal information we collect about California consumers and the rights afforded to them under the California Consumer Privacy Act or “CCPA.”

For more details about the personal information, we have collected over the last 12 months, including the categories of sources, please see the “Information We Collect and Receive” section above. We collect this information for the business and commercial purposes described in the How We Use Information  section above. We share this information with the categories of third parties described in the How We Share and Disclose Information  section above. StratusLIVE does not sell (as such term is defined in the CCPA) the personal information we collect (and will not sell it without providing a right to opt out). Please note that we do use Third Party cookies for our advertising purposes as further described in our “Information We Collect and Receive” section above.

Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of personal information we collect (including how we use and disclose this information), to delete their personal information, to opt out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights.

California consumers may make a request pursuant to their rights under the CCPA by contacting us at legal@StratusLIVE.com. We will verify your request using the information associated with your account, including email address. Government identification may be required. Consumers can also designate an authorized agent to exercise these rights on their behalf.

Your Right to Delete Personal Data

You have the right to request the deletion of Your Personal Data, subject to certain exceptions. Once we receive and confirm your request, 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 the processor to:

• 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.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• 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.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which You provided it.

Data Protection Authority

Subject to applicable law, you also have the right to (i) restrict StratusLIVE’s use of Other Information that constitutes your Personal Data and (ii) lodge a complaint with your local data protection authority.

Contacting StratusLIVE

Please also feel free to contact StratusLIVE if you have any questions about this Data Privacy Policy or StratusLIVE’s practices, or if you are seeking to exercise any of your statutory rights. StratusLIVE will respond within a reasonable timeframe. You may contact us at legal@StratusLIVE.com or at our mailing address below:

For Customers and Authorized Users who use Instances established for Customers in the U.S. and Canada:

StratusLIVE, LLC
860 Greenbrier Circle, Suite 504
Chesapeake, VA 23320
United States

Data Request Policy

StratusLIVE receives requests from government agencies, users, and other third parties to disclose data other than in the ordinary operation and provision of the Services. This Data Request Policy outlines StratusLIVE’s policies and procedures for responding to such formal requests for Customer Data. Any capitalized terms used in this Data Request Policy that are not defined will have the meaning set forth in the Subscription Agreement Terms of Use and Conditions. In the event of any inconsistency between the provisions of this Data Request Policy and the Subscription Agreement Terms of Use and Conditions or written agreement with Customer, as the case may be, the Subscription Agreement Terms of Use and Conditions or written agreement will control.

Requests for Customer Data by Individuals

Third parties seeking Customer Data should contact the Customer regarding such requests. The Customer controls the Customer Data and generally gets to decide what to do with all Customer Data.

Requests for Customer Data by Legal Authority

StratusLIVE is committed to the importance of trust and transparency for the benefit of our Customers. Except as expressly permitted by the Contract or as described in this policy, StratusLIVE will only disclose Customer Data in response to valid legal process. StratusLIVE requires a search warrant issued by a court of competent jurisdiction or the equivalent legal process in the applicable jurisdiction to disclose the contents of Customer Data. StratusLIVE does not voluntarily disclose any data to governmental entities unless (a) there is an emergency involving imminent danger of death or serious physical injury to any person, or (b) to prevent harm to the Services or Customers. StratusLIVE also does not voluntarily provide governments with access to any data about users for surveillance purposes.

• All requests by governmental entities or parties involved in litigation seeking content data associated with Customers who are under contract with StratusLIVE, LLC, a U.S.-based limited liability company, should be sent to legal@StratusLIVE.com.
• All requests should include the following information: (a) the requesting party, (b) the relevant criminal or civil matter, and (c) a description of the specific Customer Data being requested, including the relevant Customer’s name and relevant Authorized User’s name (if applicable), StratusLIVE customer instance url, and type of data sought.

Requests should be prepared and served in accordance with applicable law. All requests should be focused on the specific Customer Data sought. All requests will be construed narrowly by StratusLIVE, so please do not submit unnecessarily broad requests. If legally permitted, Customer will be responsible for any costs arising from StratusLIVE’s response to such requests.

Customer Notice

Unless StratusLIVE is prohibited from doing so or there is a clear indication of illegal conduct or risk of harm, StratusLIVE will notify Customer of the request before disclosing any of Customer’s Customer Data so that the Customer may seek legal remedies.  If StratusLIVE is legally prohibited from notifying the Customer prior to disclosure, StratusLIVE will take reasonable steps to notify the Customer of the demand after the nondisclosure requirement expires. In addition, if StratusLIVE receives legal process subject to an indefinite non-disclosure requirement (including a National Security Letter), StratusLIVE will challenge that non-disclosure requirement in court.

Domestication and International Requests

StratusLIVE requires that any individual or entity issuing legal process or legal information requests (e.g., discovery requests, warrants, or subpoenas) ensure that the process or request is properly domesticated. For data stored in the United States, StratusLIVE does not accept legal process or requests directly from law enforcement entities outside the U.S. or Canada. Foreign law enforcement agencies seeking data stored within the U.S. should proceed through a Mutual Legal Assistance Treaty or other diplomatic or legal means to obtain data through a court where StratusLIVE, LLC is located.