Strumn and strumn.com Privacy/Cookie Policy

Last updated March 7, 2022

Your information, whether public or private, will not be sold, exchanged, transferred, or given to any other company for any reason whatsoever, without your consent, other than for the express purpose of delivering the purchased product or service requested.

This Privacy Policy (the “Policy”) has been compiled to better serve Strumn customers who are concerned with how their personally identifiable information (“PII”) is used online. PII is defined information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. Please read our Privacy Policy carefully to obtain a clear understanding of how we collect, use, and protect your PII in conjunction with our content.

What personal information do we collect?

The strumn.com web site, the strumn services, and the strumn application (available from the apple app store or the google play store), and content are, individually and collectively, referred to as the “Strumn Content”). When you register for or access the Strumn Content, you may be asked for your name, e-mail address, mailing address or phone number, and other details that can help us assist you. In addition, when you visit the Strumn Content, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Strumn Content, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Strumn Content, and information about how you interact with the Strumn Content. We refer to this automatically-collected information as “Device Information”.

We collect Device Information using the following technologies:

• “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
• “Log files” track actions occurring on the Strumn Content, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
• “Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse the Strumn Content.

When do we collect information?

We collect information when you register on our site, talk to one of our representatives, or fill out a form. We also collect information when you perform such activities as signing up for our newsletter, responding to a survey or marketing communication, navigating the Strumn Content, or using certain other site features.

How do we use this information?

We may use your PII in the following ways:

• To verify and authenticate you and access to your Strumn Content account.
• To personalize your user experience and to deliver the type of content and product offerings for which you are most interested. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at:http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

We may share your PII with third parties as we work to provide you with services and/or products, as described above. For example, we use Zoho to provide support to clients and prospective clients. We also use Zoho to provide us with certain marketing technology services (you can read more about how Zoho uses your PII here: https://www.zoho.com/privacy.html. We also use Google Analytics to help us understand how our customers use the Strumn Content (you can read more about how Google uses your PII here: https://www.google.com/intl/en/policies/privacy/). You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.

You can opt out of targeted advertising by using the links below:

Facebook: https://www.facebook.com/settings/?tab=ads

Google: https://www.google.com/settings/ads/anonymous

Bing: https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.

• To help you better when responding to your customer service requests.
• To administer a contest, promotion, survey, or other site feature.
• To send periodic emails regarding your account or other products and services.
• To otherwise communicate with you.
• To screen orders for potential risk or fraud.
• To process transactions or provide the services we offer that require the exchange of PII or NPI (non-public personal information).
• We may also share your PII to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.

How do we protect the information we collect?

We protect your PII in the following ways:

• The Strumn Content is scanned on a regular basis for security holes, known vulnerabilities, and malware (software designed to interfere with the normal functions of a computer or computer system). This helps make your visit to our site as safe as possible.
• Your personal information is saved on secure networks and is accessible only to a limited number of persons who have special access rights to such systems, and who are required to keep the information confidential. In addition, all sensitive information you supply via the Strumn Content is encrypted both on disk and via Secure Socket Layer (SSL/TLS) technology in communication.
• We implement a variety of security measures when you enter, submit, or access your information to maintain the safety of your personal information.

Do we use cookies?

Yes. Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your web browser should you permit it. Cookies allows our web services to recognize your browser, capture, and remember certain information. We may use cookies in the following ways:

• To help us verify your authentication or active session on our website, app, and services.
• To help us understand your preferences based on previous or current site activity. This allows us to provide you with improved services.
• To help us compile aggregate data about site traffic and site interaction so we can offer better site experiences and tools.

If you prefer, you can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies via your browser settings. Like most websites, if you turn your cookies off, some of our services may not function properly. Most browsers let you change your cookie settings. Typically, this can be modified in the Options or Preferences section of your browser. If needed, check your browser’s Help menu to find out how to change your cookie settings.

IMPORTANT

If you completely disable cookies in your browser, you will disable some features of our Strumn Content that make your site experience more efficient. In addition, many of our services will not function properly.

When do we disclose information to third parties?

We do not sell, trade, or otherwise transfer your PII to outside parties except when doing so is necessary for us to transact purchases that you have made via the Strumn Content or perform the services we contract to do for you. Such as, we may share information with third parties who help us operate our Strumn Content, conduct business, or offer you services, as long as those parties agree to keep this information confidential. We may also release your information to comply with the law; enforce our site policies; or protect ours or others’ rights, property, or safety.

Non-personal identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.

Third party links

We do not include or offer third party products or services on our Strumn Content.

Google

We, along with third-party vendors such as Google, use first-party cookies (such as the Google Analytics cookies) to gather information about Strumn Content usage and user behavior for statistical purposes and to help us better understand how our customers use our Strumn Content.

You can use the Google Analytics Opt Out browser add-on to opt out of participating in this statistic gathering.

COPPA (Children’s Online Privacy Protection Act)

We do not specifically market to children under 13.

What if there’s a data breach?

In alignment with fair information practices, if a data breach occurs, we will notify you via email, as well as on our app or website, within seven (7) business days of our identifying the breach.

We also agree to the individual redress principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or a government agency to investigate and/or prosecute non-compliance by data processors.

CAN-SPAM Act

The CAN-SPAM Act sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.

We collect your email address so that we can send you information and respond to your inquiries and/or other requests or questions.

To be in accordance with CAN-SPAM, we agree to the following:

• We will not use false or misleading header information, email subjects, or email addresses.
• We will identify a reasonable way advertisements are sent as email.
• We will include the physical address of our business or site headquarters in our emails.
• We will monitor third party email marketing services for compliance, if one is used.
• We will include a link at the bottom of each email that lets you opt out of receiving email from us.
• You can also contact us to unsubscribe from any and all email correspondence.
• We will honor opt-out/unsubscribe requests within five (5) days of our receipt of notice therefor.

Data Retention

When you access or place an order through the Strumn Content, we will maintain your PII for our records unless and until you ask us to delete this information.

Changes

We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.

European Resident

If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below.

Additionally, if you are a European resident, we note that we are processing your information in order to fulfill contracts we might have with you (for example if you make an order through the Site), or otherwise to pursue our legitimate business interests listed above. Additionally, please note that your information will be transferred outside of Europe, including to Canada and the United States.

Your Consent to this Privacy Policy

By using the Strumn Content, you agree to this Privacy Policy. This is our entire and exclusive Privacy Policy, and it supersedes any earlier version. We may change this Privacy Policy by posting a new version of this Privacy Policy in our Strumn Content. When we do change the policy, we will also revise the “Last Updated” date herein. Your continued use of the Strumn Content constitutes your agreement to this Privacy Policy and any updates.

How do I contact you?

Please converse with us at www.strumn.com or in our app.

Email: support@strumn.com

Telephone: (385) 422-2900

Posted mail address: