Latest revision: June 1, 2019
1.1 General Overview
1.2 Overview of Privacy Practices on the Platform
1.3 Overview of Privacy Practices on the Site
Street Contxt does not collect any Personal Information through the Site, unless you voluntarily choose to provide it to us (e.g., inquiring about or requesting products or services, forwarding an employment inquiry or a copy of your resume). If you do not want your Personal Information collected, please do not submit it to us. If you provide us with contact information, we will maintain the confidentiality of your contact information and use it only for the purposes for which we have collected it, as described below, unless you agree that we may disclose it to other third parties (subject to the exclusions we have listed below).
2. COLLECTION OF INFORMATION
We collect Personal Information and Non-Personal Information through the Site and the Platform as follows:
2.1 Personal Information–Site
We collect Personal Information through the Site that you provide directly to us, which may include name, address, e-mail address, date of birth, employment and education history, survey responses, etc. We may also receive Personal Information from our business partners and other third parties, provided that such third parties confirm to us that their use of the Personal Information conforms to applicable privacy laws.
2.2 Personal Information-Platform
We collect or derive Non-Personal Information in the course of operating the Site and the Platform such as the domain used to access the Site or Platform, and the type and version of browser or operating system being used.
We also collect aggregate information, including demographic statistics of our users (e.g. average age or geographical allocation of our users), number of visitors, what pages users access or visit, average time spent on the Site or the Platform.
With respect to the Platform only, we collect aggregate information from Platform users with respect to their e-mail, including what Platform content is opened, replied to, forwarded, deleted and otherwise engaged with by users.
We may determine the approximate location of your computer or device from your IP address. We collect and use this information to, for example, calculate how many people visit the Site or the Platform from certain geographic regions.
We collect, use and disclose your Personal Information for the following purposes:
•to comply with legal and regulatory requirements.
Persons interested in employment opportunities with Street Contxt may make inquiries through the Site or forward to us their resumes or Personal Information about their interest, skills and experience, and we may use this information to assess and evaluate potential job applicants. We ask that such persons immediately contact us should they wish us to remove this information from our records. All such records are maintained by our Chief of Staff and are kept in a secure location.
We do not sell, rent or otherwise market Personal Information to third parties. We limit the collection, use, retention and disclosure of your Personal Information to that which is reasonably necessary for the purposes identified above.
We will obtain your consent to collect, use or disclose Personal Information except where we are authorized or required by law to do so without consent. For example, we may collect, use or disclose Personal Information without your knowledge or consent where: the information is publicly available, as defined by statute or regulation; we are obtaining legal advice; or we reasonably expect that obtaining consent would compromise an investigation or proceeding. Other exceptions may apply.
Your consent can be express, implied or given through an authorized representative.
Consent may be provided orally, in writing, electronically, through inaction (such as when you do not notify us that you do not wish your personal information collected/used/disclosed for various purposes after you ave received notice of those purposes) or otherwise.
You may withdraw consent at any time, subject to legal, contractual and other restrictions, provided that you give us reasonable notice of your withdrawal of consent. If you notify us that you withdraw consent, we will inform you of the likely consequences of that withdrawal , which may include our inability to provide certain services for which that information is necessary.
5. LIMITS ON COLLECTION USE AND DISCLOSURE OF PERSONAL INFORMATION
We will not collect personal information indiscriminately but will limit collection of personal information to that which is reasonable and necessary. We may also collect personal information as authorized by law.
Your Personal Information will only be used or disclosed for the purposes set out above and as authorized by law.
6. DISCLOSURE OF INFORM ATION; SERVICE PROVIDERS
6.1 Disclosure and Sharing
From time to time we may engage third parties to help us improve our site and to provide various services (e.g. hosting, analytics, CRM, marketing automation, lead capture, email marketing, database management, maintenance, etc.). These third parties may have limited access to Personal Information solely for the purpose of helping us to provide such services. If we require a service provider to deal with your Personal Information, we will take reasonable steps to ensure that the service provider adheres to privacy procedures and will keep your Personal Information confidential. We will not provide more information than is necessary to the service provider and will ensure that the information is returned or destroyed once the purpose for which it was given is filled.
6.2 Important Exceptions
6.3 Service Providers, Hosting and Servers
Our service providers may be located outside of the country in which you are located, and our servers are currently located in the United States of America. You therefore acknowledge that your Personal Information may be processed and stored in foreign jurisdictions and that governments, courts, law enforcement or government or regulatory agencies in the USA, Canada and elsewhere may be able to access or obtain disclosure of your Personal Information under a lawful order or otherwise through the laws of the foreign jurisdiction, irrespective of the safeguards we have put in place for the protection of your Personal Information.
6.4 Third Parties and Sites
Street Contxt uses commercially reasonable physical, technical, managerial, organizational and electronic efforts to ensure that your Personal Information is stored and maintained in a secure environment. We will take reasonable measures, through contractual or other reasonable means, to ensure that a comparable level of personal information protection is implemented by the suppliers and agents who assist in providing services. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our safeguards.
Street Contxt will keep your Personal Information for as long as necessary in connection with the purposes identified in Section 3 or as required by law, which may extend beyond the termination of our relationship with you. You must notify Street Contxt if you no longer want us to retain your information.
We will destroy, erase or make anonymous documents or other records containing Personal Information as soon as it is reasonable to assume that the original purpose is no longer being served by retention of the information and retention is no longer necessary for a legal or business purpose. We will take due care when destroying Personal Information so as to prevent unauthorized access to the information.
9. ACCESS AND ACCURACY
We will make a reasonable effort to ensure that Personal Information we are using or disclosing is accurate and complete. If you demonstrate the inaccuracy or incompleteness of Personal Information, we will amend the information as required. If appropriate, we will send the amended information to third parties to whom the information has been disclosed. If a challenge regarding the accuracy of Personal Information is not resolved to your satisfaction, we will annotate the Personal Information under our control with a note that the correction was requested but not made.
You can access the Personal Information we hold about you by sending us an e-mail at firstname.lastname@example.org. We will advise you in advance of any charges for copies of your file. We may be unable to provide you with some information in certain circumstances, such as if the information also refers to other individuals, is subject to legal privilege, contains confidential information, cannot be retrieved using your name or account number, or as otherwise permitted or restricted by law. We will notify in writing if we refuse an access request, and will document the reasons for refusal and outline further steps that are available to you.
10. AMENDMENT OF THIS POLICY
11. CONTACT US