Latest Revision: October 5, 2024

This document ("Privacy Policy") explains the manner in which we handle privacy matters pertaining to the activities outlined herein. Kindly read this Privacy Policy thoroughly to grasp our approach towards gathering, utilizing, disclosing, and otherwise managing information linked to individuals ("Personal Data"), and to become acquainted with your entitlements and preferences concerning your Personal Data. When mentioning "Strada Growth," "we," "us," or the "Company," we are referring to Kulesa Enterprises LLC and its pertinent affiliates responsible for the collection, utilization, sharing, or other forms of processing of Personal Data.

Table of Contents:

Responsible EntityProcessing Activities CoveredWhat Personal Data Do We Collect?What Device and Usage Data Do We Process?Purposes for Processing Personal DataWho Do We Share Personal Data With?International Transfer of Personal DataMinorsHow Long Do We Keep Your Personal Data?Your Rights Relating to Your Personal DataOur Approach to Safeguarding Your Personal DataRevisions to This Privacy PolicyContact Us

1. Responsible EntityRegarding your Personal Data, Strada Growth assumes the role of the responsible party as outlined within this Privacy Policy, unless explicitly stated otherwise.This Privacy Policy's scope excludes situations in which we handle Personal Data as a processor or service provider on behalf of our clients. This includes instances where we provide various software products, platforms, and services to our clients, through which our clients (or their associated entities) gather, employ, distribute, or manage Personal Data.To access comprehensive privacy details pertinent to a Strada Growth client or an affiliated entity of a client, utilizing Strada Growth's software products, platforms, and services as the responsible party, please reach out directly to our client. The privacy and data security practices of our clients, distinct from those elaborated in this Privacy Policy, are not within our purview.For further insights, please also consult Section 10.5 presented below.

2. Processing Activities CoveredThis Privacy Policy pertains to the handling of Personal Data gathered by us in the following situations:

When you visit our websites displaying or linking to this Privacy Policy.When you visit our official social media pages.When you receive communications from us, which includes emails, phone calls, texts, or faxes.When you utilize our software products, platforms, and services as an authorized user, in cases where we function as a controller of your Personal Data.When you apply for employment opportunities with us.

It's important to note that our websites, platforms, and services might include links to third-party websites. Should you click on any of these links, please be aware that these websites have their own privacy policies. We hold no responsibility or liability for these policies. It's advisable to review these policies before sharing any data on these websites.

3. What Personal Data Do We Collect?The information we gather from you that is of a personal nature encompasses identifiers, geolocation data, details linked to your profession or employment, visual data, information about your online activities, and conclusions drawn from any of these groupings. We gather this data in the subsequent scenarios:

If you express interest in acquiring more details about our services, request customer support, enroll on our platform, or otherwise register to employ our services, we may necessitate that you furnish us with your contact specifics. These may encompass your name, the name of your school or company, your address, telephone number, email address, username, and password.When you interact with our websites or emails, we automatically compile information about your device and how you use our websites or emails. This information may include Internet Protocol (IP) addresses or other identifying data. These practices involve technologies like cookies, web beacons, or similar mechanisms. (For further details, consult the "What device and usage data do we process?" section below.)In cases where you utilize and engage with our services, we naturally accumulate data regarding your device and the manner in which you utilize our services. This is done through log files and other related technologies, some of which may be classified as Personal Data. (please see the “What device and usage data do we process?” section, below);Should you communicate with us via a phone call initiated by us, the conversation may be recorded.If you willingly provide certain data to our services, such as submitting online forms or participating in surveys, the information you supply in these instances will be collected as part of the corresponding request.

If you provide us, or our service providers, with any Personal Data concerning other individuals, you assert that you possess the necessary authorization to do so. Furthermore, where mandatory, you affirm that you have obtained requisite consent. You acknowledge that this information may be utilized in adherence to this Privacy Policy. If you suspect that your Personal Data has been shared with us in an inappropriate manner or if you wish to exercise your rights related to your Personal Data, please contact us using the details provided in the "Contact us" section below.

4. What Device and Usage Data Do We Process?We employ typical information-acquisition instruments like tools designed to gather usage data, cookies, web beacons, pixels, and akin technologies. These mechanisms autonomously gather data, which might encompass Personal Data, as you browse our websites, use our services, or engage with emails we've dispatched to you.1. Device and Usage DataSimilar to most websites, we automatically gather certain information when individual users visit our sites. This data may encompass identifiers, commercial details, and internet activity data such as IP addresses (or proxy server information), device and application particulars, ID numbers and features, location details, browser types, plugins, integrations, internet service providers, mobile carriers, viewed pages and files, searches, referring websites, apps or ads, operating systems, system configurations, advertising and language preferences, as well as timestamps associated with usage and visit frequency to the sites.We utilize this information to analyze overall trends, enhance and maintain our websites, provide a personalized experience for users, and ensure the security of our sites. Additionally, we automatically collect certain information when you use our software products and services. This includes identifiers, commercial information, and internet activity details such as IP addresses (or proxy servers), mobile device numbers, device and application ID numbers, location data, browser types, internet service providers or mobile carriers, viewed pages and files, interactions on websites and webpages including searches and other actions, operating systems, system configurations, and timestamps associated with usage.This collected information is employed to maintain service security, ensure necessary functionality, improve service performance, enhance customer and user experiences, assess compliance with usage terms, identify opportunities for service development, determine capacity requirements, pinpoint customer prospects, and enhance overall security. It's important to note that some of the device and usage data collected by the services, either alone or combined with other data, could potentially personally identify you. Please be aware that this data primarily serves to distinguish the uniqueness of each logged-in user (rather than specific individuals), except when strictly necessary for security purposes or as required for our service provision to customers.2. Cookies, Web Beacons and Other Tracking TechnologiesIn order to ensure the proper functioning of our websites and services, we occasionally employ small data files known as cookies on your device. A cookie is a compact textual document that a website stores on your computer or mobile device when you visit the platform. This tool empowers the website to recall your activities and preferences (like logins, shopping cart contents, or other preferences) over a stretch of time. As a result, there's no need to repeatedly input them every time you revisit the site or navigate between pages.If you desire, you can limit the utilization of cookies. It's important to note that certain functionalities of our website might not perform as intended if you choose to deactivate cookies.The majority of modern web browsers grant you the ability to modify your cookie settings. These options are usually located in your browser's preferences or settings menu. To comprehend and adjust these settings, you might find the following links beneficial, particularly if you're using commonly employed browsers:

Cookie settings in ChromeCookie settings in FirefoxCookie settings in Internet ExplorerCookie settings in Safari web and iOS

3. Do-Not-Track SignalsDo Not Track (“DNT”) serves as a privacy choice accessible to users within specific web browsers. DNT provides users with the means to notify websites and services that they prefer to abstain from having specific details regarding their website visits accumulated gradually or across various websites and online platforms. We do not acknowledge or react to DNT signals initiated through browsers, given that the internet sector is presently in the process of establishing a precise delineation of DNT's implications, the criteria for DNT compliance, and a unified method for addressing DNT requests.

5. Purposes for Processing Personal DataWe gather and handle your Personal Data for the subsequent intentions:

Provision of Websites, Platforms, and Services: Your Personal Data is processed to fulfill our commitment to you for utilizing our websites, platforms, and services, and to meet the obligations outlined in the applicable terms of use and service.Enhancement of Security for Websites and Services: By monitoring the usage of our websites and services, generating aggregated anonymous data, confirming accounts and activities, scrutinizing suspicious actions, and enforcing our terms and policies, we process your Personal Data to enhance the safety and security of our services, systems, and applications.Management of User Registrations: If you've registered an account with us, your Personal Data is processed to effectively manage your user account in alignment with the relevant terms of service.Handling Contact and User Support Inquiries: In cases where you complete a web form, seek user support, or initiate contact through other means, including phone calls, your Personal Data is processed to fulfill our commitment to you and to address your requests and communications.Advancement and Betterment of Websites and Services: For the purpose of enhancing and refining our websites and services, we may process your Personal Data to analyze trends, monitor interactions, and track usage patterns.Evaluation and Enhancement of User Experience: By utilizing device and usage data, as outlined in Section 4.1 above, and occasionally associated with your Personal Data, we analyze trends and evaluate and enhance the overall user experience to further improve our service offerings.Identification of Customer Opportunities: Processing your Personal Data enables us to evaluate potential customer opportunities, ensuring alignment with customer demands and enhancing user experiences.Recording of Phone Calls: Phone calls may be recorded for training, quality assurance, and administrative reasons. Should the law require, we will secure your prior consent or provide the option to decline call recording.Adherence to Legal Obligations: In compliance with legal responsibilities as dictated by applicable laws, we process your Personal Data when cooperating with public and governmental entities, courts, or regulators. This is carried out to safeguard against misuse, protect personal assets and safety, seek available remedies, and minimize damages. Our actions may encompass responding to legal requests, participating in judicial proceedings, adhering to court orders, and facilitating audits.

It is essential to note that if we are legally obligated or contractually bound to collect and process Personal Data, and you fail to furnish the required information upon request, we might be unable to fulfill our commitment to you.

6. Who Do We Share Personal Data With?The sharing of personal data is carried out in accordance with our practices and policies, as outlined below:

Service Providers: We collaborate with contracted service providers and their subcontractors to deliver our products and services effectively. These service providers support various aspects of our Services using third-party platforms and software tools. They help with functions such as content moderation, crash analytics, email/mobile messaging campaigns, as well as technical and customer support. Some of these external service providers might collect information directly from you, following their respective privacy policies.

Professional Advertisers: On specific occasions, we might share your Personal Data with professional advisers who function as service providers, processors, or joint controllers. This group includes professionals like lawyers, bankers, auditors, and insurers. They provide essential consultancy, banking, legal, insurance, and accounting services.

Third Parties in Corporate Transactions: If our company goes through significant changes such as a merger, reorganization, dissolution, or any fundamental corporate shift, we might share Personal Data as necessary. This could also involve the sale of a website or business unit, or the acquisition of a portion/all of our business, assets, or stock by a third party. We will comply with applicable laws and make reasonable attempts to inform you about any transfer of Personal Data to an unrelated third party.

In addition, we might share anonymous or de-identified usage data with Strada Growth's service providers. This data is intended to assist Strada Growth in conducting analysis and making improvements. Moreover, Strada Growth could share such anonymous or de-identified usage data in an aggregated manner, as part of our regular business operations. This might involve sharing information publicly to showcase trends related to the general usage of our services.For more detailed information about the entities receiving your Personal Data, please get in touch with us through the contact details provided in the "Contact Us" section below. If you have any concerns or inquiries regarding the sharing of your personal data, we are here to address them.7. International Transfer of Personal DataAny information you furnish to us could be accessed, shared, or processed by our United States-based offices and service providers situated in the United States. Such data transfers will only occur when they are necessary for the explicit purpose for which you originally provided the data, such as fulfilling obligations stated in a written contract for goods or services.This might entail the movement of your personal data across national boundaries. It's important to note that data protection standards could vary and might not match the levels mandated in your jurisdiction. We diligently uphold appropriate safeguards, as mandated by relevant laws, for any international transfer of personal data. These measures could include the utilization of standard contractual clauses, where applicable. Should you wish to obtain a copy of these clauses, please don't hesitate to get in touch using the contact information provided in the "Contact Us" section below.8. MinorsOur online platforms are not intended for individuals under 16 years of age. We do not intentionally gather personal data from children below the age of 16. If you become aware that a minor has shared personal information with us, kindly get in touch using the contact information provided in the "Contact Us" section below. If we discover that a child under 16 has submitted personal information, we will take necessary actions to remove such data.9. How Long Do We Keep Your Personal Data?The duration for which we retain your personal data depends on the original purpose for its collection, as outlined in the "Purposes For Processing Personal Data" section above. Additionally, we keep your personal data for as long as necessary to comply with our legal obligations.Our determination of the appropriate retention period considers factors such as the quantity, type, and sensitivity of the personal data being processed, the potential risks associated with unauthorized use or disclosure, the feasibility of achieving the processing objectives through alternative methods, and the requirements imposed by relevant legal regulations (including statutes of limitation).Once the designated retention periods expire, we will proceed to delete your personal data. In cases where technical constraints prevent us from completely erasing the data from our systems, we will implement suitable measures to prevent any further use or access to this data.For more detailed insights into the specific data retention periods applicable to your situation, please don't hesitate to reach out to us using the contact information provided in the "Contact us" section below.10. Your Rights Relating to Your Personal Data1. Your Entitlements

Subject to local data protection regulations, you possess specific entitlements concerning your Personal Data. Depending on the relevant laws, these entitlements may incorporate the right to:Gain access to your Personal Data retained by us.Obtain further insight into our handling of your Personal Data.Remove or obliterate your Personal Data, within the boundaries allowed by pertinent data protection laws.Impose constraints on our handling of your Personal Data, as permitted by law.Express objections to our management of your Personal Data. If we utilize your Personal Data for direct marketing objectives or share it with third parties for their individual direct marketing intentions, you can object at any time without the necessity of providing a particular reason.Choose to exclude specific disclosures of your Personal Data to external parties.Be safeguarded against any prejudiced actions for exercising the aforementioned rights.

2. Additional Declarations for Residents of California, Colorado, or VirginiaAlthough we've detailed privacy rights pertaining to diverse U.S. state jurisdictions below, we acknowledge that you might possess added rights in your specific jurisdiction. Feel free to directly communicate with us at any time to enact your data protection rights. We will process your request according to applicable laws.Certain state regulations mandate us to define the types of Personal Data we reveal for specific "business objectives," like involving service providers in enhancing our services or promoting our products.For our business objectives, we unveil these categories of Personal Data:

IdentifiersPersonal information under California Civil Code section 1798.80Information on internet activitiesVisual dataProfessional or job-related informationEducational dataInferences drawn from the above-mentioned data categoriesSensitive Categories of Personal Data:Account access informationGeolocation information

Numerous jurisdictions afford state inhabitants specific rights, including the right to access distinct types of Personal Data, comprehend how we manage Personal Data, be aware of whether and how we reveal or vend Personal Data, the ability to opt out of Personal Data sales, the right to solicit Personal Data deletion under specific conditions, and the right to not be refused products or services for exercising these rights.California law also permits you to request information regarding the disclosure of your personal information to third parties for their direct marketing aims. We do not disclose your personal information to third parties for such purposes. Over the preceding twelve months, we have not sold personal information.For guidance on exercising your rights, kindly refer to Section 10.4 below.If you are an authorized representative looking to exercise rights on behalf of a state resident, please connect with us using the details in the "Contact Us" segment below and provide the consumer's written authorization that designates you as their representative. We may need to validate your identity and residency before fulfilling your rights request.3. Further Disclosures for Individuals in the EEA and the U.K.Residents in the European Economic Area and the United Kingdom (referred to collectively as "EEA" in this Privacy Policy section), along with other relevant jurisdictions, are entitled to specific rights and disclosures concerning their Personal Data.Our legal grounds for collecting and utilizing your Personal Data include:

Fulfillment of your contract or initiation of a contract and responding to your requests. For example, processing your account registration, delivering services and products, providing customer support.Legitimate business interests. For instance, fraud prevention, safeguarding our network and services, and enhancing our products and services.Adherence to mandatory legal obligations. For instance, maintaining administrative records under mandatory retention periods. We may also gather your Personal Data to document your requests to enact your rights and validate your identity for such requests.Consent that you grant when another legal basis is not applicable. You can retract consent at any point.In specific countries, especially if you reside in the EEA, you might possess the right to:Access your personal details.Rectify inaccurate personal details.Request prompt erasure of your personal details.Request restricted processing of your personal details.Request the transfer of the personal details you provided us.Oppose the processing of your personal details.

To exercise any of these rights, please approach us as specified in the "Contact Us" segment below and stipulate which privacy right(s) you intend to exercise. We may need to confirm your identity to honor your request.Should you encounter any issues with our compliance, you have the option to file a complaint with a supervisory authority in the EEA. However, we would appreciate the chance to address your concerns first and encourage you to initially reach out to us via the "Contact Us" segment below.4. How to Exercise Your EntitlementsTo enact your entitlements, please reach out to us utilizing the information in the "Contact Us" section below. Your personal data may be processed in response to these rights. We will address all legitimate requests in a timely manner and in alignment with applicable laws. If necessary, we will contact you for additional information to honor your request or verify your identity.5. Your Entitlements Regarding Customer DataAs previously stated, we might process Personal Data provided by or on behalf of customers for our software products, platforms, and services. In this regard, unless explicitly stated otherwise in this Privacy Policy or a separate disclosure, we process such Personal Data as a processor on behalf of our customer (and its affiliated entities), who serves as the controller of said data (refer to the "Responsible entity" section above). We are not liable for, nor do we have authority over, the privacy and data security practices of our customers, which may diverge from those outlined in this Privacy Policy. If your data was furnished to us by or on behalf of a Strada Growth customer, and you wish to assert your rights under applicable data protection laws, please directly communicate with them. Given that we can only access a customer's data based on their instructions, if you prefer to approach us directly, kindly provide the name of the Strada Growth customer who submitted your data to us. We will direct your request to the customer and offer assistance as needed, ensuring a reasonable timeframe for response.11. Our Approach to Safeguarding Your Personal DataWe have implemented a range of security measures to ensure the utmost protection for your personal information when you provide, input, or retrieve it. For instance, whenever feasible, we employ encryption for both the transfer and storage of data. Moreover, we exercise stringent control over access to this data through access management and confidentiality commitments.Nevertheless, it's important to recognize that no website, application, or transmission can offer an absolute assurance of security. As a result, while we have put in place and uphold what we consider to be rational protocols to uphold the confidentiality, security, and integrity of personal information collected via our platforms, we cannot guarantee or promise the security of any information you send to us.12. Revisions to This Privacy PolicyOur Privacy Policy is subject to modification at any point. In the event of substantial alterations to this policy, we might inform you through a noticeable display of such revisions or by sending you a notification directly. We recommend that you regularly assess this Privacy Policy to guarantee your familiarity with the most up-to-date rendition.13. Contact usIf you wish to contact us or have any questions about or complaints in relation to this Privacy Policy, please contact us at the following contact details: [email protected]