Effective Date: May 25, 2018

This Privacy Policy governs our standards and practices with respect to the personally identifiable information (“Personal Information”) and other data that is collected by Strike Exchange, L.L.C. and any of our corporate affiliates (collectively, “Strike Social”, “we”, “us” and/or “our”) in connection with our website, located at https://strikesocial.com (the “Site”) and our mobile applications and related services (together with the Site, the “Service(s)”).

Strike Exchange, L.L.C. is the Data Administrator regarding all the Personal Information collected and processed according to this Privacy Policy. Strike Exchange, L.L.C. may allow other subjects to process Personal Information in accordance to this Privacy Policy and applicable law.

Please note that your privacy is important to us. This policy is adjusted to current US and EU data protection regulations and is intended to help you understand:

  • What information we collect about you
  • How we use information we collect
  • How we share information we collect
  • How we store and secure information we collect
  • How to access and control your information
  • How we transfer information we collect internationally
  • Other important privacy information

By using the Services, you are consenting to our processing of your Personal Information and data as set forth in this Privacy Policy now and as amended, from time to time, by Strike Social. As used herein, “processing” means using or accessing information in any way, including, but not limited to, collecting, storing, deleting, combining, and disclosing information. Our servers are located in the United States. Accordingly, if you reside outside the U.S., by using the Services, you acknowledge and agree that your Personal Information will be transferred to the United States, and processed and stored in the United States. By using the Services, you understand that your information may be transferred to our facilities and those third parties with whom we share it as described in this Privacy Policy. This policy also explains your choices about how we use information about you. Your choices include how you can react to certain uses of information about you and how you can access and update certain information about you. If you do not agree with this policy, please do not access or use the Services or interact with any other aspect of our business.

GENERAL INFORMATION

The Services collect and analyze data that is made available publicly through the Internet in order to measure and manage YouTube channels and videos and create a score (“Strike Score”) for Internet users, including, but not limited to, our registered users. Strike Social presents some of this data on the Site and our mobile application(s); such data may also be available on other websites, and Strike Social may share this data with our third party partners (as described in more detail below). Strike Social does not analyze non-public data from private networks (in other words, networks that are password-protected) unless you authorize us to access such data.

Information Collection

The Personal Information we use is the information you submit to us to gain access to the Services (to log in). The basis to process your Personal Information is your consent, which is expressed during the registration to the Product. We find this consent as a lawful reason for holding and processing any personal data.

The other basis to process your Personal Information may be a legal contract, in which there is expressed consent and which specifies to Personal Information given by the you. We find such legal contract as a lawful reason for holding and processing any Personal Information.

We do not collect or process any Personal Information that belongs to the special category of data, for example, about ethnicity, religion, and/or other sensitive information.

Under the “personal data” minimalization rule, we are trying to minimalize the amount of Personal Information stored in connection with realisation of the Services.

INFORMATION COLLECTED UPON REGISTRATION.

If you desire to have access to certain restricted sections of the Services and/or to have access to or use of certain parts of the Services, you will be required to become a registered user, and to submit certain Personal Information to Strike Social. Personal Information that we may collect in such instances may include your full user name, password, email address, city, time zone, telephone number, and other information that you decide to provide us with, or that you decide to include in your public profile.

Providing additional information beyond what is required at registration is entirely optional, but enables you to better identify yourself and find opportunities in the Strike Social system.

Log Data. When you interact with the Site or use the Services, our servers automatically receive and store certain personally non-identifiable information (“Log Data”). This Log Data is collected passively and may include information such as your IP address, browser type, and/or the domain from which you are visiting, the Site pages you visit, the search terms you use, and any advertisements on which you click. For most users accessing the Internet from an Internet service provider, the IP address will be different every time you log on. We use Log Data to provide you with the Services (for example, to provide push notifications on your mobile device) and pool it with other information to monitor the use of the Services, and for the technical administration of the Services. We do not associate your IP address with any other Personal Information to identify you personally, except in cases where we are asked to comply with a subpoena or other legal demand or where we suspect that there has been a violation of our policies, our Terms of Service, and/or applicable law.

Cookies. Like many websites and services, we also use “cookie” technology to collect additional Site usage data and to improve the Site and Services. A cookie is a small data file that we transfer to your computer’s hard disk. We do not use cookies to collect Personal Information. Also, our cookies only collect information with respect to your visits to and actions on our Site. Strike Social may use both session cookies and persistent cookies to better understand how you interact with the Services, to monitor aggregate usage by our users and web traffic routing on the Site, and to improve the Site and the Services. A session cookie enables certain features of the Site and Services and is deleted from your computer when you disconnect from or leave the Site. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the Site. Persistent cookies can be removed by following your web browser help-file directions. Most Internet browsers automatically accept cookies. You can instruct your browser, by editing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit.

Use of Personal Information

Strike Social uses the Personal Information you provide in a manner that is consistent with this Privacy Policy. We will use your Personal Information in order to provide you with access to and use of the Services, to help us improve the content and functionality of the Services, and to better understand our users. If you contact us by email through the Services, you agree that we may keep a record of your contact information and correspondence, and may use your email address, and any information that you provide to us in your message, to respond to you. In addition, we may use your contact information to market to you, and provide you with information about our products and services and the products and services of our partners that we believe may be of interest to you. If you decide at any time that you no longer wish to receive such marketing information or communications from us, please follow the unsubscribe instructions provided in any of the communications.

In an ongoing effort to better understand and serve the users of the Services, Strike Social also often conducts research on its customer demographics, interests and behavior based on the Personal Information and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and Strike Social may share this aggregate data with its affiliates, agents, and/or business partners. This aggregate information does not identify you personally. Strike Social may also disclose aggregated user statistics in order to describe the Services to current and prospective business partners and to other third parties for other lawful purposes.

Information Sharing and Disclosure

We consider your Personal Information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your Personal Information with certain third parties, without further notice to you, as set forth below.

Service Providers. We engage certain trusted third parties to perform functions and provide services to us, including, without limitation, hosting and maintenance, customer relationship, database storage and management, and direct marketing campaigns. We will share your Personal Information with these third parties, but only to the extent necessary to perform these functions and provide such services.

Partners. From time to time, Strike Social may partner with third parties to improve your Strike Social experience. For example, Strike Social or its partners may offer third party products and services, which may be accessed through the Services. To use certain of the Services, our partners may request that you provide Personal Information to them directly; please be aware that the privacy policy of such partners will govern their use of your Personal Information.

Furthermore, in connection with the operation, promotion, advertising or marketing of the Services, we may provide certain of our partners (e.g., Microsoft; special reward providers; etc.) with Personal Information (e.g., your name or Strike Social username) and other content or information related to you (e.g., your profile picture or Strike Score, etc.), or provide certain of our partners with access to our application programming interfaces (“APIs”) in order to access such information using information (such as Twitter handles) already in their possession.

Please note that each time we provide any of your Personal Information or other information to our partners, we only provide information to these partners that is publicly available or publicly viewable in your Strike Social profile at the time we provide it.

Social Media Services. You can choose to access certain third-party social media Web sites and services through the Services (such as YouTube, Twitter, or Facebook) (“Social Media Services”). When you do so, you are sharing information with those Social Media Services, and the information you share will be governed by their privacy policies and terms of service. You may also be able to modify your privacy settings with these Social Media Services to, for example, control what information the Social Media Services disclose to third parties like Strike Social. When you add Social Media Services accounts to the Services or log into the Services using your Social Media Services account, we will collect relevant information necessary to enable the Services to access that Social Media Services, but you will provide your login information, like your password, directly to such Social Media Services (and not to Strike Social). As part of such integration, the Social Media Services will provide us with access to certain information that you have provided to such Social Media Services, and we will use, store and disclose such information in accordance with this Privacy Policy and, if and to the extent applicable, the policies of such Social Media Services. However, please remember that the manner in which Social Media Services use, store, and disclose your information is governed by the policies of such third parties, and Strike Social shall have no liability or responsibility for the privacy practices or other actions of any Social Media Services that may be enabled within the Services.

Business Transfers. Strike Social may sell, transfer, and/or otherwise share some or all of its assets, including your Personal Information, in connection with a merger, acquisition, reorganization, sale of assets, or in the event of bankruptcy.

Disclosures for Legal Purposes. Strike Social may disclose your Personal Information if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of Strike Social, (iii) act in urgent circumstances to protect the personal safety of users of the Services or the public, and/or (iv) protect against legal liability.

Security

Strike Social is very concerned about the security of your Personal Information. We employ administrative, physical, and electronic measures designed to protect your information from unauthorized access. However, no Internet or email transmission is ever fully secure or error free. We will make any legally-required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted, electronically-stored Personal Information to you via email or a conspicuous posting on this Site in the most-expedient time reasonably possible and without unreasonable delay, consistent with (i) the legitimate needs of law enforcement and/or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.

The Services contain links to other websites. The fact that we link to a website is not an endorsement, authorization, or representation of our affiliation with that third party. We do not exercise control over third-party websites. These other websites may place their own cookies or other files on your computer and collect data or solicit personally identifiable information from you. Other sites follow different rules regarding the use or disclosure of the personally-identifiable information you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit.

YOUR RIGHTS AND CHOICES

Your Choices: You have the right to request a copy of your Personal Information, to object to our use of your Personal Information (including for marketing purposes), to request the deletion or restriction of your Personal Information, or to request your Personal Information in a structured, electronic format. You can exercise some of the choices by logging into the Services and using settings available within the Services or your account with Strike Social. Where the Services are administered for you by an administrator, you may need to contact your administrator to assist with your requests first. For all other requests, you may contact us as provided in the Questions section below and request our help.

Your rights in ths are may be limited in certain cases: for example, if fulfilling your request would reveal information about another person, or if you ask to delete Personal Information which we or your administrator are fully entitled by law or have compelling legitimate interests to keep. If you have unresolved concerns, you may have the right to complain under personal data-protection regulations to a data-protection authority.

Access and update your information: You can access and update your profile information within your profile settings and modify content that contains information about you using the editing tools associated with that content.

Deactivate the account: If you would like to stop using the Services, you or your administrator may be able to deactivate your account with Strike Social. If you wish deactivate your own account, that setting should be available to you in your account settings. Otherwise, please contact your administrator. If you are an administrator and are unable to deactivate an account through your account settings, please contact us. Please be aware that deactivating your account does not delete your information.

Delete your information: You may ask us to remove your Personal Information. Please note, however, that we may need to retain certain information for record-keeping purposes, to complete transactions, and/or to comply with our legal obligations.

Request that we stop using your information: You may ask us to stop processing your Personal Information where you believe we don’t have the right to do so. Where you gave us consent to use your Personal Information for a limited purpose, you can contact us to withdraw that consent, but this will not affect any processing that has already taken place at or prior to that time. You can also opt-out of our use of your Personal Information for purposes other than necessary in order to use the Services. After such requests, we may need reasonalble time to process your request.

Opt out of communications: You may opt out of receiving some promotional communications from us.

Data portability: You may obtain some of your Personal Information in a format you can move from one service provider to another. Depending on the context, this applies to some of your Personal Information, but not to all of your information. Should you request it, we will provide you with an electronic file of your basic account information and the information you create in your profile.

As it was presented above, you may easily update or delete your Personal Information or modify your account preferences for the Services by accessing the account management area of the Services or sending us an email to privacy@strikesocial.com requesting us to update or delete your Personal Information.

Please note that when you delete your account, we may retain your account information thereafter for the purpose of internal account management and fraud prevention activities in a scope that international regulations allow us to. We retain your account information for as long as your account is active and a reasonable period thereafter in case you decide to re-activate the Services. We also retain some of your Personal Information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations, and to continue to develop and improve the Services. Where we retain your Personal Information for improvement and development of the Services, we shall take necessary steps to eliminate Personal Information that directly identifies you, and we only use the Personal Information to uncover collective insights about the use of the Services, not to specifically analyze personal characteristics about you.

Our Policy Towards Children

If a parent or guardian becomes aware that his or her child has provided us with Personal Information without his/her consent, he or she should contact us at privacy@strikesocial.com. We do not knowingly collect Personal Information from children under 16 years of age. If we become aware that a child under 16 has provided us with Personal Information, we will delete such Personal Information from our files. If you are under the age of 16, please do not submit any Personal Information through the Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Information via the Services without their permission.

European Union and Switzerland Directive on Data Protection – Safe Harbor

Strike Social complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. Strike Social adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Strike Social’s certification, please visit https://www.export.gov/safeharbor/.

European Union – GDPR

GDPR stands for the General Data Protection Regulation and is effective as of May 25, 2018. GDPR replaces national privacy and security laws that previously existed within the EU with a single, comprehensive, EU-wide law that governs the use, sharing, transfer, and processing of any personal data that originates from the EU.

Our policy is to respect all laws that apply to our business and this includes GDPR. We also appreciate that our customers have requirements under GDPR that are directly impacted by their use of the Services. We are committed to undertaking reasonable efforts to stay in compliance with GDPR and local requirements of our users in their respective countries.

Mediation

If you are a resident of a country outside of the European Union, you also agree that, in the event any dispute or claim arises out of or relating to this Privacy Policy, you and Strike Social will attempt in good faith to negotiate a written resolution of the matter directly between the parties. You agree that if the matter remains unresolved for forty-five (45) days after notification (via certified mail or personal delivery) that a dispute exists, all parties shall join in mediation services in New York, New York, with a mutually-agreed-upon mediator in an attempt to resolve the dispute. Should you file any arbitration claims, or any administrative or legal actions, without first having attempted to resolve the matter by mediation, then you agree that you will not be entitled to recover attorney’s fees, even if you would otherwise be entitled to them.

Dispute Resolution for Residents of the European Union

If you are a resident of the European Union, in the event that you have any dispute or claim arising out of or relating to this Privacy Policy, you may report your claim connected with the GDPR to the European Union Data Protection Authorities located in your jurisdiction.

Changes to this Privacy Policy.

The Services and our business may change from time to time. As a result, at times, it may be necessary for Strike Social to make changes to this Privacy Policy. This Privacy Policy may be updated or modified by Strike Social from time to time for any reason without prior notice. We will notify you of any material changes to our Privacy Policy by posting the new Privacy Policy on our Site. This Privacy Policy was last updated on the Effective Date indicated above. Your continued use of the Services after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such changed/revised Privacy Policy. You are advised to consult this Privacy Policy regularly for any changes.

Other Terms and Conditions.

Your access to and use of the Services is subject to the Terms and Conditions.

Questions.

If you have any questions or comments about this Privacy Policy or our use of your Personal Information, please contact us at privacy@strikesocial.com, or:

Strike Exchange, L.L.C . One East Wacker, Suite 1950 Chicago, IL 60601