Last Updated: June 11, 2020
I. Information We Collect
This policy applies to personal data provided by: (i) individuals who visit our website and voluntarily provide their information, and (ii) from our customers, vendors, contractors, affiliates, and agents. Our service provides educational materials and various types of consulting to assist our customers with their law, business and graduate school admissions planning and application process. Through providing this service, the personal data we may collect includes:
- First and last names
- Email addresses
- Phone numbers
- State/regional identification
- Links to LinkedIn profiles
- Test scores
- Professional history/Resume/CV
- Username and password for your Stratus account
- Education history, including degrees, dates and locations of attendance, grades, extracurricular accomplishments and educational institution affiliations
- Personal information you submit to us via our customer service methods or through leaving reviews
- Usage, viewing, and technical data, including device identifier and/or IP address, or location information
- Billing information (for subscribers)
- Data submitted by our customers, which we process on their behalf
- Log files, information collected by cookies or similar technologies about actions taken when accessing our platform
A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyze web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
We use traffic log cookies to identify which pages are being used. This helps us analyze data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
II. Purposes of Personal Information Collection and Use
Stratus collects, uses and processes personal data for the purposes of:
- Providing information about our products, services and events
- Providing products, services and support to our customers
- Communicating with customers, business partners, vendors, agents and contractors about business matters
- Analysis of information in order to improve business practices, products and services
- Conducting related tasks for legitimate business purposes
- Other purposes disclosed at the time of collection
- Compliance with legal requirements
Stratus will only process personal data in ways that are compatible with the purpose for which Stratus collected the personal data, or for purposes that the individual or customer providing the personal data authorizes. Before we use your personal data for a purpose that is materially different than the purpose for which it was collected or that you authorized, we will provide you with the opportunity to opt out.
III. Data Transfer to Third Parties
- Subcontractors. We transfer personal data to our subcontractors that perform consulting services and other functions on our behalf. We enter into written agreements with each of our subcontractors requiring them to provide the same level of protection that Stratus provides for its customers, limiting their use of the personal data to the specified services provided on our behalf. We take reasonable and appropriate steps (i) to ensure that subcontractors process personal data in accordance with our company policies and (ii) to stop and remediate any unauthorized processing.
- Third Party Agents or Service Providers. We may transfer personal data to our third-party agents or service providers that perform functions on our behalf. You can access our current list of subprocessors below. We enter into written agreements with those third-party agents and service providers requiring them to provide the level of protection Stratus provides, limiting their use of the personal data to the specified services provided on our behalf. We take reasonable and appropriate steps (i) to ensure that third-party agents and service providers process personal data in accordance with our company policies and (ii) to stop and remediate any unauthorized processing.
- Third Party Data Controllers. In some cases, we may transfer personal data to unaffiliated third-party data controllers. These third parties do not act as agents or service providers and are not performing functions on our behalf. We may transfer your personal data to third party software and services companies whose products interact with Stratus products and services in certain instances where a Stratus customer is also a client of such third party. We will only provide your personal data to third party data controllers where you have not opted-out of such disclosures.
IV. Disclosures for National Security or Law Enforcement
Under certain circumstances, we may be required to disclose your personal data in response to valid requests by public authorities or to meet national security or law enforcement requirements.
Stratus maintains reasonable and appropriate security measures to protect personal data from loss, misuse, unauthorized access, disclosure, alteration, or destruction.
Our website may contain links to enable you to visit other websites of interest easily. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
VI. Access rights
You may have the right to access the personal data that we hold about you and to request that we correct, amend, or delete it if it is inaccurate or processed in violation of applicable law. These access rights may not apply in some cases, including where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of someone other than the individual requesting access. If you would like to request access to, correction, amendment, or deletion of your personal data, you can submit a written request to the email contact information provided below. We may request specific information from you to confirm your identity. If your personal data was provided to us by a Stratus customer, we may facilitate your access to such data by directing you to the customer that provided your data to us.
Stratus would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:
The right to access – You have the right to request Stratus for copies of your personal data. We may charge you a small fee for this service.
The right to rectification – You have the right to request that Stratus correct any information you believe is inaccurate. You also have the right to request Stratus to complete the information you believe is incomplete.
The right to erasure – You have the right to request that Stratus erase your personal data, under certain conditions.
The right to restrict processing – You have the right to request that Stratus restrict the processing of your personal data, under certain conditions.
The right to object to processing – You have the right to object to Stratus’s processing of your personal data, under certain conditions.
The right to data portability – You have the right to request that Stratus transfer the data that we have collected to another organization, or directly to you, under certain conditions.
If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at our email: email@example.com
VII. Staff and Responsibilities
Everyone who works for or with Stratus has some responsibility for ensuring data is collected, stored and handled appropriately. Only employees who need to access or know the personal data in order to accomplish their work have access to such personal data. Our employees that have access to personal data must ensure that it is handled and processed in line with this policy and data protection principles. Stratus shall review and approve any material changes to this policy as necessary.
VIII. Questions and Concerns
Any questions, concerns, or comments regarding this Statement or our use of your personal data, please contact us at firstname.lastname@example.org.
Address: PO Box 108, Waban, MA 02468
We reserve the right to amend this Policy from time to time consistent with applicable law.
List of Subprocessors
- Remedy Point Solutions
- Single Origin
- Stratus Counselors and Staff
- Acuity Scheduling