THE STRATEGY GROUP PRIVACY POLICY
INTRODUCTION
The Strategy Group LLC (“The Strategy Group” (or “we” or “us” or “our”)) cares about your privacy and the security of your information, and we want you to understand how we collect, use and disclose your information. This Privacy Policy discloses our privacy practices with respect to your access to and use of the tsgco.com website, our email newsletters, social media pages, mobile and other applications owned and operated by us, and any other services associated therewith (“TSG”). This Privacy Policy also discloses our privacy practices with respect to your access to and use of our products, such as the products available at the tsgco.com website, which includes our proprietary The Strategy Group software-as-a-service (“SaaS”) platform, and any and all underlying software, including for the avoidance of doubt the portion of our products that you may access when we provide professional services (“TSG Products”). This Privacy Policy governs The Strategy Group’s collection of information from you through your use of TSG Products (together, the “TSG Assets”). It does not apply to any information you may provide to The Strategy Group through other means, e.g., via mail or via telephone. Please read this Privacy Policy carefully so that you understand The Strategy Group’s online privacy practices. By using TSG, you agree that your visit to, download or use of TSG, and any dispute over The Strategy Group’s online privacy practices in connection therewith, is governed by this Privacy Policy and The Strategy Group’s Terms and Conditions By using TSG Products, you agree that any processing of Information (as defined below) in connection with your use of TSG Products, and any dispute over The Strategy Group’s online privacy practices in connection therewith, is governed by this Privacy Policy and the Terms and Conditions. To the extent that the terms of this Privacy Policy or the Terms and Conditions conflict with the terms of any written agreement entered into between you (or your employer, or an affiliate of your employer, as the case may be) and The Strategy Group governing the use of TSG Products, the terms of such written agreement shall prevail. Questions regarding privacy issues should be directed to info@tsgco.com or to The Strategy Group, Attn.: Privacy Counsel, 7669 Stagers Loop, Delaware, OH, 43015.
INFORMATION WE COLLECT
The Strategy Group may collect and store information, personal or otherwise, that you supply either voluntarily or while navigating or using TSG Assets. That information may include personal information (e.g., information that identifies you as an individual or relates to an identifiable individual), technical information (e.g., device identifier, Internet protocol (“IP”) address, browser type, or operating system), and usage information (e.g., how you use, navigate, and respond to TSG Assets and information about content or advertisements you have been shown or have clicked on while using TSG). We may combine these types of information together, and collectively refer to all of this information in this Privacy Policy as “Information.”
Information You Voluntarily Give Us –
TSG: In connection with your use of TSG, The Strategy Group collects identity and contact Information you voluntarily supply when registering for optional subscriptions and setting/adjusting subscription preferences or otherwise interacting with TSG. Examples of this type of Information include the personal information you provide when you subscribe for TSG (e.g., your name, job title, organizational affiliation, and email address). Supplying such Information is entirely voluntary. However, if you choose NOT to supply the requested Information, The Strategy Group may be unable to provide you with services made available to other users of TSG. When you interact with TSG you may share other Information about yourself by, for example, signing up for a webinar, downloading a report, requesting a demo, participating in surveys, or applying for jobs. This type of Information may include your name, email address, phone number, state, demographic information, and resume.
TSG Products: In connection with your use of TSG Products, The Strategy Group collects identity and contact Information that is voluntarily supplied by you (or your employer, or an affiliate of your employer, as the case may be), as our customer (herein referred to as an “Authorized User”). Examples of this type of Information include the personal information you provide when your employer registers you as an Authorized User to access TSG Products (e.g., your name, organizational affiliation, and email address), through a unique username and password, or such other login method we may designate from time to time. Supplying such information is entirely voluntary. However, if you choose NOT to supply the requested Information, The Strategy Group may be unable to provide you with access to our SaaS platform.
Information Collected Automatically –
We also collect certain usage and technical information regarding your navigation through, interaction with, and use of TSG Assets.
As is true of most websites, The Strategy Group may also collect and store information that is generated automatically as you navigate through and use TSG Assets, which may be stored in log files. This information includes cookies, tracking pixels, web beacons, users’ IP addresses, browser type, device information (e.g., family, ID, type, and platform), operating system, session ID, general location data and other information about your use of TSG Assets, including a history of the pages you view. See the “Cookies and Other Technologies” section below for more information on how we may use these technologies to collect this information.
Information Collected from Other Sources –
We may also collect Information about you from other sources, including through interactive applications (such as mobile devices, third-party services, and embedded audio and video players), and in the case of TSG, from co-branded partners and from commercially available sources (such as data aggregators and public databases).
The Strategy Group may authorize the collection of Information by third party advertisers through advertising technologies deployed in ads that may appear on TSG without separate consent. The collection and use of Information by these third party advertisers is governed by the privacy policies of those third parties and is not covered by The Strategy Group’s Privacy Policy. We are not responsible for the privacy practices of those parties. The Strategy Group may also collect your Information if you choose to provide it via forms in our advertisements that appear on third party websites (e.g., to subscribe to TSG).
SENSITIVE PERSONAL INFORMATION
We ask that you not send us, and that you do not disclose to us, any sensitive personal information (e.g., social security numbers, information related to political opinions, racial or ethnic origin, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, trade union membership, sex life or sexual orientation) on or through MC Assets or otherwise. Any requested information that relates to sensitive personal information can be left unanswered by you.
HOW WE USE THE INFORMATION
We use Information for the purposes described in this Privacy Policy, or disclosed at the time of collection, or with your consent, or as specified in the Terms and Conditions or the Terms and Conditions, or the terms of any written agreement entered into between you (or your employer, or an affiliate of your employer, as the case may be) and The Strategy Group governing the use of TSG Products.
To Personalize Your Experience –
The Strategy Group uses the Information it collects from you in a variety of ways, such as customizing features on TSG Assets and advertising that appears on TSG. The Information you supply will help The Strategy Group provide the services requested, offer you enhanced or more personalized features, and tailor TSG and advertisements to your perceived interests.
Please note that all of the Information we collect about you may be combined to help us tailor our communications to you and to develop rich online content and services. We rely upon your consent to process the Information you voluntarily supply.
To Evaluate and Develop New Features, Technologies, and Improvements –
We use your IP address and the information obtained through cookies, web beacons, and similar technologies to deliver TSG Assets’ content to you upon request and to measure traffic within TSG Assets, as well as to track access and use of TSG Assets across devices you use to access TSG Assets. Processing this Information is necessary for our legitimate interests to further develop, study and analyze how TSG Assets are used, to keep TSG Assets updated and relevant by tracking user interests, engagement, trends, and patterns, and to grow our business and inform our marketing strategy.
For Marketing, Promotion, and Advertising Purposes –
The Strategy Group may use the Information you provide to send you advertisements on behalf of third parties through TSG. We may also use third party advertising companies to target and serve some of the advertisements that appear on TSG, and these companies likewise may use their own cookies, web beacons, and similar technologies to collect Information from users of TSG. The Information collected by these companies may include the IP address of your computer.
These companies may use that Information, sometimes in conjunction with similar Information gathered from other websites, to deliver advertisements on TSG, and possibly on other websites (e.g., if the third party advertising company operates an advertising network), tailored to match the perceived interests of consumers.
We do not currently serve advertisements on TSG Products.
To Communicate with You and Provide Updates –
TSG: We may use your Information (a) to contact you for customer service purposes, (b) to inform you of important changes and additions to TSG or the services offered over TSG, (c) to provide you with updates on new data, products, events, invitations to participate in surveys, or messages from partners, and (d) to provide or deliver any other communications that The Strategy Group believes may be of interest to you. Our legal basis for processing this Information is based on your consent as well as for our legitimate interests to keep our records updated, to study how TSG is used, to determine your eligibility to participate in surveys, and to understand your preferences and viewpoints for or on behalf of our partners. If you are eligible to participate in a survey, we may use your Information to provide you with gift card offers/payments or charitable donation opportunities.
TSG Products: We may use your Information to (a) to contact you for customer service purposes, (b) to inform you of important changes and additions to TSG Products or the services offered over TSG Products, and (c) provide or deliver any other communications that The Strategy Group believes may be of interest to you as it relates to your use of TSG Products. Our legal basis for processing this Information is based on your consent, this Privacy Policy and the Terms and Conditions or the terms of any written agreement entered into between you (or your employer, or an affiliate of your employer, as the case may be) and The Strategy Group governing the use of TSG Products.
On occasion, at the request of our customers, The Strategy Group may send Authorized Users of TSG Products our content, such as newsletters or marketing emails. If, as an Authorized User, you wish to no longer receive these communications, please follow the instructions below on unsubscribing.
For Administrative, Compliance, and Legal Tasks –
We may also use your identity and contact Information for (a) auditing purposes, to verify that our internal processes function as intended and comply with legal, regulatory and contractual requirements, (b) fraud and security monitoring purposes, including, for example, to detect and prevent cyberattacks, and (c) sending you administrative notices, offers, and requests for feedback.
This Information may also be used in order to comply with various legal processes and to protect and enforce the rights and interests of The Strategy Group and others. Therefore, we may access, preserve and disclose Information if we are required to do so by law or we have a good faith belief that such action is necessary to (a) comply with the law or with legal process, (b) protect and defend our rights, safety and property, including in connection with the Terms and Conditions, (c) protect against misuse or unauthorized use of MC Assets, (d) protect and defend the rights, safety and property of our users or the public (among other things, this means that if you provide false or misleading information or attempt to pose as someone else, Information about you may be disclosed as part of any investigation into your actions) and (e) cooperate with public and government authorities (which may be outside your country of residence). Processing this Information is necessary for running our business, e.g., complying with legal obligations, provision of administrative and IT services, network security, prevention of fraud, and in the unlikely context of a business reorganization or group restructuring.
SHARING YOUR INFORMATION
The Strategy Group may share your Information with third parties, such as service providers, contractors, and advertisers. For example, The Strategy Group may provide The Strategy Group’s advertisers with Information about you and other visitors collected from TSG that will enable The Strategy Group’s advertisers to better target advertisements that are more relevant to you.
Please also note that as The Strategy Group’s business grows, The Strategy Group may buy or sell various assets. We have a legitimate interest in disclosing or transferring your Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business (including in connection with any bankruptcy or similar proceedings). In the event that The Strategy Group is involved in any of the foregoing transactions, including the transfer of TSG Assets to another company, your Information may be among the transferred assets.
YOUR CONTROLS AND CHOICES
We provide you the ability to exercise certain controls and choices in relation to our collection, use, and sharing of your personal information. In accordance with applicable law, you may have the following rights:
- Right of access – the right to be informed of, and request access to, the personal information we process about you;
- Right to rectification – the right to request that we amend or update your personal information where it is inaccurate or incomplete;
- Right to erasure – the right to request that we delete your personal information;
- Right to restrict – the right to request that we temporarily or permanently stop processing all or some of your personal information;
- Right to object – the right to object to us processing your personal information;
- Right to data portability – the right to request a copy of your personal information in electronic format and the right to transmit that personal information for use in another party’s service; and
- Right not to be subject to automated decision-making – the right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.
You can exercise these controls and choices in various ways, such as by submitting a The Strategy Group Data Request or by contacting us at info@tsgco.com.
If you reside in the State of California in the United States, you have certain rights under the California Consumer Privacy Act (“CCPA”). For more information, please email: info@tsgco.com for The Strategy Group’s California Privacy Notice.
Unsubscribing. You may also manage and modify your subscriptions, and otherwise limit our communications with you, by using one or more subscription management links at the bottom of each newsletter/marketing email sent by The Strategy Group, at any time. If you have been invited to participate in a survey and do not wish to receive such communications from The Strategy Group in the future, you may unsubscribe by following the instructions in the email on how to do so.
Ad Choices. For more information about interest-based advertising on your desktop or mobile browser, and to opt out of this type of advertising by third parties that participate in self-regulatory programs, please visit the Network Advertising Initiative website and/or the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising Website.
If you experience any issues with unsubscribing or managing and/or modifying your preferences as described above, please contact us at info@tsgco.com. Be sure to (a) provide your email address along with the name of the newsletter or subscription from which you would like to unsubscribe and (b) include “Opt Out” or “Change Preferences” in the subject line. By contacting us, you grant The Strategy Group permission to use your email address for purposes of responding to your request. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting the change or deletion.
You may lodge a complaint with a data protection authority for your country or region or where an alleged infringement of applicable data protection law occurs. We would, however, appreciate the chance to address your concerns before you lodge a formal complaint so please contact us in the first instance
STORAGE AND RETENTION OF YOUR INFORMATION
We retain Information for as long as needed or permitted in light of the purpose(s) for which it was obtained, consistent with applicable law. The criteria used to determine our retention periods include (a) the length of time we have an ongoing relationship with you and provide you with access to TSG (e.g., for as long as you continue to use TSG), (b) the length of time specified in the terms of any written agreement entered into between you as an Authorized User (or your employer, or an affiliate of your employer, as the case may be) and The Strategy Group regarding TSG Products, (c) whether there is a legal obligation to which we are subject (e.g., certain laws require us to keep records of your transactions for a certain period of time before we can delete them), or (d) whether retention is advisable in light of our legal position (e.g., applicable statutes of limitations, litigation or regulatory investigations).
Information Security –
We have put in place reasonable controls designed to help safeguard the Information we collect via TSG Assets. However, no security measures are perfect, and we cannot assure you that Information that we collect will never be accessed or used in an unauthorized way.
To further protect your data, we recommend that you use complex passwords for any accounts you have with us where password protection is offered as an option. Please do not use the passwords you use for TSG Assets for other services or share passwords with unauthorized persons. If you have reason to believe that your interaction with us is no longer secure, please immediately contact us at info@tsgco.com.
THIRD PARTY SITES
TSG Assets include links to third party websites whose privacy policies The Strategy Group does not control. Once you leave TSG Assets, any Information you provide at another site will be governed by the privacy policy of the operator of the site you are visiting. The privacy policies of third-party websites will differ from ours.
Please note that if you make a purchase through a third-party site, the privacy policy of the third-party site will govern the use and distribution of your credit card number or other financial information.
COOKIES AND OTHER TECHNOLOGIES
To help make TSG Assets more responsive to the needs of users, The Strategy Group employs a standard feature of browser software, called a “cookie,” to assign each user a unique, random number that resides on a user’s computer. The cookie does not personally identify the user; it merely identifies the computer with which the user accesses TSG Assets. Unless a user voluntarily identifies himself or herself (through subscription or as an Authorized User, for example), neither TSG nor TSG Products will be able to identify the identity of the user, even if a cookie is assigned to a user’s computer.
The personal information a cookie can contain is information supplied by a user. Cookies prevent you from having to re-enter your preferences on certain areas of TSG Assets where you have previously entered preference information. Most web browsers are initially set to accept cookies, but you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Consult the “Help” section of your browser for more information. Please note that by blocking any or all cookies, you may render your computer unable to take advantage of the personalized features enjoyed by other users of TSG Assets.
TSG Assets’ servers automatically collect limited information about your computer’s connection to the Internet, including your IP address. The IP address is a number that lets computers attached to the Internet know where to send data – such as the web pages users view.
The Strategy Group may also use web beacons (also known as “single-pixel GIFs”) to access cookies and to count users who visit TSG Assets or open The Strategy Group’s HTML-formatted email messages, as well as track device identification statistics and other non-identifying information for the purpose of analytics, push notifications, and error reporting. These analytics may be provided to third party vendors.
Do Not Track Notice –
The Strategy Group takes privacy and security very seriously, and strives to put our users first in all aspects of our business. With regard to Do Not Track (“DNT”) signals, The Strategy Group currently does not respond to DNT signals in browsers because a uniform technological standard has not yet been developed. We continue to review new technologies and may adopt a standard once one is created.
CHILDREN’S PRIVACY
This children’s privacy statement explains The Strategy Group’s practices with respect to the online collection and use of personal information from children under the age of thirteen, and provides important information on children’s and parental rights under federal law with respect to such information.
TSG Assets are not directed to children under the age of thirteen and The Strategy Group does NOT knowingly collect personal information from children under the age of thirteen. In fact, The Strategy Group requires subscribers’ occupational information in part to dissuade users under the age of thirteen from subscribing. By subscribing to TSG and/or registering for TSG Products, you represent and warrant that you are thirteen years of age or older. Subscription or registration under false or fraudulent pretenses constitutes unauthorized use and will be terminated.
If The Strategy Group becomes aware that it has inadvertently received personal information from a user under the age of thirteen, The Strategy Group will delete such information from The Strategy Group’s records. Because The Strategy Group does not knowingly collect any personal information from children under the age of thirteen, The Strategy Group also does NOT knowingly distribute any such information to third parties. The Strategy Group does NOT knowingly allow children under the age of thirteen to distribute personal contact information. If you learn that your child has provided us with personal information without your consent, you may alert us at info@tsgco.com.
INTERNATIONAL TRANSFER
Our computer systems are currently based in the United States. This means Information we collect will be processed by us in the United States where data protection and privacy regulations may be subject to different requirements. If you use or visit our websites from outside the United States, you consent to the collection and/or processing of the Information we collect from you in the United States.CHANGES TO THIS POLICY
CHANGES TO THIS POLICY
We evaluate this Privacy Policy periodically in light of changing business practices, technology and legal requirements. As a result, we may update this Privacy Policy from time to time. In the event that The Strategy Group does update this Privacy Policy, the modified Privacy Policy will be accessible on TSG Assets and will be effective as of the date set forth below. We will notify you about material changes to this Privacy Policy by placing a notice on our website. Your continued use of TSG and/or TSG Products after The Strategy Group modifies this Privacy Policy shall constitute your agreement to be bound by the terms hereof as modified. For the avoidance of doubt, nothing contained in this Privacy Policy establishes any license or any other right to use or access TSG Products, and any such license or right shall be exclusively established by, and governed under the terms of, a separate written agreement between you (or your employer, or an affiliate of your employer, as the case may be) and The Strategy Group.
CONTACT INFORMATION
If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your personal information, your rights regarding such use, or wish to exercise any privacy rights available to you under applicable law, please contact us at:
Email: info@tsgco.com
Address:
The Strategy Group
Attn: Privacy Counsel
7669 Stagers Loop, Delaware, OH, 43015
Phone: 740.201.5500
Last Updated: July 2, 2022