Privacy policy

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Privacy policy

Last update: June 15, 2024

Stratton Analytics LLC («Stratton», «we», «us», or «our») has developed this Privacy Policy (the «Policy”) to provide individuals with comprehensive information about our privacy practices and to demonstrate our strong commitment to privacy. This Privacy Policy, together with the Cookie Policy and the International Privacy Policy (collectively, the «Policy»), describes how we collect, use, disclose, transfer, store, retain or otherwise process your personal information in the course of our general business activities, which include the administration of the stratton.ua website and related subdomains (the «Website»), and in email, text and other electronic communications between you and us (collectively, the «Services»).

When we say «you» or «your», we mean the person about whom we collect personal information or data. If the person accessing the website is doing so on behalf of or for the purposes of another person, including a business or other organization, «you» or «your» also means that other person, including the business organization, if applicable.

We generally provide our services to companies, not individuals. However, in the course of providing our services, we may collect personal information from individuals as described in this Policy. This may include personal information we collect about you when you visit our website, your business contact information if we provide our services to a company you work with, or if you are a sole proprietor and use our services.

Please read this Policy carefully. Our policy includes:

General information
What information we collect and disclose and for what purpose
Personal information relating to children
How long we keep your information
Marketing and advertising communications
Links to other sites
Security.
Changes to this Privacy Policy
Contact us

This Policy includes and hereby incorporates by reference the following:

International privacy policy
Cookie policy

1. GENERAL INFORMATION

Our data centers and website are located in Ukraine. If you are visiting this website from outside of Ukraine, please note that by providing us with your information, you are storing or processing it in Ukraine, where our data centers and servers are located and operated. If you are located outside of Ukraine and do not wish to allow the collection and storage of your personal information in Ukraine, you should not use this website and you should refuse the collection of cookies by setting your browser to refuse cookies that you use to visit our website.

This Policy sets out our data processing policies and practices for Ukraine. If you are located outside of Ukraine, please also read our International Privacy Policy. Depending on your country of residence, applicable privacy laws may entitle you to additional disclosures, as well as specific data subject rights with respect to your personal information.

This Policy applies only to our website and services and not to the websites, mobile applications and services of other companies or organizations to which we link. We are not responsible for the privacy practices of other companies or the content of other websites, including any websites that may indicate a special relationship or partnership with us (such as co-branded pages or «in association with» relationships). To ensure that your privacy is protected, always review the privacy policies of companies with whom you do business.

2. WHAT INFORMATION WE COLLECT AND DISCLOSE AND FOR WHAT PURPOSE

In the course of providing our services, we collect various types of personal information from different individuals. The information we collect and the purposes for which it is collected depend on the context of our activities or the service we provide. Therefore, the fact that this Policy lists specific data collection methods does not mean that we have necessarily collected that data from you. Instead, please review the relevant disclosures below to learn about how we may have collected your personal information depending on how you interacted with us.

When you visit our website

The personal information we collect may include identification information, geolocation information, information about your activity on the Internet or other electronic networks, and/or device information. More detailed information can be found below.

Identifying information (the personal information we collect may include your name, email address, address, Internet Protocol (IP) address, device identifiers, cookie identifiers, and other similar identifiers).

Sources of collection — we may collect your personal information from: you directly.

Business purpose of the collection — the purposes of the collection include:

facilitating the use of our website
enforce any applicable terms of service or other applicable agreements or policies
protecting our networks, systems and databases from external threats

Categories of third parties to whom personal information is disclosed — we may disclose your personal information:

our service providers (we may disclose your personal information to our security monitoring service providers, data analytics service providers, database hosting providers and our auditors)
our affiliates
to other entities in the course of corporate transactions
to courts, parties to legal proceedings, regulators, arbitrators, administrative authorities or law enforcement agencies for legal purposes

Business purpose of disclosure — disclosure objectives include

to facilitate your use of and our provision of the website services
website
enforce any applicable terms of service or other applicable agreements or policies
preventing attacks and intrusions into our systems
protecting our networks, systems and databases from external threats
to audit our systems, policies and procedures
as part of a sale, assignment, merger or other transfer of all or part of our organization or assets to others
as required by law or to resolve, investigate or manage actual or suspected legal claims

Will this information be sold or used for targeted advertising?

Yes, we may sell this information to our marketing and analytics service providers for online marketing purposes
we may also share this information with our marketing service providers for the purposes of targeted advertising or cross-contextual behavioral advertising

Geolocation information (the information we collect may include your geolocation).

Sources of collection — we may collect your personal information directly from you

Business purpose of data collection — The purposes of data collection include:

personalize and facilitate your use of our website
measuring, tracking and analyzing trends and usage in connection with your use or performance of our website

Categories of third parties to whom personal information is disclosed — we may disclose your personal information to

our service providers (we may disclose your personal information to our security monitoring service providers, data analytics service providers, database hosting providers and our auditors)
our affiliates
to other entities in the course of corporate transactions
to courts, parties to legal proceedings, regulators, arbitrators, administrative authorities or law enforcement agencies for legal purposes

Business purpose of disclosure — disclosure objectives include:

facilitating your use of and our provision of the website
measuring, tracking and analyzing trends and usage in connection with your use of or performance on our website
protect our networks, systems and databases from external threats
to conduct audits of our systems, policies and procedures
as part of a sale, assignment, merger or other transfer of all or part of our organization or assets to other entities

Will this information be sold or used for targeted advertising?

Yes, we may sell this information to our marketing and analytics service providers for online marketing purposes
we may also share this information with our marketing service providers for the purposes of targeted advertising or cross-contextual behavioral advertising

Information about activities on the Internet or other electronic networks (the information we collect may include time zone settings, authorization logs, pages visited, pages viewed, events and page loads, types and versions of browser plug-ins).

Sources of Collection — We may collect your personal information from:

directly from you

Business purpose of the collection — the purposes of the collection include:

maintaining and improving our website
personalize and facilitate your use of our website
measuring, tracking and analyzing trends and usage in connection with your use or performance of our website
provide marketing and advertising services

Categories of third parties to whom personal information is disclosed — we may disclose your personal information to

our service providers (we may disclose your personal information to our marketing service providers, security monitoring providers, data analytics providers, database hosting providers, and our auditors)
our affiliates
to other entities in the course of corporate transactions
to courts, parties to litigation, regulators, arbitrators, administrative authorities or law enforcement agencies for legal purposes

Business purpose of disclosure — disclosure objectives include:

facilitating your use of and provision of our website measuring, tracking and analyzing trends and usage in connection with your use or performance of our website
participate in marketing and advertising protect our networks, systems and databases from external threats
to audit our systems, policies and procedures
as part of a sale, assignment, merger or other transfer of all or part of our organization or assets to other entities
As required by law or to resolve, investigate or manage actual or suspected legal claims

Will this information be sold or used for targeted advertising?

Yes, we may sell this information to our marketing and analytics service providers for online marketing purposes
we may also share this information with our marketing service providers for the purposes of targeted advertising or cross-contextual behavioral advertising

Device information (the information we collect may include your operating system and platform, device ID, and other technologies on the devices you use to access the website).

Sources of Collection — We may collect your personal information from

directly from you

Business purpose of the collection — the purposes of the collection include:

maintaining and improving our website
personalize and facilitate your use of our website
measuring, tracking and analyzing trends and usage in connection with your use or performance of our website

Categories of third parties to whom personal information is disclosed — we may disclose your personal information to

our service providers (we may disclose your personal information to our security monitoring service providers, data analytics service providers, database hosting providers and our auditors)
our affiliates
to other entities in the course of corporate transactions
to courts, parties to legal proceedings, regulators, arbitrators, administrative authorities or law enforcement agencies for legal purposes

Business purpose of disclosure — disclosure objectives include:

facilitating your use of and provision of our website measuring, tracking and analyzing trends and usage in connection with your use or performance of our website
participate in marketing and advertising protect our networks, systems and databases from external threats
to audit our systems, policies and procedures
as part of a sale, assignment, merger or other transfer of all or part of our organization or assets to other entities
As required by law or to resolve, investigate or manage actual or suspected legal claims

Will this information be sold or used for targeted advertising?

Yes, we may sell this information to our marketing and analytics service providers for online marketing purposes
we may also share this information with our marketing service providers for the purposes of targeted advertising or cross-contextual behavioral advertising

Anonymized and aggregated information

We may process your personal information in an aggregated, anonymized or depersonalized form for any purpose. Aggregated, anonymized or de-identified information is information that can no longer be reasonably identified with a specific individual and is no longer «personal information». We will only store and use this type of information in an anonymized form and will not attempt to re-identify this information except for the purposes of verifying our de-identification process.

3. PERSONAL INFORMATION CONCERNING CHILDREN

Our website is not intended for children under the age of 13. Persons under the age of 13 are not authorized to provide any personal information to or access our website. We do not knowingly collect personal information from children under the age of 13. If you are under 13, do not use or submit any information on or through this site or any of its features, do not use any interactive or public comment features of this site, and do not provide us with any information about yourself, including your name, address, telephone number, email address, or any screen name or username you may use. If we learn that we have collected or received personal information from a child under the age of 13 without verification of parental consent, we will delete that information. If you believe that we may have any information from or about a child under the age of 13, please contact us using the information provided in the “Contact Us” section. Please delete all Stratton-related cookies and restrict the collection of further cookies using the methods outlined in our Cookie Policy.

4. HOW LONG WE KEEP YOUR INFORMATION

We may retain your personal information for the period of time necessary to provide our services and to comply with applicable laws, applicable statutes of limitations and our data retention practices. We may also retain your personal information if we believe it is reasonably necessary to comply with legal process or governmental request, detect or prevent fraud, collect debts, resolve disputes, address concerns, assist in investigations, enforce other applicable agreements or policies, or to take any other action in accordance with applicable law.

5. MARKETING AND ADVERTISING COMMUNICATIONS

You may opt out of receiving marketing and promotional communications from us if such communications are sent by us by following the instructions in those communications. If you choose to opt-out, you will still receive non-promotional communications that are necessary to provide our services.

Transparency and choice

People have different attitudes towards privacy. Our goal is to clearly explain what information we collect and how we use it so that you can make informed choices about the personal information you provide to us. We have put in place mechanisms to give you control over your personal information as follows:

Tracking technologies. You can configure your browser to refuse all or some cookies (including cookies related to our services) or to warn you when a cookie is being sent. To learn how you can manage cookies on our website, please read our Cookie Policy.

Google Ads. View and edit your preferences for the Google ads that are shown to you on Google and across the web, such as which categories you might be interested in, using your ad settings. You can also visit this page to opt out of certain Google advertising services.

Profile Information. Delete any of your personal information associated with any Stratton profile.

Personalized advertising. If you do not want us to use the personal information we collect or that you provide to us to deliver advertising tailored to the preferences of our target audience, you can opt out by selecting «opt out» on our cookie banner. If you have previously accepted cookies on our website and would like to opt out, please clear your cookies and select «opt out» on our cookie banner.

We do not control the collection or use of your information by third parties to serve you ads based on your interests. However, these third parties may provide you with the opportunity to opt-out of the collection or use of your information.

From time to time, interactive areas may appear on our website. You are not required to provide any personal information when using these areas, but you may do so at your own discretion. We strongly advise you not to use your personal information as a username or to post any personal information online, as such information will be publicly available. We cannot guarantee the security of any information you choose to make public in a chat room, forum or bulletin board. Nor can we guarantee that parties who have access to such publicly available information will respect your privacy. Please exercise caution when deciding whether to disclose personal information in these areas.

We use remarketing services to show you advertisements on third-party websites after you have visited the website. We and our service providers use cookies to inform, optimize, and serve ads based on your previous visits to our website. You can opt-out of such marketing by deleting all Stratton-related cookies and limit the future collection of cookies using the methods described in the «How do I disable or delete cookies?» section of our Cookie Policy.

6. LINKS TO OTHER SITES

This website contains links to other websites. Once you follow a link to another site, you are subject to the privacy policy of the new site and its operator. We recommend that you carefully read the privacy policy of each entity to which you provide information.

7. SECURITY

We understand that the security of your personal information is extremely important to you. Accordingly, we make every effort to protect Stratton and the individuals about whom we collect personal information from unauthorized access or unauthorized alteration, disclosure or destruction of the information in our possession. We have implemented measures designed to protect your personal information from accidental loss, as well as from unauthorized access, use, alteration and disclosure.

8. CHANGES TO THIS PRIVACY POLICY

As we provide more services and/or functionality on our website, and as privacy laws and regulations evolve, it may become necessary to revise or update our Privacy Policy. It is our policy to post any changes we make to our Policy, with a notice that the Policy has been updated, on the home page of the website. If we make material changes to the way we process our users’ personal information, we will notify you by means of a notice on the home page of the website. The date of the last revision of the Privacy Policy is indicated at the top of the page. You are responsible for periodically visiting our website and this Privacy Policy to check for any changes. Your continued use of this website after we post changes is deemed to be acceptance of those changes, so please check the Privacy Policy periodically for updates.

9. CONTACT US

To ask questions, inquire or make a request related to data rights, you can contact us at the following addresses:

By sending us an email to info@stratton.com.ua

INTERNATIONAL PRIVACY POLICY

The above General Policy still applies to individuals who reside outside of Ukraine or whose personal data has been collected by Stratton Analytics LLC or its agents («Stratton», «we», «us» or «our») in a country other than Ukraine. However, under various international regulations, these individuals may be entitled to additional disclosures. This International Privacy Policy (the «International Policy») supplements the above general policy, but if the provisions of the general policy and this International Policy cannot be interpreted in a consistent manner, the International Policy will prevail.

Please note that when you visit the website or receive personal information collected by us, your personal information is stored or processed in Ukraine, where our data center is located and our servers are operated. Ukraine may not have privacy laws that are as strict or comprehensive as the privacy laws in your country. Your personal information may also be stored in a multi-tenant cloud environment hosted by our service providers.

Depending on your country of residence, you may have data rights under various laws, regulations and codes, which may include the U.S. Data Protection Act, the Canadian Personal Information Protection and Electronic Documents Act, the European Union General Data Protection Regulation, the UK Data Protection Act, the revised Swiss Federal Data Protection Act and the Federal Data Protection Act Regulation, as well as other laws, regulations and codes.

THIS INTERNATIONAL POLICY APPLIES TO ALL PERSONAL INFORMATION ABOUT YOU THAT WE COLLECT, STORE, USE AND DISCLOSE, REGARDLESS OF HOW WE COLLECT IT (I.E., THROUGH THE WEBSITE, SERVICES OR OTHERWISE).

Our international policy includes:

Collection of personal data
How we use personal information
Grounds on which we process your personal information
Obtaining consent
Third parties
Restrictions
Storage of personal information
Access and rights to your personal information
Response time
Costs
Identification of you in connection with requests
Refusal and unsubscription from the mailing list
Accuracy
Security measures
Contact us

1. COLLECTION OF PERSONAL INFORMATION

You can find specific information about the personal information we collect about you in the «What information we collect and disclose and for what purpose» section of this general policy.

If we are the data controller with respect to the personal information we process, you may exercise your rights as a data subject, including the right to object to the processing of your personal information when it is processed on the basis of legitimate interests as described in this International Policy. However, in providing services to our clients, we primarily collect and process your personal information as a processor or service provider on behalf of our clients. This means that we collect, process and disclose your personal information at the direction of our clients. If we collect your personal information on behalf of another person (i.e., we are not the data controller), we will provide you with information about the data controller if required by law.

2. HOW WE USE PERSONAL INFORMATION

We generally collect your personal information to provide our services and administer our website. You can find specific information about the purposes for which we collect your personal information in the section «What information we collect and disclose and for what purpose».

3. THE BASIS ON WHICH WE PROCESS YOUR PERSONAL INFORMATION

We will only collect and process your personal information to the extent that is reasonably necessary or directly related to one or more of our functions or activities, including administering our website or providing our services to you or our customers. You can find specific information about the purposes for which we collect your personal information in the «What information we collect from you and for what purposes» section of the general policy.

4. OBTAINING CONSENT

Except as otherwise permitted by law or mandatory regulation, we will obtain the necessary consent from you before collecting and, in any event, before using or disclosing your personal information for any purpose other than as set forth in this International Policy. You may provide us with your consent orally, in writing, by electronic means, by your actions, or in any other way that allows you to express your consent.

Generally, we will seek your explicit consent if we collect, use or disclose sensitive personal information about you. However, your refusal to consent to the collection (or withdrawal of previously provided consent) or to provide your personal information when requested may have negative consequences. For example, if you do not consent to our collection of cookies, the website will not remember your preferences. In another example, if you do not provide your personal information when requested, we may not be able to provide you with the requested materials, disclosures or services.

5. THIRD PARTIES

We are responsible for all personal information transferred to other entities for processing on our behalf. As such, we ensure that other entities engaged to provide products or services on our behalf and receiving personal information are required to comply with the intent of this International Policy by providing a comparable level of security protection or, where appropriate, by assuring us (through a confidentiality agreement) that they will not use or disclose personal information for any purpose other than that for which it was shared. You can find detailed information about who we disclose your personal information to in the section «What information we collect and disclose and for what purpose».

6. LIMITATIONS

We collect only the personal information that is necessary to fulfill the purposes identified by you before or at the time of collection, or any other reasonable and legitimate purposes, or as required by law.

We do not use or disclose your personal information except for the purposes for which it was collected or for new purposes to which you have consented, or as required or otherwise permitted by applicable law.

We do not require consent to collect, use or disclose personal information other than as reasonably necessary for such purposes, or to comply with our obligations under applicable law or regulation, as a condition of providing the website or services, or as an administrative or managerial requirement.

7. STORAGE OF PERSONAL INFORMATION

We may retain your personal information, including correspondence or comments, in a file that relates only to you. We will only use, disclose or retain your personal information for as long as is necessary to fulfill the purposes for which it was collected and to comply with legal or business requirements. We will establish minimum and maximum retention periods, as well as procedures for the retention and destruction of your personal information. When personal information is retained to make a decision about you, we will retain such information for the period necessary to comply with our internal data retention policies.

8. ACCESS AND RIGHTS TO YOUR PERSONAL INFORMATION

There are a number of data privacy laws that provide specific rights to data subjects residing in certain jurisdictions. This section of this International Policy describes the rights available to those individuals who are entitled to them. Not all individuals about whom we hold information will have access to these rights, and we may not be able to provide these rights to everyone due to legal and jurisdictional restrictions. We may not be able to honor your request for a number of reasons, including:

you do not reside in a jurisdiction that provides you with the specific right you have requested
the information you are requesting is not covered by a provision that gives you the right to request your personal information
law, regulation or policy prohibits us from complying with your request
we cannot comply with your request without disproportionate burden or expense; or if complying with your request would interfere with the integrity of our services or our ability to operate our business, manage our business and related relationships, or establish, defend or administer legal claims

If any of the above reasons apply, we will let you know in our response to your request. Please note that we may need to collect additional information from you to process your request. We will only use this information in the context of evaluating and responding to your request. If you are unable or refuse to provide the required information, we will not be able to process your request.

Except as otherwise provided by applicable law or regulation, and depending on your country of residence, you may have the following rights with respect to your personal information:

if we process your personal data on the basis of your consent, you have the right to withdraw your consent to further processing at any time
you have the right to request access to your personal data, its rectification or deletion
you have the right to object to the processing of your personal data
You have the right to request that we transfer your personal data to another controller
you have the right to request that we restrict the processing of your personal data

Finally, you have the right to lodge a complaint with us or with the appropriate data protection authority in your country of residence if you believe that our processing of your personal information violates your personal rights, is not in accordance with this International Policy, or violates the privacy principles, laws or regulations of your country of residence.

You may request to exercise these rights using the information provided in the «Contact Us» section. Please be as specific as possible in your request so that we can meet the appropriate processing timeframes.

9. RESPONSE TIME

We will use all reasonable efforts to respond to your written request no later than 30 days after receiving such request. We will notify you in writing if we are unable to comply with your request within this timeframe. Where applicable, you have the right to lodge a complaint with the appropriate supervisory authority as set forth in this International Policy regarding this timeframe.

10. EXPENSES

We expect to be able to respond to your request free of charge as a general rule. However, where permitted by law, we reserve the right to charge a reasonable fee when you request the transcription, reproduction or transmission of such information. We will notify you upon your request of the applicable amount that will be charged. You will then have the opportunity to withdraw your request.

11. IDENTIFYING YOU IN CONNECTION WITH REQUESTS

We may require you to provide us with additional information to identify you before we provide information about the existence, use or disclosure of your personal information in our possession. Any such information you provide to us will be used only for that purpose.

12. REFUSAL AND UNSUBSCRIPTION

You may opt-out of receiving marketing and promotional communications from us if such communications are sent by us by following the instructions in those communications. If you choose to opt-out, you will still receive non-promotional communications that are necessary to maintain the existing business relationship between you and us, if any.

We use remarketing services to show you ads on third-party websites after you have visited our website. We and our service providers use cookies to inform, optimize, and serve ads based on your previous visits to our website. We only engage in remarketing with your consent by accepting a cookie banner when you visit the relevant web pages. You can opt-out of such marketing by deleting all Stratton-related cookies and limit the further collection of cookies using the methods described in the «How can I disable or delete cookies?» section of our Cookie Policy.

13. ACCURACY

We will make every effort to keep your personal information as accurate, complete and up-to-date as possible. We do not update your personal information in our possession unless it is necessary to do so. To help us maintain and ensure that your personal information is accurate and up-to-date, you must promptly inform us of any changes to the data you have provided to us.

You may challenge the accuracy or completeness of the personal information we hold about you at any time, subject to exceptions provided for by applicable law. If you prove that the personal information we have about you is inaccurate or incomplete, we will make the necessary changes to the personal information. If necessary, we will transfer the amended data to the third parties to whom we have transferred your personal information.

14. SECURITY MEASURES

We use security measures appropriate to the sensitivity of personal information to protect it from loss or theft, and from unauthorized access, disclosure, copying, use or modification. These measures include physical measures, such as restricting access to offices and equipment, organizational measures, such as security reviews and the publication of this policy to relevant personnel with instructions to act in accordance with its principles (e.g., restricting access on a need-to-know basis), and technological measures, such as the use of passwords and/or encryption.

15. CONTACT US

To ask questions, receive information or make a request related to data rights, our Privacy Office can be contacted at: info@stratton.com.ua

Date of entry into force: December 29, 2016