PRIVACY POLICY

Who we are

Stratforce Group Ltd (“Stratforce”; “we”)
152-160 City Road, London, EC1V 2NX, UK
Company Number 12160449
Our website address is: http://stratforcegroup.com.

This privacy policy is effective as of 26 March, 2020. Please note that this privacy policy will be updated regularly to reflect any changes in the way we handle your personal data (“your personal data”; “your data”) or any changes in applicable regulations.

 

How do we protect your personal data

Stratforce attaches great importance to your right to privacy and the protection of your personal data. We protect your personal data in accordance with applicable laws and our data privacy policies. 

In addition, Stratforce maintains the appropriate technical and organizational measures to protect your personal data against unauthorized or unlawful processing and/or against accidental loss, alteration, disclosure or access, or accidental or unlawful destruction of or damage thereto.

What personal data do we collect and how do we process such data?

We collect personal data of our employees, potential employees, clients, suppliers, business contacts, shareholders and website users. If the data we collect are not listed in this privacy statement, we will give individuals (when required by law) appropriate notice of which other data will be collected and how they will be used.

On our website

Stratforce collects personal data at its websites in two ways: (1) directly (for example, when you provide personal data to sign up for a newsletter or register to comment on a forum website); and (2) indirectly (for example, through our website’s technology).

We may collect and process the following personal data:

  • Personal data that you provide by filling in forms on our website. This includes registering to use the website, subscribing to services, newsletters and alerts, registering for a conference or requesting a white paper or further information. Pages that collect this type of personal data may provide further information as to why your personal data are needed and how it will be used. It is completely up to you whether you want to provide it. Specifically:
    • Comments: When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection. An anonymised string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.
    • Media: If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.
  • If you contact us, we may keep a record of that correspondence.
  • We may ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
  • Our website collects personal data about your computer, including (where available) your IP address, operating system and browser type, for system administration, to filter traffic, to look up user domains and to report on statistics.
  • Details of your visits to our website, the pages you view and resources you access or download, including but not limited to, traffic data, location data, weblogs and other communication data. Please see the Cookies section below for more information.

Our websites may include:

  • Links to and from the sites of our partner networks, advertisers and affiliates.
  • Certain programs (widgets and apps) of third parties. Where this is the case, note that such third parties may process your personal data collected through such programs for their own purposes.
  • Embedded content from other websites such as:
    • Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.
    • These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

We do not accept any responsibility or liability for such third parties’ sites or programs. Please check such third parties’ terms of use and privacy statements before using and providing any information to such third parties’ sites and programs.

Specifically we may also collect the following personal data:

Additional personal details, contact details and identifiers
In addition to the personal details listed above, Stratforce may collect additional personal details for recruitment/employment purposes, such as national identification number, social security number, insurance information, marital/civil partnership status, domestic partners, dependents, emergency contact information, and military history.

Education information and professional or employment-related information
Stratforce may collect information about your education and professional or employment-related information, such as your employment history.

Sensitive data for recruitment purposes
Stratforce may collect certain types of sensitive information when permitted by local law or with your consent, such as health/medical information (including disability status), trade union membership information, religion, race or ethnicity, minority flag, and information on criminal convictions and offences. Stratforce collects this information for specific purposes, such as health/medical information in order to accommodate a disability or illness (subject to legal limits on the timing of collection of such information and other applicable limitations) and to provide benefits; background checks and diversity-related personal information (such as race or ethnicity) in order to comply with legal obligations and internal policies relating to diversity and anti-discrimination.

Documentation required under immigration laws
Stratforce may collect data on citizenship, passport data, and details of residency or work permit (a physical copy and/or an electronic copy).

Financial information for payroll/benefits purposes
Your banking and other relevant financial details we need for payroll/benefits purposes.

Talent management information
Information necessary to complete a background check, details on performance decisions and outcomes, performance feedback and warnings, e-learning/training programs, performance and development reviews (including information you provide when asking for/providing feedback, creating priorities, updating your input in relevant tools), driver’s license and car ownership information, and information used to populate biographies.

Requested recruitment information
Information requested to provide during the recruitment process, to the extent allowed by applicable law.

Recruitment information you submit
Information that you submit in résumés / CVs, letters, writing samples, or other written materials (including photographs).

Information generated by us during recruitment
Information generated by interviewers and recruiters related to you, based on their interactions with you or basic Internet searches where allowed under applicable law.

Recruitment information received from third parties
Information related to you provided by third-party placement firms, recruiters, or job-search websites, where applicable.

Audiovisual information processed during recruitment, work related video conferencing, and remote working situations
Photograph, and images/audio/footage captured on CCTV or other video systems when visiting our office, meeting venues, meeting rooms, or captured in the course of recruitment events, video recruitment interviews, or phone based conference calls or video conference calls.

Recommendations
Recommendations related information provided on your behalf by others.

Immigration
Documentation and related information required under immigration laws.

Employment history and background checks
Information about your prior employment, education, and where applicable and allowed by applicable law, credit history, criminal records or other information revealed during background screenings.

Diversity related information
Information about race / ethnicity / religion / disability / gender and self-identified LGBT status, for purposes of government reporting where required by law, as well as to understand the diversity characteristics of the Stratforce workforce, subject to legal limits.

Assessment information
Information generated by your participation in psychological, technical or behavioural assessments. You will receive more information about the nature of such assessments before your participation in any of them.

Except for certain information that is required by law or by Stratforce policies (including management of an employment relationship with Stratforce), your decision to provide any personal data to us is voluntary. You will therefore not be subject to adverse consequences if you do not wish to provide us with your personal data. However, please note that if you do not provide certain information, we may not be able to accomplish some or all of the purposes outlined in this privacy statement, and you may not be able to use certain tools and systems which require the use of such personal data.

If you provide us with personal data of another person (for instance, a potential employee/referral), you are responsible for ensuring that such person is made aware of the information contained in this privacy statement and that the person has given you his/her consent for sharing the information with Stratforce.

The above-mentioned personal data has been obtained either directly from you (for example, when you provide information to sign up for a newsletter or register to comment on a forum website) or indirectly from certain third parties (for example, through our website’s technology). Such third parties include public authorities, public websites and social media, suppliers and vendors.

 

How do we use personal data that we collect?

We use personal data only where required for specific purposes. Most of these are outlined below. If they are not, you will be notified at the time the data is collected as to the purpose it is being collected for. We also use personal data to provide you with information you request or to process online job applications.

  • Managing our contractual and/or employment relationship with you.
  • Recruitment.
  • Facilitating communication with you (including in case of emergencies, and to provide you with requested information).
  • Operating and managing our business operations.
  • Complying with legal requirements.
  • Monitoring your use of our systems (including monitoring the use of our website and any apps and tools you use).
  • Social listening (Identifying and assessing what is being said about Stratforce and our clients on social media (only publicly accessible content) to understand sentiment, intent, mood and market trends and our stakeholders’ needs and thereby improving our services. We do this through key-word searches and our goal is to gain insights in conversation trends over a specified period and not to identify an individual. To achieve this, we analyze and monitor conversation streams and monitor publicly available opinions, statements or other interactions on social media channels.)
  • Improving the security and functioning of our website, networks and information.
  • Undertaking data analytics, i.e. applying analytics to business operations and data to describe, predict and improve business performance within Stratforce and/or to provide a better user experience.
  • Analyzing your IP and browser information to determine what is most effective about our website, to help us identify ways to improve it and make it more effective.
  • Marketing our products and services to you (unless you objected against such processing).
  • Assess your suitability for employment for the role for which you are applying, as well as future roles that may become available.
  • Manage your job application.
  • Perform administrative functions.
  • Perform data analytics, including analysis of our applicant pool in order to better understand who is applying to positions at Stratforce and how to attract and keep top talent.
  • In some cases, record your online interview for review by additional recruiters and hiring managers.
  • In some cases, record any online, phone, or video conference for review by additional managers.
  • Administration of employee benefits.
  • Perform any legally required reporting and respond to legal process.

We will process your personal data for the purposes mentioned above based on your prior consent, to the extent such consent is mandatory under applicable laws.

To the extent you are asked to click on/check “I accept”, “I agree” or similar buttons/checkboxes/functionalities in relation to a privacy statement, doing so will be considered as providing your consent to process your personal data, only in the countries where such consent is required by mandatory law. In all other countries, such action will be considered as a mere acknowledgement and the legal basis of the processing of your personal data will not be your consent but any other applicable legal basis.

We will not use your personal data for purposes that are incompatible with the purposes of which you have been informed, unless it is required or authorized by law, or it is in your own vital interest (e.g. in case of a medical emergency) to do so.

3rd Parties

We may transfer personal data to our service providers, professional advisors, public and governmental authorities or third parties in connection with a (potential) corporate or commercial transaction. Such third parties may be located in other countries. Before we do so, we shall take the necessary steps to ensure that your personal data will be given adequate protection as required by relevant data privacy laws and Stratforce’s internal policies.

For example, we may disclose personal information to third parties for other business purposes as follows:

  • We share your information with third-party service providers that provide services to us, including billing, payment processing, customer service, email deployment, advertising and marketing, security and performance monitoring, maintaining or servicing accounts, processing or fulfilling orders and transactions, verifying customer information, research, data hosting, auditing, and data processing;
  • To protect and defend the legal rights, safety, and security of Stratforce, our affiliates, users, or the public, including to protect against fraud and malicious activity; and
  • For other business purposes described in this privacy statement or for any other purpose disclosed to you at the time we collect the information or pursuant to your consent.
  • We may also share your information in connection with a substantial corporate transaction, such as the sale of a website, a merger, consolidation, asset sale, initial public offering, or in the unlikely event of a bankruptcy.

Unless you are otherwise notified, any transfers of your personal data from within the European Economic Area (EEA) to third parties outside the EEA will be based on an adequacy decision or are governed by the standard contractual clauses. Any other non-EEA related transfers of your personal data will take place in accordance with the appropriate international data transfer mechanisms and standards.

Sensitive Data

We do not generally seek to collect sensitive data through this site or otherwise. In the limited cases where we do seek to collect such data, we will do this in accordance with data privacy law requirements and/or ask for your consent.

The term “sensitive data” refers to the various categories of personal data identified by data privacy laws as requiring special treatment, including in some circumstances the need to obtain explicit consent from you. These categories include racial or ethnic origin, political opinions, religious, philosophical or other similar beliefs, membership of a trade union, physical or mental health, biometric or genetic data, sexual life or orientation, or criminal convictions and offences (including information about suspected criminal activities).

Data Security

We maintain organizational, physical and technical security arrangements for all the personal data we hold. We have protocols, controls and relevant policies, procedures and guidance to maintain these arrangements taking into account the risks associated with the categories of personal data and the processing we undertake.

How do we use cookies (and other tracking technologies)?

By continuing to use this website you agree that we can place cookies and other similar technology on your device, including mobile device. By continuing to use your mobile device to access this website, you agree that the following information may be collected: your unique device identifier, mobile device IP address, information about your device’s operating system, mobile carrier and your location information (to the extent permissible under applicable law).

Cookies do a lot of different jobs, such as letting you navigate between pages efficiently, remembering your preferences and generally improving the user experience. They can also help to ensure that the advertisements you see online are more relevant to you and your interests.

We use cookies to

We analyze your IP and browser information to determine what is most effective about our website, to help us identify ways to improve it and, eventually, to determine how we can tailor our website to make it a more positive and relevant user experience.

If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you have an account and you log in to this site, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

We may use information collected from our cookies to identify user behaviour and to serve content and offers based on your profile, and for the other purposes described below, to the extent legally permissible in certain jurisdictions.

Some of the cookies we use don’t collect information that identifies a visitor. For example:

  • Performance cookies – These cookies collect information about your visit and use of this website, for instance which pages you visit the most often, and if you get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is anonymous and is only used to improve how this website works.
  • Targeting cookies where you are not a registered user – These cookies are used to (1) deliver advertisements more relevant to you and your interests; (2) limit the number of times you see an advertisement; (3) help measure the effectiveness of the advertising campaign; and (4) understand people’s behavior after they view an advertisement. They are usually placed on behalf of advertising networks with the site operator’s permission. They remember that you have visited a site and quite often they will be linked to site functionality provided by the other organization.

In other cases we can associate cookie information (including information from cookies placed via our advertisements on third party sites) with an identifiable individual. For example:

  • If we send you a targeted email which includes web beacons, cookies or similar technologies we will know whether you open, read, or delete the message.
  • When you click a link in a marketing e-mail you receive from Stratforce, we will also use a cookie to log what pages you view and what content you download from our websites, even if you are not registered at or signed into our site.
  • Combining and analyzing personal data – we may combine data from publicly available sources, and from our different e-mail, website, and personal interactions with you (this includes information collected across our websites and information collected when you sign-up or log on to our sites or connect to our sites using your social media credentials (such as LinkedIn). We combine this data to better assess your experience with Stratforce and to perform the other activities described throughout our privacy policy.

Third party cookies

Some cookies we use are from third party companies, such as Google Analytics, Hubspot, Keap, and Linkedin Analytics to provide us with web analytics and intelligence about our sites. These companies use programming code to collect information about your interaction with our sites, such as the pages you visit, the links you click on and how long you are on our sites. This code is only active while you are on a Stratforce website.

Non-cookie tracking technologies

We may also use web beacons (including conversion pixels) or other technologies for similar purposes as above and we may include these on our sites, in marketing e-mail messages or our newsletter, affiliated websites, to determine whether messages have been opened and links clicked on. Web beacons do not place information on your device, but they may work in conjunction with cookies to monitor website activity. Conversion pixels are small codes located on a particular web page which are triggered when someone visits a page resulting in an increase in the conversion count.

How we use personal data for marketing purposes

Sources of marketing data

The bulk of the personal data we collect and use for marketing purposes relates to individual employees of our clients and other companies with which we have an existing business relationship. We may also obtain contact information from public sources, including content made public at social media websites, to make an initial contact with a relevant individual at a client or other company.

Targeted e-mails

We send commercial e-mail to individuals at our client or other companies with whom we want to develop or maintain a business relationship in accordance with applicable marketing laws. Our targeted e-mail messages typically include web beacons, cookies, and similar technologies that allow us to know whether you open, read, or delete the message, and links you may click. When you click a link in a marketing e-mail you receive from Stratforce, we will also use a cookie to log what pages you view and what content you download from our websites, even if you are not registered at or signed into our site.

Targeted e-mails from Stratforce may include additional data privacy information, as required by applicable laws.

Our Customer Relationship Management (CRM) database

Like most companies, Stratforce uses customer relationship management (CRM) database technology to manage and track our marketing efforts. Our CRM databases include personal data belonging to individuals at our client and other companies with whom we already have a business relationship or want to develop one. The personal data used for these purposes includes relevant business information, such as: contact data, publicly available information (e.g. board membership, published articles, press releases, your public posts on social media sites if relevant for business purpose), your responses to targeted e-mail (including web activity following links from our e-mails), website activity of registered users of our website, and other business information included by Stratforce professionals based on their personal interactions with you. If you wish to be excluded from our CRM databases, please contact us.

Combine and analyze personal data

We may combine data from publicly available sources, and from our different e-mail, website, and personal interactions with you (this includes information collected across our different websites and information collected when you sign-up or log on to our sites or connect to our sites using your social media credentials (such as LinkedIn). We combine this data to better assess your experience with Stratforce and to perform the other activities described throughout our privacy policy.

Sharing personal data with third parties for marketing purposes

In addition to the third parties mentioned above, we may share your personal data with marketing agencies.

Your rights regarding marketing communications

You can exercise your right to prevent marketing communications to you by checking certain boxes on the forms we use to collect your personal data, or by utilizing opt-out mechanisms in e-mails we send to you. You can also exercise the right to discontinue marketing communications to you, or to have your personal data removed from our customer relationship management (CRM) databases at any time by contacting us. In such cases, we will retain minimum personal data to note that you opted out in order to avoid contacting you again.

 

Other possible uses of your personal data

We may process your personal data in connection with any content creation / production purposes.

Some Stratforce entities are in the business of content production. We may process your personal data for these TV, film, marketing, advertising or other related content creation, production and distribution activities.

The personal data that we process for production purposes include images and footage of you and may include your location at the time of filming.

If you are a member of the public, we will diligently attempt to make you aware of our location and filming activities in advance and will give you an opportunity not to enter the location where filming is taking place and participate in them.

If you are a focus of our filming activities (i.e. a contributor or talent such as an interviewee, extra or actor, as opposed to a member of the public) we will also collect and process your name, contact information and any other information provided in any pre-filming questionnaires and/or release forms, such as next of kin details.

We may also collect and process special categories of data such as health or disability information to the extent that this is necessary to enable us to make any necessary adjustments to our filming arrangements to assist or support you.

If you have any questions on data privacy or any aspects of our production activities, please contact us.

 

How long we retain your data

If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognise and approve any follow-up comments automatically instead of holding them in a moderation queue.

For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.

All other personal data will be retained either for as long as is required to undertake the purpose for which it is collected (as per those identified in this privacy policy) or until you inform us you no longer want us to keep it.

 

What rights you have over your data

If you have an account on this site, have left comments, or have been entered into our CRM database, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.

 

Where we send your data

Visitor comments may be checked through an automated spam detection service. Data may be sent to third parties and to internal parties as described in this privacy policy.

 

Contact Us

Please contact our Data Privacy Officer by clicking here if:

  • You have a general question about how Accenture protects your personal data.
  • You wish to exercise your rights in relation to your personal data rights
  • You wish to make a complaint about Stratforce’s use of your data.

 

You can also contact Stratforce as data controller of your personal data via post, clearly marked for the attention of the Data Privacy Officer, at this address: Stratforce Group Ltd, 152-160 City Road, London, EC1V 2NX, UK.