How Suite 900 Group Inc. Values Your Privacy

INTRODUCTION

Thank you considering Suite 900 Group, Inc. ("company", "we", "us", or "our") services. We are committed to protecting your personal information and your right to privacy.

When you visit www.suite900.com, www.9nerdz.com, and www.sparrowva.com ("Site" or "Websites") and use our services, you trust us with your personal information. We take your privacy very seriously. In this privacy notice, we describe how Suite 900 Group, Inc. handles personal data and our GDPR compliance and policies. We explain to you in the clearest way possible what information we collect, how we use it, and what rights you have in relation to it.

This privacy policy applies to all information collected through our Websites and/or any related services, sales, or marketing. Please read this privacy policy carefully as it will help you make informed decisions about sharing your personal information with us. If there are any terms in this privacy policy that you do not agree with, please discontinue use of our Website and our services.

WHAT INFORMATION DO WE COLLECT?

Information automatically collected:

In Short: Some information, such as IP address and/or browser and device characteristics, is collected automatically when you visit our Websites.

We automatically collect certain information when you visit, use, or navigate the Sites. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Site, and other technical information. This information is primarily needed to maintain the security and operation of our Sites, and for our internal analytics and reporting purposes.

Like many businesses, we collect information through cookies and similar technologies. You can learn more about this in our Cookies Policy.

Personal information you disclose to us:

In Short: We collect personal information that you provide to us such as name, address, contact details, when you contact us, and other personal information when you enter a service agreement with us.

We collect personal information that you voluntarily provide to us when registering for our services, expressing an interest in obtaining information about us or our products and services, when participating in activities on the Sites (such as posting messages in our online blog or entering contests), or otherwise contacting us.

The personal information that we collect depends on the context of your interactions with us and the Sites, the choices you make, and the services and features you use. The personal information we collect can include the following:

Name and Contact Data. We collect your first and last name, company name, email address, postal address, phone number, and other similar contact data.

Credentials. We collect passwords and similar security information used for authentication and account access for the performance of our services for you.

Social Media Login Data. We may provide you with the option to register on our Sites using social media account details, like your Facebook, Twitter, or other social media account. In such cases, if you choose to register in this way, we will collect the information described in the section called "Social Logins" below.

All personal information that you provide to us should be complete and accurate, and you must notify us of any changes to such personal information.

Information collected from other sources:

In Short: We may collect limited data from public databases, marketing partners, social media platforms, and other third-party sources.

We may obtain information about you from other sources, such as public databases, joint marketing partners, social media advertising platforms (such as Facebook), as well as from other third parties. Examples of the information we receive from other sources include: social media profile information (your name, gender, birthday, email, current city, state and country, user identification numbers for your contacts, profile picture URL and any other information that you choose to make public); and marketing leads and search results and links, including paid listings (such as sponsored links).

DO WE COLLECT PAYMENT INFORMATION?

In Short: Suite 900 Group, Inc. does not collect payment information

We neither store nor collect data such as credit card numbers or credit card expiration dates in relation to payment of invoices. All credit card information is collected and processed by third-party PCI and GDPR compliant payment processors. Your credit card information is passed directly to them, meaning your card details never hit our servers.

For our member's security and convenience, we use the following payment processors:

Stripe, a PCI-certified service used for web payment processing. Stripe data points collected are outlined in their privacy policy: https://stripe.com/us/privacy/

PayPal his a worldwide online payment solution that allows individuals and businesses to transfer funds electronically. You do not need to have an account with PayPal to avail the PayPal payment option. PayPal data points collected are outlined in their privacy policy: https://www.paypal.com/us/webapps/mpp/ua/privacy-full

HOW DO WE USE YOUR INFORMATION?

In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.

We use personal information collected through our Websites for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests ("business"), in order to enter into or in the performance of a contract with you ("contractual"), with your consent ("consent"), and/or in compliance with our legal obligations ("legal "). We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:

To deliver administrative information to you (business, legal, and/or contractual reasons). We may use your personal information to send you product, service and new feature information, and/or information about changes to our terms, conditions, and policies; or to follow up with your chat, email, or phone correspondence with us.
To fulfill and manage our service agreement (business, legal, and/or contractual reasons). We may use your information to fulfill and manage your orders and instructions made through the Sites or otherwise through correspondence with us.
To request feedback (business purposes). We may use your information to request feedback and to contact you about your use of our Sites.
To post testimonials (business purposes). We post testimonials on our Sites that may contain personal information limited to your name (first initial of your first name and complete last name, or vice versa), title, company name, and/or website address. Use of our standard services (i.e., services that are not white labeled) is deemed an implied consent to use this information and relevant statements regarding our services. If you wish to update or delete your testimonial, please contact us.
For analytical purposes (business purposes). We may use your information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our campaigns, and to evaluate and improve our Websites, products, services, marketing, and your experience.
To facilitate account creation and logon process (with your consent). If you choose to link an account you create with us to a third-party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process. See the section below titled "Social Logins" for further information.
To administer prize draws (business purposes and/or with your consent). We may use your information to administer prize draws and competitions in which you elect to participate.
To send you marketing communications (business purposes and/or with your consent). We may use the personal information you send to us for our marketing purposes. We do not exceed two targeted promotional emails in any given month, and you may choose to opt-out of our marketing emails at any time. (See the section titled Your Privacy Rights below.)
To deliver targeted content to you (business purposes and/or with your consent). We may use your information to develop and display content and advertising (and work with third parties who do so) tailored to your interests. For more information, see our Cookies Policy.
To respond to legal inquiries and prevent harm (legal reasons). The receipt of a subpoena or other legal request may require us to inspect the data we hold to determine how to respond.
To protect our Websites (business, legal, and/or contractual reasons). We may use your information as part of our efforts to keep our Websites safe and secure (for example, for fraud monitoring and prevention).
To enforce our terms, conditions and policies (business, legal and/or contractual reasons).

WILL YOUR INFORMATION BE SHARED WITH ANYONE?

In Short: We only share information with your consent, to comply with laws, to protect your rights, or to fulfill business obligations to you.

We only share and disclose your information in the following situations:

Compliance with laws. We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or subpoena, or in response to public authority or law enforcement requirement.
Vital interests and legal rights. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person, illegal activities, or as evidence in litigation in which we are involved.
Vendors, consultants, and other third-party service providers. We may share your data with third-party vendors, service providers, contractors, or agents who perform services or functions for us or on our behalf which are offered as part of the Suite 900 Group, Inc's products and services and require access to such information to do that work. Examples include payment processing, survey solutions, data analysis, email delivery, data center hosting services, customer service, and marketing efforts. These providers all certify compliance with the EU-U.S. and Swiss-U.S. Privacy Shield Framework, are bound by confidentiality agreements, and are restricted from direct access to your information; but, if necessary, they may be granted access to your personal information only to the extent necessary to permit them to perform their contracted services and are restricted from using the information for other purposes. Such selected third parties may use tracking technology on the Sites, which will enable them to collect data about how you interact with our Websites. This information is used to analyze and track data, determine the popularity of certain content, and better understand online activity.
Unless otherwise described in this privacy policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.
Business transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
Third-party advertisers. We may use reputable third-party companies to serve content when you visit some areas of our Websites, for example Google AdSense. These companies may use information about your visits to our Websites and other websites that are contained in cookies and other tracking technologies in order to provide marketing content about products and services of interest to you. See our Cookies Policy for further information.
Affiliates. We may share your information with our affiliates, which include our parent company, subsidiaries, joint venture partners, or other entities that we control or that are under common control with us, and therefore subject to compliance with this privacy policy.
Other users. When you share personal information (for example, by posting comments, contributions, or other content to the Sites) or otherwise interact with public areas of the Websites, such personal information may be viewed by all users and may be publicly distributed outside the Site in perpetuity.

DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is described in our Cookies Policy.

HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: If you choose to register or log in to our Websites using a social media account, we may have access to certain information about you.

Our Websites may offer you the ability to register and log in using your third-party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, profile picture, as well as other information you choose to make public.

We will use the information we receive only for the purposes that are described in this privacy policy or that are otherwise made clear to you on our Websites. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy policy to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.

IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

In Short: We may transfer, store, and process your information in locations other than your own.

When you access our Websites, your information may be transferred to, stored, and processed at our Fremont, California server facilities and our Cebu, Philippines headquarters. We take all necessary measures to protect your personal information in accordance with this privacy policy and applicable law.

For additional information, please review "How Do We Keep Your Information Safe" below.

WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?

In Short: We are not responsible for the safety of any information that you share with third-party providers who advertise on, but are not affiliated with, our Websites.

We cannot guarantee the safety and privacy of data you provide to any unaffiliated third-party advertisers on our Website that link to other websites. We are not responsible for the content privacy and security practices and policies of any third parties, including other websites, services, or applications that may be linked to or from our Sites. Any data collected by these third parties is not covered by this privacy policy. You should review the policies of such third parties and contact them directly to respond to your questions.

HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is otherwise required or permitted by law. With the exception of transactional documentation (such as invoices and receipts) retained for up to three (3) years per U.S. tax law recommendations, no purpose in this policy will require us to retain your personal information for longer than two (2) years past the expiration of any service agreement.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim protect your personal information through a system of organizational and technical security measures and adherence to NDPR principles and guidelines.

Data transmission over the Internet is inherently insecure and we cannot guarantee the security of data sent over the Internet. We have implemented appropriate technical and organizational security measures designed to maintain the safety of any personal information we process, receive, transfer, or make available for access.

When you submit personal information through our Website, your data is encrypted and transmitted using Secure Socket Layer with Extended Validation technology (SSL-EV). Sensitive information is stored on our secure servers, which are scanned daily for security holes and known vulnerabilities to keep your data as safe as possible.

We implement reasonable precautions to prevent the loss, misuse, or alteration of your personal data stored on our secure network or offline. Your personal identifiable information (PII) is accessible by specific persons with special access rights to such systems and who are required to keep the information confidential. Only employees who need access to the information for the performance of our service to you (for example, billing or customer service, or your virtual employee/manager) are granted access to personally identifiable information (PII) on a need-to-know basis. All Suite 900 Group, Inc. employees are bound by non-disclosure agreements (NDAs).

We also maintain regulatory security measures. For example, CCTVs monitor all areas of our office, and workstation-installed software record all employee computer activity and are routinely audited to help prevent data leakage. We also have a range of regulations that prohibit or limit access and use of personal accounts and portable devices, and policies that address known security concerns, such as third-party visitation and the exchange of passwords and credentials

Suite 900 Group, Inc. is a privately held corporate entity registered with the Security and Exchange Commission (SEC) in Cebu, Philippines (SEC: #CS201130007). Although our location precludes Privacy Shield governance, our on-site team of American and Filipino directors and managers actively monitor our alignment with the EU-U.S. and the Swiss-U.S. Privacy Shield Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. Suite 900 Group, Inc. adheres to the Privacy Shield principles of notice, choice, onward transfer, security, data integrity, access, and enforcement.

Because Suite 900 Group, Inc. is primarily American-owned, it is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission (FTC).

DO WE COLLECT INFORMATION FROM MINORS?

In Short: No. Our Websites are intended for business professionals.

We do not knowingly solicit data from or market to persons under eighteen (18) years of age. By using our Websites, you represent that you are at least 18, or that you are the parent or guardian of such a minor and consent to minor dependent’s use of our Websites. If we learn that personal information from users who are less than eighteen (18) years of age has been collected, we will deactivate any associated account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from a minor, please contact us at privacy@suite900.com.

WHAT ARE YOUR PRIVACY RIGHTS AND HOW DO YOU ASSERT THEM?

In Short: Under applicable data protection laws, you may review, change, or erase your personal data at any time. Contact us and we will act upon your request in accordance with all applicable data protection laws.

The implementation of General Data Protection Regulations (GDPR), on May 25, 2018 establishes a range of rights and entitlements available to you:

You are entitled to have any inadequate, incomplete, or incorrect personal data corrected (rectified).
You have the right to request access to your personal data and information about its processing.
You have the right to receive personal data which you have provided us in a structured, commonly-used machine-readable format, and to require its transmittal to another controller where technically feasible.
You are entitled to have your personal data erased, under specific circumstances, such as where you have withdrawn your consent, where you object to processing based on legitimate interests and we have no overriding legitimate grounds, or where personal data has been unlawfully processed.
You have the right to withdraw consent to process your personal data at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
You have the right to restrict the processing of your personal data (that is, allow only its storage) where:
1. you contest the accuracy of the personal data, until we have taken sufficient steps to correct or verify its accuracy; or
2. the processing is unlawful, but you do not want us to erase the personal data; or
3. we no longer need your personal data for the purposes of the processing, but you require such personal data for the establishment, exercise, or defense of legal claims; or
4. you have objected to processing justified on legitimate interest lawful grounds, pending verification as to whether we have compelling legitimate grounds to continue processing.
You have the right to object to processing (including profiling) based on legitimate interest grounds, unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms, or our need to process the personal data for the establishment, exercise, or defense of legal claims, or as applicable law otherwise requires.
You are entitled to object to our use of your personal data for direct marketing or profiling purposes.
You have the right to lodge a complaint with the supervisory authority of your habitual residence, or if you perceive processing of your personal data infringes applicable law, the place of alleged infringement.

Reviewing, editing, and deleting personal information: You may at any time contact us to review or update your personal information or request its deletion. Upon request of deletion, we will delete your personal data from our active databases. However, some information may be retained in our files to comply with legal requirements.

Cookies and similar technologies: You may at any time opt-out of interest-based advertising, by choosing to set your browser to remove and/or to reject cookies from our Websites. If you choose to remove or reject cookies, this could affect accessibility to certain features of our Sites. For further information, please review our Cookies Policy.

Opting out of email marketing: You can opt-out from receiving our promotional emails at any time by clicking on the unsubscribe link found at the bottom of our emails; however, if we are bound by a service agreement, we will still need to send you emails necessary for the performance of our service for you.

If you wish to exercise any of your rights regarding your personal data processed on our Websites, please submit your request in writing to us using the contact information provided at the end of this page. We will promptly act upon any request in accordance with all applicable data protection laws.

DO WE RESPOND TO ‘DO NOT TRACK’ (DNT) SIGNALS?

In Short: We do not respond due to nuances and lack of an established DNT standard.

Currently, various browsers, including Internet Explorer, Firefox, and Safari, offer a "Do Not Track" or "DNT" option that relies on a technology known as a DNT header, which sends a signal to websites visited by the user about the user’s browser DNT preference setting. Suite 900 Group, Inc. Websites do not currently commit to responding to browsers’ DNT signals, in part, because no common industry standard for DNT has been adopted by industry groups, technology companies, or regulators, including no consistent standard of interpreting user intent, and varying default settings of browsers. Suite 900 Group, Inc. takes privacy and meaningful choice seriously and will make efforts to continue to monitor developments around DNT browser technology and the implementation of a standard. Irrespective to whether or not you browse with DNT enabled, Suite 900 Group, Inc. does not track you across the Internet, and does not change or disable the DNT setting in your browser.

DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under eighteen (18) years of age and reside in California, you have the right to request removal of unwanted data you have provided us. To request removal of such data, please contact us using the contact information provided below. We will make sure the data is not publicly displayed on our Websites and take reasonable steps to comprehensively remove your data from our systems.

DO WE MAKE UPDATES TO THIS POLICY?

In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.

We may update this privacy policy from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to stay informed about how we are protecting your information.

HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have any questions about this privacy policy or our treatment of your personal data, please write to us.

In support of the EU-U.S. and Swiss-U.S. Privacy Shield Principles, we commit to resolve complaints about your privacy and our collection or use of your personal information. Inquiries or complaints regarding this privacy policy should first be directed to Suite 900 Group, Inc. at:

Joseph Miller
Data Protection Officer (DPO)
Suite 900 Group, Inc.
Sardius Building Unit 401
71 Katipunan, Labangon
Cebu City, Cebu 6000, Philippines

Or at: privacy@suite900.com

Suite 900 Group, Inc. has further committed to refer unresolved privacy complaints under the EU-U.S. and Swiss Privacy Shield Principles to an independent dispute resolution mechanism operated by JAMS. If you do not receive timely acknowledgment of your complaint or if your complaint is not satisfactorily addressed, please visit JAMS to file a complaint or obtain more information.

Under certain conditions, which are described in greater detail on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

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