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Privacy Policy

Last Updated: March 5, 2024

This Privacy Policy (“Privacy Policy”) describes the ways in which Stairwell, Inc. and its subsidiaries and affiliates (collectively, “Stairwell,” “we,” “our,” or “us”) may collect, use, and disclose personal information in connection with our website, stairwell.com, and any other websites or platforms that link to this Privacy Policy (collectively, the “Website”), together with our products, services, social media pages, events, emails, and other electronic communications (collectively, the “Offerings”), and the choices you have with respect to your personal information.

This Privacy Policy does not apply to personal information that we may store or maintain on behalf of any of our customers who use our threat awareness and malware detection product platform and accompanying services (the “Service”), where applicable. For more information about the privacy practices of one of our customers, please reach out to the customer directly. 

1. Personal Information that Stairwell Collects or Receives and How that Information Is Obtained

Stairwell may collect or receive different types of personal information about you, which may include the following:

  • Contact information, name, postal address, email address, and telephone number. 
  • Professional information, such as company name, job title, company location, and other details we may collect about your business or profession.
  • Customer account information, such as authentication credentials, information you provide during agreement submission, and order history.
  • Preferences, such as any marketing or communications preferences you communicate to us.
  • Survey responses, such as the information you provide in response to our surveys, questionnaires, or contests.
  • Communications, such as the information associated with your requests or inquiries, including for support, assistance, or order information, and any feedback you provide when you communicate with us. If you communicate with Stairwell by telephone or through our chat feature on our Website, you consent that Stairwell and our service provider may monitor or record the call or record the chat. This is done for reasons such as maintaining the integrity of your account, providing effective and timely service, and the improvement of our Offerings and Services. 
  • Device data, such as your computer or mobile device operating system type and version number, manufacturer and model, browser type, screen resolution, IP address, unique identifiers, the website you visited before browsing to our Website, and general location information such as city, state, or geographic area.
  • Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.

This personal information may be collected:

  • Directly from you, such as when you fill out a form on our Website, engage with our branded social media pages, register for or attend a webinar, training, or other event, download one of our available knowledge resources (such as white papers, research reports, etc.), or otherwise communicate with us. 
  • From third parties, such as social media platforms and other public sources, third parties that help us advertise our services and find new customers, joint marketing partners, event co-sponsors, or when you use third party authentication options to sign-up for or log-in to our Offerings, and other third parties.
  • From referrals by customers and users of our Offerings who may have the opportunity to refer friends, colleagues, or other contacts to us and share their contact information with us. Please do not refer someone to us or share their contact information with us unless you have their permission to do so.
  • Automatically. Stairwell, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your activity over time on our Website, through our Offerings, and other sites and online services, such as the device data and online activity data described above. Like many online services, we may use the following technologies to facilitate some of our automatic data collection:
    • Cookies, which are text files that websites store on a visitor’s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating online advertising.
    • Web beacons, also known as pixel tags or clear GIFs, which are typically used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked, typically to compile statistics about usage of websites and the success of marketing campaigns.
    • Local storage, which is used to save data on a visitor’s device. We may use data from local storage to, for example, turn on web navigation, store multimedia preferences, customize what we show you based on your past interactions with our Website and Offerings, and remember your preferences. 
    • Session-replay technologies, which are third-party software programs that we may use on the Website or in some locations of the Service to record a video replay of user’s interactions with the Website or Service. The video replay may include users’ clicks, mouse movements, scrolls, typing, and other activity taken during the session. We use these replays for research and development purposes, such as to help us troubleshoot problems with the Website or Service, understand how users interact with and use the Website or Service, and identify areas for improvement.

2. How Stairwell Uses Personal Information

We collect and process your personal information for the purposes set forth below and as otherwise described in this Privacy Policy or at the time of collection.

  • To Provide our Offerings and Service. We may use personal information to provide our Offerings and Service, and to operate our business. For example, we use personal information to:
    • Process your transaction, including providing our Offerings and granting access to our Service and technology;
    • improve and personalize your experience on or with the Offerings;
    • verify your identity or determine your eligibility for offers or promotions;
    • communicate with you, including providing notices about your transaction (e.g., confirmations, invoices, technical notices, updates, and security alerts) and responding to any of your requests, feedback, or questions;
    • contact you by phone, email, SMS, or other form of communication;
    • provide any contests, surveys, sweepstakes, webinar, training, or other events or promotions you participate in, including sending related communications to you;
    • provide maintenance and support; and
    • fulfill any other purpose for which you provide personal information.
  • Research and Development. We may use your personal information for research and development purposes, including to study and improve the Service, Offerings, and our business, understand and analyze the usage trends and preferences of our users and customers, and develop new features, functionality, products, and services. As part of these activities, we may create aggregated, de-identified, or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes.
  • Direct Marketing. We may send you Stairwell-related or other direct marketing communications as permitted by law, including materials, updates, information, special offers, and promotional material from us and our business partners. You may opt-out of our marketing communications as described in the “How You Can Exercise Your Rights” section below. 
  • Interest-Based Advertising. We work with third-party advertising companies and social media companies to help us advertise our business and to display ads for our business and Service. These companies may use cookies and similar technologies to collect information about you (including the online activity information and device information described above) over time across our Website and Offerings and other websites and services or your interaction with our emails, and use that information to serve ads that they think will interest you. In addition, some of these companies may use hashed customer lists that we share with them to deliver ads to you and to similar users on their platforms. You can learn more about your choices for limiting interest-based advertising in the “How You Can Exercise Your Rights” section below. 
  • To Comply with Law. We will use personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
  • For Compliance, Fraud Prevention, and Safety. We may use personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) maintain the safety, security, and integrity of the Service, business, databases, and other technology assets; (b) protect our, your, or others’ rights, privacy, safety or property (including by making and defending legal claims); (c) audit our internal processes for compliance with legal and contractual requirements and internal policies; (d) enforce the terms and conditions that govern the Website, Offerings, and Service; and (e) prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
  • With Your Consent. We will disclose your personal information in accordance with your prior direction or, in some cases, we may specifically ask you for your consent to collect, use, or share your personal information, such as when required by law.

3. With Whom Stairwell Shares Personal Information

In addition to the sharing described elsewhere in this Privacy Policy or at the point of collection, Stairwell may share your personal information as follows:

  • Related Companies. We may share your personal information with our affiliates, subsidiaries, and other related companies.
  • Service providers. With our contracted service providers, who provide services such as IT and system administration and hosting, credit card processing, research and analytics, marketing, customer support, and data enrichment.
  • Event sponsors. If you attend an event or webinar organized by us, or download or access content on our Website, we may share your personal information with sponsors of the event or content. If required by applicable law, you may consent to such sharing via the registration. In these circumstances, your information will be subject to the sponsors’ privacy statements. If you do not wish for your information to be shared, you may choose to not opt-in via event/webinar registration.
  • Contest and promotion sponsors. With sponsors of contests or promotions for which you register in order to fulfill the contest or promotion.
  • Advertising partners. With third-party social media networks, advertising networks and websites, so that Stairwell can market and advertise on third party platforms and websites, as further described in the “Interest-Based Advertising” paragraph above.
  • Partners and resellers. We may disclose personal information, such as contact information, business details, and content interest and activity details, to our partners and resellers for business purposes, such as to carry out our business or for joint marketing efforts to reach our customers and prospective customers. In many cases, you intentionally disclose your details by providing your information to these sponsors through consent via a registration form.
  • Professional advisers. We may share personal information with persons, companies, or professional firms providing Stairwell with advice and consulting in accounting, administrative, legal, tax, financial, debt collection, and other matters, in each case to the extent necessary for the advisor to provide its services to Stairwell.
  • Law enforcement, government authorities, and private parties. Under certain circumstances, we may be required to disclose personal information to law enforcement, government authorities, and other parties if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency). We may also disclose personal information in the good faith belief that such action is necessary to comply with a legal obligation or for the purposes described above in the section titled “For Compliance, Fraud Prevention, and Safety.”
  • Third parties involved in a corporate transaction. We may disclose personal information to third parties in connection with any business transaction (or potential transaction) involving a merger, acquisition, sale of shares or assets, financing, consolidation, reorganization, divestiture, or dissolution of all or a portion of our business (including in connection with a bankruptcy or similar proceedings).

We may also share aggregated usage data with Stairwell’s service providers for the purpose of helping Stairwell in such analysis and improvements. Additionally, Stairwell may share usage data on an aggregate basis in the normal course of operating our business; for example, we may share information publicly to show trends about the general use of our Offerings and Service.

4. International Transfers of Personal Information

Stairwell is based in the United States, and we have service providers in the United States and potentially other countries. Your personal information may be collected, used, and stored in these countries or other locations outside of your home country. Privacy laws in the locations where we handle your personal information may not be as protective as the privacy laws in your home country. By providing your personal information, where applicable law permits, you specifically and expressly consent to such transfer and processing and the collection, use, and disclosure set forth herein.

5. How You Can Exercise Your Rights

  • Marketing Emails. You may opt-out of marketing-related emails by clicking the “unsubscribe” link at the bottom of the email or by contacting us using the contact information at the end of this Privacy Policy. You may still receive service-related communications, such as those relating to your account, an event you registered for, or similar notifications or announcements.
  • Cookies. Most browsers let you remove and/or stop accepting cookies from the websites you visit. To do this, follow the instructions in your browser’s settings. Many browsers accept cookies by default until you change your settings. If you do not accept cookies, however, you may not be able to use all functionality of the Website or Service and they may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org. 
  • Google Analytics. We use Google Analytics to help us analyze how our Website is being accessed and used. You can learn more about Google Analytics cookies by clicking here and about how Google protects your data by clicking here. To opt-out of Google Analytics, you can download and install the Google Analytics Opt-out Browser Add-on, available here. 
  • Advertising Choices. You can limit the use of your information for interest-based advertising by blocking third-party cookies in your browser settings, using browser plug-ins/extensions, or using your mobile device settings to limit the use of the advertising ID associated with your mobile device. You can also opt out of interest-based ads from companies participating in the following industry opt-out programs by visiting the linked websites: the Network Advertising Initiative (http://www.networkadvertising.org/managing/opt_out.asp) and the Digital Advertising Alliance (https://optout.aboutads.info). Some of the companies we work with may offer their own opt-out mechanisms. For example, you can learn more about how Google uses cookies for advertising purposes by clicking here and opt-out of ad personalization by Google by clicking here.Many of the opt-out preferences described in this section must be set on each device or browser for which you want them to apply. Please note that some of the advertising companies we work with may not participate in the opt-out mechanisms described above, so even after opting-out, you may still receive interest-based advertisements from other companies. If you opt-out of interest-based advertisements, you will still see advertisements online but they may be less relevant to you.
  • Do Not Track. Some browsers may be configured to send “Do Not Track” signals to the online services that you visit. We do not currently respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com. 

6. How Stairwell Secures Personal Information

We take appropriate precautions including organizational, technical, and physical measures designed to help safeguard against accidental or unlawful destruction, loss, alteration, and unauthorized disclosure of, or access to, the personal information we process. However, no method of storage or transmission is 100% secure and we cannot guarantee the security of your personal information.

7. Third Party Websites and Services
Our Website and Offerings may contain links to other websites, applications, platforms and services maintained by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or online services that are not associated with us. The information practices of these third parties, including the social media platforms that host our branded social media pages, are governed by their privacy statements, which you should review to better understand their privacy practices. We do not control third party websites or online services, and we are not responsible for their actions.

Stairwell uses Calendly on its website to make scheduling meetings easy. If a website visitor elects to schedule a meeting with Stairwell using the Calendly functionality on the Stairwell website, Calendly will collect certain information from the website visitor as set out in Calendly’s Privacy Notice, which is available at https://calendly.com/legal/privacy-notice.

8. Notice to California Residents (Shine The Light Law)
Under California Civil Code sections 1798.83-1798.84, California residents who have an established business relationship with Stairwell are entitled to ask us for a notice describing what categories of personal information we share with third parties for the third parties’ direct marketing purposes. If you are a California resident and would like a copy of this notice, please submit your request to the email address listed at the end of this Privacy Policy with “Shine the Light” in the subject line.

9. Notice to Nevada Residents
Nevada Revised Statutes Chapter 603A allows Nevada residents to opt-out of the “sale” of certain types of personal information. Subject to several exceptions, Nevada law defines “sale” to mean the exchange of certain types of personal information for monetary consideration to another person. If you are a Nevada resident who wishes to exercise your “sale” opt-out rights, you may submit a request to us using the contact information listed at the end of this Privacy Policy with “Nevada Opt-Out Request” in the subject line.

10. How Stairwell Makes Changes to this Privacy Policy

We will update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, and other factors. If we do, we will update the “last updated” date at the top. If certain circumstances, we may notify you about an update by sending you an email, posting a notice on our Website, or other means as may be required by applicable law.

We encourage you to periodically review this Privacy Policy to stay informed about our collection, processing and sharing of your personal information.

11. How to Contact Stairwell 

If you have questions regarding this Privacy Policy or our privacy practices, please email us at [email protected] or write to us at:

Stairwell, Inc.
ATTN: Legal
150 Mathilda Place, Suite 100
Sunnyvale, CA 94086

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