Effective Date: September 21, 2021
Welcome! We are Stairwell, whose mission is to help organizations outsmart any attacker. This Privacy Notice explains how Stairwell, Inc. (“Stairwell”, “we”, “us” or “our”) collects, uses, discloses, and otherwise processes Personal Information (as defined below) in connection with our website, www.stairwell.com (the “Site”) and the related content, platform, services, and other functionality offered on or through the online services (collectively, the “Services”). It does not address our privacy practices relating to Stairwell employees and other personnel.
When our customers use our Services to submit, manage, or otherwise use content relating to our customers’ data (“Customer Data”), we have contractually committed ourselves to only process such information on behalf of and under the instruction of the respective customer, who is the “data controller”. This Privacy Notice does not apply to such processing and we recommend you read the privacy notice of the respective customer if their processing concerns your Personal Information.
What is Personal Information?
When we use the term “Personal Information” in this Privacy Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual. It does not include aggregated or deidentified information that is maintained in a form that is not reasonably capable of being associated with or linked to an individual.
Our Collection of Personal Information
Sometimes we collect Personal Information automatically when an individual interacts with our Services and sometimes we collect Personal Information directly from an individual. At times, we may collect Personal Information about an individual from other sources and third parties, even before our first direct interaction.
Personal Information Collected from Site Visitors and Account Holders
We collect the following Personal Information submitted to us by visitors to our Site and account holders:
- Contact Information, including name, email address, mailing address, company, employer, phone number, newsletter preferences and communication preferences.
- Inquiry Information, including information provided in custom messages sent through the forms or contact information provided on our Site.
- Employment Application Information, including your contact and demographic information, date of birth, photo, educational and work history, employment interests, information obtained during interviews and any other information you choose to provide, if you apply for employment.
- Survey Information, including information provided in any questions submitted through surveys, or content of any testimonials.
Personal Information Automatically Collected
As is true of most digital platforms, we and our third-party providers may also collect Personal Information from an individual’s device, browsing actions and site usage patterns automatically when visiting or interacting with our Site, which may include log data (such as internet protocol (IP) address, operating system, browser type, browser id, the URL entered and the referring page/campaign, date/time of visit, the time spent on our Site and any errors that may occur during the visit to our Site), analytics data (such as the electronic path taken to our Site, through our Site and when exiting our Site, as well as usage and activity on our Site) and location data (such as general geographic location based on the log data we or our third-party providers collect).
To manage cookies, an individual may change their browser settings to: (i) notify them when they receive a cookie, so the individual can choose whether or not to accept it; (ii) disable existing cookies; or (iii) automatically reject cookies. Please note that doing so may negatively impact an individual’s experience using our Site, as some features and offerings may not work properly or at all. Depending on an individual’s device and operating system, the individual may not be able to delete or block all cookies. In addition, if an individual wants to reject cookies across all browsers and devices, the individual will need to do so on each browser on each device they actively use. An individual may also set their email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether they have accessed our email and performed certain functions with it.
Personal Information from Third Parties
We also obtain Personal Information from third parties; which we often combine with Personal Information we collect either automatically or directly from an individual.
We may receive the same categories of Personal Information as described above from the following third parties:
- Your Employer / Company: If you engage in our Services through your employer or company, we may receive information from the company such as name and contact information.
- Social Media: When an individual interacts with our Services through various social media networks, such as when someone “Likes” us on Facebook or follows us or shares our content on Google, Facebook, Twitter, or other social networks, we may receive some information about individuals that they permit the social network to share with third parties. The data we receive is dependent upon an individual’s privacy settings with the social network. Individuals should always review and, if necessary, adjust their privacy settings on third-party websites and social media networks and services before sharing information and/or linking or connecting them to other services.
- Service Providers: Our service providers that perform services solely on our behalf, such as survey and marketing providers, collect Personal Information and often share some or all of this information with us.
- Information Providers: We may from time to time obtain information from third-party information providers to correct or supplement Personal Information we collect. For example, we may obtain updated contact information from third-party information providers to reconnect with an individual.
- Third Parties Related to Employment Applications: If you apply for a job with Stairwell, we may receive information from your current or past employers, background check providers, third-party social media platforms and other third parties we use to obtain information about job applicants.
- Publicly Available Sources: We collect Personal Information about individuals that we do not otherwise have, such as contact information, employment-related information, and interest-in-services information, from publicly available sources. We may combine this information with the information we collect from an individual directly. We use this information to contact individuals, to send advertising or promotional materials or to personalize our Services and to better understand the demographics of the individuals with whom we interact.
Our Use of Personal Information
We use Personal Information we collect to:
- Fulfill or meet the reason the information was provided, such as to fulfill our contractual obligations, to deliver the Services you have requested and to process transactions;
- Manage our organization and its day-to-day operations;
- Communicate with individuals, including via email, text message, social media and/or telephone calls;
- Request individuals to complete surveys about our organization, organizations we partner with, and Services;
- Market our Services to individuals, including through email, direct mail, text message, social media and telephone calls;
- Administer, improve and personalize our Services, including by recognizing an individual and remembering their information when they return to our Site;
- Facilitate customer benefits and services, including customer support through our command center services;
- Identify and analyze how individuals use our Services;
- Conduct research and analytics on our customer base and our Services;
- Improve and customize our Services to address the needs and interests of our customer base and other individuals we interact with;
- Evaluate your candidacy for employment, communicate with you during the job application process, and facilitate the onboarding process;
- Test, enhance, update and monitor the Services, or diagnose or fix technology problems;
- Help maintain the safety, security and integrity of our property and Services, technology assets and business;
- Defend, protect or enforce our rights or applicable contracts and agreements;
- Prevent, investigate or provide notice of fraud or unlawful or criminal activity; and
- Comply with legal obligations.
Where an individual chooses to contact us, we may need additional information to fulfill the request or respond to inquiries. We may provide additional privacy disclosures where the scope of the inquiry/request and/or Personal Information we require fall outside the scope of this Privacy Notice. In that case, the additional privacy disclosures will govern how we may process the information provided at that time.
Our Disclosure of Personal Information
We disclose Personal Information in the following ways:
- Affiliates. We may share Personal Information with other companies owned or controlled by Stairwell, and other companies owned by or under common ownership as Stairwell, which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns, particularly when we collaborate in providing the Services.
- Your Employer / Company: If you engage in our Services through your employer, or company, we disclose your information to the company such as name and contact information.
- Survey Providers: We share Personal Information with third parties who assist us in delivering our survey offerings and processing the responses.
- Marketing Providers: We coordinate and share Personal Information with our marketing providers in order to communicate with individuals about the Services we make available.
- Customer Service and Communication Providers: We share Personal Information with third parties who assist us in providing our customer services and facilitating our communications with individuals that submit inquiries.
- Other Service Providers: In addition to the third parties identified above, we engage other third-party service providers that perform business or operational services for us or on our behalf, such as website hosting, infrastructure provisioning, IT services, analytics services, administrative services, background checks and recruiting.
- Other Business as Needed to Provide Services: We may share Personal Information with third parties that an individual engages with through our Services or as needed to fulfill a request or transaction.
- We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose Personal Information to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal Information may also be disclosed in the event of insolvency, bankruptcy or receivership.
- Legal Obligations and Rights: We may disclose Personal Information to third parties, such as legal advisors and law enforcement:
- in connection with the establishment, exercise, or defense of legal claims;
- to comply with laws or to respond to lawful requests and legal process;
- to protect our rights and property and the rights and property of others, including to enforce our agreements and policies;
- to detect, suppress, or prevent fraud;
- to protect the health and safety of us and others; or
- as otherwise required by applicable law.
- Otherwise with Consent or Direction: We may disclose Personal Information about an individual to certain other third parties or publicly with their consent or direction. For example, with an individual’s consent or direction we may post their testimonial on our Site or service-related publications.
If you are a resident of the State of Nevada, Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. Please contact us at [email protected] to submit such a request.
Children’s Personal Information
Our Services are not directed to, and we do not intend to, or knowingly, collect or solicit Personal Information from children under the age of 13. If an individual is under the age of 13, they should not use our Services or otherwise provide us with any Personal Information either directly or by other means. If a child under the age of 13 has provided Personal Information to us, we encourage the child’s parent or guardian to contact us to request that we remove the Personal Information from our systems. If we learn that any Personal Information we collect has been provided by a child under the age of 13, we will promptly delete that Personal Information.
Links to Third-Party Websites or Services
Our Services may include links to third-party websites, plug-ins and applications. Except where we post, link to or expressly adopt or refer to this Privacy Notice, this Privacy Notice does not apply to, and we are not responsible for, any Personal Information practices of third-party websites and online services or the practices of other third parties. To learn about the Personal Information practices of third parties, please visit their respective privacy notices.
Updates to This Privacy Notice
We will update this Privacy Notice from time to time. When we make changes to this Privacy Notice, we will change the date at the beginning of this Privacy Notice. If we make material changes to this Privacy Notice, we will notify individuals by email to their registered email address, by prominent posting on our Services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.
If you have any questions or requests in connection with this Privacy Notice or other privacy-related matters, please send an email to [email protected].