Privacy Policy

Effective 12/21/22

STRAFFORD takes the protection of your personal data very seriously, and it is very important to us. The following paragraphs provide information about what we do with your data, in particular, how we use your data and with whom we share your data. We are obliged to provide this information under the EU General Data Protection Regulation (GDPR), the Data Protection Act 2018, and several individual states across the United States. This privacy notice aims to give you information on how STRAFFORD collects and processes your personal data, including any data that you may provide when applying for any courses with us.

BY DISCLOSING THE INFORMATION TO US, YOU AGREE TO THE TERMS OF THE POLICY.

Who we are

We are STRAFFORD PUBLICATIONS, LLC (a company registered in the United States whose registered address is at: 12222 Merit Drive, Suite 1340 Dallas, Texas 75251) (“STRAFFORD”), and we respect your privacy. This policy describes how we use your personal information.

When you use our websites or apps and purchase or use our products and/or services, you trust us with your information. There are many ways this information can help us to make our service better, for instance, we can remember your details so it’s easier for you to use the service/website.

But we respect your privacy, and we value the trust you have placed in us by sharing your information. This privacy policy sets out the way we use your information arising from your use of our websites and our apps or purchase or use of our products and/or services, as well as registering an account with us: including what we collect, how we collect it, how we use it, why we use it, who we share it with and the rights to which you may be entitled.

We have tried to keep this document as clear and direct as possible, however there are contact details at the end of this policy if you have any questions or anything is unclear.

This privacy policy also covers our group companies. Each group company is a data controller and we’ve listed them below:

STRAFFORD Collection and Storage of Your Information

We will collect and use your personal information, including your:

Full name
Home address
Phone number
Email address
Company
Title
Professional License / Permit Number
Course and webinar enrollments, course access dates/times and course completion data
Credit card details

When you register for or use our services and/or purchase our products and/or use our websites or apps. We also collect aggregate user data regarding your use and activity of/on our websites and our apps.

We also collect information about you from other sources, such as orders placed by you or from third-party mailing lists. Our partners who obtain this information will have informed you, at the point of collection, that they are collecting the information (in part) for us and that the information will be provided to us. Any of your personal information we collect from other sources will be stored and used in accordance with this Privacy Policy.

We maintain your information securely in our customer database and will only store it for a reasonable period of time, which if you have an account with us will be duration of your subscription to our service and for six years thereafter.

Use of Information

This information is used:

to provide the service or product requested;
to enable billing and shipping;
to personalize our service;
to analyze and report on your performance;
to provide you with information about related products and services, based on the preferences you have indicated;
to improve our website;
for the development of new products and services; and
for systems administration and troubleshooting purposes.

If you have inquired about, applied for, or enrolled in a STRAFFORD course or program, we (or one of our group companies) may occasionally update you on our latest policies, products/services, news, and special offers via e-mail. At the bottom of any electronic communication, you receive from us or one of our group companies, you will have an option to unsubscribe and opt-out of receiving further marketing communications.

Your information may be shared with members of our group and some third parties. Please note:

We will not share your credit card number with parties outside of our group of companies, or the payment processor.
Basic demographic data including name, address, phone, email, company, title, school, graduation data, course for which you are registered, and related information may be disclosed to marketing partners (including but not limited to Google ‘Adwords’, Facebook ‘Ads’ and LinkedIn ‘Insights’). You can prohibit this using the steps set out in the “How to prohibit sharing to our marketing partners” section.
Information concerning your usage of our site and your progress using our study materials may be disclosed to third parties such as educational institutions, associations, professors, and product development partners. If your company has sponsored your attendance or certification, we will also share progress (started, in progress, completed) course data, and successful certification outcomes.

Our marketing partners and other third parties who we may share your information with will be required to meet our standards on processing information and security. The information we provide them, including your information, will only be provided in connection with the performance of their function.

Your personal information may be transferred to other third-party organizations in certain scenarios:

if we’re discussing selling or transferring part or all of our business – the information may be transferred to prospective purchasers under suitable terms as to confidentiality;
if we are reorganized or sold, information may be transferred to a buyer who can continue to provide services to you;
if we’re required to by law, or under any regulatory code or practice we follow, or if we are asked by any public or regulatory authority; or
if we are defending a legal claim your information may be transferred as required in connection with defending such claim.

Your personal information may be shared if it is made anonymous and aggregated, as in such circumstances the information will cease to be personal data.

Why we use your information

We use the information we collect about you in the manner set out above either because it is necessary to perform the contract between us (providing the products or services ordered from us or opening and maintaining your account with us) or because we have a legitimate business interest. Our legitimate business interests include but are not limited to:

ensuring we continue to improve our service and better understand our users and customers and how you use our website, our apps and our products and services;
ensuring we can communicate with you, and you can easily communicate with us and amend your preferences from time-to-time; and
ensuring we develop and maintain strong relationships with our suppliers and partners.

Our marketing partners use your information because they believe they have legitimate business interests to do so as they think you would be interested in hearing from them about similar products and services to those we provide. If you wish to prohibit us sharing your personal information to our marketing partners, please follow the process set out in the “How to prohibit sharing to our marketing partners” section below.

The employer, educational institutions, association, professors, and product development partners to which we may share your information also use your information on the basis that they have legitimate interests as they process your data to analyze and improve team cohesion, reduce errors, speed onboarding and other improvements, and for the development of new products and services.

How to prohibit sharing to our marketing partners

Locate an Email from Strafford
Click “Email Preferences” at the bottom
Uncheck the types of emails you do not want to receive
Click “Update Email Preferences"

You may prohibit sharing of your personal information to our marketing by following these steps:

Your Rights

You may have certain rights in relation to your information including a right to access or to correct the information we hold about you. Other rights may be available in certain circumstances.

We’ve listed the rights you have over your information and how you can use them below.

These rights will only apply in certain circumstances. They will generally not be available if there are outstanding contracts between us, if we required by law to keep the information or if the information is relevant to a legal dispute.

You can remove consent, where you have provided it, at any time.
You can ask us to confirm if we are processing your information.
You can ask for access to your information.
You can ask to correct your information if it’s wrong.
You can ask us to delete your information.
You have a right to be forgotten and you can ask that our systems stop using your information.
You can ask us to restrict how we use your information.
You can ask us to help you move your information to other companies. To help with that, you have a right to ask that we provide your information in an easily readable format to another company.
You can ask us to stop using your personal information, but only in certain cases.
You have the right to complain to the relevant supervisory authority.

How to contact us

If you have any questions about this policy, please contact our Data Privacy representative at privacy@straffordpub.com.

Changes to the policy

This policy will be changed from time to time.

If we change anything important about this policy (the information we collect, how we use it or why) we will highlight those changes at the top of the policy and provide a prominent link to it for a reasonable length of time following the change.

If you would like access to a previous version of its policy, please contact us using the details set out above.

International Data Transfers

We operate and process information in multiple jurisdictions. Some of our Education Partners, Service Providers, and Other Third Parties may be located or process information outside of the jurisdiction in which you reside. In such cases, your Personal Information may be collected, used, disclosed, stored, and processed in these other jurisdictions for the purposes described in this policy. The data protection and other laws of the United States and other countries might differ from your jurisdiction. Your Personal Information may also be subject to those other jurisdictions' laws, including lawful requirements to disclose Personal Information to government authorities.

Cookies

The Straffordpub.com websites uses cookies, tracking pixels and related technologies. Cookies are small data files that are served by our platform and stored on your device.

For more information about cookies, the types of cookies we use and how we use them, please see our cookie policy, a copy of which can be found here.

Privacy Notice for California Residents

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Statement of Strafford, Inc and its subsidiaries (collectively, “we,” “us,” or “our”) and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”), the California Privacy Rights Act of 2023 (“CRPA”) and other California privacy laws. Any terms defined in the CCPA and CRPA have the same meaning when used in this notice.

Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Category	Examples	Collected
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.	YES
B. “Sensitive” Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, account log-in information with password, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	YES
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	YES
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	YES
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.	YES
G. Geolocation data.	Physical location or movements.	YES
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
I. Professional or employment-related information.	Current or past job history or performance evaluations.	YES
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	YES
K. Inferences drawn from other personal information.	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	NO

Personal information does not include:

Publicly available information from government records.
De-identified or aggregated consumer information.
Information excluded from the CCPA's scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the following categories of sources:

Directly from our clients or their agents. For example, from documents that our clients provide to us related to the services for which they engage us.
Indirectly from our clients or their agents. For example, through information we collect from our clients in the course of providing services to them.
Directly and indirectly from activity on our website (www.Straffordpub.com). For example, from submissions through our website portal or website usage details collected automatically.
From third parties that interact with us in connection with the services we perform. For example, from agencies when we prepare readiness assessments for projects that receive government funding.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

To provide you with information, products or services that you request from us.
To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
To improve our website and present its contents to you.
For testing, research, analysis and product development.
As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to you when collecting your personal information or as otherwise set forth in the CCPA, and CPRA.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

Category A:	Identifiers
Category B:	California Customer Records personal information categories
Category C:	Protected classification characteristics under California or federal law
Category D:	Commercial information
Category F:	Internet or other similar network activity
Category G:	Geolocation data
Category I:	Professional or employment-related information
Category J:	Non-public education information

We disclose your personal information for a business purpose to the following categories of third parties:

Our affiliates.
Service providers.
Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.

In the preceding twelve (12) months, we have not sold any personal information.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting or selling that personal information.
The categories of third parties with whom we share that personal information.
The specific pieces of personal information we collected about you (also called a data portability request).
The right to correct inaccuracies in your personal information.
If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

Calling us at 866-624-9037
Visiting https://s3.us-east-1.amazonaws.com/assets.straffordpub.com/files/strafford-privacy-policy-form.pdf
Email: privacy@straffordpub.com

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.

Contact Information

If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: 866-624-9037
Website: https://s3.us-east-1.amazonaws.com/assets.straffordpub.com/files/strafford-privacy-policy-form.pdf
Email: legal@straffordpub.com
Postal Address: Strafford
Attn: Legal Department
12222 Merit Drive, Suite 1340, Dallas Texas 75251

Updated: December 21, 2022