Streamline Digital Holdings, LLC

Privacy Policy

Last Updated: August 1, 2024

Streamline Digital Holdings, LLC, (together with subsidiaries and affiliates, “ SDH,” “we,” or “us”) values the privacy of everyone who uses our websites (such as www.nativeframe.com, collectively the “Site”), as well as all related web sites, events (career applications, recruitment activities, events and surveys), networks, embeddable widgets, downloadable software (including any development kits and any associated tools, also known as SDKs), mobile applications, beta products, and other services that link to this Privacy Policy (collectively, together with the Site, our “Service”).

This Privacy Policy (“Policy”) describes how we collect and use Personal Information from or about you through the Service we provide and in connection with our customer, partner and vendor relationships, your rights, and choices with respect to your Personal Information, and how you can contact us if you have any questions or concerns. For the purpose of this Policy, “Personal Information” means any information relating to an identified or identifiable individual and does not include data whereby personally identifiable information has been removed (such as anonymous data).  In addition to the activities described in this Policy, we may process Personal Information provided by our enterprise customers (“Enterprise Customers”) when they use our Service. We process such Personal Information as a data processor on behalf of and following instructions from our Enterprise Customers, which are the entities responsible for the data processing.  To understand how an Enterprise Customer processes your Personal Information, please refer to that Enterprise Customer’s privacy policy.  If you are interested in what Personal Information we process when providing services to our Enterprise Customers, please refer to the SDH Processor Privacy Statement for more information.

Please read this Policy carefully. If you do not agree with this Policy or any part thereof, you should not access or use any part of the Service, or otherwise provide us with your Personal Information. If you change your mind in the future, you should stop using the Service and provide us with no further Personal Information.

Contents of this Policy

This Policy outlines the following topics:

  1. Personal Information We Collect and How We Use It
  2. Our Legal Basis for Processing European Personal Information
  3. How We Disclose or Share Your Personal Information
  4. Your Rights and Choices
  5. Third-Party Services
  6. Children’s Privacy
  7. Data Security
  8. Data Transfers
  9. Data Retention
  10. Changes and Updates to This Policy
  11. Contact Us

1. Personal Information We Collect and How We Use It

We obtain Personal Information relating to you from various sources described below. Where applicable, we indicate whether and why you must provide us with your Personal Information, as well as the consequences of failing to do so. If you do not provide Personal Information when requested, you may not be able to benefit from our Service if that information is necessary to provide you with the Service, or if we are legally required to collect it.

Personal Information Collected from You

Account Registration: If you register to use the Service, then you must provide us with:

Communication and Support: When you communicate with us via the Service, or you send us a request, application, claim, report, or complaint, we collect Personal Information, such as:

Further, we provide you with the option of using our chatbot or similar tools to communicate with us.

If you choose to interact with such tools, you agree that we will process your Personal Information provided by you during your interaction with such tools in accordance with this Policy, the Personal Information of which may include your account preferences, IP address, and the nature of any issues you want to resolve which you enter into the chatbot or similar tools.

Cookie Information

The information collected will typically include Personal Information, such as:

For detailed information about the Cookies and similar technologies we use in our Site, please visit our Cookie Policy. Analyze how our Site is used to generate a better experience:

Job Applications

We will collect any information you choose to provide to us when you apply for a job with SDH, including your resume and references.

Events and Meetings

If you do not object to recording of the meetings/events (for meetings/events in the European Economic Area (“EEA”) or the United Kingdom (“UK”), we or third parties on our behalf , will ask you for your explicit consent before such recording), we will typically collect your voice, images, photographs, or video shared or captured with or on behalf of us during the events/meetings, including, without limitation, the content of media:

We might also collect your age, gender, or other Personal Information; however, we will only collect those with your explicit consent.

Send marketing or promotions

Payment Information

We will collect payment-related information for the purpose of creating your paid account, and process your payment to provide you with our paid services, including your:

You can provide us with this information through your account dashboard or directly in our Enterprise Customer agreement.

If you are using the Service as an end user of an Enterprise Customer, we may process Personal Information about you provided by our Enterprise Customers who use the Service with their own end users.

Information from Other Third Parties

We may obtain information, including Personal Information from third parties and sources other than from our Service. If we combine or associate information from other sources with Personal Information that we collect through our Service, we will treat the combined information as Personal Information in accordance with this Policy.

Notwithstanding the above, we may use your Personal Information to enforce our End User License Agreement, to defend our legal rights, to conduct audits, to comply with our legal obligations and internal policies, to contact you for administrative purposes such as to address intellectual property infringement, privacy violations or defamation issues related to user content posted on the Service. Where we do so, we will use the Personal Information relevant to such a case. Some processing may also be necessary to comply with a legal obligation placed on us.

2. Our Legal Basis for Processing European Personal Information

If you are located in the European Economic Area or the United Kingdom, we only process your Personal Information based on a valid legal basis, including when:

You have consented to the use of your Personal Information;

We need your Personal Information to provide you with the Service, including for account registration and to respond to your inquiries;

We have a legal obligation to use your Personal Information; or

We, or a third party, have a legitimate interest in using your Personal Information. In particular, we have a legitimate interest in using your Personal Information to conduct business analytics and direct marketing, and otherwise improve the safety, security, and performance of our Service. We only rely on our, or a third party’s, legitimate interests to process your Personal Information when these interests are not overridden by your rights and interests.

3. How We Disclose or Share Your Personal Information

SDH Affiliates and Subsidiaries

We will typically disclose Personal Information about you within our SDH affiliates and subsidiaries in a secure manner for the purpose of providing our Service or communicating with you.

SDH Users

Any Personal Information that you choose to include on or through the Service, including information in a publicly accessible area of the Service (such as a public profile page) or information you share with or allow to be shared with other users, will be available to anyone who has access to that content, including other users. We are not responsible for privacy practices of the other users who will view and use the posted information.

SDH’s Partners, Vendors and Service Providers

We work with third party service providers to provide website or application development, hosting, maintenance, and other services for us. These third parties may have access to or process your Personal Information as part of providing those services for us. We limit the information provided to these service providers to that which is necessary for them to perform their functions, and we require them to agree to maintain the confidentiality of such information. Such third parties may typically include storage vendors, internet carriers, payment processing partners, survey firms and virtual or in-person event organizers.

For more information about third parties and partners we use or work with to provide you with a better experience and service, please refer to our Cookie Policy, attached hereto as Exhibit A.

Advertising Partners

We may share your Personal Information with our third-party advertising partners to provide ads that we think may interest you. For more information about our advertising and marketing practices and those of the third-party advertising partners, please see our Cookie Policy.

Other Third Parties

We may also share Personal Information about you with other third parties in the following circumstances:

In Aggregated Form. We may make certain automatically collected, aggregated, or otherwise de-identified information available to third parties for various purposes, including (i) compliance with various reporting obligations; (ii) for business or marketing purposes; or (iii) to assist such parties in understanding our users’ interests, habits, and usage patterns for certain programs, content, services, advertisements, promotions, and/or functionality available through the Service.

To Comply with Legal Obligations. We may disclose your information if required to do so by law or in the good-faith belief that such action is necessary to comply with state and federal laws (such as U.S. copyright law), in response to a court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies.

To Protect and Enforce Our Rights. We also reserve the right to disclose your information that we believe, in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of the Service and any facilities or equipment used to make the Service available, or (v) protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights, property, or safety of others.

In case of Merger, Sale, or Other Asset Transfer. Information about our users, including Personal Information, may be disclosed, and otherwise transferred to an acquirer, or successor or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.

With Your Consent. We also may disclose your Personal Information as may be described in a notice to you at the time the information is collected or before it is shared, or in any other manner to which you consent.

4. Your Rights and Choices

Account Information

You are entitled to decline to share certain Personal Information with us, in which case we may not be able to provide you with some of the features and functionalities of the Service. You may update, correct, or delete your profile information and preferences at any time by accessing your account settings page on the Service. If you wish to access or amend any other Personal Information we hold about you, you may contact us at privacy@gostreamline.io. Please note that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so, to the extent permitted under applicable law.

Opt-Out from Commercial Communication

If you receive any commercial emails from us, you may unsubscribe at any time by following the instructions contained within the email. You may also opt-out from receiving commercial emails from us, and any other promotional communications that we may send to you from time to time, by sending your request to us by email (to privacy@gostreamline.io) or by writing to us at the address given at the end of this policy. We may allow you to view and modify settings relating to the nature and frequency of promotional communications that you receive from us in user account functionality on the Service. Please be aware that if you opt-out of receiving commercial email from us or otherwise modify the nature or frequency of promotional communications you receive from us, it may take up to fifteen business days for us to process your request, and you may receive promotional communications from us that you have opted-out from during that period, unless we are required by applicable law to process your request within a shorter period of time. Additionally, even after you opt-out from receiving commercial messages from us, you will continue to receive administrative messages from us regarding the Service.

Privacy Settings

Although we may allow you to adjust your privacy settings to limit access to certain Personal Information, please be aware that no security measures are perfect or impenetrable. To the fullest extent permitted under applicable law, we are not responsible for circumvention of any privacy settings or security measures on the Service. Additionally, we cannot control the actions of other users with whom you may choose to share your information. Further, even after information posted on the Service is removed, caching and archiving services may have saved that information, and other users or third parties may have copied or stored the information available on the Service. To the fullest extent permitted under applicable law, we cannot and do not guarantee that information you post on or transmit to the Service will not be viewed by unauthorized persons.

Do Not Track

Some web browsers incorporate a “Do Not Track” feature. Because there is not yet an accepted standard for how to respond to Do Not Track signals, our website does not currently respond to such signals.

Do Not Sell Personal Information

We will not sell your Personal Information to any third party without your prior written consent.

Additional Privacy Rights

Depending on your jurisdiction and applicable data protection legislation, you may have additional rights. If you are located in EEA or UK, you may have these additional rights in relation to the Personal Information that we hold:

Withdrawal of Consent

Where we rely on consent for the processing of your Personal Information, you have the right to withdraw your consent at any time.

Access

You have the right to access the Personal Information we hold about you, and to receive an explanation of how we use it and with whom we share it.

Correction

You have the right to correct any Personal Information we hold about you that is inaccurate or incomplete.

Erasure

You have the right to request your Personal Information to be erased or deleted.

Object to Processing

You have the right to object to our processing of your Personal Information where we are relying on a legitimate interest.

Restrict Processing

You have a right in certain circumstances to stop us processing your Personal Information other than for storage purposes.

Portability

You have the right to receive, in a structured, commonly used, and machine-readable format, Personal Information that you have provided with us if we process it on the basis of our contract with you or with your consent, or to request that we transfer such Personal Information to a third party.

Complaint

You have the right to lodge a complaint with a data protection supervisory authority in your country of residence, place of work, or where an incident takes place.

Exercising Your Rights

Please note that, prior to any response to the exercise of such rights, we may require you to verify your identity. In addition, we may have valid legal reasons to refuse your request and will inform you if that is the case. For more information on, or to exercise your rights, please email privacy@gostreamline.io.

5. Third-Party Services

This Policy applies only to the processing of your Personal Information by SDH. The Service may contain features or links to websites and services provided by third parties. The policies and procedures described in this Privacy Policy do not apply to Third Party websites. Any information you provide on third-party sites or services is provided directly to the operators of such services and is subject to those operators’ policies, if any, governing privacy, and security, even if accessed through the Service. We are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through the Service. We encourage you to learn about third parties’ privacy and security policies before providing them with information.

6. Children’s Privacy

Our Service is not directed to children under the age of 16, and we do not knowingly collect Personal Information from children under the age of 16 without obtaining parental consent. If you are under 16 years of age, then please do not use or access the Service at any time or in any manner. If we learn that Personal Information has been collected on the Service from persons under 16 years of age and without verifiable parental consent, then we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child under 16 years of age has obtained an account on the Service, then you may alert us at privacy@gostreamline.io and request that we delete that child’s Personal Information from our systems.

7. Data Security

We use certain physical, managerial, and technical safeguards that are designed to appropriately protect Personal Information against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the Personal Information in our possession. WE CANNOT, HOWEVER, ENSURE OR WARRANT THE SECURITY OF ANY INFORMATION YOU TRANSMIT TO US OR STORE ON THE SERVICE, AND YOU DO SO AT YOUR OWN RISK. WE ALSO CANNOT GUARANTEE THAT SUCH INFORMATION MAY NOT BE ACCESSED, DISCLOSED, ALTERED, OR DESTROYED BY BREACH OF ANY OF OUR PHYSICAL, TECHNICAL, OR MANAGERIAL SAFEGUARDS. The foregoing is subject to requirements under applicable law to ensure or warrant information security.

If, under applicable law, we learn of a security breach, then we may attempt to notify you electronically so that you can take appropriate protective steps. We may post a notice through the Service if a security breach occurs. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive a free written notice of a security breach, you should notify us at the address below.

8. Data Transfers

While SDH provides its Service globally, the Service is hosted in the United States. If you choose to use the Service, then please note that you are transferring your Personal Information outside of your jurisdiction to the United States and other regions where our data centers are located for storage and processing, which may not have the same level of data protection as that of your jurisdiction. Also, we may further transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Service.

If you’re from EEA or UK, when we transfer your Personal Information out of the EEA or UK, we will comply with applicable EEA/UK data protection laws and take appropriate measures to safeguard the security of your Personal Information. For example, we may transfer your Personal Information to countries which have been found to provide adequate protection by the EU Commission (e.g., Switzerland and Canada) to process and store your Personal Information, or we may use contractual protections for the transfer of your Personal Information to regions which haven’t been found to provide adequate protection by the EU Commission. You may contact us as specified below to obtain a copy of the safeguards we use to transfer your Personal Information outside of EEA or the UK.

9. Data Retention

We take measures to delete your Personal Information or keep it in a form that does not permit identification when this information is no longer required for the purposes for which we processed it unless we are required by law to keep this information for a longer period.

When determining the retention period, we consider various criteria which include:

Mandatory retention periods provided by law and the statute of limitations

Additionally, if you no longer desire to use our Service, you can choose to delete your account and associated information. We provide you with this option when accessing your account dashboard, where, after authenticating yourself and satisfying certain conditions, you’ll be able to request the deletion of your SDH account and associated information, unless we are legally required to keep it.

10. Changes and Updates to This Policy

Please revisit this page periodically to stay aware of any changes to this Policy, which we may update from time to time. If we modify the Policy, we will make it available through the Service, and indicate the date of the latest revision. If the modifications materially alter your rights or obligations hereunder, we will make reasonable efforts to notify you of the change. For example, we may send a message to your email address, if we have one on file, or generate a pop-up or similar notification when you access the Service for the first time after such material changes are made. If you have an SDH account, we may also notify you of any changes / updates to this Policy in your account dashboard. Your continued use of the Service after the revised Policy has become effective indicates that you have read, understood, and agreed to the current version of the Policy.

11. Contact Us

SDH is the entity responsible for the processing of your Personal Information as described in this Policy. If you have any questions or comments about this Policy, your Personal Information, our use and disclosure practices, your consent choices, or if you would like to exercise your rights, please contact us by email at privacy@gostreamline.io or write to us at:

Streamline Digital Holdings, LLC

P.O. Box 10933

Bradenton, FL 34282

Exhibit A

Cookie Policy

Our Site may use “Cookies” and other tracking technologies such as “Web Beacons.” Cookies are small text files that are transferred to your computer’s hard disk by the website. Web Beacons (also referred to as GIF files, pixels, or action tags) help us recognize a unique cookie on your browser. This information includes Personal Information and other information such as IP addresses, search terms, domain names, and browser types. We use these tracking technologies to collect this information and to track usage and other patterns on the Site. We may share this information with our partners, service providers, or other third parties.

Types of cookies we collect

Necessary Cookies

Necessary cookies allow us to offer you the best possible experience when accessing and navigating through the Site and using its features. For example, these cookies let us recognize that you have created an account and have logged into that account to access the Site’s content.

Functionality Cookies

Functionality cookies allow us to operate the Site in accordance with the choices you make. For example, we will recognize your username and remember how you customized the Site for future visits.

Analytical Cookies

Analytical cookies enable us and third-party services to collect aggregated data for statistical purposes on how our visitors use the Site.

Advertising Cookies

Advertising cookies allow us to personalize, measure, and deliver advertising and marketing messages.

How to delete cookies

If you wish to restrict or block the cookies collected by the Site, you may do so through your browser settings.

Third-party use of cookies and other tracking technologies

Some content or applications, including advertisements, on the Website are served by third parties, including advertisers, ad networks/servers, content providers, and application providers. These third parties may use cookies, alone or in conjunction with web beacons or other tracking technologies, to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.