Global Privacy Policy

Introduction

ON-STRATEGY, LLC is committed to protecting and respecting the privacy of individuals.
This policy sets out how and why we collect, use, and disclose personal information of individuals who interact with ON-STRATEGY, LLC, as well as how we safeguard this information.
This policy also covers information that is collected, used, or disclosed through use of our websites, which are available to visitors located throughout the world and operated for different purposes.

Personal Information

Personal information means information that identifies you or could reasonably be used to identify you. Examples of personal information include your name, address, e-mail address, affiliated organization or company name, birth date, age, gender, telephone number, account numbers, profession or specialty, education, or other specific types of personal information. It also includes certain highly sensitive information about an individual, such as race, religion, gender, sexual orientation, medical/health records, credit card information, dietary requirements, and political beliefs. Some kinds of personal information are sensitive personal information. In this policy when we use the term personal information, we include sensitive personal information unless we specifically state otherwise.

Examples of Personal Information relevant to ON-STRATEGY, LLC business may include:
• Client or Prospect Information: Name, email address, business address, employer/ company-related information, website registration, subject matter preference information. This information may be found on marketing/mailing/contact lists (e.g., in contacts function of MS Outlook or on a PDA), in corporate data bases, on spreadsheets.
• Event Attendee and/or Sponsor Information: Name, email address, business address, employer/ company-related information, credit card information (in rare instances). This information may be found on registration forms/profiles, attendee lists, business cards, photos, video clips, online streaming.
• Sales Order Fulfillment Information: Name, email address, business address, employer/ company-related information. This information may be found on Sales Order Forms, Inquiry record.
• Third Party Service Provider Information: Name, email address, business address, employer/company-related information. This information may be found in corporate databases.

Useful Terms

• Processing: any operation that is performed on Personal Information, whether or not by automatic means, such as collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction.
• Sensitive Personal Information: a subset of Personal Information, which due to its sensitive nature has been classified by law or policy as deserving heightened privacy protections. Sensitive Personal Information includes, without limitation: race, ethnicity, medical records. As a rule, ON-STRATEGY, LLC does not accept Sensitive Personal Information of any class and in kind, shape or form, since it is not needed for our business.
• Third Party or Third Party Service Provider is any natural or legal person, public authority, agency or other body outside of ON-STRATEGY, LLC that processes Personal Information solely on behalf of and under the instructions of ON-STRATEGY, LLC. All such Third Parties agree to collect, safeguard and use the Personal Information in accordance with the terms of this Policy and applicable data privacy laws.

Collection and Use of Personal Information

We and our service providers collect any information that you provide when you use the Online Services. For example, when you register for a service, we may collect basic information about you such as your name, username, password, email address, physical address, phone number, and other personal and business demographic or contact information.
We use the information we collect and receive from you to provide you with Online Services; to communicate with you; to operate, maintain, and enhance the Online Services; and to fulfill your specific requests. For example, if you send us an email message requesting information about ON-STRATEGY, LLS, we will use your email address and other information you supply to respond to your request. If you send us a resume or curriculum vitae (CV) to apply online for a position with ON-STRATEGY, LLC, we will use the information that you provide to match you with available job opportunities. Your personal information is not used for other purposes, unless we obtain your permission, or unless otherwise required or permitted by applicable data privacy laws.

• Cookies: ON-STRATEGY, LLC may employ a cookie, or small piece of information stored on a file in the ON-STRATEGY, LCC User’s browser or hard drive, which enables Web servers to “identify” that User each time he/she initiates a session on a ON-STRATEGY, LCC Web site. Unless the User has adjusted his/her browser settings to refuse cookies, the ON-STRATEGY, LCC system will issue a cookie when the User visits a ON-STRATEGY, LCC Web site. Important information about cookies:
o First Party cookies are set by the ON-STRATEGY, LCC Web site you are visiting.
o Third Party cookies are set by a domain outside of the ON-STRATEGY, LCC Web sites.
o Persistent cookies remain on your computing device for the period specified in the cookie and are activated each time you revisit the website that set such cookie.
o Session cookies remain on your computing device until you close your browser window, at which point they are automatically deleted. ON-STRATEGY, LCC uses cookie technology to enable registered Users (i) to move quickly and securely through access-controlled areas of the Web sites; and (ii) to take advantage of certain useful features on the sites, such as “remember my password.”
• Email alerts: ON-STRATEGY, LCC Users are asked to provide their email address when signing up for email alerts on ON-STRATEGY, LCC Web sites.
• Event Registration: Where ON-STRATEGY, LCC collects Personal Information for Event Registration, ON-STRATEGY, LCC will not disclose such information to any Third Party (other than in connection with administration of the ON-STRATEGY, LCC Event) without the registrant’s consent. ON-STRATEGY, LCC does not rent, sell or otherwise disclose this collected Personal Information for non-Event-related mailings.
• ON-STRATEGY, LCC Web Sites: The ON-STRATEGY, LCC Web sites are owned and operated by ON-STRATEGY, LCC to deploy the ON-STRATEGY, LCC products and services. ON-STRATEGY, LCC does not sell, rent or share (outside the ON-STRATEGY, LCC family) Personal Information collected on the ON-STRATEGY, LCC Web sites. ON-STRATEGY, LCC obtains the User’s consent prior to disclosing Personal Information to Third Parties for consumer marketing purposes. ON-STRATEGY, LCC Web sites may contain links to other Web sites. ON-STRATEGY, LCC is not responsible for the privacy practices of such other sites. ON-STRATEGY, LCC Users should be aware when leaving a ON-STRATEGY, LCC Web site and should read the privacy statements of the new Web site they enter.
• Purchases & Fulfillment: When ON-STRATEGY, LCC Users place an order or register for an Event, additional Personal Information, such as credit card number and expiration date, may in some instances be requested. ON-STRATEGY, LCC may also collect additional information about hotel, meal and other travel preferences. This Sensitive Personal Information, which is used solely for confirmation and billing purposes and to service the order, is used only for the purpose identified hereunder and is deleted in a secure and timely manner once that purpose has been served.
• Recruiting. Candidates for employment must provide Personal Information as required by the recruiting and interview process, such as full name and mailing address, personal email address, job resume, photo, references and other employment-related information. This information is retained by ON-STRATEGY, LCC only until such time as the successful candidate is appointed, or the unsuccessful candidate requests that ON-STRATEGY, LCC continue to retain his/her Personal Information for future opportunities.
• Registration for ON-STRATEGY, LCC Web sites: When ON-STRATEGY, LCC Users register on ON-STRATEGY, LCC Web sites, or for ON-STRATEGY, LCC events, or to purchase products, ON-STRATEGY, LCC may request certain Personal Information. ON-STRATEGY, LCC uses this Personal Information to provide advice and service, as well as to share offers deemed relevant by ON-STRATEGY, LCC. In circumstances where data processing is not permitted under local law, ON-STRATEGY, LCC requests express consent from the ON-STRATEGY, LCC User. ON-STRATEGY, LCC may also contact ON-STRATEGY, LCC Users regarding Web site problems or other customer service-related issues.
• Social Media: Online social media resources are interactive tools that enable ON-STRATEGY, LCC Users to collaborate and share information with others. Social media resources include but are not limited to social networks, discussion boards, bulletin boards, Blogs, Wikis and referral functions to share Web site content and tools with a friend or colleague. Where a ON-STRATEGY, LCC User makes specific reference to ON-STRATEGY, LCC on a social media resource, ON-STRATEGY, LCC may collect the ON-STRATEGY, LCC User’s Personal Information. When using social media resources, ON-STRATEGY, LCC Users are advised to take care with what Personal Information they share with others. ON-STRATEGY, LCC provides additional notice and choices on its Web sites about how Personal Information is collected, used and disclosed with regard to social media resources.
• Usage Tracking: ON-STRATEGY, LCC may monitor how Users use its Web sites, including search terms entered, pages visited and documents viewed. For registered Users, this information is stored with their registration information. It is uniquely numbered, and is used solely for purposes of enabling ON-STRATEGY, LCC to provide the registered User with a personalized Web site experience. This data may also be used, in an aggregated (i.e., not personally identifiable) format to (i) help ON-STRATEGY, LCC understand areas for future research; and (ii) identify appropriate product offerings and subscription plans. This same data may also be used by ON-STRATEGY, LCC clients, in a form that is personally identifiable to the specific client, to better understand how their employees are using their ON-STRATEGY, LCC subscriptions.
• Choice: We do not share personal information about you outside ON-STRATEGY, LCC unless you give us permission to do so or when the law requires it. ON-STRATEGY, LCC gives each User the opportunity to opt-out (i) from allowing ON-STRATEGY, LCC to disclose his/her Personal Information to a Third Party unless the disclosure is required by law or is for the fulfillment of a contractual obligation (e.g., employment contract) and (ii) from allowing ON-STRATEGY, LCC to process Personal Information for a purpose other the original purpose for which it was collected or the purpose authorized subsequently by the User. An “Unsubscribe” link and other identifying information as required by applicable law, is provided in each electronic communication sent by ON-STRATEGY, LCC (other than those required by law or to administer a current contract) so that the User may manage their marketing communication preferences to opt-out or otherwise direct the proposed use of their Personal Information.
• Children: ON-STRATEGY, LCC understands the importance of protecting children’s privacy, especially in an online environment. In particular, our Online Services are not intentionally designed for or directed at children. It is our policy never to knowingly collect or maintain information about anyone under the age of 18. Cross Border Transfer: ON-STRATEGY, LCC may transfer certain PII across geographical borders to other ON-STRATEGY, LCC member firms or outside companies working with us or on our behalf. ON-STRATEGY, LCC may also store PII in a jurisdiction other than where you are based and such jurisdiction may not provide the same level of protection for your personal information as your home country. By providing your information to ON-STRATEGY, LCC, you are consenting to this transfer and/or storage of your information across borders.

SECURITY & ENFORCEMENT

We safeguard and protect your Personal Information. We educate our employees and service providers on our Privacy Policy and Principles as well as their roles and responsibilities in complying with them; and we enforce remedial penalties for non-compliance. At ON-STRATEGY, LCC, we:
• maintain the security and confidentiality of Personal Information;
• safeguard against any anticipated threats or hazards to the security, confidentiality and integrity of Personal Information; and
• protect against unauthorized access, disclosure, alteration or destruction of Personal Information that could result in harm to ON-STRATEGY, LCC or ON-STRATEGY, LCC Users.
The nature and extent of protection will correspond to applicable local laws and regulations.