1. Introduction

Techstrong Group, Inc., its subsidiaries and affiliates (together, “Techstrong,” “we”, “us” or “our”) is a provider of content for cybersecurity, DevOps, Digital Transformation and Cloud-native communities. Techstrong owns and operates over 12 different brands, websites and content aggregation online locations and publishes or sponsors articles, blogs, newsletters, definitions, surveys, research, and other original content. As such, Techstrong appeals to a wide range of individuals, some of whom casually visit our websites and reference our content and others who register to become members of our network of members. Our website visitors and members are generally professionals in their respective industries and, for those who chose to complete a registration form or otherwise chose to become a member, gain access to events and content subject to the terms of this Privacy Policy and our Terms of Use. In order for us to provide these services and events for free, members agree to receive personalized content, ads, and sales and marketing communications from us and our Partners (e.g., our clients that purchase our member contact information through lead generation, content syndication, branding, and other similar products and services) that are relevant to their professional interests. If you do not want to receive personalized content, ads, and sales and marketing communications from Techstrong and its Partners, please do not become a member. Importantly, you can unsubscribe from these communications at any time, while continuing to receive free access to our content.

We are committed to your data protection and data privacy. We recommend you read this Privacy Policy to better understand what information we collect, how we use it, and who we may share it with. Additionally, this Privacy Policy will provide you with details on how you can control the use and disclosure of your information.

Please note that Techstrong is deemed a “data controller” as it relates to any Personal Data or Personal Information (as those terms are defined by applicable law) shared in connection with your use of our website, including your membership information, as applicable. By visiting, joining, or using Techstrong, or otherwise indicating that you agree to this Privacy Policy, you agree to, and authorize our use of your Personal Information as described in this Privacy Policy.

If you have any questions regarding this Privacy Policy, please contact us through the “Contact Us” link on any of our websites, by emailing us at: [email protected].

2. What Does this Privacy Policy Cover?

This Privacy Policy covers information collected by Techstrong through its websites and details the Personal Data that we process and collect from website visitors, users completing a registration form to become a Techstrong member, Service Providers and third parties who perform functions for us, personnel who are our employees or authorized contractors, and job applicants. For purposes of this Privacy Policy, Personal Data means any information relating to an identified or identifiable natural person. From time to time, Techstrong may utilize the services of third parties such as data append or data hygiene service providers and receive other Personal Data from these service providers to, among other things, ensure the accuracy of its membership records. As such, Techstrong’s services may include Personal Data received from third parties.

3. What Information Do We Collect or Receive?

We collect or receive information in several different ways. In many cases you choose what information to provide.

A. Directly from You. We collect a variety of information from you when you provide it to us directly or when we request it from you. Some examples of these instances are as follows:

  • Personal Data that you Provide to Us. We receive, store, and collect any Personal Data you provide to us directly through one of our websites or give us in any other way, including business cards, emails, and telephone communications. For example, when you fill out and submit a registration form to become a Techstrong member, register for a webinar or virtual event, download a specific piece of content, or in person physical event or had your badge scanned as part of your attendance at such event, then we may have received your contact information including your company, name, work address, business email, phone number, job information, and geographic location. We may ask you for similar information at other times.
  • Information About Others Who May be Interested in Our Content or Websites. Our websites may include an “share this” feature, which allows someone to email or send content to a third party. If you utilize the feature, we will only use the email address of the intended recipient for purposes of emailing the respective content to that person. You should never share another person’s Personal Information with others without first receiving their permission.
  • Member Generated Content. Some websites feature member generated content in the form of a member review section or forum communities. In order to interact in these forums, an individual must first complete the applicable registration form. The information provided by the individual may be displayed in the individual’s public profile in our forums and can be viewed by all visitors to the website. To ensure individuals’ privacy, we do not display any the email addresses of individuals who have commented in such forums or who have contributed such content.

B. Third Party Service Providers and Partners. We engage third party service providers and partners to provide us with information, and we also use publicly available sources, to supplement our member account information to help improve personalization of our services. For example:

  • Supplementary and Third-Party Information. We may collect, obtain, or supplement your Personal Data from third parties who license it to us or otherwise provide it to us. This may include information provided through telephone, mailings, or events, from customers, vendors, suppliers, third parties, or commercially available sources (e.g., data brokers, data aggregators, public databases, etc.), and from third party partners or affiliates running co-branded campaigns or membership initiatives. For example, we may contract with a third-party partner or affiliate to contact you by email or telephone to determine if you would be interested in certain content tailored to your professional interest and/or becoming a member.
  • Public and Social Network Sources. We may collect or obtain your Personal Data from publicly accessible sources like corporate websites, business listings, or social networking platforms. You can opt-out of the third parties’ (such as a social media network or advertiser platform) collection and use of information for ad targeting by updating your account ad settings with the third party or by following the instructions regarding Tracking Technologies described in the paragraph below.

C. Cookies and Other Tracking Tools. We use Cookies, Clear GIFs, Web Beacons, Tracking Technologies or other similar solutions (“Tracking Technologies”) to collect or receive certain information when you visit or use a Techstrong website or read an email, newsletter, or otherwise interact with content from us. These Tracking Technologies may include first party cookies (i.e., those placed by the website being visited) and third party cookies (i.e., those placed by a website other than the one being visited), local shared objects (commonly referred to as “Flash Cookies” or “HTML 5 Cookies”) and tracking pixels (including transparent or clear gifs).

Cookies are small data files which are placed on your computer or mobile device when you visit a website or use an online service. For example, cookies enable us to identify and authenticate you and remember your preferences so we can enhance your experience on our websites. They also help us serve you ads relevant to your professional interests and to provide aggregated auditing, research, and reporting for advertisers, understand and improve our service, and know when content has been shown to you. Because your web browser may request advertisements and beacons directly from third party ad network servers, these networks can view, edit, or set third party cookies, just as if you had requested a web page from their site. Ads served by Techstrong may also set third party cookies. Most browsers are initially set up to accept cookies, but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent.

We strongly recommend that you leave the cookies activated, however, because cookies enable you to take advantage of some of Techstrong’s website features and if you decline or delete them then parts of our website and services may not work properly. Even if you decline or delete cookies, you will continue to be served with advertisements; however, they will not be tailored to your preferences, usage patterns or professional interests. Where legally permitted, we will assume that you have agreed to receive all cookies on our websites through your continued use; otherwise, your acceptance of such cookies by way of your browser settings or our consent management tool shall be deemed your acceptance of the use of such Tracking Technologies.

Techstrong and our Partners use several different types of cookies on our websites, including the following.

  • Strictly Necessary Cookies. Strictly necessary cookies facilitate the operation of our websites. Without the use of these cookies, portions of our websites would not function properly. For example, we use essential cookies to help us identify which of our visitors have previously registered in order to access our Premium Services.
  • Performance Cookies. Performance cookies help us monitor the performance of our websites and how users interact with them. These cookies collect information such as how often users visit our websites, what pages they visit when they do so, and what other websites they used prior to coming to our websites and provide us with information that allows us to improve our websites and services.
  • Functional Cookies. Functional cookies are used to remember your preferences on our websites and to authenticate your identity. For example, we use functional cookies to recognize and save your name and password on our websites.
  • Flash Cookies. When you use one of our websites that employs Macromedia Flash Player, a small Flash Cookie may be used. The purpose of using these cookies is to store your flash player preferences and enhance your browsing experience.
  • Behavioral Advertising Cookies. Techstrong and its Partners use behavioral advertising cookies in order to provide you with advertising which is tailored to your interests when you visit websites on and off our network. Behavioral advertising cookies analyze information about your interests and your browsing history and provide you with advertisements on and off our network that match these interests. Behavioral advertising is a type of advertising that is based upon your web browsing activity over a period of time – so it’s different than advertising you may see when you’re looking for something online using a search engine (e.g., Google, Yahoo, or Bing) or on a website you may be visiting at a particular time. As an example, you may be doing research on products and services related to data center virtualization. If a data center virtualization provider is conducting an advertising campaign on our network, as you browse the relevant portions of our websites, then we may serve you with an advertisement of one of their solutions.

Although our websites currently do not respond to “do not track” browser headers, you can limit tracking through third-party programs and by taking the other steps discussed in this section. You may opt-out of Techstrong’s internet-based advertising by removing cookies or by setting your web browser settings to refuse cookies and similar Tracking Technologies. Please note that web browsers operate using different identifiers. As such, you must adjust your settings in each web browser and for each computer or device that you would like to opt-out on. Further, if you simply delete your cookies, you will need to remove cookies from your device after every visit to websites. You may block cookies entirely by disabling cookie use in your browser or by setting your browser to ask for your permission before setting a cookie. Blocking cookies entirely may cause some websites to work incorrectly.

Please note that the use of online tracking mechanisms by third parties, such as our Partners, is subject to those third parties’ own privacy policies, and not this Privacy Policy. You may remove yourself from the targeted advertising of companies within the Network Advertising Initiative by opting out here, or of companies participating in the Digital Advertising Alliance program by opting out here, the Digital Advertising Alliance of Canada (DAAC) (for Canadian users) by opting out here; or the European Interactive Digital Advertising Alliance (EDAA) (for users in the EU) by opting out here.

Google reCAPTCHA. In addition to the foregoing, in order to protect our registration forms and other website features, we use Google reCAPTCHA provided by Google Inc. (“reCAPTCHA”). We employ reCAPTCHA to check whether data is entered into our forms by a person or by an automated program, script or bot. reCAPTCHA analyzes the behavior of the person entering the data using various features. This analysis starts automatically as soon as the website is accessed. For analysis, reCAPTCHA evaluates various information (e.g., IP address, browser type, settings, and plugins, URL of the referring website, time spent on the respective website, mouse movements, input characteristics of the data entry, including speed, sequence and selection of inputs, etc.). The data collected during the analysis is forwarded to a Google server in the USA, where it is stored and evaluated. We carry this processing out based on our legitimate interest in preventing the misuse of our websites through automated means. You can find Google’s current privacy policy at: https://policies.google.com/privacy. Detailed information about Google reCAPTCHA can be found at the following address: https://www.google.com/recaptcha.

Additionally, Techstrong may use other CAPTCHA and similar technology providers from time to time.

4. Why Do We Collect Personal Data?

We collect Personal Data about you to provide you with the best and most useful content and services and to offer you opportunities to obtain other products and services from us and our Partners. By providing us with your Personal Data, we can cater our content and services to your interests and ensure that you receive relevant offers. Additionally, the collection and use of your Personal Data helps us tailor and improve our services and communicate with you effectively as we know many of our website visitors and members make use of a range of media channels. Finally, collecting and sharing your Personal Data with our Partners makes it possible to operate our business and provide you with free content, products, or services relevant to your professional interests.

5. What is the Legal Basis for the Processing of Personal Data?

We only collect and process your Personal Data as permitted by applicable law. These lawful bases include where it is: necessary for the performance of a contract to which you are a party; necessary for us to take steps, at your request, to enter into such a contract; necessary for the purposes of our legitimate interests or those of a third party and not overridden by the interests or fundamental rights and freedoms of any data subject; where you provide us with consent; or necessary for compliance with a legal obligation to which we are subject. Under applicable law, we may be obliged to secure and maintain technical and organizational measures to protect the security of your data, investigate and report any (suspected) breaches of those technical and organizational measures, or comply with legal and regulatory obligations, including, but not limited to, complying with minimum retention periods for certain types of data.

6. How is Your Personal Data Used?

We use, aggregate, and retain your Personal Data as needed to provide you with access to content, products, and services catered to your professional interests and for other legitimate business reasons. Some information is required in order to use our websites and for us to provide the Premium Services. At a high level, we use the Personal Data that has been provided by you directly or indirectly:

  • To provide you with our services including, publications, and information that you request, access, or which may be of interest to you (e.g., sending you whitepapers and newsletters regarding information you are researching);
  • To create your member profile
  • To send you satisfaction questionnaires, surveys, and marketing information.
  • To deliver or display content, advertisements, and other materials that match your professional interests and responsibilities for the purposes of online behavioral advertising (e.g., displaying advertisements that relate to your business or research);
  • To tailor the newsletters delivered to you based on your activity, interests, and responsibilities;
  • For Techstrong and its Partners to contact you for direct marketing purposes regarding information about, and invitations for, products, services, and events relevant to your professional interests and responsibilities;
  • To communicate with you, advertise to you or invite you to join us on social media platforms on which you participate;
  • To offer you opportunities to connect directly with your peers and with providers of technologies, goods, and services that may be of interest to you;
  • To operate our websites and improve our products and services;
  • To understand trends, usage statistics, and purchase-intent data;
  • To respond to your product or service inquiries or support requests and comments;
  • To test and evaluate potential new products and features;
  • To diagnose and resolve problems, analyze trends, and monitor usage and resource needs; and
  • For any other purpose that we tell you about when you give us your Personal Data.

By way of example, we analyze information collected from you to (a) help us recognize your computer as a previous visitor, and save and remember any preferences that you may have while you were visiting one of our websites or a co-branded website, (b) track, accumulate and report information on our website and content usage to our Partners so that they can measure the effectiveness of advertisements and content viewed on the website, (c) help us customize the content that you are shown while visiting the websites and potentially other websites, (d) to help us improve the quality and presentation of our content and websites, (e) to personalize your user experience, and (f) identify market sensitivities and relative market interest in specific product categories. Techstrong also uses the information that is collected to link your activity to your member account. Linking this activity allows our system to confirm your identity on our websites and allows easy access to our content by saving and recognizing member log-in information.

In addition to providing you with our own editorial content, we offer you the opportunity to access the branded content and expertise of our Partners. When you choose to take advantage of our Partner’s content or expertise, you choose to have your Personal Data shared with them as well. Techstrong and its Partners may use information collected from you directly to provide you with access to content related to your interests based on your activity on our websites and other information that you have shared with us. Techstrong and its Partners may, subject to applicable law, also send you emails on topics of interest, marketing research surveys, incentives, as well as promotional emails and direct marketing offers for products and services. We also use your information in aggregated form as well to understand our member base, and to market our services to our customers. In addition, we may inform our customers that a pre-existing contact in their marketing and sales databases is also a member of our websites subject to the terms and conditions of their purchase of such services.

7. Who Do We Share Your Information With?

Techstrong shares information with service providers, affiliates, Partners, and other third parties where it is necessary to meet the requirements of our Terms of Use, to provide the Premium Services, or for any other purposes described in this Privacy Policy.

Partners. Techstrong provides Partners with access to business contact lists and reports that may include your Personal Data and information about your areas of interest derived from your activity on our websites and interaction with our content or Partner content that has been published on our websites. Partners use this information to improve their sales and marketing outreach to their target audience and to optimize their sales and marketing strategies. They may also use this information to contact you about products or services that are relevant to your professional interests. For example, a summary report which is provided to a Partner may include a statement like the following “3,000 people looked at the xyz white paper this week and, of those 3,000 people, 60% clicked through to read the full white paper.” Information provided in summary reports is aggregated and does not disclose any member information. Techstrong may also disclose aggregated user statistics (for example, “25% of our users are interested in Networking”) to our customers, prospective customers and Partners and other third parties, and for other lawful purposes. Techstrong’s contractual arrangements with its Partners, when subject to our standard terms and conditions, require, among other things, that our Partners (a) only use this information to contact you via email, telephone, mail or other means of communication for internal sales and marketing purposes; and (b) secure and protect your information in accordance with applicable law and our instructions. If you do not want this information shared, please see “Your Privacy Rights and Controlling Your Personal Data” below.

Vendors and Service Providers. Techstrong may provide your Personal Data to certain vendors and service providers who are working for or with Techstrong as described in this Privacy Policy and who require access to such information to facilitate the provision of our services, such as the provision of data storage or processing activities, member acquisition or lead generation services, or corporate auditing services. Techstrong will always attempt to limit the information that we provide to what is reasonably sufficient for those vendors or service providers to carry out their responsibilities as they relate to the fulfillment of our services.

Third-Party Analytics and Interest-Based Advertising Partners. We allow our third-party analytics and interest-based advertising partners to collect certain information on our websites, as described above in Section 3.

Business transfers, Affiliates, and Subsidiaries. We may share or transfer the information that we collect in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. We may share your Personal Data within our organization, including with our affiliates and subsidiaries, in order to facilitate the provision of services in connection with your use of our websites or your membership to our network of websites.

Vital Interests. We may disclose the information that we collect where we believe that it is necessary in order to protect the vital interests of any person, or to exercise, establish, or defend our legal rights.

Other ways in which you specifically consent We may share the information that we collect in other ways that you specifically consent.

Legal Compliance and Public Safety. We may share your Personal Data when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to (a) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (b) enforce our agreements, (c) investigate and defend ourselves against any third-party claims or allegations, (d) protect the security or integrity of our services; or (e) exercise or protect the rights and safety of our members, personnel, or others. We may attempt to notify members about legal demands for their Personal Data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.

8. Data Retention.

We retain your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We will retain member’s Personal Data for so long as a member’s account remains in existence or as needed to provide our Premium Services to our member, to comply with our legal obligations, to resolve disputes, and to enforce our agreements. We may retain Personal Data after a member has cancelled their membership if retention is reasonably necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce this Privacy Policy and our Terms of Use. We may also retain Personal Data, for a limited period, if requested by law enforcement.

9. How Do We Protect Your Information?

Techstrong takes the security of the data that it collects very seriously. Techstrong has implemented a myriad of technical, organizational and administrative measures which are generally accepted by the industry to protect the Personal Data in its possession. These measures include, but are not limited to, the implementation of current security technologies and processes to protect your information from loss, misuse and unauthorized access, disclosure, alteration or destruction. Our security systems include authenticated access to internal databases, regular audits of processes and procedures, scheduled reviews of overall web security, and the use of restrictions of access to Personal Data in our possession. Additionally, we use encryption (HTTPS/TLS) to protect data transmitted to and from our websites.

10. Your EU and UK GDPR Privacy Rights and Controlling Your Personal Data.

If you wish to access, rectify, erase, restrict, transfer, or object to the use of your information, or deactivate your membership, you can contact us at [email protected] If you have any other questions in connection with this Privacy Policy or the use of your personal information, please send us an email at [email protected].

Every email sent by or on the behalf of Techstrong includes information as to how you can easily unsubscribe from future communications.

Subject to applicable law, you have the following rights in relation to your Personal Data:

  • Right of access: If you ask us, we will confirm whether we are processing your Personal Data and, if so, provide you with a copy of that Personal Data (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.
  • Right to rectification: If your Personal Data is inaccurate or incomplete, you are entitled to have it rectified or completed. If we have shared your Personal Data with others, we will where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so that you can contact them directly.
  • Right to erasure: You may ask us to delete or remove your Personal Data and we will do so in some circumstances, such as where we no longer need it (we may not delete your data when other interests outweigh your right to deletion, for example if we are required by law to keep it). If we have shared your data with others, we will tell them about the erasure where possible. If you ask us, where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so that you can contact them directly.
  • Right to restrict processing: You may ask us to restrict or ‘block’ the processing of your Personal Data in certain circumstances, such as where you contest the accuracy of that Personal Data or object to us processing it. We will tell you before we lift any restriction on processing. If we have shared your Personal Data with others, we will tell them about the restriction where possible. If you ask us, where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so that you can contact them directly.
  • Right to data portability: You have the right to obtain your Personal Data from us that you consented to give us or that is necessary to perform a contract with you. We will give you your Personal Data in a structured, commonly used and machine-readable format. You may reuse it elsewhere.
  • Right to object: You may ask us at any time to stop processing your Personal Data, and we will do so if we are processing your Personal Data for direct marketing and otherwise. However, if we are relying on a legitimate interest to process your Personal Data and we demonstrate compelling legitimate grounds for the processing we may continue; or
  • Rights in relation to automated decision-making and profiling: You have the right to be free from decisions based solely on automated processing of your Personal Data, including profiling, which produce a significant legal effect on you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us, or with your explicit consent.
  • Right to withdraw consent: If we rely on your consent to process your Personal Data, you have the right to withdraw that consent at any time. Your withdrawal of consent will not affect apply to data that was processed prior to our receipt of your withdrawal of consent.
  • Right to lodge a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we have handled your Personal Data, you can report it to the data protection authority that is authorized to hear those concerns.

11. Privacy Shield / Transfer of Your Information?

Update: On July 16, 2020, the Court of Justice of the European Union (CJEU) invalidated the EU-U.S. Privacy Shield. Following the CJEU decision, the U.S. Department of Commerce announced that it will continue to enforce the Privacy Shield for current registrants while working with the EU Commission to develop and implement a new data transfer framework. Further, on September 8, 2020, the Swiss Data

Protection Authority announced that it no longer considers the Swiss-U.S. Privacy Shield adequate for the purposes of transfers of personal data from Switzerland to the U.S. In light of these decisions, the Company will continue to honor its commitments under the Privacy Shield and will rely on Standard Contractual Clauses for the transfer of personal data and/or another appropriate legal basis for data transfers, where required. We will continue to monitor guidance regarding appropriate and lawful transfer mechanisms and will update our processes as needed.

Techstrong collects, stores, transfers, and processes Personal Data in accordance with applicable data protection law, including where it is necessary to provide our services, to perform the Terms of Use, or to perform obligations under contract. We may transfer your information to affiliates, partners and other third parties as described herein. We will protect your Personal Data in accordance with this Privacy Policy wherever it is processed.

Techstrong complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework (together, the “Privacy Shield.”) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Data transferred from the European Union, the United Kingdom, and Switzerland to the United States in reliance on Privacy Shield. Techstrong has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

Techstrong has certified that (1) it has certain protections and procedures in place which meet EU and Swiss data protection and privacy standards, (2) it adheres to the Privacy Shield principals of notice, choice, security, data integration and purpose limitation, access, accountability for the onward transfer of personal data, recourse, enforcement, and liability, and (3) it is committed to cooperating with the panel established by the EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning data transferred from the United States in connection with this Privacy Policy. In the context of an onward transfer of Personal Information that is subject to the Privacy Shield Framework, Techstrong may have responsibility for the processing and transfer of Personal Information. Techstrong will remain liable under the Privacy Shield principles if a third party agent processes Personal Information in a manner that is inconsistent with the Privacy Shield principles, unless Techstrong proves that it is not responsible for the event giving rise to the damage. To learn more about the EU-US Privacy Shield, and to view Techstrong’s certification, please visit the Privacy Shield website. Techstrong’s commitments under the Privacy Shield are subject to the investigatory and enforcement powers of the United States Federal Trade Commission.

If you have questions about Techstrong’s commitment to the Privacy Shield, complaints about our privacy practices, or in the event that you consider our processing of your personal information to not comply with applicable data protection laws you can lodge a complaint directly with us by sending an email to [email protected].

You can lodge a complaint with the competent data protection authority. Techstrong further commits to cooperate with the panel established by the EU or United Kingdom data protection authorities (DPAs) and/or the Swiss Federal Data Protection and Information Commissioner, as applicable and comply with the advice given by the panel and/or Commissioner, as applicable with regard to data transferred from the EU, United Kingdom, and/or Switzerland, as applicable.

12. Children’s Privacy.

Our products, services, events and offerings are directed to professionals. Our business is not directed at children, and we do not solicit or knowingly collect any personal information from children under the age of 16 without verifiable parental consent. If you are not 18 or older, you are not authorized to use our websites or services. Parents should be aware that there are parental control tools available online that you can use to prevent children from submitting information online without parental permission or from accessing material that is harmful to minors. If you learn that a child under 13 has provided us with Personal Data without consent, please contact us via the information provided below.

13. Your California Privacy Rights.

If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information to third parties for their direct marketing purposes. To learn more about your California privacy rights, please read our CCPA Privacy Notice. To request a list of the names and addresses of third parties to whom we disclosed such information during the preceding calendar year along with a list of the categories of information disclosed, please send an email to [email protected] or write to us at the address listed in Section 16 below.

14. Your LGPD Privacy Rights

If you are a resident of Brazil, the Lei Geral de Proteção de Dados Pessoais (LGPD), Federal Law No. 13,709/2018, may provide you with additional privacy rights with respect to the collection and use of your personal information. To learn more about your Brazil privacy rights, please read our LGPD Privacy Notice.

15. Changes to this Privacy Policy.

Techstrong may modify or amend this Privacy Policy from time to time. If we change our Privacy Policy, we will post those changes in addition to updating the “Last Updated” date at the top of this policy. We encourage you to read this Privacy Policy regularly. Where applicable, your continued use of our Premium Services, our websites, or accessing content posted on our websites shall constitute your acceptance of the modified or amended Privacy Policy. If there will be any changes made to the use of your Personal Data in a manner materially different from that stated at the time of collection, we will notify you by posting a notice on our website.

16. How to Contact Us?

If you wish to exercise any rights that you may have to your Personal Data, you can contact us via: [email protected].

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