Privacy Policy

PRIVACY POLICY

YOUR PRIVACY IS IMPORTANT TO US

Apex Systems d.b.a Stratacuity (“the Company”, “we”, “our” or “us”) is committed to protecting the privacy and security of your personal information. This Privacy Policy describes how the Company may collect, use, disclose, and safeguard personal information that we may collect about you through our websites, and via offline means such as during interactions with our corporate suppliers and customers, via trade shows or other offline interactions, where applicable. This Privacy Policy also tells you about your rights and choices with respect to your personal information, and how you can reach us to exercise your rights and get answers to your questions. Our privacy practices with respect to personal information about our employees and contractors, past and present, are addressed through other internal company policies and procedures, and are outside the scope of this Policy.

This Privacy Policy covers:

1. Information We Collect About You

2. How We Collect Your Personal Information

3. How We Use Your Personal Information

4. Disclosures of Your Personal Information

5. Data Security

6. Retention Period

7. Your Rights in Relation to Your Personal Information

8. Other Important Information

9. California Information Sharing Disclosure

10. Contact Us

1. Information We Collect About You

We collect, maintain, and use different types of personal information in the context of our relationship or potential relationship with you. The following provides examples of the type of information that we collect from you and how we use the information.

Context	Categories of Information	Primary Purpose for Collection and Use of Information
Commercial Information	We collect basic identifying information such as your name, title, employer, and contact information such as your work and/or personal email address, and telephone numbers (including your mobile number).	We have a legitimate interest in communicating with our clients concerning normal business administration such as projects, services, and billing. We have a legitimate interest in fulfilling our contract with you for the provision of services.
Client Information	We collect the name, and contact information, of our clients and their employees with whom we may interact.	We have a legitimate interest in contacting our clients and communicating with them concerning normal business administration such as projects, services, and billing.
Cookies and First Party Tracking	We use cookies and web beacons, clear GIF, pixels, internet tags, and other similar tracking technologies (collectively “tracking technologies”) to monitor how you interact with our websites. This may include which links you click on, information that you type into our online forms, or identifying information about your device or browser. For more information relating to the use of such tools, review the “Cookie and Similar Tracking Technologies” section below.	We have a legitimate interest in making our website operate efficiently, providing account related functionalities, understanding how you interact with our websites to better improve them, and maintaining security standards. We also have a legitimate interest in detecting and preventing fraud.
Cookies and Third Party Tracking	We collect information about your internet or other network activity including your device identifier, Internet Protocol (IP) address, mobile ad identifier, or similar unique identifiers, so that we can provide advertising about products and services tailored to your interests on our websites, or on other websites. For more information relating to the use of such tools, review the “Cookie and Similar Tracking Technologies” section below.	We have a legitimate interest in engaging in behavior-based advertising.
CCTV Recording and Photographs	Your image which may be recorded on CCTV or by our sign in system when you visit our premises.	We have a legitimate interest in protecting our customers, our premises, assets, and business partners from crime. We operate CCTV security and sign in systems in a number of our premises and parking lots which record images for security.
Email Interconnectivity	If you receive email from us, we use certain tools to capture data related to when you open or interact with our messages.	We have a legitimate interest in understanding how you interact with our communications to you.
Feedback/Support	If you provide us feedback or contact us for support we will collect your name and e-mail address, as well as any other content that you send to us, in order to reply.	We have a legitimate interest in receiving, and acting upon, your feedback or issues.
Mailing List	When you sign up for one of our mailing lists we collect basic identifying and contact information such as your name, email address or postal address.	We disclose information about our services with individuals that consent to receive such information. We also have a legitimate interest in disclosing information about our services.
Mobile Devices	We may collect information from your mobile device such as unique identifying information broadcast from your device when visiting our websites.	We have a legitimate interest in identifying unique visitors, and in understanding how users interact with us on their mobile devices.
Supplier Relationship Management	We collect certain contact and related business information (name, email address, professional contact information) when you or your organization provides us with certain products or services. In some instances, we may collect certain background or screening information to the extent needed and in accordance with applicable law.	We have a legitimate interest in administering our relationship with our suppliers and performing our contract with your organization. We also use such information to administer and maintain our relationship with your organization.
Social Media Information	We may collect, as a result of using third party social media plugins, widgets, or other tools, information related to your social media usage as it relates to our websites.	We have a legitimate interest in sharing our social media pages with you.
Web logs	We collect information, including your browser type, operating system, Internet Protocol (IP) address, domain name, click-activity, referring website, and/or a date/time stamp for visitors.	We have a legitimate interest in monitoring our networks and the visitors to our websites.

2. How We Collect Your Personal Information

We collect your personal information in the following ways, pursuant to applicable law:

Directly From You, when you apply for our services, attend trade shows and industry events, engage with our websites, transact business with us, register for an account, contact us, respond to a survey, sign up to receive emails, and/or postal mailings. If you provide us a mobile phone number, you agree to receive text messages from the Company. Text messages may be sent to notify you of a position or keep you updated on activities relevant to your application process, which may include reminders.

Through Our Use of Cookies and Other Automatic Data Collection Technologies, when you visit our websites, open or click on emails we send you, or interact with our advertisements. We or third parties we work with automatically collect certain information using technologies such as cookies, web beacons, clear GIF, pixels, internet tags, web server logs, and other data collection tools.

Through On Premise and Other Offline Technologies. In some cases, we record customer service calls for quality assurance. We also use Closed Circuit Television or CCTV in our locations for safety, security, fraud, loss prevention, and operational purposes.

From Third Parties, including business partners, our affiliates, data analytics providers, third parties that we have partnered with for marketing or other purposes, or other publicly available sources.

3. How We Use Your Personal Information

In addition to the purposes and uses described above, we use your personal information for the following purposes:

To provide services to your business or employer;
To respond to inquiries related to support, employment opportunities, or other requests;
To send marketing and promotional materials, including information relating to our services;
To comply with laws or regulations to which the Company is subject;
To comply with our contractual obligations;
To conduct research and analytics related to our websites and services, including combining any or all of the information that we collect or obtain;
To detect and prevent fraud or crime;
To enforce, exercise, or defend legal claims;
To detect, investigate, prevent, or take action regarding possible malicious, deceptive, fraudulent, or illegal activity, including fraudulent transactions, attempts to manipulate or violate our policies, procedures, and terms and conditions, security incidents, and harm to the rights, property, or safety of us and our customers, employees, or others; and
For internal administrative purposes, as well as to manage our relationships.

Although the sections above describe our primary purpose in collecting your information, in many situations we have more than one purpose. Our collection and processing of your information is based in different contexts upon your consent, our need to perform a contract, our obligations under law, and/or our general interest in conducting our business. Note that this Privacy Policy may be updated to notify you of additional purposes for which we process your personal information.

4. Disclosures of Your Personal Information

In addition to the specific situations discussed elsewhere in this policy, we may disclose your personal information in the following situations:

Affiliates. We may disclose information to our corporate affiliates (e.g., parent company, sister companies, subsidiaries, joint ventures, or other companies under common control) in the course of our normal business operations.
Business Transactions. If another company acquires, or plans to acquire, any part of our company, business, or our assets, or similar corporate restructuring activities, we will also disclose information to that company, including at the negotiation stage.
Legal or Regulatory Requests and Investigations. We may disclose information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws or regulations. We may also need to disclose your personal information with tax authorities, courts, regulators, the police and other governmental authorities where we are required or permitted to do so by law.
Other Disclosures with Your Consent. We may ask to disclose your information to other unaffiliated third parties who are not described elsewhere in this Privacy Policy.
Protection of the Company or Others. We may disclose your information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies.
Third-Party Service Providers. We may disclose your information with service providers. Among other things, service providers may help us to administer our website, provide technical support, and assist in the fulfillment of services.
De-identified Personal Information. We may disclose or use aggregated or de-identified data for any lawful purpose. De-identified information is generally not considered to be Personal Information under applicable laws.

5. Data Security

No method of transmission over the Internet, or method of electronic storage, is fully secure. While we maintain reasonable physical, technical and procedural safeguards that are designed to protect your personal information against unauthorized access, use, or disclosure, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of any privacy or security event relating to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

Some of our websites may permit you to create an account. When you do you will be prompted to create a password. You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else that has obtained your password, whether or not such access or use has been authorized by you. You should notify us of any unauthorized use of your password or account by using one of the methods listed below under “Contact Information.”

6. Retention Period

We retain information about you and your relationship with us for as long as is needed to fulfill our legitimate business purposes outlined in this Policy. The specific periods for which we keep information about you vary depending on the nature of the information, why we need it, and whether the personal information is de-identified. We also consider the minimum necessary retention period prescribed by applicable laws, recommended by industry standards, and stated in contracts and other legal obligations.

7. Your Rights in Relation to Your Personal Information

Depending on your location, you may have the following rights with regard to your personal information:

Notification of Employment Opportunities. You may choose to provide us with your email address for the purpose of allowing us to send employment or candidate opportunities to you. You can stop receiving these emails by following the unsubscribe instructions in e-mails that you receive. If you decide not to receive these emails, we may still send you service related communications.
Request access to your personal information. You have the right to request access to personal information we hold about you. Specifically, you have the right to request access to information about the categories of personal information concerned and categories of recipients to whom the personal information has been or will be disclosed, and the sources from which we receive that personal information among other information. You generally have the right to receive this personal information, in a structured, commonly used, and machine-readable format so you can transmit this personal information to another entity.
Request correction or deletion of your personal information. You may request that we correct your personal information that is inaccurate or incomplete or delete your personal information. There may be instances where applicable law or regulatory requirements allow or require us to refuse a deletion request. For example, we may keep your personal information as needed to comply with our legal obligations, resolve disputes, and/or enforce any of our agreements.
Revocation Of Consent. If you revoke your consent for the processing of personal information then we may no longer be able to provide you services. In some cases, we may limit or deny your request to revoke consent if the law permits or requires us to do so, or if we are unable to adequately verify your identity. You may revoke consent to processing (where such processing is based upon consent) by contacting us at the address described below.
Opt-Out of the Sale or Sharing of Personal Information. Subject to certain exceptions, California residents have the right to opt out of the "sale"/”sharing” of their personal information. It may be considered a “sale”/”sharing” of personal information under California law when we use services that help deliver our ads to you and may transfer personal information to business partners for their use. Making personal information (such as online/device identifiers, browsing activity, or geolocation) available to these third parties may be considered a “share” under California law. To opt out of the "sale"/”sharing” of your personal information as just described, please click the “Do Not Sell/Share My Personal Information” link at the bottom of our website
Automated Processing: We do not use any technology that makes a significant decision based solely on automated processing (i.e., without human intervention). In the event we begin to use such technology, you have the right to object to that automated processing unless that decision is required or authorized by law.
Portability. You may have a right to ask us to provide your personal information to a third party.
Online Tracking. Some web browsers incorporate a “Do Not Track” (DNT) or similar feature that signals to websites that a visitor does not want to have his/her online activity and behavior tracked. Not all browsers offer a DNT option and there is currently no industry consensus for how to recognize or respond to a DNT signal. For these reasons, we do not currently respond to DNT signals. We will endeavor to recognize commercially recognized opt out signals (e.g., Global Privacy Control). Recognition of this signal will only take place with respect to the device and/or browser that communicates the signal.
Right of Non-Discrimination/Retaliation: We do not discriminate against individuals who exercise any of their rights described in this Privacy Policy, nor do we retaliate against individuals who exercise these rights
Right to Restrict Use of your Sensitive Personal Information. You may have the right to request the restriction of processing of your sensitive personal information in certain instances. At the current time, however, we do not use or disclose sensitive personal information for purposes other than those described in this Policy and these uses cannot be limited under applicable law.
SMS/Text Messages. If you provide us a mobile phone number, you will receive a single text message from us to confirm your enrollment in SMS/text messaging. You will not be enrolled to receive SMS unless you confirm. By consenting, you certify, warrant and represent that the telephone number you provided to us is your contact number and understand that consent is not a condition to apply for a job. Text messages will be sent to notify you of a position or keep you updated on activities relevant to your application process, which may include reminders. You can opt out of SMS or text messages by sending ‘STOP’, ‘END’, ‘CANCEL’, ‘UNSUBSCRIBE’, or ‘QUIT’ to the number you receive the message from. Once you confirm, you will receive a ‘STOP’ confirmation reply. You agree that SMS or text messages may be delivered using an automatic texting system. As always, message and data rates may apply for any SMS or text messages sent to you from us. We do not claim or guarantee availability or performance of the SMS service, including liability for transmission delays or message failures.

If you choose to assert any of these rights under applicable law, we will respond within the time period prescribed by such law. Please note that many of the above rights are subject to exceptions and limitations. Your rights and our responses will vary based on the circumstances of the request.

A person authorized to act on your behalf may make a verifiable request related to your personal information. If you designate an authorized person to submit requests to exercise certain privacy rights on your behalf, we will require verification that you provided the authorized agent permission to make a request on your behalf.

Your verifiable request must: (i) provide sufficient information that allows us to reasonably verify that you are the person about whom we collected personal information or an authorized representative of that person; and (ii) describe the request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

If you would like to exercise any of the above rights (to the extent these rights are provided to you by law), you may:

1. Call us at 1-800-536-1390; or

2. In the U.S., submit your request online HERE.

3. Outside of the U.S., submit your request online HERE.

8. Other Important Information

The following additional information relates to our privacy practices:

Transmission Of Information To Other Countries. As a multi-national company we transmit information between and among our affiliates. As a result your information may be processed in a foreign country where privacy laws may be less stringent than the laws in your country. Nonetheless, where possible we take steps to treat personal information using the same privacy principles that apply pursuant to the law of the country in which we first received your information. Specifically, we use European Union Model Clauses (“Model Clauses”) also known as Standard Contractual Clauses, to meet the adequacy and security requirements for data transferred from the EEA, Switzerland and the UK and for other international transfers of personal information as relevant. By submitting your personal information to us you agree to the transfer, storage and processing of your information in a country other than your country of residence including, but not necessarily limited to, the United States. If you would like more information concerning our attempts to apply the privacy principles applicable in one jurisdiction to data when it goes to another jurisdiction you can contact us using the contact information below.
Third Party Applications/Websites. We have no control over the privacy practices of websites or applications that we do not own.
Changes To This Privacy Policy. We may change our privacy policy and practices over time. To the extent that our policy changes in a material way, the policy that was in place at the time that you submitted personal information to us will generally govern that information unless we receive your consent to the new privacy policy. Our privacy policy includes an “effective” and “last updated” date. The effective date refers to the date that the current version took effect. The last updated date refers to the date that the current version was last substantively modified.
Minors. This site is not intended for use by children under the age of 13, and we do not knowingly collect or use any personal information from such children.
Information for California Residents. If you would like more information concerning the categories of personal information (if any) we disclose to third parties or affiliates for those parties to use for direct marketing please submit a written request to us using the information in the "Contact Information" section below.
Contact Information. If you have any questions about this Privacy Policy, please us contact us at MyPrivacy@apexsystems.com. If you are a resident of the UK or the European Union, please contact us at MyPrivacyGDPR@apexsystems.com. If you are not satisfied with our response, and are in the European Union, you may have a right to lodge a complaint with your local supervisory authority.

Last Revised: January 1, 2023.