Public Privacy Policy


Overview



This Public Privacy Policy describes how Astreya Partners, and associated entities, collects and uses personal information that we gather from our website and customers.


What Personal Information We Collect
Visitors to our website may elect to provide personal information in order to obtain more information about our products and services. Such information may include:

  • Name
  • Contact information (phone number and e-mail address)
  • Country (citizenship and residence)

Customer representatives and users of our services may also be asked to provide contract signatures and additional company information for the purposes of processing invoices and payments and enabling business processes.


How We Use Personal Information
Astreya Partners will use the information we collect from the website to respond to inquiries, or market relevant products or services.

Astreya Partners will retain your personal information for as long as we find it useful in accordance with all applicable privacy and security regulations.


Collection and Use of Non-Personal Information
We may also collect data in a form that, on its own, does not allow us to identify or contact a specific individual. We may use, transfer or disclose non-personal identifiable information for any purpose. The following are examples of non-personal information that we collect and how we may use it:

  • When you visit our websites, we may collect technical and navigational information, such as web browser type, Internet protocol address, language, location, time zone, unique device/browser identifier, and URLs requested so that we may better understand visitor behavior and improve our products, services, and content.
  • We may also collect information regarding specific activities that you perform on our websites. This information is used to help us improve the content and usability of our websites. This information is aggregated and we consider aggregated information as non-personal for the purposes of this privacy policy.


Cookies and Other Technologies
Astreya Partners’ websites, products, services, and content may use “cookies” and other technologies such as web beacons and pixel tags. These technologies may be used to deliver our services as well as to help us better understand user behavior.

We may use this information to analyze trends, administer our website, and to learn about user behavior.


Transfer to Third-Parties
In order to respond to inquiries, or market relevant products or services, we may share your information with third-party service providers that may be engaged to assist us in managing the processes required to provide these services. Any engagement of a third-party service provider will be governed by appropriate contractual requirements prohibiting the use of your information for any purposes beyond those specifically directed by Astreya Partners, and requiring that they ensure sufficient administrative and technical security mechanisms are in place to prevent your information from being improperly used, disclosed, or accessed.

For individuals located in the European Economic Area (“EEA”) or Switzerland, when transfers to third parties outside of the EEA or Switzerland occur, Astreya Partners will put sufficient protections in place to ensure compliance with the applicable legal requirements, such as use of European Union (“EU”) Model Contracts, or language requiring adherence to the EU-U.S. or Swiss-U.S. Privacy Shield, or other such protocols as may be in place from time to time.

We may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security, law enforcement or data privacy requirements.


Access to Personal Information
The amount of personal information that we require you to supply in order to use our services will be limited to that which is relevant to supply such services.

You have the right to request access to, withdraw your consent to the use and processing of, and request the correction of inaccuracies or erasure of your information that we maintain about you, subject to our obligations to maintain your information under applicable laws. We may limit or deny requests that interfere with our legitimate interests, or charge reasonable fees for access, except as prohibited by applicable law.

Astreya Partners will only store personally identifiable data about you for as long as it’s reasonably required to fulfill the purposes under which it was first provided by you unless a longer retention period is required or permitted by law.

You may make review, update access, correction, withdraw, or deletion requests by contacting us at privacy@astreya.com.


Protection of Personal Information
We take precautions to safeguard your information. Astreya Partners uses commercially reasonable technical, administrative and physical controls to protect your data. We use a combination of firewall barriers, data encryption techniques and authentication procedures, among others, to maintain the security of your personal information and our systems from unauthorized access. We also enforce physical access controls to our buildings and files.


Third-Party Sites and Services
Our websites and content may contain links to other websites. As such, Astreya Partners does not endorse and is not responsible for the privacy practices or the content of these third-party websites. We exercise no control over how your information is stored, maintained or displayed by third parties or on third-party sites.


Privacy Shield
Astreya Partners complies with the EU-US and Swiss-US Privacy Shield Frameworks as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. Astreya Partners has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. Astreya Partners has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the policies 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 page, please visit www.privacyshield.gov

In compliance with the EU-US and Swiss-US Privacy Shield Principles, Astreya Partners commits to resolve complaints about your privacy and our collection or use of your personal information. European Union or Swiss individuals with inquiries or complaints regarding this privacy policy should first contact us via email privacy@astreya.com, or via mail at:

Astreya Partners
Attn: Privacy Officer
2099 Gateway Pl Suite 140
San Jose, CA 95110

For inquiries and complaints not related to human resource data, Astreya Partners has committed to refer unresolved privacy complaints under the EU-US and Swiss-US Privacy Shield Principles to JAMS Mediation, Arbitration, ADR Services, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit https://www.jamsadr.com/file-an-eu-us-privacy-shield-or-safe-harbor-claim for more information or to file a complaint.

Our commitments under the Privacy Shield are subject to the investigatory and enforcement powers of the United States Federal Trade Commission.

Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.


Children
The Service is not directed to children. We do not knowingly collect personally identifiable information from children. If you, as a parent or guardian, become aware that your child has provided us with Personal Information without your consent, please contact us. If we become aware that a user is under the age of 13 and has provided us with Personal Information without verifiable parental consent, we will delete such information from our files.


Privacy Changes and Questions
Astreya Partners may update its Privacy policy from time to time. When we change the policy in a material way, a notice will be posted on our website along with the updated Privacy Policy.