Last Modified March 13, 2024
Keelson Strategic (“Keelson,” “us,” our” or “we”) is committed to protecting your privacy. “You/your/user(s)” means you as a user of our Website, including any information, tools and services available from the Website (collectively, the “Website”). Our privacy policy, which applies to all users of our Website, is designed to explain the information we collect and how we use it to provide our Website and services and give our users a better experience (“Privacy Policy”).
This Privacy Policy describes the Personal Information (as defined below) we collect about you online through our Website, why we collect it, how we use it, and when we share it with third parties. This Privacy Policy also describes the choices you can make about how we collect and use certain of that information. The Personal Information provided by you is not used for any purpose other than as outlined in this Privacy Policy.
By accessing and using our Website you are agreeing to our collection, storage, use and disclosure of your Personal Information and other information as described in this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not use our Website or provide any Personal Information to us. If you choose not to provide any Personal Information that is necessary for us to provide any of our services to you, we may not be able to provide those services to you.
1. Types of Information We Collect
a. Personal Information that we collect about you. We collect Personal Information about our users. “Personal Information” is information relating to an individual that can be used to contact or identify you or individuals about whom you enter information as part of your activities on our Website, such as first name, last name, e-mail address, phone number, company name, company address, content of any communication you send us, as well as information that is linked to the forgoing information.
b. User-Provided Information. We collect information that you provide directly to us when you engage in the following:
- When you submit information to us to request information about our services through our “contact me” form
- When you apply for employment with Keelson through LinkedIn or Indeed
- When you communicate with Keelson via e-mail, telephone, or other methods
When you use the Website, you may be given the option to subscribe to or to be added to our e-mail list, to schedule a personal call/meeting and to request certain resource materials. Whether or not you select this/these option(s), your Personal Information may be shared with third parties consistent with this Privacy Policy. You may opt-out or unsubscribe from these e-mail list or call/meeting requests at any time.
c. Third-Parties. While visiting the Website, you may link to websites operated by third parties. We may obtain information from these third parties and combine that with information we collect directly. When you interact with us through social media networks, such as when you submit a job application through LinkedIn, Indeed.com, or other sites, we may receive information about you, including your profile information, picture, user ID associated with the social media account, and any other information you permit the social media network to share with third parties. The data we receive is dependent upon your privacy settings with the social network in question. The privacy policies and data practices of such third parties may significantly differ from ours, and we make no representation or warranty whatsoever about their policies and practices in respect of their own processing of your Personal Information.
2. How We Use Your Information
a. Personal Information. We may use your Personal Information for the following representative purposes:
- Store your information in our customer relations management system, Keap. You can learn how Keap stores your information by reviewing their privacy policy at https://keap.com/legal/privacy-policy
- Review and process your submissions for a job position
- Send communications, including information you request from us about our services or respond to a job application you submit to us
- Communicate with you by email or other means about our company, our services, or other information that we believe may be of interest to you
3. Lawful Processing; Legitimate Interests. Processing of your Personal Information for the purposes set out in this Privacy Policy is necessary for one or more of the following:
- Protecting your vital interests or the interests of another person
- Complying with our legal obligations
- Pursuing our legitimate interests, including without limitation:
- Administration of our operations
- Exploring ways to develop and grow
4. How We Share and Disclose Personal Information
a. We will not rent, sell or share your Personal Information with third parties except as set forth herein. If you do not want us to use or disclose Personal Information collected about you in the ways identified in this Privacy Policy, you may choose not to use the Website or provide your Personal Information at any time.
b. We may disclose information we have collected about you if required to do so by law or if we, in our sole discretion, believe that disclosure is reasonable to: (i) satisfy any applicable law, regulation, legal process or governmental request; (ii) enforce this Privacy Policy and our Terms of Service, including investigation of potential violations hereof; (iii) detect, prevent, or otherwise address fraud, security or technical issues; (iv) respond to user support requests, or (v) protect our rights, property or safety, our users and the public. This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention.
5. Data Retention
a. We will retain your Personal Information for as long as is necessary for the purposes set out in this Privacy Policy unless a longer period is required under applicable law or is needed to resolve disputes or protect our legal rights or otherwise to comply with legal obligations.
b. Where we are processing Personal Information based on our legitimate interests, we generally will retain the data for a reasonable period of time based on the particular interest, taking into account the fundamental interests and the rights and freedoms of the data subjects.
c. Where we are processing Personal Information as set out in this policy, we generally will retain the information for the period of time necessary to carry out the processing activities to which you consented, subject to your right, under certain circumstances, to have certain of your Personal Information erased (see Section 7, Deleting, Changing & Updating Your Personal Information).
d. Where we are processing Personal Information based on contract, we generally will retain the information for the duration of the contract plus some additional limited period of time that is necessary to comply with law or that represents the statute of limitations for legal claims that could arise from the contractual relationship.
6. Deleting, Changing & Updating Your Personal Information
a. For users outside the EEA or UK, you may correct, update or revise your Personal Information that is inaccurate or request that we delete your Personal Information from our system. In certain cases, you may also have a right to: (i) to restrict or limit the ways in which we use your Personal Information; (ii) to object to the processing of your Personal Information; and (iii) to obtain a copy of your Personal Information in an easily accessible format.
b. For users outside the EEA or UK, if you withdraw your consent to the use or sharing of your Personal Information for the purposes set out in this Privacy Policy, you may not have access to the related services, and we might not be able to provide you with certain or any services.
c. To submit a request, please send an e-mail message to info@KeelsonStrategic.com. We do not want to take any action regarding your Personal Information at the direction of someone other than you and may therefore ask you for information verifying your identity.
7. Basis For Continued Use of Your Personal Information
Please note that, in certain cases, we may continue to process your Personal Information after you have withdrawn consent and requested that we delete your Personal Information, if we have a legal basis to do so. For example, we may retain certain data if we need to do so to comply with an independent legal obligation, if we still need the data for the lawful purposes for which we obtained the data, or if it is necessary to do so to pursue our legitimate interest in keeping our services and operations safe and secure. Furthermore, if we have already disclosed your Personal Information to third-parties pursuant to the terms of this Privacy Policy, we cannot access that Personal Information any longer and cannot compel the deletion or modification of any such information by the parties to whom we have made those disclosures.
8. Notice to Californian Users Regarding Your Privacy Rights
a. Shine the Light. Pursuant to California Civil Code Section 1798.83, also known as the “Shine The Light” law, California residents have the right to request in writing from businesses with whom they have an established business relationship: (i) a list of the categories of Personal Information, such as name, address, e-mail address, and the type of services provided to that individual, and (ii) the names and addresses of all such third-parties that your data was shared with. Keelson does not share Personal Information with third-parties for those parties’ direct marketing. To request the above information, California residents can e-mail us at info@KeelsonStrategic.com or write to us at Keelson Strategic Corporation, 1160 Battery Street East, Suite 100, San Francisco, CA 94111. Please note that, under California law, a business is only required to respond to such a request twice in any calendar year.
b. California Consumer Privacy Act. The California Consumer Privacy Act, Cal. Civ. Code §1798.100 et. seq. (“CCPA”), grants residents of California certain rights with respect to their Personal Information and requires us to provide such individuals with certain information, described in this Section.
- Your Rights. California residents may exercise the following rights by contacting us at info@KeelsonStrategic.com, or as described at the end of this document:
- Know the ways in which we acquire, use, share, disclose and otherwise process your Personal Information;
- Know the specific pieces of your Personal Information that we hold;
- Request the deletion of your Personal Information, subject to several exceptions; and
- Not to be denied goods or services for exercising these rights
c. Requesting Access to or Deletion of Personal Information. If you are a California resident, you have the right, subject to certain exceptions defined in the CCPA and other applicable laws and regulations, to request that we disclose certain information to you about our collection and use of your Personal Information over the past twelve (12) months.
In order to verify your request, you will need to provide us with sufficient information to identify you individually so that we can comply with you request, including the name you provided to us when you created your account(s) (i.e. your legal first, last name or variants thereof, e.g. nicknames, aliases, titles (“Mr.”, “Mrs.”, “Dr.”, “Jr.”, etc.), the e-mail address(es) you use to correspond with us and any other e-mail addresses you have used with us in the past, your relationship with us (e.g. prospective client or employee.), your mailing address, including the state and city you reside in currently.
To make an information access and/or deletion request you may contact us by e-mail at info@KeelsonStrategic.com.
d. Notice Disclosures. Depending on the circumstances, we have disclosed the following categories of your Personal Information for a “business purpose” (as defined in the CCPA) in the preceding twelve (12) months:
- First name, last name, username, your image and/or likeness, e-mail address, phone number, comments, company name and address, title, work experience and skills
- Non-Personally Identifiable Information
- Inferences drawn from any of the above information.
e. Non-Discrimination. We will not discriminate against you for exercising any of your rights under California law, including:
- Deny you services or provide you with a different quality of services
- Charge you different prices or rates for services, including through granting discounts or other benefits, or imposing penalties
- Deny your interview request due to your exercising of any of these rights
f. Do Not Track. Some web browsers may let you enable a “do not track” feature that sends signals to the websites you visit, indicating that you do not want your online activities tracked. This is different than blocking or deleting cookies, as browsers with a “do not track” feature enabled may still accept cookies. There is currently no industry standard for how companies should respond to “do not track” signals, although one may develop in the future. We do not respond to “do not track” requests or signals at this time.
9. NON-U.S. DATA SUBJECTS
A Note to Users Outside of the United States. If you are a non-U.S. user of our Website and are providing us with data, you acknowledge and agree that your Personal Data may be processed for the purposes identified in the Privacy Policy. In addition, your Personal Data may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of Personal Data may be less or more stringent than the laws in your country. By providing your data, you consent to such transfer.
10. Children
This Website is not directed to or intended for children under 16 years of age. We do not knowingly solicit, collect or maintain information from those we actually know are under 16, and no part of our Website is targeted to attract anyone under 16. We also do not send e-mail correspondence to anyone who advises that they are under the age of 16. If we later obtain actual knowledge that a user is under 16 years of age we will take steps to remove that user’s Personal Information from our systems. If you are the parent or guardian of a child whom you believe has disclosed Personal Information to us, please contact us at info@KeelsonStrategic.com so that we may delete and remove such information from our system.
11. Security; Legally Required Disclosures
a. Security. We strive to keep your Personal Information private and safe. We take commercially reasonable physical, electronic and administrative steps to maintain the security of Personal Information collected, including limiting the number of people who have physical access to database servers, as well as employing electronic security systems and password protections that guard against unauthorized access.
b. Unfortunately, despite our best efforts, the transmission of data over the Internet cannot be guaranteed to be 100% secure. While we will use reasonable means to ensure the security of information you transmit through the Website, any transmission of Personal Information by you is at your own risk. We cannot guarantee that such information will not be intercepted by third-parties and we shall not be liable for any breach of the security of your Personal Information resulting from causes or events that are beyond our control, including, without limitation, your own act or omission, corruption of storage media, defects in third party data security products or services, power failures, natural phenomena, riots, acts of vandalism, hacking, sabotage, or terrorism, and we are not responsible for circumvention of any privacy settings or security measures contained on the Website.
12. Third-Party Websites
While visiting the Website, you may link to websites operated by third parties or you may have come to the Website using a link found in another website. We do not make any representations or warranties about any third-party website, we have no control over them or the information, services, products they provide or the manner or methods they employ to collect, store, access, or otherwise use your Personal Information. If you provide Personal Information at one of those websites, you are subject to the privacy policy of the operator of that website, not our Privacy Policy. Please make sure you understand any other website’s privacy policy before providing Personal Information.
13. Changes to Our Privacy Policy
We reserve the right to change, modify, add or remove portions of this Privacy Policy at any time and without prior notice, and any changes will become effective immediately upon being posted. However, we will not use your Personal Information in a way that is adverse and materially different from the uses described in this Privacy Policy without giving you an opportunity to opt out. The “Last Modified” date indicates if and as of when changes have been made to this Privacy Policy. Your continued use of the Website after this Privacy Policy has been amended shall be deemed to be your continued acceptance of the terms and conditions of the Privacy Policy, as amended.
14. Contact Us
If you have any questions regarding our Privacy Policy, or if you wish to issue a request to exercise your rights where applicable by law, you can contact us via e-mail at info@KeelsonStrategic.com or write to us at Keelson Strategic Corporation, 1160 Battery Street East, Suite 100, San Francisco, CA 94111.
