Who we are
Strategy, Advisory, & Management (“SAM”) takes the privacy of its entrusted Users very seriously. SAM is committed to protecting the confidentiality of information entrusted to it by Users, and has prepared this Privacy Policy to inform Users of SAM’s practices concerning the collection, use, maintenance and disclosure of personal information.
What is covered
This Privacy Policy covers SAM’s treatment of personally identifiable information (“Personal Information”) collected by the company when a User accesses and uses the SAM’s website and while using SAM’s services. This Privacy Policy also covers SAM’s subsidiaries, affiliates and business partners.
This Privacy Policy does not cover aggregated and/or anonymized data from which the identity of an individual cannot be determined. SAM retains the right to use aggregated and/or anonymized data in any way SAM deems appropriate.
SAM has no control over the content of third party websites that may be identified on the SAM’s website or, if applicable, accessed through hyperlinks on SAM’s website. Some examples are using citations from credible sources & governing accreditations.
Information collected
As a User browses SAM’s website, Personal Information including without limitation a User’s name, address, phone numbers, email addresses, and company domain that a User provides, as well as information that is collected electronically concerning a User’s use of SAM’s website, via cookies or third party software. “Cookies” are files or information that is stored on a User’s computer hard drive when a User visits SAM’s website, and are used to remember that assist a User in the future use of the SAM website. Most internet browsers are set up to accept cookies. If a User does not wish to accept cookies, a User can adjust its internet browser to refuse the use of cookies or alert the User when cookies are being transmitted.
SAM may collect other information about a User, including without limitation the server that a User’s computer is logged onto, a User’s browser type (e.g., Internet Explorer, Microsoft Edge, Google Chrome), and the pages a User views or requests. This type of information, however, will only be collected in the aggregate in connection with all Users of SAM’s website for tracking, planning, forecasting and/or evaluation purposes.
User consent
A User’s providing of Personal Information to SAM shall be deemed to mean that a User acknowledges this Privacy Policy, and provides express informed consent to SAM’s collection, use, maintenance and disclosure of said User’s Personal Information in accordance with this Privacy Policy. If, for some reason, a User does not agree with the terms of this Privacy Policy, then said User should not, and is requested not to, provide any Personal Information to SAM. Certain services offered by SAM, however, can only be provided if a User provides Personal Information to SAM. If a User chooses not to provide SAM with certain required personal information, the User may not be permitted to obtain certain services.
Information used
SAM may use Personal Information it has collected through its website, in order to (a) provide a User with a service or software offered by SAM or one of its subsidiaries, affiliates and business partners, (b) measure a User’s interest in certain services or software or to inform a User about a service or software offered by SAM or one of its subsidiaries, affiliates and business partners, (c) understand a User’s preferences in order to enhance a User’s experience with SAM or one of its subsidiaries, affiliates and business partners, (d) measure and attempt to predict the effectiveness of the marketing and sales effort of SAM or one of its subsidiaries, affiliates and business partners.
In addition to the foregoing, if a User has provided its email address to SAM or to a company SAM has partnered with to make their products and services available to the User, SAM may send the User email offers and information. SAM may send a User email offers if the User has provided its email address to a third party and has actively chosen or requested, on an opt-in basis, to receive email offers from other parties.
SAM does not, however, provide a User’s email address to its business partners. SAM may, however, send a User offers on behalf of its subsidiaries, affiliates, and business partners. If a User’s email address is html-enabled, SAM may choose to send a User graphic-rich html emails.
Information sharing and disclosure
SAM uses all information collected from a User for internal purposes only. SAM does not and will not sell your Personal Information to anyone. SAM may, from time to time, send Personal Information about a User to other persons or entities that perform services on behalf of SAM (“Service Providers”), but only when:
- The Service Provider has agreed to use such information solely for the purposes of providing services to SAM;
- The Service Provider agrees to protect such information in the same manner as the policies set forth in this Policy Statement;
- SAM has obtained the User’s consent to share the information;
- SAM needs to share the User’s information in order to provide the service the User has requested;
- SAM needs to send the information to a Service Provider who works on behalf of SAM to provide a service to you.
Unless SAM informs a User otherwise, a Service Provider does not have any right to use the Personal Information SAM provides to them beyond what is necessary to assist SAM, or in response to a legal obligation including without limitation a subpoena, court order or SAM believes that the law requires disclosure, or where the information is currently in the public domain.
Maintenance and Security of Personal Information
SAM holds all of the Personal Information in the United States at this time. SAM keeps a User’s Personal Information for as long as SAM determines necessary to fulfill the objective for which it was collected. Said Personal Information is maintained on SAM systems that are protected using security measures. Unfortunately, however, SAM cannot guaranty that the information submitted to, maintained by or transmitted from SAM is or will always be completely secure, as transmission of information over the internet is oftentimes susceptible to potential interception, misuse, willful and/or negligent acts or omissions, misrouting, or possible loss.
Your User Rights
- Right to Know.
- You have the right to request information about the categories and specific pieces of personal information we have collected about you in the preceding 12 months, as well as the categories of sources from which such information is collected, the purpose for collecting such information, and the categories of third parties with whom we share such information.
- You have the right to request information about our sale or disclosure for business purposes of your personal information to third parties.
- Right to Request Deletion, Modification or Addition. You have the right to request the deletion and modification of your personal information.
- Right to Non-discrimination. You have the right to not be discriminated against for exercising any of these rights.
Only you, or a person you designate to act on your behalf, may make a verifiable consumer request related to your personal information. We may request that your authorized agent have written authorization to make the request on your behalf and may need to verify the authorized agent’s identity.
In some instances, you may be requested to verify your identity prior to access or deletion of your personal information such as a government-issued ID. Once identity has been verified, the request will proceed.
Age Restrictions
Must be at least 18 years old to contract with SAM for our services. At the time of registration and submitting contact information (email address, first and last name, and phone number) via website, you have confirmed your review of our privacy policy here and your age.
Changes to this Privacy Policy
Any changes shall be effective from the date of posting of any revisions hereto as well as to any existing information then being retained by SAM.
Contact Information
For all modifications, requests, complaints, disputes, and all other privacy related inquiries, email so@complysam.com or call/text the operator at 1-312-600-8780.
October 2023 by Sam Oberholtzer, DPO & Founder