Effective Date: May 15, 2020

Small Business Strong Privacy Policy
You have arrived at the www.smallbstrong.com website (the “Website”) or are participating in some capacity in Small Business Strong, LLC’s (“SBS”) business support and professional service referral services program (the Website and those services collectively the “Service”).  This Small Business Strong Privacy Policy (the “Privacy Policy”) is related to your use of, application to enroll in, or participation in the Service.  Throughout this Privacy Policy, the words “we”, “us”, and “our” refer to SBS and the words “you” and “your” refer to the user interacting with or providing the Service.  This Privacy Policy applies to information that we collect and handle from those applying to enroll in, enrolled in and contributing to the Service and supplements separate terms that Service participants will agree to.  If you choose to enroll in the Service, you must agree to the appropriate Participant Agreement (provided under separate cover to those accepted for enrollment in the Service), and you agree that the collection, use and disclosure of your Personal Information (as defined below) that you agree to as described in this Privacy Policy extends to the collection, use and disclosure of your Personal Information by Professionals (as defined below).  If you choose to act as a Business Advisor or Functional Specialist, you must agree to the terms of the Professional Agreement (to be provided and agreed to separately).Business Advisors and Functional Specialists are not employees of SBS – they help facilitate the Service and are referred to as “Professionals” in this Privacy Policy.
By accessing, using or providing the Service, you consent to our collection, use, and sharing of your information and data, and other activities as described below.  

1. What Information Do We Collect?

(a) Information We Collect About You We may obtain information that can reasonably be used to identify an individual (“Personal Information”) in the form of: (i) information you provide when first expressing interest in the Service at the Website, which might include your name, company name, race and/or ethnicity, email address, phone number, mailing address and industry; (ii) information you otherwise provide when you contact us, and (iii) information you provide when you otherwise interact with the Service, including information that you provide to any Professionals who assist you as part of the Service.

(b) Information Collected or Stored as You Access and Use the Service In addition to any information that we receive as described above, we and our third-party service providers may use a variety of technologies that automatically (or passively) store or collect certain information whenever you interact with the Service (“Usage Information”).  This Usage Information may be stored or accessed using a variety of technologies that may be downloaded to your personal computer, browser, laptop, tablet, mobile phone, or other device (a “Device”) whenever you interact with the Service.

To the extent we associate Usage Information with Personal Information we collect directly from you through the Service, we will treat it as Personal Information. This Usage Information may include:

●        your IP address, UDID or other unique identifier (“Device Identifier”).  A Device Identifier is a number that is automatically assigned to your Device used to access the Service, and our computers identify your Device by its Device Identifier;

●        your Device functionality (including browser, operating system, hardware, mobile network information);

●        the URL that referred you to the Service;

●        the areas within the Service that you visit and your activities there, including remembering you and your preferences;

●        your Device location;

●        your Device characteristics; and

●        certain other Device data, including the time of day, among other information.


Tracking Technologies.  We may use various methods and technologies to store or collect Usage Information (“Tracking Technologies”).  Tracking Technologies may set, change, alter, or modify settings or configurations on your Device.  A few of the Tracking Technologies include, without limitation, the following (and subsequent technology and methods later developed):

Cookies.  Cookies are small text files that are placed on your computer by the websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. The use of cookies is now standard for most websites. If you are uncomfortable with the use of cookies, you can manage and control them through your browser, including removing cookies by deleting them from your ‘browser history’ (cache) when you leave the site.

Managing cookies on your device We use cookies to personalize content and to provide you with an improved user experience. By using this website or application you consent to the deployment of cookies. You can control and manage cookies using your browser (see below). Please note that removing or blocking cookies can impact your user experience and some functionality may no longer be available.

Using your browser to control cookies Most browsers allow you to view, manage, delete and block cookies for a website. Be aware that if you delete all cookies then any preferences you have set will be lost, including the ability to opt-out from cookies as this function itself requires placement of an opt out cookie on your device. Guidance on how to control cookies for common browsers is linked below.
Google Chrome
Mozilla Firefox
MacOS Safari
Microsoft Internet Explorer

For information on additional browsers and device types please see:  http://www.aboutcookies.org/ or http://www.cookiecentral.com/faq/.

Managing Analytics cookies You can opt-out of having your anonymized browsing history within our websites or applications recorded by analytics cookies. We use the following service providers and you can learn more about their privacy policies and how to opt-out of their analytics cookies by clicking on following links:

Adobe: http://www.adobe.com/privacy/opt-out.html

Google Analytics: http://www.google.com/analytics/learn/privacy.html

Types of cookies ‘Session’ cookies remain in your browser during your browser session only, ie until you leave the website.

‘Persistent’ cookies remain in your browser after the
session (unless deleted by you).

‘Performance’ cookies collect information about your
use of the website, such as webpages visited and any error messages; they do
not collect personally identifiable information, and the information collected
is aggregated such that it is anonymous. Performance cookies are used to
improve how a website works.

‘Functionality’ cookies allow the website to remember
any choices you make about the website (such as changes to text size,
customized pages) or enable services such as commenting on a blog.

Web Beacons.  Small graphic images or other web programming code called web beacons (also known as “1x1 GIFs” or “clear GIFs”) may be included in the Service’ pages and messages.  Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a page or e-mail can act as a web beacon.  Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Service, to monitor how users navigate the Service, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed.

Embedded Scripts.  An embedded script is programming code that is designed to collect information about your interactions with the Service, such as the links you click on.  The code is temporarily downloaded onto your Device from our web server or a third-party service provider, is active only while you are connected to the Service, and is deactivated or deleted thereafter.

Browser Fingerprinting.  Collection and analysis of information from your Device, such as, without limitation, your operating system, plug-ins, system fonts, and other data, for purposes of identification.

ETag, or Entity Tag.  A feature of the cache in browsers.  It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL.  If the resource content at that URL ever changes, a new and different ETag is assigned.  Used in this manner, ETags are a form of Device Identifier.  ETag tracking may generate unique tracking values even where the consumer blocks HTTP, Flash, and/or HTML5 cookies.

Recognition Technologies.  Technologies, including application of statistical probability to data sets, which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices in the same user).

Tracking Technologies Usage.  We may use Tracking Technologies for a variety of purposes, including:

Strictly Necessary.  We may use cookies or other Tracking Technologies that we consider are strictly necessary to allow you to use and access the Service, including cookies required to prevent fraudulent activity and improve security.

Performance-Related.  We may use cookies or other Tracking Technologies that are useful in order to assess the performance of the Service, including as part of our analytic practices or otherwise to improve the content, products, or services offered through the Service.

Functionality-Related.  We may use cookies or other Tracking Technologies that are required to offer you enhanced functionality when accessing the Service, including identifying you when you sign-in to the Service or keeping track of our specified preferences, including in terms of the presentation of content on the Service.

Targeting-Related.  We may use Tracking Technologies to deliver content relevant to your interests on the Service and third-party websites based on how you interact with our content.  This includes using Tracking Technologies to understand the usefulness to you of the content that has been delivered to you.

Technologies Choices and Consent

We obtain your consent to our information
storage or collection of Tracking Technologies by providing you with
transparent information in this Privacy Policy and providing you with the
opportunity to make a choice to disable cookies as set forth above.  Please note that we are not required to
obtain your consent to the information collection Tracking Technologies
identified above that are strictly necessary. 

We are giving you detailed notice of the
Tracking Technologies and your limited choices regarding them so that your
consent is meaningfully informed.

(c) Information Third Parties Provide About You

We may, from time to time, supplement the information
we collect directly from you through the Service with outside records from
third parties for various purposes, including to enhance our ability to serve
you, to tailor our content to you, and to offer you opportunities that may be
of interest to you.  To the extent we
combine information we receive from those sources with your Personal
Information we collect through the Service, it will be treated as Personal
Information and we will apply this Privacy Policy to such combined information,
unless we have disclosed otherwise.  In
no other circumstances do our statements under this Privacy Policy apply to
information we receive about you from third parties, even if they have used our
technology to collect it and share it with us.

(d) Does SBS or its Service Collect Personal Information that a Participant Shares With a Professional as Part of the Service?

Other than the initial information requested, collected and evaluated for purposes of determining enrollment eligibility and otherwise as described in this Privacy Policy, SBS does not collect Personal Information about you, including any information that a Participant provides to a Professional in the course of the Service.  If you are a Participant, SBS does not receive any Personal Information about you arising from your work with a Professional other than Personal Information you happen to provide directly to SBS.


2. How Do We Use the Information Collected?

Generally.  We may use Personal Information that we collect about you: (1) to provide you with information or services or to process transactions that you have requested or agreed to receive, including providing general information about our Service in response to a request submitted online; (2) to provide you with information about new service offerings on an ongoing basis, unless you opt out of receiving such messages; (3) to enable you to participate in a variety of the Service’s features; (4) to send you customized communications based on your habits and behavior, which may be analyzed using algorithms and other Tracking Technologies as part of the Service; (5) to send promotional or marketing messages to you on behalf of the other businesses or organizations; (6) to process inquiries about your enrollment, including your enrollment status; (7) to improve the Service, to create new service offerings, to customize your experience on the Service, or to serve you specific content that is most relevant to you; (8) to contact you with regard to your use of any of the Service, and, in our discretion, changes to the Service and/or any of the Service’s policies; (9) for internal business purposes; and (10) for purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy.


3. How and When Do We Share Information with Third Parties?

We will never sell or rent your Personal Information
to anyone without your permission and will never use your Personal Information
for any purpose other than as described here or to carry out the Service (if
you are a businessperson seeking assistance, your Personal Information must be
shared with Professionals to enable the rendering of the Service) as specified
in any Service user agreement that you agree to.

We will not share Personal Information with third
parties for direct marketing purposes.
We may, however, freely share non-Personal Information, such as
aggregated user statistics, browsing behavior information and non-identifying
demographic information such as racial and ethnic identity information and
postal code information, with third parties.
We may share the information we have
collected, including Personal Information, as disclosed at the time you provide
the information and as described or otherwise in this Privacy Policy.  We or the Professionals may also disclose Personal
Information as follows:

(a) When You Request Information from or Provide Information to Third Parties  

You may be presented with an option through the Service
to receive certain information directly from third parties or to have us send
certain information to third parties or give them access to it.  If you choose to do so, your Personal Information
and other information may be disclosed to such third parties and all
information you disclose will be subject to the third-party privacy policies
and practices of such third parties.

(b) Third Parties Providing Service on Our Behalf

We may use third-party vendors to perform certain
services on behalf of us or the Service, such as hosting the online platform,
designing and/or operating the online platform’s features, tracking the online
platform’s activities and analytics, and enabling us to send you Service
updates or perform other administrative services.  We may provide these vendors with access to Personal
information, including Device Identifiers and Usage Information, to carry out
the services they are performing for you or for us.  Third-party
analytics and other service providers may set and access their own Tracking
Technologies on your Device and they may otherwise collect or have access
to User Information.  We are not
responsible for those third-party technologies or activities arising out of
them, nor are we responsible for the effectiveness of or compliance with any
third party’s opt-out options.

(c) To Protect the Rights of SBS and Others and Comply with Laws

To the fullest extent permitted by applicable law, we
may also disclose Personal Information if we believe in good faith that doing
so is necessary or appropriate to: (i) protect or defend our rights, safety, or
property or the rights, safety, or property of third parties (including through
the enforcement of this Privacy Policy or other applicable agreements and
policies); or (ii) comply with legal and regulatory obligations (e.g., pursuant
to law enforcement inquiries, subpoenas or court orders).  To the fullest extent permitted by applicable
law, we have complete discretion in electing to make or not make such
disclosures, and to contest or not contest requests for such disclosures, all
without notice to you.

(d) Affiliates and Business Transfer

We may share Personal Information with our parent,
subsidiaries and affiliates.  We also
reserve the right to disclose and transfer all such information: (i) to a
subsequent owner, co-owner or operator of the Service; or (ii) in connection
with a merger, consolidation, restructuring, the sale of substantially all of
our interests and/or assets or other corporate change, including, during the
course of any due diligence process.


4. Does Third-Party Content or Links to Third-Party Websites Appear on the Service?

The Service may contain content that is supplied by a third party, and those third parties may collect Personal Information and your Device Identifier.  In addition, when you use the Service you may be directed to other services that are operated and controlled by third parties that we do not control.  We are not responsible for the data collection and privacy practices employed by any of these third parties or their services, and they may be tracking you across multiple websites and may be sharing the results of that tracking with us and/or others.  For example, if you “click” on a link, the “click” may take you onto a different website.  These other websites may associate their Tracking Technologies with you, independently collect data about you or others, including Personal Information, and may or may not have their own published privacy policies.  We encourage you to note when you leave the Service and to review the third-party privacy policies of all third-party websites and exercise caution in connection with them.


5. How Can You Change Your Information and Communications Preferences?

You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of Service enrollment.  The Service may allow you to review, correct, or update Personal Information you have provided through registration forms or otherwise, and you may provide registration updates and changes by contacting us.  If so, we will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable (but we may retain prior information as business records).  Please note that it is not always possible to completely remove or delete all of your information from our databases and that residual data may remain on backup media or for other reasons.  When you edit your Personal Information or change your preferences, information that you remove may persist internally for our administrative purposes.  You may cancel or modify our e-mail communications you receive from us by following the instructions contained within our promotional messages or in some cases by logging into your Service account and changing your communication preferences.  This will not affect your Service enrollment and if your opt-out is limited to certain types of messages the opt-out will be so limited.  Please note that we reserve the right to send you certain communications relating to your use of the Service, such as administrative and service announcements, and these transactional account messages may be unaffected if you choose to opt-out from receiving our communications.  If you have any questions about the Privacy Policy or practices described in it, or if at any time you want to withdraw your consent to SBS’ sending communications other than those required to provide the Service, you should contact us at [email protected].


6. What About Transfers of Information to the United States?

The Service are operated in the United States.  If you are located outside of the United States, please be aware that information we collect, including Personal Information, will be transferred to, and processed, stored and used in the United States.  The data protection laws in the United States may differ from those of the country in which you are located, and your Personal Information may be subject to access requests from governments, courts, or law enforcement in the United States according to the laws of the United States.  By using the Service or providing us with any information, you consent to the transfer to, and processing, usage, sharing, and storage of, your information, including Personal Information, in the United States as set forth in this Privacy Policy.


7. What About Security?

We endeavor to incorporate commercially reasonable safeguards to help protect and secure Personal Information.  However, no data transmission over the Internet, mobile networks, wireless transmission, or electronic storage of information can be guaranteed to be 100% secure.  Please note that we cannot ensure the security of any information you transmit to us, and you use the Service and provide us with your information at your own risk.


8. What About Changes to the Privacy Policy?

We reserve the right to
change this Privacy Policy at any time.
Any changes will be effective immediately upon the posting of the revised
Privacy Policy and your use of the Service indicates your consent to the
privacy policy posted at the time of use.
However, we will not use your
previously collected Personal Information in a
manner materially different than represented at the time it was collected
without your consent.  To the extent any
provision of this Privacy Policy is found by a competent tribunal to be invalid
or unenforceable, such provision shall be severed to the extent necessary for
the remainder to be valid and enforceable.