Stova Privacy Policy

Stova Privacy Policy

 

Stova Group, LLC is committed to protecting the privacy of visitors to its websites and all users of its products and services, through our compliance with our Privacy Policy.  We have published this Privacy Policy to provide you with details regarding the type of information Stova may collect from you, and to explain how we gather, use, protect and share your information.  Please read this Privacy Policy carefully to familiarize yourself with Stova’s privacy practices and procedures.

  1. About Our Privacy Policy.

This Privacy Policy applies to information that Stova may collect about you (a) through Stova’s cloud-based event management and registration platforms, mobile applications, and other software applications and solutions (collectively, the “Platform”),   (b) in connection with your access and use of Stova’s websites (including www.stova.io, www.aventri.com, www.eventcore.com, www.meetingplay.com, and any other Stova websites that link to this Privacy Policy, the “Websites”), and (c) through Stova’s own external marketing activities (such as promotional events and our social media pages). In this Privacy Policy, the Websites, Platform, and any other Stova-operated digital environments through which you may interact with Stova to provide your information are collectively referred to as the “Sites.”

Where this Privacy Policy uses the term “personal data,” that term refers to information relating to a natural identified or identifiable person. Personal data may include your name, contact information, ID numbers, and other information that could be used to identify you.

This Policy also describes your data protection rights, including your right to object to some of Stova’s processing activities. However, this Privacy Policy does not apply to data collected by any third parties, including through third party applications or any other third-party products, advertisements, or websites that link to or are accessible from our Sites.

If you do not agree with this Privacy Policy, please do not access or use the Stova Sites.

  1. Who We Are.

As used in this Privacy Policy, “Stova” “we” or “us” refers to Stova Group, LLC, together with its wholly-owned subsidiary operating companies (Aventri, LLC; eventcore LLC; MeetingPlay, LLC; Loopd, LLC.; Zentila, LLC.; Aventri (UK) Ltd.; Aventri Asia Pacific Pty. Limited; Aventri India Private Ltd.; ITN International LLC; Aventri (Calgary) Corp.; and TapCrowd BVBA).

  1. Who You Are: Client, Client Contact, or Visitor.

“You” are an individual who visits our Websites, uses our Platform, or otherwise interacts with Stova, as one of the following:

  • A Client – Clients are individuals who are employees, agents, contractors, or representatives of an organization (such as a host, organizer, or planner of an event) that has entered a master services agreement or similar commercial contract with Stova, and orders services directly from Stova under that master services agreement. For purposes of this Privacy Policy, “Clients” include client personnel that are assigned a login ID and are authorized to access and use the Platform on behalf of the client organization.

 

  • A Client Contact – A Client Contact is an individual that interacts with our Client through the Platform. Client Contacts may include a Client’s customers and prospective customers, event attendees, sponsors, exhibitors, speakers, and other Client business partners or contacts.   Client Contacts may include, for example, individuals who are invited to, register for, check into, or receive information regarding a Client event via the Platform, people who participate in a virtual, onsite or hybrid event organized by a Client, or those who download a mobile application in connection with a Client event.

 

  • A Visitor – This category includes individuals who visit and interact with our Websites (for example, to find out more about Stova’s products and services, download a whitepaper, sign up for a Stova demo, or register for a Stova webinar), those who attend Stova’s marketing or networking events, and prospective clients that we meet at tradeshows or through a referral from third parties.

 

How your data is collected, used, stored, transferred, and otherwise processed will depend on whether you are a Client, Client Contact, or Visitor. 

When we collect information from you as a Visitor, we are doing so on our own behalf (in which case Stova will be considered a “controller” of your data).  When we are collecting information from you as a Client or as a Client Contact, we are doing so for the benefit or on behalf of a Stova Client who is using the Platform to organize an event and manage other event-related activities; in this case, the Client will be the “controller” and Stova will be considered a “processor” of your data.

  1. Clients and Client Contact Data.

4.1       How our Clients Collect and Use Personal Data

  1. Types of Personal Data Collected by Our Clients. The Stova Platform allows our Clients to collect, store and process a variety of information from and about their event registrants, attendees, and other Client Contacts, including personal data such as name, organization, title, physical address, email address, telephone number, social media IDs, occupation, meal preferences, professional and personal interests and opinions, and payment information. Clients will also have access to information (including personal data and Platform usage data) related to how Client Contacts interact with the Platform, as well as information that Client Contacts may submit on event-related message boards, and chat room posts. Stova does not control the Client’s event management process, or the personal data that a Client requests from its Client Contacts or collects through our Platform. If a Client is submitting or collecting personal data of its Client personnel or any Client Contact through the Platform, Client must have obtained required consents prior to transferring this information to Stova for processing.

If you are a Client Contact, please make sure to read the privacy policies of the Client who is organizing the event, in order to understand more about the types of data being collected by the Client, and how they will collect, use, share and otherwise process that data.

  1. How Our Clients Collect Personal Data from Client Contacts. Clients can use the Stova Platform to collect personal data from Client Contacts in a number of ways.  For example:
  • Client Contacts may voluntarily and directly enter their personal data into our Platform
  • Client may enter Client Contact information into our Platform when permitted to do so (for example, by having been granted explicit consent from the Client Contact, or when the Client has a legitimate business interest).
  • A Client Contact’s data may be collected automatically, as the Client Contact interacts with the Stova Platform, by means of commonly used automated information gathering technology such as cookies. For additional information about these types of technologies, please see Section 6 of this Privacy Policy, and our Stova Cookie Policy.
    • For instance, if a Client Contact downloads and uses a mobile app provided by Stova for a Client event, it may collect app usage data, including what type of mobile device they are using. If, where applicable, a Client Contact has requested or consented to location services in connection with their use of a Stova mobile app, tracking technology may automatically gather information about their location and use this data to provide location-based event information. (Most mobile devices enable you to shut off location-based services; please access your mobile device’s “Settings” for more information.)
  1. How our Clients Use Personal Data. If a Client chooses to use our Platform to interact or conduct business with a Client Contact, any personal data submitted by the Client Contact in connection with that interaction (for instance, in registering for an event, responding to an online survey, downloading a mobile application, or communicating with event exhibitors or speakers) will be transferred to the Client, who will be considered to be under the owner and controller of such data. The Client determines how it will use the Client Contact’s Personal Data.

Stova only collects and processes a Client Contact’s personal data at the Client’s direction, in accordance with instructions provided by the Client, including applicable terms in any Client contract. With respect to the persona data of a Client Contact, Stova is a “data processor” and, for all purposes, the Client acts as the “data controller” under the data protection laws of the European Economic Area (the “EEA”), the United Kingdom (“UK”), and Switzerland.  Therefore, Stova cannot and will not take responsibility for the privacy practices of any Client.  The ways in which Clients will collect, use and process your personal data are governed by each Client’s own privacy policies and procedures. Please read the applicable privacy policies of the Client who is organizing the event before submitting personal data in connection with that event.  Stova is not responsible for any decisions or actions taken by the Client with respect to your information (or by any third party with whom the Client may share your information).

  1. Will Stova Use or Sell Personal Data Collected by Our Clients? No, Stova will not sell or use personal data of Clients or Client Contacts.  Stova’s use of Client Contact personal data collected through the Platform is limited to the purpose of providing services that our Client have ordered, to improve those services, or as required or permitted by law.

4.2       How Stova Collects and Processes Personal Data of Clients and Client Contacts

  1. How Stova Collects Personal Data from its Clients. Stova collects personal data from its Clients in order to facilitate service-related communications and the delivery of Stova services ordered by the Client.  We may collect Client personal data in connection with, for example, a Client’s execution of a contract, creation of an account on one of our Sites, interaction with a chatbot or our customer support team, response to a customer satisfaction survey or service-related email, or participation in Stova training sessions. We may also collect personal data and payment information (for example, credit card number and billing address) as needed for Client billing and payment purposes.

Stova may, on occasion, record calls or video conferences between Client and our customer support or training teams for legitimate business interests relating to the provision of Client support, training and quality assurance purposes, or compliance with applicable laws; in such cases, Stova will obtain Client consent before proceeding with the recording, when required by applicable law, and retain such recordings no longer than necessary to support the legitimate business interest.

Stova also collects Client usage information regarding how a Client interacts with our Platform (for example, which Platform modules you visit, how long you spend on certain Sites, what language you prefer, etc.)

  1. How Stova Processes the Personal Data of Clients and Client Contacts.

(i) If you are a Client Contact, Stova may process your personal data in following manner and for the following purposes, pursuant to a Client’s instructions and applicable law:

  • To deliver those services that our Clients have ordered us to provide through our Platform. For example:
    • If a Client Contact uses our Platform to register for an event, we will use their provided email address to send them information and announcements related to that event;
    • If a Client Contact uses our Platform to pay for event registration fees, we will pass the credit card information to the payment card processor to complete the transaction;
    • If a Client purchases lead retrieval services, and Client Contact consents to having an event exhibitor or sponsor scan their event badge to share contact information, or the Client Contact opts in, through the Platform, to receive exhibitor or sponsor information, we will disclose the Client Contact’s personal data to that event exhibitor or sponsor;
    • As instructed by the Client, to connect Client Contacts with one another for optional business networking purposes;
    • If a Client Contact submits meal or hotel room preferences through the Platform, we will share that information with the event organizer or venue.
  • For other purposes when Client Contacts have provided express consent.

 

(ii) If you are a Client, Stova may process your personal data in the following manner and for the following purposes:

  • To respond to your inquiries and fulfill your requests, and to provide you with customer support when you ask for it.
  • To send you service updates, product specifications and other content that you have requested or subscribed to, as well as instructional materials regarding our Services.
  • To provide you with legal, technical and administrative information relating to your use of our Sites and services, such as security notices, Service-related status reports, and changes to our policies or terms of use. Please note that these communications are considered part of our Services and you may not opt out of them.
  • If you have consented and it is in compliance with applicable laws, to send you marketing communications regarding additional products and services that we believe may be of interest to you. If you later decide that you no longer want to receive this type of marketing or promotional information, you may opt out at any time by clicking the “Unsubscribe” button at the bottom of the marketing communication, or contacting us at the email or mailing address provided in the “Contact Information” section of this Privacy Policy.
  • For any other purposes disclosed to you at the time of collection or pursuant to your consent.

(iii) If you are a Client or Client Contact, Stova may also process your personal data as follows:

  • For our legitimate internal business purposes that include administering your access and use of our Platform, Platform-related data analysis, securely identifying users when they log onto the Platform, security monitoring, enhancing or updating our Platform features, and billing for services.
  • To personalize your experience on the Platform by offering features tailored to your preferences.
  • As we believe to be necessary: (i) under applicable law, including laws outside your country of residence; (ii) to protect against or identify fraudulent transactions; and (iii) to enforce our terms of service.
  • If you are accessing any Site as a Client Contact or an authorized user of a Client (for example, as a Client employee with administrator account access to the Platform), Stova is permitted to provide the Client with your information, including but not limited to your personal data, access information and usage data.

Also, please note that if information is aggregated or de-identified so that it is no longer reasonably associated or trackable to an identifiable natural person, it is no longer considered “personal data” under this Privacy Policy and Stova may process and use it for any legitimate and lawful business purpose.

  1. How Stova Processes the Payment Data of Clients and Client Contacts.

If you opt in to the storage of your credit card information, you hereby consent to Stova storing the credit card information (each such credit card and accompanying information being a “Stored Payment"). You acknowledge that your Stored Payment may contain personal information. You acknowledge and agree that you are responsible for the completeness and accuracy of the Stored Payment you provide. Stova regularly reviews the security measures relating to our storage; however, we cannot guarantee that the information you transmit or store via the Internet is entirely secure.

 

You hereby consent that your Stored Payment may be used by Stova as permitted:

  • To process payment for orders received from you;
  • For pre-authorized credit card transactions; and
  • To process any refunds as required.

Your Stored Payment will be linked or otherwise transferred to our payment card processor as necessary to complete the permitted purpose.

Your consent to Stova for storage of the Stored Payment shall remain in effect indefinitely or until (i) you withdraw your consent; or (ii) a Stored Payment is no longer effective as reasonably determined by Stova. You may withdraw your consent by updating your saved payment preference to opt out.

  1. How long Stova Processes Personal Data of Clients and Client Contacts. Stova will collect personal data about Clients and Client Contacts, process that data on behalf of the Client, and retain any such information in accordance with the Client’s instructions (including the terms of any applicable Client contract) for as long as necessary to provide our services to the Client and comply with applicable laws and regulations. Unless otherwise instructed by a Client or agreed in our contract with a Client, Stova will process the data until 60 days after the termination of the contract, at which time we remove it from our production environment.  In 12 months, the data is removed from our backup media.
  2. How Stova Collects and Processes Visitor Data

Stova collects and processes Visitor data separately and differently from the way in which it collects and processes the data of Clients and Client Contacts.  By visiting Stova’s Websites, attending Stova marketing or networking events, agreeing to be introduced to Stova through a third-party referral, or providing us with your personal data as a potential Client, employee, supplier, business partner or otherwise, Visitors consent to the collection and processing of their personal information as described in this Privacy Policy.

  1. Types of Visitor Personal Data Collected by Stova.

Stova may collect, store and process a variety of information from Visitors, including personal data such as name, employer, title, email address, postal address, telephone number, IP address, social media ID, company information (including financial and billing information if Visitor is purchasing Stova products or services), IP address, computer or mobile device information (such as device type, browser, plug-ins, language, and time zone, actions taken on our Websites (for example, clicks, reference pages, and search terms that led a Visitor to our Website), the content of survey responses, chat messages and promotional inquiries.

 

  1. How We Collect Visitor Personal Data. We collect Visitor Personal Data in a number of ways.  For example, if you visit one of our Websites and fill out a form, submit a message to our chatbot, request a free demo, contact a Stova sales or customer support representative, download content (such as a white paper) from our Website, sign up for a Stova webinar, register for a Stova promotional event, or respond to a Stova survey or marketing outreach message, you may be asked to provide certain personal data, including your contact details. We use this personal data for purposes such as answering questions about our products and services, conducting market research, providing information you have requested, or following up after your visit.

We may request and collect Visitor personal data offline as well - for example, when you attend a Stova marketing event or tradeshow, or if you call one of our sales representatives for information about our product offerings.  We may also collect customer testimonials which contain personal data; we obtain each customer’s consent prior to publishing the customer’s name, image, and testimonial.

We also collect personal data from third party sources, such as public databases, marketing partners, referral partners, and social media platforms. For example, if a Visitor comes to our Website through a link on a social media platform, certain personal data associated with their social media account profile may be shared with us.  If you believe a third party has provided us with your personal information without your consent, please submit an inquiry to [email protected].

  1. How We Use Visitor Personal Data.

 

Stova may use Visitor personal data in order to do one or more of the following:

 

  • Analyze how our Websites are accessed and improve the user experience;
  • Personalize your browsing experience and present you with marketing offers and additional products or features that may be of interest or more relevant to you;
  • Identify Website technical issues;
  • Discover, investigate and remediate fraudulent or illegal activity;
  • Transmit notices related to product, service, or policy changes;
  • Respond to your product and service inquiries;
  • Send you information such as product announcements, newsletters, whitepapers, other relevant offers, and details of upcoming promotions or events (where required, dependent on jurisdiction, we will seek and obtain your explicit consent before sending marketing emails);
  • Plan and host Stova marketing events, online webinars and social network activities in which Visitors may participate;
  • Analyze and identify new business prospects;
  • Create tailored advertising, sales and promotional campaigns;
  • Send invoices for any products or services purchased by a Visitor;
  • For other purposes when Visitors have provided express consent; and
  • To comply with applicable laws and regulations

 

To remove yourself from Stova mailing lists and opt out of Stova marketing communications please click the “Unsubscribe” button on Stova email communications and/or contact us at [email protected].

 

  1. How Long We Process and Retain Visitor Personal Data.

 

Where we process Visitor personal data for our own marketing purposes or with Visitor consent, we process the data for so long as we have a legitimate business need to do so.  After a reasonable amount of time, we will either delete or anonymize your information. We will delete personal data earlier, if a Visitor withdraws consent or otherwise requests us to stop. We will implement such request in a timely manner, within the period required by applicable law.  In any event, Stova will not retain Visitor personal data longer than the statutory retention period permitted in the local jurisdictions where Stova services are marketed and provided. We also keep a record of when Visitors have asked us not to send direct marketing communications or to process Visitor data, so that we can honor the Visitor’s request in the future.

 

  1. How We Share Visitor Personal Data

 

Stova may share Visitor information with third party service providers contracted to provide services on our behalf as well as third parties who resell Stova services. Stova will share personal data of Visitors who attend a Stova marketing event with third parties if a) the Visitor explicitly consents, (b) the Visitor allows their badge to be scanned by or on behalf of the third party, or (c) it is permissible under applicable law.

 

  1. Additional Ways Stova May Collect Your Data:

 

6.1       Cookies and Similar Technologies.

When you visit our Sites, Stova may automatically collect additional information from your computer or device through the use of tracking technologies such as “cookies,” which are small data files placed on your computer’s hard drive to assign an identification code to your computer.  These technologies gather details of your visits to our Sites, such as:

  • The date and duration of your visit;
  • the pages, content and actions you view or take and links you click on while navigating within our Sites;
  • your computer type (e.g., Mac or Windows), mobile device type and carrier, language, and internet browser
  • any web pages that referred you to our Site,
  • Your Internet Protocol (IP) address (a numerical address assigned to your computer or device by your Internet service provider so that other computers or devices connected to the Internet can communicate with your computer or device online) that can sometimes be used to derive your general geographic area;

We use information gathered by cookies and similar technologies to make our products and services more useful to you, for reasons including improving Site performance and security, performing statistical analytics, and enhancing the user experience (by, for example, identifying a registered user who logs into the Stova Platform, and storing that user’s preferences). You may set your computer’s browser preferences to remove and disable cookies. But please note that some features of the Sites may not be accessible or operate properly if you disable your cookies. For more details about how we use cookies, web beacons and similar technologies, please see our Stova Cookie Policy.

  •      Other Sources.

 

  • From Smart Badges: If you are using a Stova smart badge at a Client or Stova event, the badge will collect certain data regarding your attendance at that event; this may include information such as what time you check in and out, which sessions you attend, what exhibitors you visited, and with whom you exchanged contact information using the smart badge technology.
  • From Email, Texts and Phone messages: If you contact a Stova representative using our customer support email, a Stova phone line, or any one of our informational email mailboxes (e.g., [email protected], [email protected]), we will store personal data such as the email address or phone number from which you sent the message, and use the information to reply to you.
  • From Social Media features and Widgets: Our Sites may include social media features, such as the Facebook “Like” button, and widgets, such as the “Share This” button or interactive mini-programs that run on our Site. These features may collect your IP address, and may set a cookie to enable the applicable feature or widget to function properly. If you link or sign onto a Site via a social networking site, your profile photo and social network ID may be displayed. Social Media features and widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these features are governed by the privacy policy of the company (whether Stova, Facebook, Instagram, LinkedIn or some other third party) providing the feature, and you must contact them with any requests you may have for access, modification or deletion of your personal information.

 

  1. How We Share the Personal Data We Collect

 

This section describes how Stova may share or transfer personal data it collects from Clients, Client Contacts, and Visitors.

  • Subsidiaries and Affiliates. Stova may disclose personal data to its wholly-owned subsidiaries and affiliates for the purpose of providing services to our Clients and their Client Contracts, and for engaging in sales, marketing and customer support activities with Visitors. Stova Group, LLC is the entity responsible for the management and security of personal data shared among Stova subsidiaries and affiliates.  Please see Annex III of our Data Processing Addendum for a list of Stova affiliates and their locations.
  • Service Providers. Stova may use third party service providers, contractors and sub-processors to provide certain services and perform functions on our behalf. Examples include web hosting providers, data centers, and payment processors. Stova may share or transfer your personal data only to the extent necessary for such third-party service provider to perform the duties for which it has been retained by Stova. Any such third parties will be bound to strict confidentiality and use obligations with respect to your personal data, which are no less protective than those set out in this Privacy Policy. Stova agrees that it will remain responsible for the compliance of a third party service provider (“Sub-Processor”) with the obligations of our  Data Processing Addendum, and shall be liable to the relevant party for the acts and omissions of any Sub-Processor with respect to Personal Data, to the same extent as if the acts or omissions were performed by Stova.  Please see Annex III of our  Data Processing Addendum for a list of Stova’s third party sub-processors.
  • Legal Compliance and Compelled Disclosure. Stova may disclose your information to government or law enforcement officials, regulatory agencies or other third parties (such as attorneys or regulatory service providers), as necessary to (i) comply with applicable laws or regulations, (ii) cooperate with governmental or law enforcement investigations, (iii) respond to legal claims or processes, (iv) protect the safety and legal rights of the public or any individual, (v) detect, prevent or remedy any suspected fraud, market manipulation or illegal, tortious or wrongful activity; or (vi) enforce applicable contracts to which you have agreed.
  • Business Transfers. Stova may also share personal data in connection with a merger, acquisition, divestiture, restructuring, recapitalization, reorganization, dissolution or other sale or transfer of some or all Stova’s assets, in which personal data held by Stova is among the assets transferred. However, in the event of such a transfer, your information will remain subject to the protections of this Privacy Policy. Stova will notify you if your information is subject to a business transfer and becomes subject to the other company’s privacy policy.
  • Chat Rooms, Message Boards and Social Media Pages. Our Sites may offer the ability for you to engage with message boards, chat rooms, social media sites, and other forums in which you are able to post information and content. Please keep in mind that if you choose to disclose personal information during your participation in such forums, it may be viewed, collected or used by members of the public who access those forums. Please do not post any information that you do not want to be disclosed to the public.

Except as provided in this Privacy Policy, Stova will not disclose, transfer, sell, trade, rent, or otherwise provide your personal data to any third party, without your prior consent. Stova does not share, sell or trade any information with third parties for any promotional or marketing purposes.

  1. How We Transfer Data We Collect Internationally

Stova provides services globally. To facilitate Stova’s business and deliver our services, personal data may be collected internationally and accessed from, transferred to, or stored in the United States or in other countries in which we operate or maintain hosted server locations.  This Privacy Policy applies even if Stova transfers your personal data to other countries, and we have taken appropriate measures to require that your personal data will remain protected wherever it may be transferred.  To this end, Stova complies with applicable laws and regulations on the transfer of personal data between countries.  For example, when we share personal data of individuals in the EEA, Switzerland or the UK with our affiliates or third-party sub-processors, we make use of the European Commission-approved Standard Contractual Clauses (including any applicable regional addendums).  Please refer to our Data Processing Addendum for further information on Stova’s practices for the international transfer of personal data.

  1. How to Access, Correct or Delete Your Personal Data

Depending on your user type and location, we provide you with various ways to access, correct and request deletion of your personal data.

  • If you are a Client who is a registered user of the Stova Platform (for example, a Client employee who has been assigned an administrator account on the Platform), you can access, update, modify, correct or delete both personal data and non-personal information by logging onto your user account and visiting your account settings.
  • A Client or Visitor may submit requests to access, update, correct or delete their personal data, to opt out of certain communications, or to withdraw its consent to the collection, processing, and/or transfer of personal data, by contacting Stova at [email protected] and/or at the mailing address provided in the “Contact Information” section of this Policy. We will process your request in a timely fashion, but in any event within the time required under applicable law or regulation. Once we have received notification that you withdraw your consent, we will no longer process your personal data for the purpose(s) to which you originally consented unless there are compelling legitimate grounds for further processing which override your interests or rights, or for the establishment, exercise or defense of legal claims.
  • If you are a Client Contact, please note that Stova usually has no direct relationship with Client Contacts and, because Stova processes Client Contact data solely on behalf and at the direction of our Clients, we have no express control or ownership of your personal data that is processed on our Platform. If you are a Client Contact who interacts with our Platform and you would like to access, correct or delete your personal data, or would no longer like to be contacted by the Client controlling the information, please direct your request to the Client. If the Client requests that Stova turn over, correct or delete your personal data, we will respond to their request in a timely manner, but in any event within the time required by applicable regulation or law. Clients are responsible for complying with any regulations or laws requiring notice, disclosure or obtaining consent prior to transferring the data to Stova for processing.
  • If a Client, Client Contact, or Visitor is a resident of the EEA, the UK, Switzerland, or various other countries, as well as certain U.S. states, it has the right to:
    • access all of its personal that we possess, and request that copies of certain types of personal data to be delivered to them in an electronically portable and machine readable format;
    • request that we modify or update any of their personal data;
    • request that we delete any of their personal data; and
    • where Stova processes their personal data on the basis of consent, fully or partially withdraw consent to the collection, processing, and/or transfer of their personal data.
  • The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
  • Stova will not accommodate a request to change or delete information if we believe the change or deletion would violate any law or regulatory requirement, or cause the information to be incorrect.  In such instances, we will inform the Client about the legal obligations that prevent us from fulfilling the request.
  • We will maintain an audit history of any requests to access, correct or delete personal data, as necessary to maintain a record of compliance with applicable laws and regulatory requirements.
  1. Stova’s Legal Basis for Collecting and Processing Personal Data.

For individuals that are from the UK, the EEA, Switzerland, or other regions that require a lawful basis for processing personal information (such as under GDPR Article 6), Stova’s legal basis for collecting and processing personal data of Clients, Client Contact and Visitors will depend on the nature of the personal data, the context in which we are collecting it, and the circumstances of the processing activity.  When we collect, use, process or disclose your personal data, we will rely on one or more of the following legal grounds:

  • Performance of a contract (including any Client contract) – Where we need the personal data to perform our obligations under a Client master services agreement or other binding contract.
  • Consent – Where we have received your consent to do so.
  • Legitimate Interests – Where it is in our legitimate business interests (for example, to provide individuals with access to the Stova Platform, to improve our products and services, to send individuals information they have requested, to ensure the security of our Sites by preventing unauthorized access, or to enforce compliance with our terms of use and other policies), and such interests are not overridden by the individual’s data protection interests, or fundamental rights and freedoms.
  • Legal Requirement – If we are required to collect, use, process or disclose your personal data due to a legal or regulatory requirement, we may do so.

So, for example, where we are the processor for our Clients, our legal basis may be fulfilment of a contract or consent. Where we are the controller for Visitor personal data, our legal basis will be consent or legitimate interest.

  1. Information for California Residents.

California residents can make certain requests regarding their personal information pursuant to the California Privacy Rights Act ("CPRA"), including the right to request that Stova disclose information to you about your personal data that Stova has collected, used and disclosed in the past 12 months; that Stova delete your personal data, subject to certain exceptions; and the right to opt out of the sale of your personal data. To make such a request, contact Stova at [email protected] or call +1-800-516-4265.  Stova will fulfill these requests in accordance with California law. Please note these rights are not absolute, and there may be cases when a request is declined, as permitted by law.

Stova may have collected the following categories of personal data from California residents in the past twelve (12) months:

  • Identifiers such as name, e-mail address, mailing address, or phone number.
  • Categories of personal information described in subdivision (e) of California Civil Code Section 1798.80.
  • Characteristics of protected classifications under California or federal law.
  • Professional information, employment-related information, or education information
  • Internet browser or device information, such as IP addresses, and other electronic network activity information.
  • Geolocation data.
  • Audio and visual information, such as customer service call recordings.
  • Commercial information, including records of products or services purchased or considered.
  • Payment data.
  • The contents of voicemails, SMS/text messages, and chats, if you interact with us online via message boards, surveys or blogs, or by phone or email.

This data is collected and used for the purposes described in this Privacy Policy, and may have been shared pursuant to an individual’s consent, or under a written contract with a customer or service provider for a legitimate business purpose. If you wish to have your information excluded from this type of disclosure, contact us at [email protected], to submit the request.

Stova will not discriminate against you if you choose to exercise one of your privacy rights. Please note however, if you request that your personal data be deleted, it may impact your experience with the Stova Sites and you may not be able to utilize certain features or services which require personal data to function.

  1. Information about Children

The Websites, Platform and other Stova products and services are not intended for or targeted at children under sixteen (16) years of age. Stova does not directly solicit, or knowingly and intentionally collect any personal data from, children under sixteen (16) years of age. If you believe that we have collected personal data about a child under 16, please contact us at [email protected], so that we may delete the information.  Please note that this Privacy Policy does not apply to our Clients with whom your child may interact. You should review the applicable practices and policies of those Clients to determine their appropriateness for your child, including any terms regarding data collection and use.

  1. Information about the Data Privacy Framework Program

Stova complies with the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (“Swiss-U.S. DPF”) as set forth by the U.S. Department of Commerce. Stova has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (“EU-U.S. DPF Principles”) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. Stova has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (“Swiss-U.S. DPF Principles”) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (“DPF”) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Stova commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU and UK individuals and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF should first contact Stova at:  [email protected].

In compliance with the EU-U.S. DPF, Stova commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Stova commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF to JAMS, an alternative dispute resolution provider based in the United States and the United Kingdom. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://www.jamsadr.com/DPF-Dispute-Resolution for more information or to file a complaint. The services of JAMS are provided at no cost to you.

Under the Data Privacy Framework, in certain instances, individuals may be able to invoke binding arbitration. Stova’s obligation to arbitrate certain claims in accordance with the terms set forth in Annex I of the DPF Principles is subject to an individual invoking binding arbitration by (i) delivering written notice to Stova at [email protected] and [email protected]; and (ii) following the procedures and subject to the conditions set forth in Annex I of the DPF Principles. For more information regarding these options, please visit https://www.dataprivacyframework.gov/framework-article/ANNEX-I-introduction.

  1. How Stova Keeps Your Personal Data Secure

Stova makes it a priority to safeguard the security and privacy of your personal data. We follow generally accepted standards to protect the personal data submitted to us, both during transmission and after we receive it. Stova has implemented appropriate technical, organizational and administrative measures to protect your personal data from unauthorized access, disclosure, misuse, alteration or loss.

These measures include security controls to prevent unauthorized access to our facilities and systems, strong authentication procedures and strict password protection protocols, utilizing encryption software for all financial and other sensitive personal data transmitted on or through our Sites, and conducting regular penetration tests. In the event of any security breaches, we will make legally required disclosures to you.

While we take reasonable steps to protect your personal data, please be aware that no method of Internet transmission or electronic storage guarantees complete protection or is 100% secure, and there is always some risk when you share your personal data online. Stova therefore cannot guarantee the absolute security of your personal data.

If you have any questions about security on our Sites, or if you have reason to believe your interactions with us are no longer secure, please contact us at [email protected].

 

  1. Other Important Privacy Information
  2. Profiling and Automated Decision Making. While information you provide to Stova may be analyzed or processed in a manner that helps us predict and determine your interests and preferences (for example, what products and services may be of interest to you, and when you might be ready to purchase a particular service) based on your behaviors on the Sites and interactions with Stova, this process is overseen by Stova staff. We do not process your personal data using automated decision-making technology for the purposes of profiling consumers in furtherance of decisions that produce legal or similarly significant effects. If we were to establish an automated system to make such decisions based directly on your personal data without human intervention, we would provide you with a right to opt out.
  3. Emails and other Communications – Unsubscribing and Opting Out. Stova offers individuals the opportunity to choose (opt out) whether their personal information is disclosed to a third party or used for a materially different purpose than was originally collected or authorized. To choose to opt out, individuals can use the following available mechanisms to exercise their choice:
  • To remove or modify how one’s personal information is used by Stova, individuals can contact us at [email protected].
  • You may have consented to receive certain communications marketing or advertising Stova products and services. You can opt out of receiving these marketing messages at any time by clicking on the “Unsubscribe” link at the bottom of any such message, or by contacting us at the email and/or mailing address provided in the “Contact Information” section of this Policy.
  • Clients may use our Platform to send you emails and other electronic communications, if you are on their email subscription lists or have registered for one of their events. Although these messages are sent using our Platform, we don’t determine the content or recipients of these messages. You should contact the Client directly, or click any “Unsubscribe” link provided in the messages, if you no longer want to receive communications from that Client.
  • Even if you have opted to “Unsubscribe” from certain types of messages, please be aware that emails and other communications that (a) are responding to your specific requests for information or customer support, or (b) are provided as an inherent feature of specific Stova services you are still receiving, will be sent to you.  You should contact us directly at [email protected] if you no longer wish to receive responsive or service-related communications; but please be aware that if you opt out of these types of communications, you may no longer receive important messages regarding events that you are organizing or attending, or critical notifications regarding the availability, status and security of Stova services.
  1. Third-Party Websites and External Links. Our Sites may contain links to websites (including those of event venues, event sponsors, Stova business partners, and social media sites) owned and operated by third parties. When you click on such links, you may leave our Site and be directed to the third parties’ websites. These websites may themselves collect personal data about you. If you submit information to any of those sites, your information is governed by their privacy policies, which may differ from those of Stova. Stova is not, and will not be, responsible for the privacy practices or security of any such websites, and we urge you to read their privacy policies carefully.

Also, please be aware that we are not responsible for the collection, use and disclosure policies (including privacy practices) of other companies, such as Facebook, Google, Instagram, Twitter, LinkedIn, or other app providers, app stores, social media platforms, operating system providers, wireless service providers or device manufacturers, including any data that may be collected from you directly by such companies in connection with your access and use of Stova’s Sites.

  1. Sensitive Information. Where Stova is collecting, storing and processing personal data of Clients or Visitors on our own behalf, as a data controller, we will not request any sensitive personal data such as your health history, race, religion, or sexual orientation. We request that you do not send or provide us with such sensitive personal data on or through the Sites, by email, or through any other means.
  2. Our Contact Information.
  3. Our Data Protection Team. Your privacy is important to us. If you have any questions or concerns about privacy at Stova, or if you think we have not followed our Privacy Policy in some way, please contact us, and we will try to answer your question or resolve any issues for you. We take seriously any complaint, and it will be assessed by qualified staff with the goal of resolving it in a timely manner.

You may contact our Privacy Team using the following information:

Stova Group, LLC
16217 South Camp Williams Road, Suite 400

Bluffdale, Utah 84065 USA

Attention: Privacy Team
E-mail: [email protected]
Telephone: +1-800-516-4265

 

  1. Our Data Protection Officer. If you have questions regarding the role of Stova’s Data Protection Officer (DPO), or would like to contact our DPO directly to discuss any questions relating to this Privacy Policy, you may do so using the following information:

Contact Name: Jesse Braughler

E-mail: [email protected]
Telephone: +1-800-516-4265

 

  1. Others

Subject to applicable law, you also have the right to lodge a complaint with your local data protection authority or other supervisory authority about our collection and use of your personal data. For more information, please contact your local data protection authority. EEA residents can find contact information here: EU Data Protection Authorities. Stova is also subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). U.S. residents may file a complaint by contacting the Federal Trade Commission at https://reportfraud.ftc.gov/.

If you are a Client Contact, please direct any questions you may have regarding your personal data to the Client organizing the event, not to Stova. As noted previously in this Privacy Policy, if you are a Client Contact, Stova processes your personal on behalf of that Client. The Client determines what Personal Information to request from you, how it is used, with whom it may be shared, and for how long it is retained.

If you are unable to access this Privacy Policy due to a disability or any physical or mental impairment, please contact us at [email protected] or +1-800-516-4265, and we will arrange to supply you with the information you need in an alternative format that you can access.

  1. Amendments to Privacy Policy

Our business is constantly evolving and so are the laws and regulations governing privacy and personal data.  Therefore, our Privacy Policy may need to be updated from time to time. Please visit this section of the Site periodically to check for changes and updates to the Privacy Policy. If we make significant changes to this Privacy Policy, we will notify you either through the email address you have provided to us (unless you have instructed us not to), and/or by placing a prominent notice on our Websites. By continuing to access and use the Sites after such notice has been posted, you agree to be bound by the terms of the revised Privacy Policy. Personal data provided to Stova is controlled by the Privacy Policy in effect at the time the data is provided.

 

LAST UPDATED:  16 December 2024