1. INTRODUCTION

sterkly LLC (the “Company,” “we” or “us”) operates http://sterkly.wpengine.com and http://www.sterklytracking.com (the “Sites”), home of the sterkly Affiliate Network (the “Network”), an online marketing network of advertisers and affiliates. The Sites, and any other applications, products, services, features, content, or promotions offered from time to time by the Company or third party providers on the Sites or otherwise in connection with its business shall be referred to herein as the “Services”. The Company is based in the United States and the Services are hosted in the United States. This Privacy Policy (“Privacy Policy”) discloses how we collect and use information, and the choices that you can make about the way we collect and use your information.

If you are not yet 18, you are not allowed to use our Services. Further, if we learn that we have collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have any information from a child under age 13, please contact us through our support page (http://sterkly.wpengine.com/contact-us).

This Privacy Policy applies to all users, including those who use the Services without being registered with the Company and those who have registered with any Services. This Privacy Policy describes the Company’s collection and use of users’ personal information (e.g., information that identifies a specific person, such as full name or email address) where that information is not otherwise publicly available on the Services. We also describe generally the Company’s practices for handling non-personally identifiable information (e.g., demographics and site usage) to the extent such information is associated with a particular user. Your access to and use of certain Services, may require you to accept additional terms and conditions or a privacy policy applicable to such Services.

Collection, use, disclosure, and protection of personal information may be subject to different regulations outside the United States. Regardless, if you use our Services, you agree to abide by this policy.

Please read this Privacy Policy carefully so that you understand our online privacy practices regarding:

• Information We Collect
• How We Use Your Information
• How We Use and Share Your Information
• Your Choices

2. SUBMISSION AND COLLECTION OF INFORMATION

User Submitted Information

Personal Information You Submit. We may collect personal information at various times when you use our Services. The more information you volunteer (and the more accurate it is), the better we are able to customize your experience. Your participation is voluntary and you have the choice not to disclose any information that we request.
As a member of the Network, you may be required from time to time to provide the Company with certain personal information, including without limitation, your name, address, telephone number, electronic mail addresses, credit card information, bank account information, and your social insurance or social security number. We will use such account information to establish your Network account, to communicate with you, to remit payments to you from time to time when due, and for ongoing record keeping, as required by law.
Contacting Us. We collect your name and email address on the Sites’ “Contact Us” forms. We use this information for the sole purpose of responding to your inquiry. If you voluntarily submit information or contact us (e.g. technical support), we may keep a record of this communication.
Customer Support. If you use the customer support section on the Sites we will collect your email address, topic and any additional information you provide us. We use this information for the sole purpose of responding to your inquiry.

Collected Information

Transactional and Site Activity Information. When users access the Services, we collect certain non-personally identifiable information about those visits for marketing purposes. For example, in order to permit your connection to the Services, our servers receive and record information about your computer, operating system and browser, including your IP address, browser type, and other software or hardware information. If you access the Services from a mobile or other device, we may collect a unique device identifier assigned to that device or other transactional information for that device in order to serve content to it.

Tracking Technologies. The Company may use cookies and other tracking technologies (such as browser cookies, pixels, beacons, and Adobe Flash technology), which are comprised of small bits of data that often include an anonymous unique identifier. Websites send this data to your browser when you first request a web page and then store the data on your computer so the website can access information when you make subsequent requests for pages from that site. These technologies may be used to collect and store information about your usage of the Services, such as pages you have visited, search queries you have run, links you have clicked and advertisements you have seen so that we can serve you more relevant ads when using the Services. The Company may also use cookies and similar tools to relate your use of Services to personal information obtained from you or a reputable third party. For example, if you have asked us to provide you information about our upcoming products or promotions, cookie and/or click stream data about your activities on the Sites may allow us to limit the materials we provide you to items we think you will find interesting, based on your prior online activities and preferences.

3. NOTICE AND MODIFICATIONS

Means of Notice and Privacy Policy Modifications. This Privacy Policy is the means by which the Company provides you with notice about its collection and use of your personal information. The Company will not use your personal information in a manner different from what is described in this Privacy Policy. The Company may modify this Privacy Policy at any time, and each such modification will be effective upon posting on the Sites. Your continued use of the Services following any such modification constitutes your acceptance of the Privacy Policy as so modified. It is therefore important that you review this Privacy Policy regularly. You may also receive a copy of this Privacy Policy by emailing us at privacy@sterkly.com; Subject: Privacy Policy.

Location of Data. The Services are hosted in the United States. If you are a user located outside the United States, you understand and consent to having any personal information you provide transferred to, processed, and stored in the United States and other countries where data protection and other privacy laws may not offer the same level of protection as in your jurisdiction, such as the European Union. This includes the use of cookies and other tracking technologies as described above. As a result, please read this Privacy Policy with care.

Linked Services. The Services may also be linked to sites or services operated by the Company’s affiliates or third parties, and may carry advertisements or offer content, functionality, games, rewards programs, newsletters, contests or sweepstakes, or applications developed and maintained by third parties including, any online store. The Company is not responsible for the privacy practices of any such third parties, and once you leave the Services via a link, enable a third party service, or click an advertisement, you should check the applicable privacy policy of the third party site. Users who visit a Company affiliated site should still refer to its separate privacy policy, which may differ in some respects from this Privacy Policy.

4. USE & DISCLOSURE

Information Made Public Through Use of the Services

Content that you submit may be publicly available according to the permissions you grant to the Company, the applicable policies of the third party and the terms and conditions and/or terms of use for the Services.

Company’s Use and Disclosure of Information

We only share your non-public personal information with non-affiliated third parties when we believe sharing is permitted by you or authorized by this Privacy Policy. In addition, the Company may share your personal information with our affiliated companies.

We use the information we collect from and about users for the following purposes:

To provide and manage the Services. We use the information we collect from and about users to provide the Services to you, to measure and improve the Services, to personalize your experience by delivering relevant content, to allow you to comment on content, participate in online games, contests, promotions or rewards programs, to enable you to communicate and share with other users or services, and to provide you with customer support and respond to inquiries. We may use aggregated, anonymous data about use of and activity on the Services to assist us in this regard and such data is not subject to this Privacy Policy.

To allow the third party providers to assist us in providing and managing the Services. The Company may make your non-public personal information available to third party providers, such as contractors, agents or sponsors, who help us manage or provide the Services. Such examples include: managing your Network account, developing or supporting products and features, processing payments, storing and processing data or statistics, or assisting with administration. These outside service providers are required to protect non-public personal information entrusted to them and not use it for any other purpose than the specific service they are providing to the Company.

To contact you. The Company may periodically send administrative or promotional materials and notifications related to Services to the email address you may have provided to us. If you want to stop receiving promotional materials from the Company, follow the unsubscribe instructions at the bottom of each promotional email. There are certain service notification emails that you may not opt-out of as long as you are registered with or subscribed to the Services, such as notifications of changes to the Services or policies.

To protect the rights of Company and our users. There may be instances when the Company may disclose user information without providing notice or choice, including situations where the Company has a good faith belief that such disclosure is necessary in order to: (i) protect or defend the legal rights or property of the Company, our affiliated companies or their employees, agents and contractors (including enforcement of our agreements); (ii) protect the safety and security of users of the Services or members of the public; (iii) protect against fraud or for risk management purposes; or (iv) comply with the law or legal process.

To complete a merger or sale of assets. If the Company sells all or part of its business or makes a sale or transfer of its assets or is otherwise involved in a merger or transfer of all or a material part of its business, the Company may transfer your information to the party or parties involved in the transaction as part of that transaction.

5. SECURITY

The Company uses reasonable administrative, technical, personnel and physical measures to safeguard user information in its possession against loss, theft and unauthorized use, disclosure or modification. Unfortunately, no transmission of data over the Internet can ever be guaranteed to be completely secure. It may be possible for third parties not under our control to intercept or access transmissions or private communications unlawfully. While we strive to protect your personal information, the Company cannot ensure or warrant the security of any personal information you transmit to us. Any such transmission is done at your own risk. If you believe that your interaction with us is no longer secure, please notify us of the problem by emailing privacy@sterkly.com.

6. CONTACT US

If you have questions about this Privacy Policy, or if you would like access to your personal information to correct, update, or delete it, please contact us as described below:

sterkly LLC

Address: sterkly LLC, 2647 Gateway Road #105 PMB 400, Carlsbad, CA 92009; Attn: Legal Department

Email: privacy@sterkly.com

Your California Privacy Rights. California Civil Code Section 1798.83 permits users who are California residents to request certain information regarding its disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send a request to privacy@sterkly.com or the above-referenced mailing address.