Privacy policy.
Data Controller’s Contact Information:
Company: Stride Group LLC
Address: Stride Group LLC, Montecasino Hts 50 Calle Rio Grande Toa Alta PR 00953 Email address: joelocasio@stridegrouppr.com
About this Privacy Policy
This Stride Group LLC privacy policy (the “Privacy Policy”) applies to the personal data that we collect from you when you use our Jibarito de la Cajita® brand website http://www.mijibarito.com (the “Website”) and our mobile application named Los Colores de Mi Isla (the “App”) (collectively, “Stride Group LLC”).
Our Privacy Policy tells you what personal data and non-personal data we collect from you, how we collect them, how we protect them, how we share them, how you can access and change them, and how you can limit our sharing of them. The Privacy Policy also explains certain legal rights that you have with respect to your personal data.
Definitions
‘NON-PERSONAL DATA’ is information that is in no way personally identifiable.
‘PERSONAL DATA’ means any information relating to an identified or identifiable natural person (‘data subject’), such as the data subject’s name, identification number, location data, or an online identifier. Personal data is in many ways the same as Personally Identifiable Information (PII). However, personal data is broader in scope and covers more data than PII.
‘GDPR’ means the EU General Data Protection Regulation (2016/679).
‘CCPA’ means the California Consumer Privacy Act of 2018.
Information we collect and how we collect it
When you use Stride Group LLC, we may ask you to provide your personal data to us. For transparency purposes, we explain in detail what personal data we collect and have access to, the purposes for which we use them, and legal bases on which we rely when processing your personal data. We comply with data minimisation principles. This means that we collect only a minimal amount of personal data that is necessary for your use of Stride Group LLC. We use your personal data for limited, specified and legitimate purposes explicitly mentioned in this Privacy Policy. We do not re-purpose your personal data. This means that we do not use it for any purposes that are different from the purposes for which your personal data was provided. Below, you can find an overview of the types of personal data that we collect, the purposes for which we use it, and the legal bases on which we rely when processing it.
Personal data collected through the Apps
When you use the App, we collect your email address, name, and age. We use such data for the following purposes:
● To validate your age;
● To store your game progress;
● To register and maintain your user account;
● To allow you to play from multiple devices;
● To send promotional emails (if you consent to them); and
● To reply to your support emails, if you send us any.
We keep the data listed above until you stop using the Apps (e.g., uninstall the App).
In addition, we automatically collect certain information that is later used for re-engagement and re-attribution purposes. Please note that, although certain information (like your device ID) may be considered by certain laws personal data, such technical data does not allow us to identify you as an individual by any means and we do not intend to do so. The types of the technical information that we automatically collect through the Apps are mentioned below:
● Timestamps telling us when you install or first launch the App;
● Information about how you use the App;
● Your device ID;
● The URLs that you click on before accessing the App or later;
● Information sent by self-reporting networks like Facebook, Snapchat, and Google Ads;
● The ads that you click on or view; and
● Your other online behavior data.
We use the technical information listed above to analyze your use of the Apps, find out how you find the Apps, examine the reasons that encourage you to install or delete the Apps, and track your online behavior. We keep such data as long as it is necessary for its purposes, but no longer than 1 year.
The legal bases that we rely on when collecting and using your personal data are “performing a contract with you,” “your consent” (for promotional emails, marketing and advertising), and “pursuing our legitimate business interests” (i.e., to ensure the security of the Apps and our compliance with the applicable laws, as well as to analyze and grow the Apps).
Analytics data
When you use the Apps downloaded from Google Play Store, we use our third-party analytics service provider Firebase (https://firebase.google.com) offered by Google, which automatically collects the following technical personal and non-personal data from you:
● IP address;
● Number of sessions;
● Session duration;
● Retention;
● Events;
● Install source; and
● IDFA.
We use such data to:
● Analyze the technical aspects of your use of the Apps;
● Optimize the Apps for your needs;
● Prevent fraud and abuse of the Apps;
● Ensure the security of the Apps; and
● Serve you relevant ads.
We keep such data as long as it is necessary for its purposes, but no longer than 1 year. The legal bases that we rely on when processing the above-mentioned data are “pursuing our legitimate business interests” (i.e., to analyze, grow, and protect KLA) and “your consent”.
Contact with us
When you contact us by email or by using the contact form available on the Website, we collect your name, email address, and any information that you decide to provide us in your message. We use your personal data to respond to your enquiries and provide you with the requested information. The legal bases that we rely on when processing such personal data are “pursuing our legitimate business interests” (i.e., to grow and promote Stride Group LLC) and “your consent” (for optional personal data that you decide, at your sole discretion, to provide us). We keep such data until you stop communicating with us.
Newsletter
When you subscribe for a newsletter through the form available on the Website or the App, we collect your email address. We use your email address to deliver you the requested newsletters. The legal basis that we rely on when processing your email address is “your consent”. We keep such data until you unsubscribe from our newsletter.
Comments
When you leave a comment under one of our blog posts available on the Website, we collect your name, website, and any information that you decide to provide us with in your comment. We use such information to feature your comment and ensure the security of the Website. The legal basis on which we rely is “pursuing our legitimate business interests” (i.e., to maintain, grow and promote Stride Group LLC). We keep such data as long as your comment stays on the Website.
Sensitive data
We do not collect or have access to any special categories of personal data (“sensitive data”) from you, unless you decide, at your own discretion, to provide such data to us. Sensitive data refers to your health, religious and political beliefs, racial origins, membership of a professional or trade association, or sexual orientation.
Feedback
If you contact us, we may keep records of any questions, complaints, recommendations, or compliments made by you and the response. Where possible, we will de-identify your personal data (i.e., we will remove all personal data that is not necessary for keeping such records).
Cookies
The Website and the Apps use cookies. A cookie is a small piece of data or a text file that is downloaded to your computer or mobile device when you access certain websites. Cookies may contain text that can be read by the web server that delivered the cookie to you. The text contained in the cookie generally consists of a sequence of letters and numbers that uniquely identifies your computer or mobile device; it may contain other information as well.
There are several types of cookies, namely, (i) persistent cookies, which remain valid until deleted by you, (ii) cookies that remain valid until their expiration date, and (iii) session cookies that are stored on a web browser and remain valid until the moment the browser is closed. Cookies may also be (i) first-party cookies (set by the original website itself) and (ii) third-party cookies (placed by third-party websites).
By agreeing to accept our use of non-essential cookies through a cookie consent banner, you are giving us and the third parties with which we partner permission to place, store, and access some or all the cookies described below on your device.
We use the following types of cookies:
● Essential technical cookies that are strictly necessary to ensure the correct functioning of Stride Group LLC and provide the services requested by you;
● Preference cookies that allow us to save and preserve your preferences;
● Marketing cookies that allow us to create, implement, and examine our marketing campaigns. Such cookies allow us to reach the right customers, analyze the productivity of our marketing campaigns, and offer you personalized advertisement; and
● Statistics cookies that allow us to generate statistical reports about how you use Stride Group LLC.
We use cookies for the following general purposes:
● Identifying the areas of Stride Group LLC that you have visited;
● Personalizing content that you see on Stride Group LLC;
● Analyzing your use of Stride Group LLC;
● Remarketing our services to you;
● Remembering your preferences, settings, and login details;
● Targeting advertising and remarketing; and
● Affiliating marketing.
Please note that you can control and disable cookies by adjusting your browser settings. You can also opt out from certain cookies through third-party tools like Google Analytics Opt-out Browser Add-on.
How your information is used
We use the personal data that we receive from you as follows:
● To provide Stride Group LLC to you;
● To operate and maintain Stride Group LLC;
● To register and maintain your user account;
● To identify you as a user of Stride Group LLC;
● To optimize the performance of Stride Group LLC;
● To send you administrative information;
● To respond to your enquiries and provide you with technical support;
● To send you promotional emails and advertise Stride Group LLC (if you opt-in for our marketing emails);
● To track your use of Stride Group LLC;
● To analyze your use of Stride Group LLC;
● To conduct research and analysis about the use of Stride Group LLC;
● To find out where our users are located;
● To investigate and prevent security issues and abuse of Stride Group LLC; and
● To comply with our legal obligations.
How we share your information
We do not sell or rent your personal data to third parties. We disclose personal data to third parties only if such a transfer is based on your consent, our legitimate interests, performance of a contract, or legal obligations.
The disclosure of your personal data may involve third-party service providers, our IT infrastructure providers, our accountants, advisers, consultants, and lawyers. We ensure that these third parties provide sufficient guarantees to protect your personal data and implement appropriate technical and organizational measures in compliance with the applicable data protection laws.
In order to ensure the functioning of Stride Group LLC, we partner with service providers that assist us in achieving our business purposes and processing your personal data on our behalf. Such third parties include our IT infrastructure providers, analytical service providers, communication service providers, and marketing partners. Below, you can find a list of our service providers that may have access to your personal data:
● Firebase (https://firebase.google.com);
● Facebook (https://www.facebook.com);
● Google (https://www.google.com);
● Instagram (https://www.instagram.com);
● LinkedIn (https://www.linkedin.com);
● Snapchat (https://www.snapchat.com); and
● Twitter (https://www.twitter.com).
We will only share your personal data with the service providers that are located in countries which ensure an adequate level of protection in accordance with the applicable data protection laws. If you are a citizen of the European Union (EU) and the European Economic Area (EEA) and we need to transfer your personal data to the service providers that are located outside the EEA, we will make sure that such service providers are compliant with the GDPR.
Disclosure of your personal data
If we are acquired by a third party as a result of a merger or reorganization, your personal data may be transferred. We will inform you of any such acquisition through email or a notice on
Stride Group LLC. We may also disclose your personal data when such disclosure is necessary to enforce our Terms and Conditions, to protect our legal rights, or to comply with the court order or other legal process.
Keeping your personal data secure
We implement security measures designed to protect your personal data. We use encryption, secure socket layer (SSL) protocol, and anonymisation techniques. Our servers are protected by firewalls and located in secure data centers. We use appropriate technical and organizational measures to ensure that the personal data that we collect and process are secure.
Your rights regarding your personal data
You have certain rights regarding your personal data that we hold about you. These rights include the right to:
● Access your personal data;
● Rectify your personal data;
● Erase your personal data;
● Restrict the processing of your personal data;
● Object to the processing of your personal data;
● Data portability; and
● Withdraw your consent.
To exercise these rights, you can contact us using the contact details provided at the beginning of this Privacy Policy. We will respond to your request as soon as possible and in any event within one month.
Children’s Privacy
We do not knowingly collect personal data from children under the age of 13. If you are under the age of 13, please do not provide us with any personal data. If we learn that we have collected personal data from a child under the age of 13, we will delete such information as soon as possible.
Changes to this Privacy Policy
We may update this Privacy Policy from time to time to reflect changes to our practices, legal requirements, or for other operational, legal, or regulatory reasons. We will notify you of any material changes by posting the new Privacy Policy on the Website and the Apps, and, where appropriate, by other means. You are advised to review this Privacy Policy periodically for any changes.
Contact Us
If you have any questions about this Privacy Policy, please contact us using the contact details provided at the beginning of this Privacy Policy.