This Policy discloses the privacy practices of The 2112 Strategy Group, LLC (“2112”) and governs how we use and protect personal information that we collect when you visit our Website, take part in our research programs, register for our services or events, or otherwise engage with us. Any practices or points that are specific to 2112 are also clearly marked in this Policy. We will attempt to post or display a link to this Policy on all forms and online pages to which it applies.
The 2112 Strategy Group, LLC is a limited liability corporation registered in New York state, with a principal office located at 51 Shadyside Avenue, Port Washington, NY, 11050, United States of America.
2112 provides a range of business strategy and research services to help technology industry professionals lead their organizations. Our services include but are not limited to:
Questions or concerns regarding the content, meaning, or enforcement of, or compliance with, this Policy should be directed to:
FAO: Data Protection Officer
Address: The 2112 Strategy Group, LLC, 51 Shadyside Ave., Port Washington, NY 11050, USA
Email: [email protected]
The contact information above should also be used for communications relating to exercising the rights described below.
When you access or download our online content, take part in our research, create an account on our Website, register for our events, or work with us on consulting engagements, you provide us with a variety of personal information. If you are not a paid member of 2112 services, you may choose to provide us with basic contact information in order to receive updates about our services and events.
Information You Provide to Us Directly
We gather information that you provide to us when you:
The information you provide to us will include (depending on the circumstances):
Information We Collect Through Automated and Online Technology
When you visit our Website or respond to our surveys, we automatically collect certain information, including:
We use “cookies” and other automated data collection technologies, including Web beacons and clear GIFs associated with cookies, on our Web pages, in newsletters, and in our e-mail campaigns to collect information both on an aggregate and individual basis. These technologies make it easier for you to navigate our Website and to help us manage the content on our Website and are used to analyze trends, administer the site, track users’ movements around the site (including which site you clicked from to arrive at our site), and gather demographic information about our user base. Our cookies store small pieces of non-personal identifiable data on your computer’s hard drive in accordance with your Internet browser settings to provide an enhanced and customized browser experience.
Information From Other Sources
In certain circumstances, we will receive information about you from other sources, including third parties. For example, we may receive personal information from any of the following, who may be based inside and/or outside the EU:
We might also receive information about you from other third parties if you have indicated to such third parties that you would like to hear from us.
We will use your information to:
Sharing With Third Parties
We do not sell the personal information we collect to third parties. At times, 2112 may make the minimal level of your contact information available to vendors that provide services to 2112 in order to service you. In such cases, you are provided the option to opt out ahead of time. You may request our Data Processing Addendums with our vendors on a case-by-case basis. We may also share your personal information with certain third parties, in limited circumstances, including:
We will keep your information for as long as is necessary to provide you with the services that you have requested from us or for as long as we reasonably require the retention of the information for our lawful business purposes, such as for the purposes of exercising our legal rights or where we are permitted to do so.
Please contact us at [email protected] if you would like to obtain details of our retention periods for different aspects of your personal data.
We use administrative, technical, and physical safeguards to protect the security, confidentiality, and integrity of personal data against loss, misuse, and unauthorized access, disclosure, alteration, and destruction. We also operate a policy of “privacy by design” by looking for opportunities to minimize the amount of personal information we hold about you.
The safeguards we use include:
If you have any questions about the security of your personal information, please contact [email protected] for further information.
In compliance with the European Union’s General Data Protection Regulation 2016/679 (GDPR), you have the right to:
How to Exercise Your Rights
We may need to request specific information from you to help us confirm your identity and to enable you to exercise the rights set out above. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
You will not have to pay a fee to exercise the rights set out above. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We will try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or if you have made a number of requests. In this case, we will notify you and keep you updated.
Please contact [email protected] for further information.
The 2112 Strategy Group, LLC (2112) participates in, and has certified its compliance with, the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. 2112 has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement, and Liability. To learn more about the Privacy Shield program, please visit www.privacyshield.gov.
2112 is responsible for the processing of personal data it receives under the Privacy Shield Framework and subsequently transfers to a third party acting as an agent on its behalf. 2112 complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, 2112 is subject to the regulatory enforcement authority of the U.S. Federal Trade Commission. In certain situations, 2112 may be required to disclose personal data in response to lawful requests by government authorities, including to meet national security or law enforcement requirements.
In compliance with the EU-U.S. Privacy Shield, 2112 commits to resolve complaints free of charge about your privacy and our collection or use of your personal information. European Union individuals with inquiries or complaints regarding their data should first contact:
FAO: Data Protection Officer
Address: The 2112 Group, LLC, 51 Shadyside Ave., Port Washington, NY 11050, USA
Email: [email protected]
2112 is committed to refer unresolved privacy complaints under the EU-U.S. Privacy Shield Principles to BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit http://www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.
If your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.
We may update this Policy periodically to reflect changes to our information practices. If we make any changes, we will post them on this Website. We encourage you to review this page periodically for the latest information on our privacy practices. Changes take effect immediately upon posting.
This Policy was last updated on May 25, 2018.