Praytell Strategy, Inc. (Praytell) respects the privacy of its website users. We created this privacy notice (Notice) to inform you of how we collect, use, share, and protect your personal information when you use our website located at https://www.praytellagency.com/ (the Website).
By using or accessing the Website, you agree to this Notice and consent to the processing of information about you as described below.
Collection of Your Information
When you use the Website, you may choose to provide Praytell with certain personally identifiable information about yourself (PII). PII may include your name, address, email address, phone number, or IP address. Except for your IP address, we only collect PII you voluntarily provide to us.
We may collect other information when you use the Website that does not include PII, such as pages viewed, statistics, browser type, traffic to and from the Website, standard web log information, and other similar data. We may aggregate this information (Aggregate Information) in a manner that does not identify you or any individual.
How We Use and Share Your Information
Generally, we use the PII we collect on our Website in one or more of the following ways: (a) to administer our Site, (b) for marketing, (c) for recruiting and/or (d) in relation to client service purposes. We may also use or disclose your PII in accordance with your consent, when required by law to do so, or if it is necessary for a corporate transaction (such as a merger or acquisition). Other than as described in this Notice, we do not sell, distribute, lease or transfer the PII we collect. For more details, including how and when we destroy PII and about your individual rights, see “Your Individual Rights.” We may share the PII we collect as described in this section of the Notice.
We may share PII for the following reasons: With other members of the Project corporate family: Praytell is part of Project: WorldWide, Inc. (Project). Project’s group of agencies include Argonaut, George P. Johnson, Motive, Partner + Napier, Wondersauce and Spinifex. For a full list, visit https://project.com/. We may share the PII we collect with members of the Project family of entities to, among other things, provide the services you have requested or authorized and to help us manage the availability and connectivity of the Website.
With employees, contractors and agents that provide services to us: We may share the PII we collect with our employees, contractors and agents, including third-party service providers, that perform services and functions at our direction and on our behalf, but their use of such information shall be limited to the performance of their duties and is consistent with our purposes for using such information. As examples, WordPress, Servint and GoDaddy are third-party providers who assist us in hosting and running our Site. With other third parties for our business purposes or as permitted or required by law: We may share information about you with other parties for our business purposes or as permitted or required by law, including: (a) to comply with a law, legal process or regulations; (b) responding to or cooperating with law enforcement authorities, other government officials or other third parties pursuant to a subpoena, a court order or other legal process; (c) to protect the vital interests of a person; (d) to protect our property, services and legal rights; (e) to companies we plan to merge with or be acquired by; and (f) to support our audit, compliance and governance functions.
We may use Aggregate Information (i) to improve and enhance your experience on the Website, (ii) to customize, measure, and further develop the Website, our services or both, (iii) in connection with research activities and (iv) to tell you about our services or service updates. For example, we may share Aggregate Information with unaffiliated third parties, such as our business partners, in an anonymous form that does allow the third party to associate the information we shared as your PII.
We have put in place reasonable physical, electronic, and managerial procedures to safeguard the information we collect that are compliant with applicable law. The information we collect is stored on our servers located in the United States. We take reasonable steps and regularly assess our privacy and security policies and procedures and comply with laws designed to protect the privacy and security of your PII.
Google Analytics and Cookies
Cookies are small files placed on your computer. Cookies help analyze web traffic, provide information about your use of a website and help websites work more efficiently by responding to you as an individual (such as tailoring operations to your needs, likes and dislikes by gathering and remembering your preferences). Cookies provide us with technical information and do not collect personally identifiable information (except your IP address). In addition to downloading the Google Analytics Opt-out Browser Add-on, you may choose to accept or decline cookies within each web browser you use. Most web browsers automatically accept cookies, but you can modify your setting to decline cookies. The method for changing your setting for or deleting cookies varies by web browser. The settings or help tabs are among the more common locations for these features.
Do Not Track Signals and Requests
Do not track signals and requests are sent from your browser to websites you visit indicating you do not want to be tracked or monitored. Websites are not required to accept these requests and many do not. At this time, this website does not honor do not track signals or requests.
We provide links to other websites for informational purposes, for your convenience or to offer additional services through separate websites and, depending on your device and settings, applications (commonly referred to as “apps”) linked to our Site (“Linked Websites”). Linked Websites are independent from our Site and are not governed by this Notice. We do not review, have control over their content or endorse Linked Websites or the information, software, products or services available on the Linked Websites. We also have no control over the privacy notices used by Linked Websites. If you decide to access any of the Linked Websites, you do so at your own risk.
Any PII collected by or through our Site will be used only for the purpose it was provided and as described in this Notice. Once PII is no longer necessary, we will destroy the PII in accordance with its record retention and destruction policy.
Some jurisdictions (state, federal, national and international), such as California, Canada, and the European Economic Area (under the General Data Protection Regulation (“GDPR”)), provide individuals with certain rights regarding their PII. To exercise any rights your jurisdiction may provide, contact us at firstname.lastname@example.org. As examples, GDPR provides European residents with the following individual rights.
- Being informed about your PII. You may have the right to understand what PII we collect about you as well as how we use and share that PII. This Notice provides you with this information.
- Viewing and obtaining a copy of the PII we maintain about you.
- Amending or revising the PII we maintain about you.
- Having the PII we keep about you erased (also known as the right to be forgotten).
- Objecting to the use of your PII for direct marketing.
- Restricting our use of the PII we maintain about you.
- Transferring the PII we maintain about you to another entity.
- Objecting to our use of the PII we maintain about you.
- Objecting to automated decision making or profiling. We do not make automated decisions about you and do not profile individuals who visit our Site.
- Filing a complaint with us or the appropriate governmental entity.
- We may require that you verify your identity before exercising your individual rights.
International Transfers of PII
We store information received through or by our Site in the United States. If you are providing the information from another country, you agree to and understand that the information will be transferred, stored and used in the United States.
Protection for Children
We have no intention of collecting PII from children under the age of 13. If we become aware PII from a child under 13 has been collected without the consent of the parent or guardian of such child, we will use all reasonable efforts to delete such information.
Changes to the Notice and Opt-Out Process
We reserve the right, at our discretion, to amend this Notice at any time. If at any time in the future we plan to use PII in a way that differs from what is described in this Notice, we will post those changes on the Website. Your continued use of the Website following the posting of any changes to this Notice means you accept those changes. You have the right to remove your PII from our records, unless we are required by law to maintain a copy. All unsubscribe or opt-out requests should be sent to us at email@example.com. We will process your request within a reasonable time after receipt.
Privacy Shield Policy
Praytell Strategy, Inc. (“Praytell” or “we” or “our”) adheres to the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework published by the U.S. Department of Commerce (Privacy Shield).
This Privacy Shield Policy (Policy) outlines our general policy and practices for implementing Privacy Shield, including the types of Personally Identifiable Information (PII) Praytell gathers, how we use PII, and the choices individuals have regarding our use of, and the ability to correct, the PII relating to them. If there is any conflict between this statement and the Principles described by Privacy Shield at www.privacyshield.gov, the Principles will govern. To learn more about Privacy Shield and its principals, visit: https://www.privacyshield.gov.
This Policy applies to the PII we handle. For purposes of this statement, PII means information that (1) is transferred from the European Economic Area (EEA) and Switzerland to the U.S. in reliance on the Privacy Shield; (2) is about, or pertains to, a specific individual; and (3) can be linked either directly or indirectly to that individual.
In addition to this Policy, we also have other policies and procedures in place that legitimize data flows, including Standard Contract Clauses.
Principles protecting individuals’ privacy notice and choice
- We notify individuals about the PII we collect from them, how we use it and how to contact us with privacy related question and concerns.
- We provide such notice through this Policy, our Privacy Notice ([link]) and direct communication with individuals about the PII we collect.
- We collect and process PII about Praytell personnel for human resources administration, including recruitment, in accordance with Privacy Shield.
- We collect and process PII from our customers to provide them with services.
- We collect PII from individuals only as permitted by Privacy Shield.
- We obtain consent for PII to be collected, used or transferred in certain ways (such as for sensitive PII, for example, a Social Security Number) from individual. Consent is provided through our agreements with customers, the employment relationship with employees and other similar documents.
- If we will use PII in an additional or different manner than you were originally informed about, we will provide you with notice and when appropriate, obtain your consent.
Disclosures and transfers
We do not disclose PII to third parties, except when:
- We have the individual’s permission to make the disclosure.
- The disclosure is required by lawful request by public authorities.
- The disclosure is required by law.
- The disclosure is reasonably related to the sale, merger or other disposition of all or part of our business.
- The information is publicly available prior to the disclosure.
- The disclosure is reasonably necessary to establish our legal rights, defenses or claims.
- The disclosure is to a Praytell entity or third party providing services on our behalf or to our customers, but only if the disclosure is consistent with the purpose for which the information was obtained and the recipient of the information is subject to laws providing adequate level of privacy protection or has agreed to provide an adequate level of privacy protection.
Accountability and transfers
In the event we transfer PII covered by this Policy to a third party acting as a controller, we will do so consistent with any notice provided to you and any consent you have given. Further, the third party must provide us with contractual assurances that it will (i) process PII only for limited and specified purposes consistent with any consent you provided, (ii) provide at least the same level of protection as is required by this Policy and Privacy Shield and (iii) notify us if it makes a determination that it cannot do so and then cease processing the PII or take other reasonable and appropriate steps to remediate the circumstances. If we know a third party is processing PII subject to Privacy Shield as a controller in a way that is inconsistent or contrary to Privacy Shield, we will take reasonable steps to prevent or stop such processing.
With respect to our agents, we will transfer only PII covered by Privacy Shield as needed for an agent to deliver the product or service to Praytell. We will (i) permit the agent to process PII only for limited and specified purposes; (ii) require the agent to provide at least the same level of protection required by this Policy and Privacy Shield; (iii) take reasonable and appropriate steps to ensure that the agent follows this Policy and Privacy Shield when processes PII; and (iv) require the agent to notify us if it determines it can no longer meet requirements of this Policy and Privacy Shield. Upon receiving this notice, we will take reasonable and appropriate steps to stop and remediate unauthorized processing.
We may also transfer PII from one jurisdiction to another (including from the EU to the U.S. Privacy laws vary by jurisdiction, and some may provide less or different legal protection than others. However, we will protect PII in accordance with Privacy Shield regardless of the jurisdiction in which the PII resides or originates. Praytell remains liable under Privacy Shield if an agent processes PII covered by this Policy and Privacy Shield in a manner inconsistent with Privacy Shield, unless we are not responsible for the event giving rise to the damage.
Security, integrity and access
We employ various physical, electronic, administrative and managerial policies, processes procedures and training that is designed to reasonably protect PII from loss, misuse or unauthorized access, disclosure, alteration or destruction.
We process PII only for the limited and specific purpose it was originally collected. We take reasonable steps to ensure PII is accurate, complete, current and reliable for its intended use.
Individuals have the right to access the PII we holds about them in the ways specified by Privacy Shield. Individual may contact us using the information in the “Contact us” section to correct, amend or delete PII that is inaccurate or that has been processed in violation of Privacy Shield. We will take reasonable steps to ensure the individual is who they state they are before honoring their rights under Privacy Shield. In addition, we may limit or deny access to PII where providing access would be unreasonably burdensome or expensive, or where the rights of persons other than the individual would be violated. We may charge a reasonable fee, where warranted, for access to PII.
Accountability and enforcement
Our participation in the EU-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield is subject to investigation and enforcement by the Federal Trade Commission (FTC).
We have established policies and procedures to monitor our compliance with Privacy Shield. This includes a process for addressing questions and concerns about our compliance. These policies and procedures include annual written and signed statement (to be made at least annually), verifying that this statement is (1) accurate, (2) comprehensive for the information it is designed to cover, (3) prominently displayed and readily accessible, and (4) completely implemented. Interested parties and individuals are strongly encouraged to send concerns to the contact information located in the “Contact us” below.
Praytell personnel who violate this Policy will be subject to disciplinary action, including (without limitation), termination.
Individuals may file a complaint with us using the information in the “Contact us” section below. If a complaint or dispute under this Policy cannot be resolved internally:
- If the dispute involves PII collected in the context of an employment relationship, we will cooperate and comply with competent EU or Swiss data protection authorities. In the event that we or such authorities determine that we did not comply with this Policy, we will take appropriate steps to address any adverse effects and to enhance ongoing compliance.
- For all other disputes under this Policy, individuals may file a claim with JAMS.
- In certain circumstances, an individual may invoke binding arbitration by a Privacy Shield panel to be created by the U.S. Department of Commerce and the European Commission. Additional information about this process is available on the Privacy Shield website (www.privacyshield.gov).
We may amend this Policy from time to time by posting a revised version. If we amend this Policy, the new Policy will apply to PII previously collected only as the rights of the individual affected are not reduced or eliminated by the amendment. While we continue to participate in Privacy Shield, we will not amend this Policy in a manner inconsistent with Privacy Shield.
Information subject to other policies
We are committed to following the Principles for all PII within the scope of Privacy Shield. However, certain information is subject to policies that may differ in some respects from the general policies set forth in this Policy. For example, certain websites and services have their own privacy notices and information collected about or from employees and customers may be subject to additional policies or agreements.
To receive more information, address a concern or file a complaint, please contact us at:
Praytell Strategy, Inc.
Attn: Data Privacy Champion
1000 Dean St Suite 280
Brooklyn, NY 11238
+1 (718) 622-3682
Effective Date: August 1, 2018
©2014-2018, Praytell Strategy, Inc. All rights reserved.