The following Privacy Policy describes how The Strickland Institute LLC ("us" or "we" or "Strickland Institute") collects, uses, discloses, retains, and protects personal information that we obtain through this website (https://stricklandinstitute.com), from our current and potential clients; from prospective, existing, and former employees; as well as about research participants (such as survey respondents and potential research participants, online and offline); and from third-party list providers (collectively, "Services"). Please read this Privacy Policy carefully.The Strickland Institute reserves the right to update this Privacy Policy at any time. If we change the Privacy Policy, we will post an amended draft on www.stricklandinstitute.com and an effective date. Suppose we make material changes to our Privacy Policy. In that case, we will post a revised Privacy Policy at the bottom of the website's main page at www.stricklandinstitute.com that states "Privacy Policy," and a notice of the policy change will appear at the bottom of the website.

Information We Collect
Personal information is any information relating to an identified or identifiable natural person. In other words, it is information through which an individual can be identified (either directly or indirectly), and it includes name, identification number, location data, an online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of a person. Anonymized or aggregated information that cannot be used to identify a specific natural person is not considered personal information.Strickland Institute LLC collects personal information through several different online and offline channels, including, but not limited to the following: via our website on any form completed, over the phone, via email when communicating with you, in person, via internal and third-party web-based survey tools, through our customer portals, and from third-party list providers. The types of personal information we generally collect includes, but are not limited to:Client or Potential Client Information: If you use our services, or express interest in our services, you may provide this information via our website or other means, in person or remotely. This data includes: name; employer name; telephone number; email address; mailing address; additional contact information; billing, tax, and payroll information; employee background check information; inquiries about actual or potential projects; publicly available social media posts and profiles, and any other information you choose to provide us. We also may maintain documentation of discussions with current or prospective clients, either in person or remotely. We also collect any other information you choose to provide via email, website, phone, person, or other means.

Surveyor Research Information:
If you participate in one of our research projects (e.g., respond to a survey), we will potentially collect your email address, IP address, company name, job title, demographic information (such as race, ethnicity, gender, and age), and educational information, responses to our survey questions, and any other information that you provide to us, online, over the phone, or in person. You may provide this information to us via a third-party research platform, such as paperform.co, webflow, or other 3rd party services. Recruitment Information: If you applied for a job at Strickland Institute LLC, we will collect employment-related information, such as your name, age, demographics, email address, resume information, job roles, work history, compensation data, benefits information, performance metrics, and reviews, background checks, assessments, and any other information that you provide to us or we gather during your candidacy.

Third-party sources: We also collect data from third-party sources. This third-party information includes contact lists of potential survey respondents provided by our clients or other third party services such as research panel providers; contact information about potential clients from directories and databases of companies; and information that is available on the Internet, for research or business relations purposes, such as publicly available social media posts. Social media (e.g., Twitter, LinkedIn, Facebook) is analyzed based on publicly available posts and engagement (including opens, clicks, shares, etc.) subject to the respective social media platforms' individual privacy policies. Strickland Institute LLC uses the data from such third-party sources primarily to provide research services. The Strickland Institute LLC is not liable for any security breaches on any social media platform.Automated information through the use of our website or other online services: When you use our website or other online services, we automatically collect certain types of information, including IP address, browser type, device ID, referral URL, date and time of access, and the pages you visited and other automated log information.  Like many websites, Strickland Institute LLC uses website analytics services (e.g., Google Analytics) to collect website usage data. These services may use cookies, which are small text files placed on your computer, to analyze how visitors use our website. Internet browsers automatically accept cookies by default. You can change your browser settings to reject cookies or prompt you before accepting a cookie from your visit websites. This website usage data may be linked to the other personal information that we may hold about you. For further details on our use of cookies, please refer to our Cookie Policy (https://www.stricklandinstitute.com/cookie-policy).

Information About Children 13 Years Old
Although this website is not directed to children under 13 years old, Strickland Institute LLC's clients, including school districts and corporate clients, may ask Strickland Institute LLC to use online services to conduct surveys of children under 13 years old.When clients request that Strickland Institute LLC conduct surveys of children under 13 years old, they typically provide the children with links to Strickland Institute LLC-created surveys, usually hosted on a third-party site. Strickland Institute LLC collects and processes the children's responses to the surveys. The information that Strickland Institute LLC collects may include their school, grade, and IP address. Students who are surveyed on behalf of school districts usually take surveys on school computers.Strickland Institute LLC's surveys typically do not result in collecting personal information, as defined by the Children's Online Privacy Protection Act (COPPA). However, out of an abundance of caution, Strickland Institute LLC will only conduct surveys of students under 13 years old upon receiving consent from their school, school district, or parent. If the study of a child under 13 years old is conducted on behalf of a corporate client, Strickland Institute LLC will obtain verifiable consent from the child's parent.Strickland Institute LLC's online services do not enable a child under 13 years old to publicly available personal information.Strickland Institute LLC only uses information collected from children under 13 years old to produce research reports for the school districts and corporate clients who requested the survey. The information in the report does not contain personally identifiable information about any children under 13.For any inquiries concerning Strickland Institute LLC's privacy policies and use of children's information, contact: Strickland Institute LLC, Attention: Privacy & Data Protection, 4401 Wilson Boulevard, 4th Floor, Arlington, VA 22203; (202) 559-0050 privacy@stricklandinstitute.com. In the rare event that Strickland Institute LLC has collected personal information, as defined by COPPA, from a child under 13 years old, the child's parent can contact Strickland Institute LLC to request a review or deletion of the child's personal information or to refuse to permit further collection of personal information.Uses of

Personal Information
Below is a summary of the ways that we use your personal information, the purposes for those uses, and the legal bases for the services:We will use your personal information if the use is necessary for a contract's performance to which you are a party or take steps at your request before entering into a contract. Such services and purposes include:If you provide us with personal information requesting services or products from us, we will use that information to respond to your request.

We will use your personal information to provide any services that you have requested. For example, if you are a client and provide us with your phone number, we may call you. If you provided us with payment information, we might process that information. If you apply for a job, we will use your information to assess your suitability for current or future job opportunities with Strickland Institute LLC.
We will use your personal information for purposes identified at the time the personal information is collected. We may also use your personal information if the use is necessary for our clients or our legitimate interests, provided that these interests are not overridden by your interests or fundamental rights and freedoms.Strickland Institute LLC may use any information that survey respondents voluntarily provide to Strickland Institute LLC, in combination with any other information, to provide research and insights to clients. Please note that Strickland Institute LLC may act as either a data controller or a data processor depending on the client's specific contractual relationship.

We may use any information you provide to detect, prevent, mitigate, and investigate any potentially prohibited or illegal activities.We may use your personal information to comply with a legal obligation.We may use any data for which you have given consent for the processing, such as when individuals provide their information when downloading content from our website. You may withdraw this consent at any time by emailing Strickland Institute at privacy@stricklandinstitute.com.Sharing Personal Information

We may transfer or disclose your personal information to the following types of third parties:Clients: Strickland Institute LLC researches on behalf of clients, primarily through the use of surveys. We may share any information that we collect as part of our research, including responses to surveys, with our clients in accordance with the notice provided to you at the outset of the study. Strickland Institute LLC Affiliates: Strickland Institute LLC shares personal information with any parent company, subsidiary, or corporate affiliate that is owned or controlled by the same owner.Service Providers: To provide our research services, communicate with new and prospective clients, maintain our daily operations, provide information about our services, and improve our services, we provide personal information to third-party service providers (which may include our parent company, subsidiaries, or corporate affiliates). Such providers include data processing services, cloud storage, business process outsourcers, transcription services, and marketing outreach partners. Such third-party service providers must maintain the confidentiality of the information we provide to them and are prohibited from using it for their own purposes. We do not share your personal information with service providers for their own promotional use.

Law Enforcement and Legal Proceedings: We will provide personal information to third parties, such as law enforcement or government agencies, if required to do so by applicable law or valid legal process, or if we determine that such sharing is necessary to protect the rights and safety of anyone. We will also provide personal information to parties to a legal proceeding, if we receive a subpoena or similar valid legal process.
Corporate Transactions, Mergers, Sales, and Acquisitions: In the event of a prospective or actual merger, sale or acquisition of our company, your personal information may be disclosed to third parties as part of the transaction.

Security
We maintain appropriate security protocols to help protect and secure your personal information against loss, misuse, and unauthorized access, disclosure, alteration, or destruction while in transmission and storage. We require our service providers to adhere to industry best practices to safeguard the personal information they handle. However, no data transmission method or storage is 100% secure; therefore, we cannot guarantee its absolute security.Retention
We retain your personal information for as long as necessary to fulfill the purposes for which the data was collected or otherwise meet a valid business or legal requirement. Once the personal data is no longer required to satisfy any of these purposes or retained under our retention policies, we will securely dispose of it. Among the factors that we consider in determining whether to keep personal information are: whether the project for which the data was collected has ended; the sensitivity of the personal data; and whether the information could be anonymized or aggregated.Additional Information for

Individuals Located in the European Union
If you are located in the European Union or European Economic Area, and Strickland Institute LLC processes your personal information, you may have the following rights. To exercise any of the rights, you may contact Strickland Institute LLC via the "Contact Us" section of this privacy policy. Please note that for research data (such as surveys), Strickland may act as either a data controller or data processor, depending on the contractual relationship with the particular client. These rights only apply to the extent that Strickland is acting as the data controller.To the extent that any of Strickland Institute LLC's use of your personal information is based on consent, you may request to withdraw that consent.To the extent that your personal information processing is based on the legitimate interests of Strickland Institute LLC or a Strickland Institute LLC client, you may object to this processing at any time. We will no longer process this personal data unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms or establish, exercise, or defend claims.

You have a right to access your personal data, including: information about the purposes of the processing; the categories of personal data concerned; the recipients of the personal data; and where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period. This right of access may be subject to legal limitations, of which we would advise you.
You have the right to obtain from us without undue delay rectifying inaccurate personal data concerning you. Considering the processing purposes, you shall have the right to have incomplete personal data completed, including a supplementary statement.
You have a right to obtain the erasure of personal data concerning you without undue delay if one of the following grounds applies:
The personal data are no longer necessary concerning the purposes for which they were collected or otherwise processed;
If the processing was based on your consent, you withdraw your consent;
You have a legal right to object to this processing, and there are no overriding legitimate grounds for the processing;
The personal data has been unlawfully processed; or
Erasure is necessary to fulfill the legal obligation of Strickland Institute LLC.The right to erasure does not apply to the extent that processing is necessary for exercising the right of freedom of expression and information, for compliance with a legal obligation of Strickland Institute LLC or a Strickland Institute LLC client, for archiving purposes in the public interests, or for the establishment, exercise, or defense of legal claims.You may request that we transfer your personal information to another controller, if technically feasible, and the processing is based on your consent or contract performance.Your California

Privacy Rights
On January 1, 2020, the California Consumer Privacy Act ("CCPA") went into effect. The law requires companies to notify California residents about how their data is collected, used, and shared, and in some cases, gives them rights to access and delete that data. This section provides Strickland Institute LLC's disclosures as required by the CCPA. These disclosures supplement and incorporate the statements in the other portions of the Privacy Policy. This section applies to all visitors, users, and others who reside in the State of California.Information We May Collect
Strickland Institute LLC collects personal information from individuals to administer and provide Services to Strickland Institute LLC clients and for the other purposes identified in this Privacy Policy. We may collect the following categories of information, as defined in the CCPA. The examples listed are only illustrative of potential types of data within each category, and Strickland Institute LLC does not necessarily collect that data about every individual.Category examples: Identifiers, real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver's license number, passport number, or other similar identifiers

Categories of personal information described in Cal. Civ. Code 1798.80(e) Name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Characteristics of protected classifications under California or federal law. Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth, and related medical conditions), sexual orientation, veteran or military status, genetic, information (including familial genetic information).Commercial information: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies: YesBiometric information Imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or meters, and sleep, health, or exercise data that contain identifying information: No Internet or other electronic network activity information. Browsing history, search history, and information regarding a consumer's interaction with an internet website, application, or advertisement. Yes

Geolocation data
Physical location or movements: No

Sensory data
Audio, electronic, visual, thermal, olfactory, or similar information: No

Professional or employment-related information.
Current or past job history or performance evaluations: Yes

Non-public education information (per the Family Educational Rights and Privacy Act (20 USC Section 1232g, 34 CFR Part 99))
Education records directly related to a student maintained by an educational institution or party acting on its behalfs, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. No

Inferences are drawn from other personal information
Profile, reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. No Sources of California Personal Information. We obtain the above categories of personal information from the following types of sources:Directly from you: For instance, you may provide us with information when signing up for an account. Indirectly from you: For example, we may observe your interactions on our website. For instance, from third parties, a school or company with whom you conduct business may provide us with information related to our services.From publicly available information.

Use of California Personal Information
We may use any of the above categories of collected User information to provide requested services, maintain and improve our services, communicate with Clients about Strickland Institute LLC Services and related third-party services, market Strickland Institute LLC Services, prevent potentially illegal activities, protect the rights and property of Strickland Institute LLC and third parties, respond to inquiries of Clients, and for any other purpose to which the individual data subject has consented. Our use and disclosure of California Personal Information are more fully described above in the section entitled "How We Use
This Information."Sharing California Personal Information
We may disclose your personal information to a third party, as more fully described in the section above entitled "Sharing Personal Information). The vast majority of data that Strickland Institute LLC collects and discloses to its clients is its capacity as a service provider, as defined by CCPA. Accordingly, Strickland Institute LLC does not typically "sell" CCPA-covered personal information. In the past 12 months, Strickland Institute LLC has disclosed the following categories of personal data for a business purpose: Identifiers; Categories of personal information described in Cal. Civ. Code 1798.80(e)
Characteristics of protected classifications under California or federal law. Commercial Information. Internet or other electronic network activity informationIn the past 12 months, Strickland Institute LLC has disclosed personal information to the following categories of third parties: Clients, Service providers.Your rights under the CCPA
Some of the personal information that Strickland Institute LLC collects is related to employees. Most of the rights provided under the CCPA do not currently apply to employment-related personal information collected from California-based employees, job applicants, contractors, or similar individuals. The CCPA also currently exempts personal information reflecting a written or verbal business-to-business communication from many of its requirements.Moreover, Strickland Institute LLC typically acts as a service provider to its Clients. Clients solely determine the purposes and means of processing Clients' personal information. To the extent that Strickland Institute LLC collects or processes CCPA-covered personal information in its capacity as a service provider, requests for access to CCPA-covered data and deletion must be directed to the Strickland Institute LLC Client.In the rare instance that the CCPA rights apply to the personal information, and Strickland Institute LLC does not collect or process data in its capacity as a service provider, you have the following rights:Access to Personal Information Collected or Sold and Data Portability
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see "Exercising Your Rights" section), we will disclose to you:The categories of personal information we collected about you;
The categories of sources for the personal information we collected about you; Our business or commercial purpose for collecting that personal information; The types of third parties with whom we share that personal information; The specific pieces of personal information we collected about you (also called a data portability request; If we disclosed your personal information for a business purpose, a separate list disclosing disclosures for a business purpose identifies the individual information categories that each recipient category obtained.Deletion of Personal Information: You have the right to request the deletion of personal information. If you wish to do so, please contact us at any method listed below. The right to deletion is subject to certain exceptions, such as if we need personal information to provide Services or comply with legal obligations.No Discrimination: You will not be subject to discrimination for exercising any of your privacy rights.To exercise any applicable access, data portability, and deletion rights, please submit a verifiable consumer request by emailing privacy@stricklandinstitute.com.Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within 12 months. The verifiable consumer request must:
Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, including Your name, Address, Additional details depending upon the type of request, and the data's sensitivity.Please describe your request with sufficient detail to understand, evaluate, and respond to it appropriately. We use reasonable faith efforts to respond to a verifiable consumer request within forty-five (45) days after its receipt. If we need more time (up to 90 days), we will inform you why and the required extension period in writing. Any disclosures we provide will only cover the 12 months preceding the verifiable consumer request's receipt. The response we provide will also explain why we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a payment, we will tell you why we made that decision and provide you with a cost estimate before completing your request.You may designate an authorized agent to request the CCPA on your behalf.The California Shine, the Light Law, requires companies to disclose information about the information shared with third parties used for the third parties' direct marketing purposes. If you are a California resident, you may request information about disclosing your personal information to third parties for the third parties' direct marketing purposes by emailing privacy@stricklandinstitute.com.Links to Third-Party Websites
Our site provides links to third-party websites, such as those of our clients. Strickland Institute LLC does not control and is not responsible for these third parties' information policies or practices. You should review the privacy policies governing these third parties and their websites to learn more about collecting and using your personal information.International Transfers of Personal Information
If you are located outside of the United States, please be aware that the information we collect will be transferred to and processed in the United States by us and will be subject to the laws of the United States (which may include access by US law enforcement, courts, and governmental authorities).For EU and EEA residents, if we provide any personal information about you to any non-EEA members of our group or third parties, we will take appropriate measures to ensure that the recipient protects your personal information adequately following this privacy policy. These measures may include the following permitted in Articles 45 and 46 of the General Data Protection Regulation:in the case of transfers to US-based entities, entering into European Commission approved standard contractual arrangements with them, or ensuring they have signed up to the EU-US Privacy Shield (see further https://www.privacyshield.gov/welcome); or in the case of transfers to entities based in other countries outside the EEA, entering into European Commission approved standard contractual arrangements. Further details on the steps we take to protect your personal information are available from us on request by contacting us using the details below.How to Opt-Out of Communications with Strickland Institute LLC.
If you would like to opt-out of further marketing communications from us, please unsubscribe at the following link: https://www.stricklandinstitute.com/optout. Please note that you may continue to receive certain transactional or account-related communications from us.

Access to Personal Information
Following applicable law, you may access, update, and correct inaccuracies in your personal information in our custody or control at any time, subject to limited exceptions prescribed by law. You can request access, corrections, or updates to all personal information by contacting us as set out in the Contact Us section below. We may request specific personal data to verify the individual's identity seeking access to their information records.Contact Us
If you have any questions or concerns about this Privacy Policy or the information collection and handling practices of us or our service providers, or you would like to update or correct any information that you have previously provided to us, please contact us at:Email: privacy@stricklandinstitute.comWe will send you a response within 30 days. Suppose you are located in the EU or EEA. In that case, you may also make a complaint to the Information Commissioner's Office in the UK, the data protection regulator in the country where you usually live or work, or any alleged infringement of the General Data Protection Regulation has taken place. Alternatively, you may seek a remedy through the relevant European courts if you believe your rights have been breached.Effective Date: This Privacy Policy was updated on September 17, 2020, and is effective.