Privacy Policy

Effective: July 2023

This Privacy Policy informs you of important information about how Pepper Consulting Inc. d/b/a The Streamliners (“The Streamliners,” “we,” “us” or “our”) processes the personal data that we collect in online and offline formats, the privacy practices we undertake, the types of data we collect, how we secure that data, and how long we retain that data.

When we use the term “Services” we mean to refer collectively to:

• The information and services provided through websites owned and controlled by us, including the website at www.TheStreamliners.com, and any related mobile applications owned or controlled by us (the “Site(s)”); and
• Our professional services independent of or related to the Sites.

Depending on your residency, we have information specifically for US residents (Section A) as well as for residents from the European Union or other individuals to whom the GDPR applies (Section B) and residents of the United Kingdom and Switzerland (C). 

Please note: The Streamliners may change its Privacy Policy from time to time and at The Streamliners’ sole discretion. The Streamliners encourages visitors to frequently check this page for any changes to its Privacy Policy. The current status of this Privacy Policy may be found at the end of this text.

Section A: Residents of the USA

Please find below information on:

• HOW WE COLLECT YOUR PERSONAL DATA
• TYPES OF PERSONAL DATA WE COLLECT
• HOW AND WHY WE USE YOUR INFORMATION
• HOW WE SHARE AND DISCLOSE PERSONAL DATA
• DATA SECURITY
• RESIDENTS OF STATE OF CALIFORNIA, UNITED STATES
• CAPACITY
• EMAIL MARKETING
• COOKIES NOTICE
• LINKS TO OTHER SITES
• UPDATES TO THIS PRIVACY NOTICE
• HOW TO CONTACT US

1. HOW WE COLLECT YOUR PERSONAL DATA

We may collect your Personal Data through different means:

1. when you decide to interact with us, either by providing us your information through the “Contact Us” page or other forms on the Site, by email, regular mail, or telephone;

2. when you visit our Site, through automated data tracking technology; and

3. when you become a customer of The Streamliners and provide us with information directly or authorize third parties to provide us with Personal Data.

It is up to you whether you want to provide us with information or authorize third parties to provide us with information. When we ask you to provide information, you can decline and still visit the Site to learn more about us and what we do. However, if you choose not to provide information to us, we may be unable to provide our Services to you.

2. TYPES OF PERSONAL DATA WE COLLECT

We may collect the following types of personal data, which are or may be capable of identifying an individual (“Personal Data“):

Types of Information You May Provide to Us:

• Name, address, communication preferences, email address, password, company name, telephone numbers, address;
• Customer information that you provide to us or that you authorize third parties to release to us;
• Payment information; and
• Records of your correspondence with us, including messages submitted through chat functionality in the Site.

If you submit any Personal Data to us relating to other people, you represent that you have the authority to do so and permit us to use the information in accordance with this Privacy Policy. By submitting Personal Data, you grant The Streamliners the right to transmit, monitor, retrieve, store and use your information in connection with the operation of the Site and in providing our Services.

In using the Services, you may provide us with technical data or other data, which is either anonymized or not otherwise related to any identifiable individual. Such data is not considered “Personal Data” for purposes of this Privacy Policy.

Types of Information We Collect Through Technology:

When you use our Site, we use Google Analytics, to gather information on how visitors are using the Site. Specifically, we use technology to gather information about the browser, device, internet connection, IP address, time zone setting, operating system and platform, via cookies employed on our Site.  An IP address is a number automatically assigned to your computer whenever you access the Internet. IP addresses allow computers (including mobile devices and tablets) and servers to recognize and communicate with one another. We collect IP address information so that we can properly manage our system and gather information about how our site is being used. This includes the device type and browser you are using, location data, the pages you are viewing and your interactions on the page. Your IP address may be associated with records containing Personal Data. We collect details of visits to our Site, including the volume of traffic received, logs and the resources that you have accessed. We may also collect certain location information such as your mobile device’s GPS signal, or information about nearby WiFi access points and cell towers.

Additionally, when you use our Site, we use messaging and chat tools provided by ChatBot (www.chatbot.com) to enable customers and visitors to our Site to communicate with us. ChatBot’s Privacy Policy, available at https://www.chatbot.com/legal/privacy-policy/ describes the nature of the information that may be collected if you choose to make use of this functionality.

Please also see the Cookies Notice section below for more information about these technologies.

3. HOW AND WHY WE USE YOUR INFORMATION

We only collect the information reasonably necessary to respond to inquiries about our Services, to provide you the Services, to carry out our operations, as required by law, and for the other legitimate business purposes, under applicable laws, as summarized below:

• To inform you about the Services in which you have indicated an interest; Respond to your questions and requests and improve customer service; To assist in business development and general marketing and building relationships;
• To record your name and contact information, and other Personal Data for legitimate business purposes, so that we can provide our Services;
• To perform our contract with you if you become a customer; satisfy contractual necessity to conduct our operations and provide you with the services and products we offer; to perform essential business operations and to manage your account; to contact you with information that may be of interest to you;
• To improve the Site to provide you with better services, for example, we may use your personal data to improve the layout of our website based on the click path you utilized to access certain information within the website; and
• To comply with legal obligations and professional responsibilities; To verify your identity or conduct internal audits or reviews.

We do not monitor or profile visitors to our Site or collect, in any automated manner, any special categories of sensitive Personal Data about you.  No automated decision-making, including profiling, is used when processing your Personal Data.

Additional Uses of Personal Data:

In addition to the uses described above, we may use your Personal Data for the following purposes if you become a customer.  Some of these uses may, under certain circumstances be based on your consent, may be necessary to fulfill our contractual commitments to you, or are necessary to serve our legitimate interests in the following business operations:

• Providing you with newsletters, articles, alerts and announcements, and other information that we believe may be of interest to you;
• Providing you with marketing information about our services and;
• Conducting research, surveys, and similar inquiries to help us understand customer needs;
• Analyzing your interactions with us and our website, and improving our products, services, programs, and other offerings;
• Preventing, investigating, or providing notice of fraud, unlawful or criminal activity, or unauthorized access to or use of Personal Data, our Site or data systems; or to meet legal obligations; and
• Enforcing our Terms of Use, Subscription Agreement, and other agreements.

4. HOW WE SHARE AND DISCLOSE PERSONAL DATA

We may disclose aggregated information that does not identify any individual (and therefore, is not deemed to be Personal Data) without restriction.  We share Personal Data with the following categories of recipients:

Third-party vendors.  Your Personal Data will only be shared with and processed by our affiliates and non-affiliated third-party service providers as permitted by law and for the purposes described in this Privacy Policy.  We may disclose Personal Data to certain non-affiliated specialized service providers, including professional advisors, consultants, insurers, technical service providers, and other third parties, who are bound by contractual obligations to keep Personal Data confidential and use it only for the purposes for which we disclose it to them.  We may disclose your Personal Data to third-party service providers to provide us with services such as Site hosting, including information technology and telephony services, and related infrastructure, customer service, e-mail delivery, auditing and other similar services.

Corporate affiliates. We may share your information with our corporate affiliates that are subject to this policy.

Business transfers. When applicable, we may share your information in connection with a substantial corporate transaction, such as the sale of a website, a merger, consolidation, asset sale, or in the unlikely event of bankruptcy.

With your consent or at your direction. We may share information for any other purposes disclosed to you at the time we collect the information or pursuant to your consent or direction.

Other legal reasons.  In addition, we may use or disclose your Personal Data as we deem necessary or appropriate: (1) under applicable law; (2) to respond to requests from public and government authorities; (3) to pursue available remedies or limit damages we may sustain; (5) to protect our operations or those of any of our affiliates; (6) to protect the rights, privacy, safety or property of The Streamliners, our affiliates, you, and others; and (7) to enforce our Terms of Use and other agreements.

The Streamliners keeps Personal Data on file, but does not share, sell, license or transmit this information to third parties or external vendors except as set forth herein or unless required to do so by legal, judicial or governmental proceedings, or to provide the services requested.

5. DATA SECURITY

We use reasonable organizational, technical and administrative measures to maintain the privacy and security of your Personal Data within our organization.  Accordingly, we prevent unauthorized access by a secure firewall and use of security technologies to protect the integrity and privacy of any Personal Data you provide.  Although we work hard to protect your Personal Data, The Streamliners cannot guarantee the security of any information you transmit to us through online forms and applications, and you do so at your own risk.  Please note that email is considered a nonencrypted (and therefore nonsecure) form of communication, and it can be accessed and viewed by others without your knowledge and permission. For that reason, to protect your privacy, please do not use email to communicate information that you consider confidential.  Unfortunately, no data transmission or storage system can be guaranteed to be secure at all times.  If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the Contact Us section below. We will let you know promptly if a breach occurs that may have compromised the privacy or security of your information.

6. RESIDENTS OF STATE OF CALIFORNIA, UNITED STATES

California residents are entitled once a year, free of charge, to request and obtain certain information regarding what information of yours we may have collected; our disclosure, if any, of certain categories of Personal Data to third parties for their direct marketing purposes in the preceding calendar year; to request deletion of your data; and to opt out of any such sale of your data. We do not share Personal Data with third parties for their own direct marketing purposes. To make such a request, please contact us at:

Email: legal@thestreamliners.com

Mail:
The Streamliners
2590 Welton St, Suite 200 Denver, CO 80205

You may opt out of any marketing by us and from the disclosure of your Personal Data to third parties.

7. CAPACITY

This website is only intended for individuals who are at least 18 years of age. We do not knowingly encourage or solicit visitors to this website who are under the age of 18 or knowingly collect Personal Data from anyone under the age of 18 without parental fiduciary consent. If we learn we have collected or received Personal Data from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at legal@thestreamliners.com.

8. E-MAIL MARKETING

We may periodically send you relevant alerts and newsletters by e-mail. To help improve our marketing activities, we often receive a confirmation when you open an e-mail or click on a link included in one of these emails, if your computer supports such capabilities. Instructions on how to unsubscribe from these alerts and newsletters are included in each e-mail.

9. COOKIES NOTICE

How we use Cookies.  We use cookies and related technologies (“Cookies”) to provide Services, gather information when users navigate through the Sites to enhance and personalize the experience, to understand usage patterns, and to improve our Sites, products, and Services.

Cookies on our Sites are generally divided into the following categories:

Essential Cookies.  These cookies are strictly necessary to provide you with our Services and to use some of their features, such as access to secure areas. Because these cookies are strictly necessary to deliver the Services, you cannot refuse them without impacting how our Services function.

Performance and Functionality Cookies. These cookies are used to enhance the performance and functionality of our Services but are non-essential to their use. However, without these cookies, certain functionality may become unavailable.

Analytics and Customization Cookies. These cookies collect information that is used to help us understand how our Services are being used or how effective our marketing campaigns are, or to help us customize our Services for you to enhance your experience.

Targeting Cookies. These record your visit to our Sites, the pages you have visited and the links you have followed to recognize you as a previous visitor and to track your activity on the Sites and other Sites you visit. These Cookies qualify as persistent cookies, because they remain on your device for us to use during a next visit to our Sites. You can delete these cookies via your browser settings. See below for further details on how you can control third-party targeting cookies.

Google Analytics.  This Site uses Google Analytics.  We will not and will not assist or permit any third party to pass information to Google that Google could use or recognize as personally identifiable data.  You may see how Google uses data when you use this Site at www.google.com/policies/privacy/parters.

How to Control Cookies:

You can review your Internet browser settings, typically under the sections “Help” or “Internet Options,” to exercise choices you have for certain Cookies. If you disable or delete certain Cookies in your settings, you may not be able to use features of the Sites. For more information on how to control or disable cookies in particular browsers, please see the following articles:

• Cookie settings in Firefox
• Cookie settings in Chrome
• Cookie settings in Safari
• Cookie settings in Microsoft Edge
• Cookie settings in Internet Explorer

Google Analytics: To learn more about the use of Cookies by Google for analytics see https://policies.google.com/technologies/cookies. To exercise choice regarding those Cookies, please see the Google Analytics Opt-Out Browser Add-On.

Hubspot Tracking Code: To learn more about the use of Cookies by Hubspot for tracking and analytics see https://knowledge.hubspot.com/privacy-and-consent/what-cookies-does-hubspot-set-in-a-visitor-s-browser. 

Meta (Facebook) Pixel: To learn more about the use of Cookies by Meta for analytics see https://www.facebook.com/legal/businesstech.  To exercise choice regarding those Cookies, please see https://www.facebook.com/privacy/policies/cookies/?entry_point=cookie_policy_redirect&entry=0 .

LinkedIn Insight Tag: To learn more about the use LinkedIn Insight Tags for analytics see https://www.linkedin.com/legal/cookie-policy.  To exercise choice regarding this platform, please see https://www.linkedin.com/mypreferences/d/categories/ads. 

The opt-outs described above are device- and browser-specific and may not work on all devices.

10. LINKS TO OTHER SITES

Occasionally we may provide links to other sites for your convenience and information. These sites operate independently from our Sites and are not under our control. These sites may have their own privacy notices or terms of use, which you should review if you visit any sites linked through our Sites. We are not responsible for the content or use of these unrelated sites.

11. HOW TO CONTACT US

If you have any questions or concerns about this Privacy Policy or our Personal Data handling practices, please contact us at:

Email: legal@thestreamliners.com

Mail:

2590 Welton St, Suite 200 Denver, CO 80205

Section B: Residents of the European Union and other individuals to whom the GDPR applies

Information to Data Subjects of the European Union according to Art. 13 General Data Protection Regulation

Thank you for your interest in our web offerings. The protection of personal data is of great importance to us. The Streamliners processes your personal data according to the EU General Data Protection Regulation (GDPR) and other applicable local laws.

Please find below:

1. Contact Details of the Controller

Please refer to Section A No. 11 of this Privacy Policy.

2. Purposes of the Processing and the Legal Basis for the Processing

Please refer to Section A No. 2, 3 and 9 of this Privacy Policy regarding the type of data and the purposes. 

The legal bases depend on the respective purposes:

• Usage of Website: The legal basis for data processing activities shall be Article 6(1)(f) of GDPR. Our legitimate interests follow from the purposes listed above for data collection. In no case shall we use any collected data for the purpose of drawing any conclusions about your person.
• Communication per Email: The processing of your data within the scope of communication via the contact form or by e-mail takes place on the basis of Art. 6(1)(b) of GDPR, insofar as the exchange is connected with the initiation or fulfilment of a contract with you. In addition, the legal basis depends on the concrete purpose of the exchange, usually Art. 6(1)(f) GDPR (our legitimate interest to conduct business correspondence or, for example, to answer inquiries regarding data protection) will be relevant.
• E-Mail Marketing: We may periodically send you relevant alerts and newsletters by e-mail if you consent to it. To help improve our marketing activities, we often receive a confirmation when you open an e-mail or click on a link included in one of these emails, if your computer supports such capabilities. Instructions on how to unsubscribe from these alerts and newsletters are included in each e-mail.

It is possible that we have acquired your data via a third-party provider. In this case, we ask for your consent to receive e-mail marketing by actively opting-in via an e-mail we send you.

Pursuant to Art. 7(3) GDPR, you can withdraw your consent for the future at any time and without giving reasons. You can withdraw your consent by clicking unsubscribe at the bottom of each e-mail we send out, by getting in touch with us through the contact channels specified in the imprint or by e-mailing the responsible person at legal@thestreamliners.com.

3. To whom will your data be passed on or who is involved in the processing of my data?

Please refer to Section A No. 4 of this Privacy Policy.

Futhermore, if you are subject to the GDPR, you should note that your Personal Data may be transferred to third countries, including the United States where we or certain of our third-party service providers are located. The United States is deemed by the European Union to provide inadequate data protection. Transfers of your Personal Data between us and a third party shall be done pursuant to adequate protections, which may include Standard Contractual Clauses, your explicit consent, and/or other permitted mechanisms under applicable law.

4. How long is your data stored?

When using our website, your personal data collected by us shall be erased after completion of the request submitted by you. 

Your e-mail communication will be deleted insofar as they are no longer required for an exchange with you. The data may be kept longer on the basis of Art. 6(1)(c) GDPR in conjunction with the relevant statutory retention periods (in particular in accordance with commercial and tax law).

5. Obligation to provide personal information

You are not obliged to provide your personal data. Without the processing of your personal data, however, The Streamliners cannot be commissioned.

6. Automated decision-making

Please refer to Section A No. 3 of this Privacy Policy regarding automated decision-making and profiling. 

7. Your Rights

a) Right of access: You have the right to obtain from us confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, you have the right to obtain access to the personal data concerning you and the information pursuant to Art. 15 (1)(a)-(h) GDPR. Where personal data concerning you are transferred to a third country or to an international organization, you have the right to be informed of the appropriate safeguards pursuant to Art. 46 GDPR relating to the transfer. Subject to the conditions set out in Art. 15 GDPR, you have the right to receive a copy of the personal data concerning you undergoing processing.

b) Right to rectification: You have the right to obtain from us without undue delay the rectification of personal data concerning you if it is inaccurate. Taking into account the purposes of the processing, you have the right to have incomplete personal data concerning you completed, including by means of providing a supplementary statement.

c) Right to erasure: You have the right to obtain from us the erasure of personal data concerning you without undue delay if one of the grounds listed in Art. 17 GDPR applies, e.g. if the data have been unlawfully processed.

d) Right to restriction of processing: Subject to the conditions set out in Art. 18 GDPR, you have the right to obtain from us restriction of processing.

e) Right to data portability: Subject to the conditions set out in Art. 20 GDPR, you have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and you have the right to transmit those data to another controller without hindrance from us. In exercising your right to data portability, you have the right to have the personal data concerning you transmitted directly from us to another controller, where technically feasible.

f) Right to object: Subject to the conditions set out in Art. 21 GDPR, you have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on point (e) or (f) of Art. 6 (1) GDPR, including profiling based on those provisions. Where personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing. Subject to the conditions set out in Art. 21 GDPR, where personal data concerning you are processed for scientific or historical research purposes or statistical purposes pursuant to Art. 89 (1) GDPR you, on grounds relating to your particular situation, have the right to object to processing of personal data concerning you.

g) Right to withdraw consent: If the data processing is based on consent pursuant to Art. 6 (1) lit. a GDPR or Art. 9 (2) lit. a GDPR, you have the right to withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. If you withdraw your consent, you can also chose, inter alia, the contact channel that you used when giving your consent.

h) Right to lodge a complaint with a supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the GDPR.

Section C: Residents of the United Kingdom and Switzerland

RESIDENTS OF The UNITED KINGDOM AND SWITZERLAND

Your Personal Data will be treated in a secure and confidential manner, using appropriate technical and organizational measures, in compliance with all applicable laws and regulations, including the UK General Data Protection Regulation (UK GDPR), and the Swiss Federal Act on Data Protection. Depending on the context in which Personal Data is provided, we may be a data processor (“processor”) or a data controller (“controller”) of your Personal Data.

As applicable under the UK GDPR, individuals have additional rights including the following:

• to obtain a copy of your Personal Data together with information about how and on what legal basis that Personal Data is processed;
• to rectify inaccurate Personal Data (including to have incomplete Personal Data completed);
• to erase your Personal Data (in limited circumstances, such as where it is no longer necessary in relation to the purposes for which it was collected or processed);
• to restrict processing of your Personal Data under certain circumstances;
• to export certain Personal Data in machine-readable format to a third party (or to you) when we justify our processing on the basis of your consent or the performance of a contract with you and the processing is carried out by automated means;
• to withdraw your consent to our processing of your Personal Data (where that processing is based on your consent, without affecting the lawfulness of processing based on consent before its withdrawal);
• to obtain, or see a copy of the appropriate safeguards under which your Personal Data is transferred to a third country or international organization; and
• to object to our use and processing of your Personal Data that is conducted on the basis of our legitimate interest. You also have the right to object at any time to any processing of your Personal Data for direct marketing purposes, including profiling for marketing purposes.

Lodging a Complaint: You also have the right to lodge a complaint with your local supervisory authority for data protection, or privacy regulator.

Submitting a Request: To exercise the above rights or contact us with questions or complaints regarding our treatment of your Personal Data, contact us at legal@thestreamliners.com. Please note that we may request proof of identity, and we reserve the right to charge a fee where permitted by law, especially if your request is manifestly unfounded or excessive. We will respond to your request within the applicable timeframes set out by law.

International Transfers: If you are located within the United Kingdom or Switzerland, you should note that your Personal Data may be transferred to countries outside these jurisdictions, including the United States where we or certain of our third-party service providers are located. Transfers of your Personal Data between us and a third party shall be done pursuant to adequate protections.

In addition, please check the following sections of this Privacy Policy: “How we Collect Your Personal Data”; “Types of Personal Data we Collect”; “How and Why we Use Your Personal Data”; and “How we Share and Disclose Personal Data”.

If you have any questions or concerns regarding this Privacy Policy or our privacy practices, including the processing of your personal Data, if you would like to exercise your data rights under applicable laws, or if you believe your privacy rights have been violated, please contact us as provide in the “How to Contact Us” section above.