PRIVACY NOTICE—July 1, 2022
Systems Technology Group, Incorporated and its affiliated companies (“STG Infotech India LLP”, “STG”, “we” or “us”) are firmly committed to protecting your privacy. You should understand what we do with data relating to you (“personal information”) which we collect when you visit this website (stgit.com), our country-specific sites or any other websites to which this Website Privacy Notice (“Privacy Notice”) applies (collectively, the “Sites”).
As a global company, STG has a number of legal entities in different jurisdictions which are responsible for the personal information which they collect independently, and which may be processed on their behalf by STG U.S. Corporation and its affiliates. The data controller for personal information collected from a visitor to the Sites is Systems Technology Group, Inc., 3001 W Big Beaver Rd, #500, Troy, MI 48084, or the affiliate specified on the Site that references this Privacy Notice.
We may supplement this Privacy Notice to address specific situations. All supplemental notices should be read together with this Privacy Notice.
How we collect your personal information
We may collect the following personal information relating to you:
- You do not need to register to use the Sites. However, if you voluntarily register with a Site or submit your personal information to one or more of our Sites in order to receive information from us (e.g., copies of white papers, investor kits, alumni correspondence) or to attend conferences or web sessions organized by us, or if you contact us using the forms or contact details on one of our Sites, or if you log into certain STG web-based applications, you may provide us your identity information and contact details (i.e., your first and last name, physical address, telephone number, e-mail address), professional details (professional title, seniority level, employer, department, your expertise, administrative assistant’s name or contact information), the name and contact details of your emergency contact (if you sign up to attend events conducted by our marketing teams), your LinkedIn account details, your marketing preferences, and other personal data that you may wish to share with us.
We sometimes collect anonymous information from visits to the Sites. Anonymous information (or clickstream data) refers to information that does not and will not directly or indirectly reveal your identity, e.g., aggregated data relating to all of our website visitors. We may use this data to analyse trends and statistics and to help us provide you with a better experience using our Sites.
If you provide us with personal information of third parties (such as the details of your administrative assistant or your emergency contact), you agree to: (a) notify each individual before sharing their personal information with us, (b) explain that their personal information will be processed in accordance with this Privacy Notice, and (c) obtain their consent, where appropriate.
We will not sell your personal information to anyone outside the STG group of companies. However, we may need to disclose your personal information to third parties in the following instances:
- Other STG group companies: STG is a global company, and your personal information may be shared with or accessed by other companies within the STG group who will use your personal information for the purposes and in a manner set out in this Privacy Notice.
- Service providers: We will disclose your personal information to companies that provide services to us, such as companies that assist us in operating our Sites and vendors that assist us with marketing campaigns. The service providers are required to keep your personal information confidential and are not permitted to use your personal information for any other purpose than to carry out the services they are performing for us.
- Third parties to meet applicable legal requirements: We may need to disclose your personal information to a third party if it is necessary to comply with a legal obligation or the decision of a judicial authority, a public authority, or a government body, or if the disclosure is necessary for national security, law enforcement or other public interest.
- Business partners: We will disclose your personal information to our business partners if it is necessary for providing products and services to you, such as for certain software and related services.
- Third parties in connection with a business sale: If we make a sale or transfer of assets or are otherwise involved in a merger or business/asset transfer, we may transfer your personal information to one or more third parties as part of that transaction.
- Other third parties with your consent: We may also share your personal information with other third parties when you separately consent to such sharing.
Due to the global nature of STG’s business, your personal information may be shared, disclosed, and transferred between the various STG group companies and other third parties (as described in the above section on To whom we give your personal information) where such transfers are required for legitimate business reasons. Such entities may be located outside your country of residence. The level of protection for personal information is not the same in all countries, however, we will take reasonable steps and implement measures as described in this Privacy Notice to keep your personal information secure.
Your personal information will be retained only for so long as reasonably necessary for the purposes set out in this Privacy Notice in accordance with applicable laws, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.
STG implements appropriate security measures designed to prevent unlawful or unauthorized processing of personal information and accidental loss of or damage to personal information. The data collected via our Sites is stored in a secure server with our ISP who will take periodic backups of such data.
The Sites are not intentionally targeted to, or intended for, children under the age of 13. We do not knowingly collect data relating to children.
If you would like to exercise your right to modify or remove your personal information from our database or request a copy of your personal information (to the extent these rights are provided by law), you can send us an e-mail at email@example.com. For your protection, we may need to verify your identity before fulfilling your request. We will respond as soon as reasonably practicable and within the time frame specified by applicable law. We reserve the right to deny your request based on applicable law and will inform you if we do so.
The Sites contain links to other websites, including sites controlled by third parties independent of us. STG is not responsible for the privacy practices or the contents of such websites. We encourage you to read the privacy notices of such websites before providing any personal information to them. We do not take responsibility for the opinions of third parties expressed on or through our Sites.
Any questions, concerns, or complaints about our processing operations and our commitment to this Privacy Notice should be addressed to STG’s Data Protection Officer at firstname.lastname@example.org.
You can also write to us at:
Systems Technology Group, Inc.
Attention: Privacy Data Officer
3001 W Big Beaver Road, #500
Troy, Michigan 48084
United States of America
We may change and update this Privacy Notice from time to time. Any changes to our Privacy Notice will be posted on this page.
About GDPR Annex
Annex: Additional information for the purposes of the EU General Data Protection Regulation, the Swiss Federal Data Protection Act, and the UK Data Protection Act (“GDPR Annex”)
This GDPR Annex complements and supplements the main body of the Privacy Notice and covers the processing of personal information subject to EU Regulation 2016/679, also known as the EU General Data Protection Regulation (“GDPR”), the Swiss Federal Data Protection Act and the UK Data Protection Act. In case of any conflicts between the main body of the Privacy Notice and the GDPR Annex, the GDPR Annex will have precedence.
We will notify you of any material changes or additions to this Privacy Notice and will provide you with a copy of any amended Privacy Notice(s) by use of your e-mail address provided to us, or by any other suitable means.
If you have any questions or concerns about how we handle your personal information or if you would like to make a complaint, please contact our Data Protection Officer at email@example.com.
In particular, you may reach out to us with questions or concerns relating to:
- This GDPR annex or
- The client relationship, such as processing of personal information for the delivery of our services (e.g., regarding our clients, their personnel, and customers)
To the extent permitted by applicable law, we use your personal information for the purposes identified in the main body of the Privacy Notice based on the following legal grounds:
- Consent: We may process your personal information if you consent to such processing, e.g., for receiving promotional messages via phone or electronic communications means from us. You have the right to withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any prior processing based on your consent. Please note that even after the withdrawal of your consent we may be entitled to continue processing your personal information if other legal grounds apply. To withdraw your consent, you can use the unsubscribe instructions in the promotional communications you receive.
- Contractual necessity: Where it is necessary to enter a contract with you for the provision of our products or services or to perform our obligations under that contract. If you do not provide us with your personal information for processing as described below, we may not be able to provide the service, product or information requested.
- Our legitimate interests: We may process your personal information where it is necessary for our legitimate interests as a company, including to manage, promote and improve our business and manage our risk.
|Purposes and Legitimate Interests||Legal Grounds|
|Provide requested products, services, and information, e.g., copies of white papers, investor kits, and process orders.||Contractual necessity|
|Provide customer support, e.g., respond to inquiries, questions, or comments.||Contractual necessity|
|Organize and allow participation in an event.||Contractual necessity|
|Communicate important notices, such as information about changes to this Privacy Notice, our Sites and service updates.||Contractual necessity|
|Carry out analytics, market research and internal reporting to plan, develop and improve our Sites, products, services and marketing activities.||Legitimate interests|
|Create user profiles to personalize our products, services, and marketing communications.||Legitimate interests|
|Send promotional messages via email, SMS, phone, post and/or other similar communications means.||Consent or legitimate interests depending on the marketing activity and method|
Note. If you would prefer not to receive these communications, simply follow the unsubscribe instructions on the promotional communications that you receive to withdraw your consent or object to the processing.
|Prevent and detect unlawful behavior, and protect or enforce our legal rights.||Contractual necessity|
As further detailed under the section ‘International transfers of your personal information, your personal information may be processed by us in countries outside your country of residence. Some of these countries may not provide for the same level of data protection as the European Economic Area, Switzerland and/or the United Kingdom (as applicable). In this event, we will ensure that the recipient of your personal information offers an adequate level of protection, for instance by entering into standard contractual clauses for the transfer of data as approved by the European Commission (or the relevant data protection supervisory authority, as applicable).
You have the following rights with respect to your personal information that we process, subject to conditions and restrictions set out in the applicable laws:
- To learn whether your personal information is processed by us and to request a copy of your personal information and information relating to the processing of your personal information.
- To request the correction of any inaccurate or incomplete personal information.
- To request the erasure of your personal information or the restriction of the processing of your personal information.
- To object to our processing of your personal information.
- To withdraw consent you have given.
- Under certain circumstances, to demand data portability.
- To lodge a complaint with the applicable data protection supervisory authority.
To exercise your rights to the extent allowed under applicable law, please email firstname.lastname@example.org.
Your personal information will be retained only for so long as reasonably necessary for the purposes set out in this Privacy Notice in accordance with applicable laws, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements.
About CCPA Annex
This CCPA Annex integrates with and supplements the information contained in the rest of this Privacy Notice and applies solely to consumers residing in the state of California, United States of America, who visit or use the Sites (“consumers” or “you”). In case of any conflicts between the main body of the Privacy Notice and the California Consumer Privacy Act or “CCPA” Annex, the CCPA Annex will have precedence.
This section provides additional details about the personal information we collect about California consumers and the rights afforded to them under the CCPA.
Any terms defined in the CCPA have the same meaning when used in this notice.
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”).
We set out below the CCPA categories of personal information we have collected from consumers within the last twelve (12) months in respect of our products and services.
- Identifiers and other categories of personal information: full name and email address, telephone number, region or country of residence, language preference.
- Internet or other electronic network activity information: IP address and device identification information, operating system, browsing history, search history, and information regarding your interaction with the Sites.
- Professional Information: occupation, industry type, of expertise, professional title, seniority level, and department or level of expertise.
We will not collect additional categories of personal information without notifying you.
Personal Information does not include:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
We collect the above-mentioned categories of personal information when you provide it directly to us to obtain information about our Services, or to subscribe to our alerts; indirectly through our cookies and other technologies when you are browsing our Sites; and from advertising networks, data analytics providers, social networks, and data brokers.
In the preceding twelve (12) months, we have used the above-mentioned categories of personal information for the following business purposes:
- Auditing consumer interactions.
- Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
- Debugging to identify and repair errors that impair existing intended functionality.
- For our short-term, transient use.
- Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments.
- Undertaking activities to verify, maintain, improve, upgrade, or enhance the quality or safety of the services and products and the Sites.
In the preceding twelve (12) months, we also may have used the above-mentioned categories of personal information for commercial purposes, including to deliver promotional messages and personalized marketing communications to you.
If you would prefer not to receive these communications, simply follow the unsubscribe instructions on the promotional communications that you receive.
We may disclose your personal information for business purposes to the categories of third parties set out in To whom we give your personal information. In the preceding twelve (12) months, we have disclosed the following categories of personal information for our business purposes:
|Categories of Personal Information||Categories of Third Parties with Whom We Have Shared your Personal Information|
|Identifiers and other categories of personal information||Other STG Group Companies Service Providers, such as advertising networks, data analytics providers, social networks, data brokers|
|Internet or other electronic network activity information||Other STG Group Companies Service Providers, such as advertising networks, data analytics providers, social networks, data brokers|
|Professional Information||Other STG Group Companies Service Providers, such as advertising networks, data analytics providers, social networks, data brokers|
We do not sell your personal information to anyone outside the STG group of companies.
The CCPA sets forth certain obligations for businesses that “sell” personal information. Pursuant to the definition of “sell” under the CCPA and current guidance, we do not believe that we engage in such activity and have not engaged in such activity in the preceding 12 months.
The CCPA may provide you with specific rights regarding your personal information. This section describes your CCPA rights with respect to our processing of your personal information. We will not discriminate against you for exercising your CCPA rights.
1. Request To Access/Know Your Information
You may have the right to request that we disclose certain information to you about our processing of your personal information over the past 12 months:
- 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 and sharing that personal information.
- The categories of third parties with whom we shared that personal information.
- The specific pieces of personal information we have collected, used, and disclosed about you in a portable format.
2. Request To Delete Your Information
You may have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions.
1. Contact Information
To exercise your rights to the extent allowed under applicable law, please contact us at email@example.com
2. Consumer Identification Verification Requirements
Prior to responding to any access or deletion requests, STG will require a consumer to verify his or her identity. Consumer identification verification is required whether the consumer submits such a request directly or through an authorized agent as described below.
For all requests submitted by email, the following pieces of information may be required:
- First, Middle (if available), and Last Name
- Physical California Address
- Month/Year of Birth
- Valid Email Address
For all requests submitted through our toll-free Ethics and Compliance Helpline, the following pieces of information may be required:
- First, Middle (if available), and Last Name
- Physical California Address
- Month/Year of Birth
- Valid Telephone Number
- Valid Email Address (if available)
We may ask you to declare under penalty of perjury that you are the consumer, investor or partner, or his or her agent, whose personal information is the subject of the request.
3. How We Will Handle your Request
We will confirm receipt of your verifiable request within ten (10) business days and provide information about how we will process your request. STG will respond to your request within forty-five (45) days from receipt. If STG expects a delay, it will notify you and provide an explanation for the delay, which could take up to an additional forty-five (45) days. If we cannot verify your identity, we may reject your request in whole or in part.
4. Requirements for Use of Authorized Agents
The CCPA allows California consumers to use “authorized agents” to submit requests to STG on their behalf. If you have elected to use an authorized agent, or if you are an authorized agent who would like to submit requests on behalf of a consumer, the following minimum procedures will be required prior to acceptance of any requests by an authorized agent on behalf of a California consumer.
All requests from authorized agents may be submitted using the methods identified in the section titled “How to exercise your rights.” In addition, authorized agents will be required to submit the following written documentation:
Businesses – if you are operating as a business, the following documentation is required:
- Certificate of good standing with your state of incorporation;
- Written authorization document that includes each consumer’s name, address, telephone number and valid email address, signed and dated by each consumer authorizing you, as the authorized agent, to act on behalf of each consumer in making the request; and
Individuals – if you are an individual and acting as an authorized agent on behalf of a consumer, the following documentation is required:
- A “power of attorney” signed and dated by the consumer and notarized by a notary public naming you as the consumer’s authorized representative, which includes the consumer’s full name and physical California address and the consumer’s month/year of birth;
- If you do not have a power of attorney signed by the consumer, then we require a written authorization document that includes the consumer’s name, address, telephone number and valid email address, signed by the consumer authorizing you, as the authorized agent, to act on behalf of the consumer in making the request; and
For the safety and security of the consumer’s information, requests submitted to STG by an authorized agent will require a direct method of communication, preferably a valid email address, with the consumer, to fulfill the request. We may deny a request from an authorizer agent who does not submit sufficient proof to act on your behalf.
Some web browsers incorporate a “Do Not Track” feature. Our online resources do not currently alter their practices when they receive Do Not Track signals.