1. Sites covered by this Privacy Statement
2. Links to non-S2 websites
3. Privacy Shield Framework
Sullivan|Strickler LLC complies with the EU-U.S. Privacy Shield Framework, as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States.
The Federal Trade Commission has jurisdiction over Sullivan|Strickler’s compliance with the Privacy Shield.
4. Collection of personal information
To serve you better and understand your needs and interests, S2 collects, exports, and uses personal information with adequate notice and consent, when applicable. For example, when you order services, request information, subscribe to marketing or support materials, register yourself, we will ask you to provide personal information to complete these transactions. The types of personal information you provide to us on these pages may include contact information such as your name, address, telephone number, email address.
5. How we use your information
The information S2 collects to understand your needs and interests helps S2 deliver a consistent and personalized experience. For example, S2 may use your information to:
- communicate with you about products and services,
- provide service and support,
- update you on new services and benefits,
- provide personalized promotional offers,
- select content to be communicated to you,
- send you a newsletter,
- personalize some S2 websites,
- contact you for market research regarding S2 services, or
- for other purposes disclosed to you at the time we collect your information, or pursuant to your consent.
We will give you the opportunity to choose your privacy preferences regarding the communications we send.
6. How we share your information
- Except as described in this Statement, S2 will not share the personal information you provide to S2 with non-S2 third parties without your permission, except to: (i) respond to duly authorized information requests of police and governmental authorities, (ii) comply with any law, regulation, subpoena, or court order, (iii) help prevent fraud or to enforce or protect the rights and properties of S2 or its subsidiaries, (iv) protect the personal safety of S2 employees and third parties on S2 property, or (v) when we believe in good faith that disclosure is necessary to protect your safety or the safety of others.
- S2 may share personal information with trusted third-party service providers or partners to perform business-related services or perform activities on S2’s behalf. These may include but are not limited to (payment processing, accounts receivable, payroll services, consultancy, hosting services, analytics, etc).
- Circumstances may arise where, whether for strategic or other business reasons, S2 decides to sell, buy, merge, or otherwise reorganize operations in some countries. Such a transaction may involve the disclosure of personal information to prospective or actual purchasers, or the receipt of it from sellers. It is S2 practice to seek appropriate protection for information in these types of transactions.
In the context of an onward transfer Sullivan|Strickler has responsibility for the processing of personal information it receives under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf. Sullivan|Strickler shall remain liable under the Principles if its agent processes such personal information in a manner inconsistent with the Principles, unless the organization proves that it is not responsible for the event giving rise to the damage.
7. Children’s privacy
S2 does not knowingly collect personally identifiable information from children under the age of thirteen (13) without requiring parental consent, and does not target its websites to children under age thirteen. Any person who provides information to us represents that they are thirteen (13) years of age or older. We encourage parents and guardians to take an active role in their children’s online activities and interests. If you have any questions or concerns in this matter, please contact us. If you believe we have inadvertently collected personally identifiable information from a child under age thirteen (13), please encourage the parent of the child to contact us, and we will provide the parent an opportunity to review the data inadvertently collected, and further provide the parent an opportunity to have such data deleted and agree to prevent its further use or collection.
8. Your choices and selecting your privacy preferences
Subscription communications include email newsletters that may be expressly requested by you or which you consented to receive. After you request such communications, you may opt out of receiving them by using one of the following methods:
- Select the email “opt out” or “unsubscribe” link or follow the opt-out instructions included in each subscription communication.
- Return to the web page(s) where you originally registered your preferences and follow the opt-out instructions.
- Write to S2. Be sure to provide your name, email and postal address, and specific relevant information about S2 subscriptions that you no longer wish to receive.
Please be aware that when you opt out of receiving certain communications, it may affect the services you have chosen to receive from S2 where accepting the communications is a condition of receiving the services.
9. Access to and accuracy of your information
S2 strives to keep your personal information accurately recorded. We have implemented technology, management processes, and policies to help maintain data accuracy. S2 provides individuals with reasonable access to personal information that they provided to S2 and the reasonable ability to review and correct it or ask for anonymization, blockage, or deletion, as applicable. To protect your privacy and security, we will also take reasonable steps to verify your identity, such as requiring a password and user ID, before granting access to your data. To view and change the personal information that you directly provided to S2, contact S2.
10. Keeping your personal information secure
S2 takes seriously the trust you place in us. To prevent unauthorized access or disclosure, to maintain data accuracy, and to ensure the appropriate use of the information, S2 utilizes appropriate physical, technical, and administrative procedures to safeguard the information we collect.
We use Secure Sockets Layer (SSL) encryption when collecting or transferring sensitive information such as credit card information. SSL encryption is designed to make the information unreadable by anyone but us. This security measure is working when you see the symbol of either an unbroken key or a closed lock (depending on your browser) at the top or bottom of your browser window.
11. Data Retention & Security
12. Data Aggregation and Analysis
By providing data to S2, you agree S2 may use the data to build analytic models to support S2 mission, products, and services. Before including your data into our proprietary data models, we will use commercially reasonable methods to de-identify your data to allow S2 to use the data in a manner that neither identifies nor provides a reasonable basis to identify you or any other individual. Notwithstanding the foregoing, you acknowledge and agree that S2 shall be permitted to use all such data for the purpose of analyzing patterns, trends, and other statistical data derived from your data to provide, operate, maintain, and otherwise improve S2 mission, products, and services, and you grant S2 a license to your data to fulfil these purposes. Any such use of your data by S2 will be subject to the confidentiality and security provisions of this agreement. S2 will not disclose its analysis based on your data unless the data has been stripped of any information that could identify you.
13. Commitment to comply with the Swiss-U.S. Privacy Shield Framework
14. EU data protection authorities
S2 commits to cooperate with EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and comply with the advice given by such authorities with regard to human resources data and non- human resources data transferred from the EU and Switzerland in the context of the employment relationship. (added 13/08/2022)
15. Changes to this statement
If S2 changes its privacy statement, S2 will post the revised statement here with an updated revision date. If we make significant changes to our statement, we may also notify you by other means, such as sending an email or posting a notice on our home page.
16. Complaints/ Contact Us
In compliance with the Privacy Shield Principles, Sullivan|Strickler LLC and LTD commits to resolve complaints about our collection or use of your personal information. European Union individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Sullivan|Strickler at:
Sullivan|Strickler commits to cooperate with the panel established by the EU data protection authorities (DPAs), and comply with the advice given by such authorities with regard to HR data and non-HR data transferred from the EU.
Notice Principle. Section C of Annex I to the Privacy Shield Principles explains in detail when an individual may invoke binding arbitration. For complaints regarding Privacy Shield compliance not resolved by any of the other Privacy Shield mechanisms please use the link to Annex I for additional information: https://www.privacyshield.gov/article?id=ANNEX-I-introduction