Privacy Policy

As of April 18, 2023

Welcome to Strong Asian Lead (“Strong Asian Lead”, “SAL,” “we,” or “us”) and our web site at strongasianlead.com (the “Site”), as well as all related web sites, networks, applications, and other services provided by us and on which a link to this Privacy Policy (this “Policy”) is displayed (collectively, together with the Site, our “Service”).

This Policy explains how we collect, use, disclose, and protect information on the Service. By using the Service, you consent to the privacy practices described in this Policy.

This Policy is incorporated into and is subject to the Strong Asian Lead Usage Terms and Strong Asian Lead Core Principles as well as ScaleGrowth User Terms of Use and the ScaleGrowth Terms of Service.

  1. THE INFORMATION WE COLLECT ON THE SERVICE

We collect information about you when you use the Service. The information we collect falls into two categories: (1) information you provide us; and (2) information we collect automatically.

a. Information You Provide Us. We collect information you provide us, including:

  • Personal Information: We collect personal information that can identify you, such as your name, email address, mailing address, mobile phone number, and credit card or other billing information. We also collect other information you provide to us that could be linked to personal information, such as date of birth, geographic area, location, photo, or preferences. You provide us with this information when you register for an account, use the Service, make a purchase, or contact us for customer service-related requests.

b. Information We Collect Automatically. We also collect information automatically when you use the Service, including:

  • Cookies and Similar Technologies: We use cookies, web beacons, and similar technologies to collect information about your activity, browser, and device. Cookies are small text files that are stored on your device when you access the Service. We use both session cookies, which expire when you close your browser, and persistent cookies, which stay on your device until they expire or you delete them. We may use these technologies to personalize your experience, remember your preferences, and track your use of the Service.
  • Log Data: When you use the Service, we automatically collect log data, such as your IP address, browser type, operating system, the pages or features of our Service you use, and the time and date of your visit. We use this information to operate, improve, and personalize the Service, and to analyze usage patterns.
  • Analytics: We use third-party analytics tools, such as Google Analytics, to collect information about how you use and interact with the Service. These tools use cookies and similar technologies to collect and analyze information, such as how often you visit the Service, what pages you visit when you do so, and what other sites or apps you used prior to visiting the Service. We use this information to improve the Service and your experience.
  1. HOW WE USE THE INFORMATION WE COLLECT

We use the information we collect for a variety of purposes, including:

  • To provide, operate, and maintain the Service;
  • To communicate with you, respond to your inquiries, and provide customer service;
  • To personalize and improve the Service and your experience;
  • To analyze usage trends and preferences and to develop new products, services, features, and functionality;
  • To prevent fraud, protect our legal rights, and enforce our policies;
  • To comply with legal obligations and regulatory requirements; and
  • For any other purpose with your consent.
  1. HOW WE SHARE INFORMATION

We may share the information we collect in various ways, including:

  • Information from other sources. We may obtain information, including Personal Information, from third parties and sources other than the Service, such as our partners and advertisers. If we combine or associate information from other sources with Personal Information that we collect through the Service, we will treat the combined information as Personal Information in accordance with this Policy.

    1. How we use the information we collect. We use information we collect on the Service in a variety of ways in providing the Service and operating our business, including the following:
    • We use the information that we collect on the Service to operate, maintain, enhance and provide all features of the Service, to provide services and information that you request, to respond to comments and questions and otherwise to provide support to users, and to process and deliver entries and rewards in connection with promotions that may be offered from time to time on the Service.

    • We use the information that we collect on the Service to understand and analyze the usage trends and preferences of our users, to improve the Service, and to develop new products, services, features, and functionality.

    • We may use your email address or other information we collect on the Service (i) to contact you for administrative purposes such as customer service or (ii) to send communications, including updates on promotions and events, relating to products and services offered by us and by third parties we work with. Generally, you have the ability to opt-out of receiving any promotional communications as described below under “Your Choices”.

    • We may use cookies and automatically collected information we collect to: (i) personalize our Service, such as remembering your information so that you will not have to re-enter it during your visit or the next time you visit the Service; (ii) provide customized advertisements, content, and information; (iii) monitor and analyze the effectiveness of Service and third-party marketing activities; (iv) monitor aggregate site usage metrics such as total number of visitors and pages viewed; and (v) track your entries, submissions, and status in any promotions or other activities on the Service.

    1. When we disclose information. Except as described in this Policy, we will not disclose your information that we collect on the Service to third parties without your consent. We may disclose information to third parties if you consent to us doing so, as well as in the following circumstances:
    • Any information that you voluntarily choose to include in a publicly accessible area of the Service will be available to anyone who has access to that content, including other users.

    • We work with third party service providers to provide website, application development, hosting, maintenance, and other services for us. These third parties may have access to or process your information as part of providing those services for us. Generally, we limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and we either require them to agree to limit the disclosure of such information or rely on their privacy policies that require that they do so.

    • We may make certain automatically-collected, aggregated, or otherwise non-Personal Information available to third parties for various purposes, including (i) compliance with various reporting obligations; (ii) for business or marketing purposes; or (iii) to assist such parties in understanding our users’ interests, habits, and usage patterns for certain programs, content, services, advertisements, promotions, and/or functionality available through the Service.

    • We may disclose your information (i) if required to do so by law; (ii) in the good-faith belief that such action is necessary to comply with state and federal laws; (iii) in response to a court order, judicial or other government subpoena or warrant; or (iv) to otherwise cooperate with law enforcement or other governmental agencies.

    • We also reserve the right to disclose your information that we believeWith third-party service providers who help us provide and improve the Service, such as payment

      , in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of the Service and any facilities or equipment used to make the Service available, or (v) protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights, property, or safety of others.

      CALIFORNIA PRIVACY RIGHTS

      If you are a California resident, you have the right to request information from us regarding the manner in which we share certain categories of your personal information with third parties for their direct marketing purposes, in addition to the rights set forth above. Under California law, you have the right to send us a request at the designated address listed below to receive the following information:

      • The categories of information we disclosed to third parties for their direct marketing purposes during the preceding calendar year
      • The names and addresses of the third parties that received the information
      • If the nature of the third party’s business cannot be determined from their name, examples of the products or services marketed.

      We may provide this information in a standardized format that is not specific to you. The designated email address for these requests is hello@strongasianlead.com.

      INTERNATIONAL DATA TRANSFERS

      We may transfer your Personal Information to countries other than the one in which you reside, including to the United States, where our servers are located. By using the Service, you consent to the transfer of your Personal Information to any country and/or territory where we or our service providers have facilities or engage third-party service providers, and to the processing of your information in accordance with this Policy.

      SECURITY

      We have implemented commercially reasonable measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. However, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. Therefore, while we strive to protect your Personal Information, you acknowledge that: (a) there are security and privacy limitations of the Internet which are beyond our control; (b) the security, integrity, and privacy of any and all information and data exchanged between you and us through the Service cannot be guaranteed; and (c) any such information and data may be viewed or tampered with in transit by a third party, despite our best efforts.

    PRIVACY OF MINORS

    This section emphasizes the importance of protecting the privacy of minors and clarifies that the website is not directed towards individuals under the age of 13. The website does not knowingly collect any personal information from individuals under 13 years of age, and if it discovers that it has collected such information without parental consent, it will take appropriate steps to delete it. Parents or guardians who discover that their child under 13 years of age has an account on the website can request that the child’s personal information be deleted.

    The next section is:

    DATA SECURITY

    This section outlines the physical, technical, and managerial safeguards that the website employs to protect the integrity and security of personal information that it collects and maintains. While the website makes efforts to safeguard personal information, it cannot warrant the security of any information transmitted to it or stored on the website. If the website becomes aware of a security systems breach, it will attempt to notify affected users electronically.

    The next section is:

    PRIVACY SETTINGS

    This section clarifies that although the website may allow users to adjust their privacy settings to limit access to certain personal information, no security measures are perfect or impenetrable. The website is not responsible for circumvention of any privacy settings or security measures on the website. It cannot control the actions of other users with whom users may choose to share their information. Even after information is removed from the website, caching and archiving services may have saved that information, and other users or third parties may have copied or stored the information available on the website. The website cannot guarantee that information posted on or transmitted to the website will not be viewed by unauthorized persons.

    The next section is:

    INTERNATIONAL VISITORS

    This section clarifies that the website is hosted in the United States and is intended for visitors located within the United States. If users choose to use the website from regions outside of the United States with different data collection and use laws, they are transferring their personal information to the United States for storage and processing. The website may transfer user data from the United States to other countries or regions in connection with data storage and processing, fulfilling user requests, and operating the website. By providing any information, including personal information, on or to the website, users consent to such transfer, storage, and processing.

    The final section is:

    CHANGES AND UPDATES TO THIS POLICY

    This section clarifies that the website may update this Policy from time to time and advises users to periodically check the page to stay informed of any changes. If the modifications materially alter user rights or obligations under this Policy, the website will make reasonable efforts to notify users of the change, such as sending an email or generating a pop-up or banner notification. Users’ continued use of the website after the revised Policy has become effective indicates that they have read, understood, and agreed to the current version of this Policy.

    PRIVACY RIGHTS FOR CALIFORNIA RESIDENTS California Civil Code Section § 1798.83 permits users of the Site that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please contact us at: Strong Asian Lead, info@strongasianlead.com.

    GDPR PRIVACY RIGHTS FOR EEA RESIDENTS This section applies to you if you reside in the European Economic Area (an “EEA Resident”). A data controller means a party that is responsible for deciding how it uses the data that it holds. A user using the Service to create a community is the data controller of your data that the user collects through the community and is responsible for handling the requests you may make with respect to that data. We are the data controller of your data that we collect as described in this Policy, and we will handle any requests that you may make with respect to that data as described below.

    You have the right to ask us not to process your Personal Information for marketing purposes. We will usually inform you (before collecting your Personal Information) if we intend to use your Personal Information for such purposes or if we intend to disclose your Personal Information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your Personal Information. You can also exercise the right by contacting us directly.

    If you are an EEA Resident and GDPR applies and we hold your Personal Information in our capacity as a data controller, you may object to our processing of Personal Information or request that we:

    • Provide access to and/or a copy of certain Personal Information (including, in some cases, in portable form);
    • Prevent the processing of your Personal Information for direct-marketing purposes (including any direct marketing processing based on profiling);
    • Update Personal Information that is out of date or incorrect;
    • Delete certain Personal Information which we are holding about you, provided that the Personal Information is not required by us for (i) compliance with a legal obligation under European or Member State law or other applicable law or (ii) the establishment, exercise or defense of a legal claim;
    • Restrict the way that we process and disclose certain of your information except to the extent that processing is required (i) to comply with a legal obligation under European Member State law or applicable law or (ii) for the establishment, exercise or defense of legal claims;
    • Transfer your Personal Information to a third party to the extent that this is technically feasible; or
    • Honor a revocation of your consent for the processing of your Personal Information (without retroactive effect).

    We will consider all requests and provide our response within the time period required by applicable law. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include information that we need to keep processing for our legitimate interests or to comply with a legal obligation. We may request that you provide us with additional information to confirm your identity before responding to your request. You have the right to lodge a complaint with the authorities applicable to your situation, though we invite you to contact us with any concern as we would be happy to try to resolve it directly.

    If you are an EEA Resident in France, you also have the right to set guidelines for the retention and communication of your Personal Information after your death.

    If you reside in a jurisdiction other than the European Economic Area, you may also have similar rights to the above. Please contact us privacy@asianfilmnetwork.com if you would like to exercise one of these rights, and we will comply with any request to the extent required under applicable law.

    In addition, where you believe that we have not complied with our obligation under this Policy or European law, you have the right to make a complaint to an EU Data Protection Authority, such as the UK Information Commissioner’s Office. Here is a list of local data protection authorities in EEA countries.

    CHANGES TO THIS POLICY

    We reserve the right to change this Policy from time to time, with or without notice to you, in our sole and absolute discretion. The most current version of this Policy will be posted on the Service, and your continued use of the Service after we make changes constitutes your acceptance of such changes.

    CONTACT US

    If you have any questions or comments about this Policy, our privacy practices, or if you would like to exercise your rights and choices under this Policy, please contact us at:

    Strong Asian Lead
    hello@strongasianlead.com
    Attention: Legal Department

PERSONAL DATA THAT STRIPE COLLECTS

The following information comes straight from Stripe, the third-party payment system we use to collect payments for memberships. 

Personal data that Stripe collect about End Users

  • Using Link or Connecting your Bank Account. Stripe offers you the opportunity to store your payment methods with Stripe so that you can conveniently use it across merchants who are our Business Users – we call this “Link” (formerly known as “Remember Me”). When you opt in to Link, you agree to let us store your payment method so that you can more readily make purchases through Link with Business Users of our payment processing Business Services (e.g. name, card number, cvc, and expiration date). When you choose to pay with Link, we will also collect your Transaction Data. Learn More. 
 
  • If you choose to share bank account information (including for use in Link) with us, Stripe will periodically collect and process your bank account information (e.g. account owner information, account balances, account number and details, account transactions and in some cases, credentials) until you ask us to disconnect your bank account. Learn More.
 
  • Paying Stripe. If you are buying goods or services directly from Stripe, we receive Transaction Data. For example, when you make a payment to Stripe Climate, we will collect contact information, payment method information, information about that transaction and in some cases, shipping information.
 
  • Other Services. We may offer other End User Services directly to you from time to time, including certain financial Services. Learn More for information about our collection and use of Personal Data.
 
  • More. Please see below for information about additional types of Personal Data that we may collect, including about online activity.

How stripe use and share personal data of End Users

  • Services. We use your Personal Data to provide the End User Service to you, including security, delivery, support, personalization and messages related to the End User Service (e.g. communicating Policy updates and information about our Services). We also use your Personal Data for our fraud detection and mitigation Business Services and may share certain Personal Data as part of those Business Services with Business Users that you may seek to do business with. The use of this Personal Data is subject to the Business Users’ privacy policies.
 
  • Our Business Users. When you choose to connect your bank account with Stripe, you may also choose to share account information with certain Business Users that you do business with. These Business Users will have their own privacy policies which describe how they use that information. 
 
  • Transactions. For payment transactions with Link, End User Personal Data is shared with others to enable the transaction. For example, when you choose to use a payment method for the transaction with Stripe or with Link (e.g. credit card, debit card, buy now pay later, or direct debit), that payment method will receive transaction information that includes your Personal Data. Please review your payment method’s privacy policy to learn more. When you use Link, the merchant you choose to do business with will also receive Transaction Data that includes your Personal Data and with your permission, your bank account information. The merchant may share that Personal Data with others (see below regarding End Customers). Please review your merchant’s privacy policy for further information.
 
  • Fraud Detection Services. We use your Personal Data collected across our Services (e.g. Stripe Radar) to detect and prevent fraud against us, our Business Users and financial partners, including to detect unauthorized log-ins using your online activity. We may provide Business Users (including card issuers and others involved in payment processing activities) that have requested our fraud Business Services with Personal Data about you (including your attempted transactions) so that they can assess the associated fraud risk with a transaction. You can learn more about how we may use technology to assess the fraud risk associated with an attempted transaction here.
 
  • Advertising. We may use your Personal Data to assess your eligibility for and offer you other End User Services. With your permission or where allowed by law, we use and share End User Personal Data with others so that we may market our products and services to you, including through interest-based advertising where allowed by applicable law, including subject to any consent requirements. See our Cookie Policy. We do not share End User Personal Data with third parties for their marketing or advertising unless you give us or the third party permission to do so. We do not sell the data of End Users.
 
  • More. Please see below for information about additional ways in which we may use and share your Personal Data.

Stripe End Customers

  • Stripe offers Business Services to our Business Users (e.g. in-person checkout or online checkout). When we are acting as a Business User’s service provider (or data processor), we will process Personal Data in accordance with the terms of our agreement with the Business User and the Business User’s lawful instructions. For example, we process payment transactions for a Business User because you bought a product from them. Business Users are responsible for making sure that their End Customer’s privacy rights are respected, including ensuring appropriate disclosures about data collection and use that happens in connection with their services. If you are an End Customer (e.g., a purchaser of a product at an online Business User site), please refer to the privacy policy or notice of the Business User for information regarding the Business User’s privacy practices, choices and controls, or contact the Business User directly. See here for further information on the legal bases which we rely on for using (processing) your Personal Data. 

Personal data that STRIPE collects about End Customers

  • Transaction Data. If you are an End Customer, when you make payments to, get refunds from, begin a purchase, make a donation or otherwise transact with a Business User that uses us to provide payment processing Business Services, we will receive transaction data. The “Transaction Data” that we collect includes Personal Data, and may include the following: your name, email address, billing address, shipping address, payment method information (such as credit or debit card number, bank account information or payment card image selected by you), merchant and location, purchase amount, date of purchase, and in some cases, some information about what you have purchased and your phone number. We may also receive your transaction history with the Business User. Learn More. We may collect information typed into a checkout form, even if you choose not to complete the form or purchase with the Business User. Learn More.
 
  • Identity/Verification Information. Stripe provides a verification and fraud Service that allows a Business User to verify Personal Data about you, such as your age (when purchasing age restricted goods) or your authorization to use a payment method. You will be asked to share Personal Data and we will collect the information that you share for this purpose, such as your government ID, your image, and Personal Data you input or that is apparent from the physical payment method (e.g. credit card image). We may compare this information with information about you we collect from Business Users, financial partners, business partners, identity verification services, publicly available sources, and third party service providers. Learn More.
 
  • More. Please see below for information about additional types of Personal Data that we may collect, including about online activity.

How Stripe use and share personal data of End Customers

  • We generally use and share Personal Data of End Customers with Business Users to provide Business Services as described below, as well as for Stripe’s own purposes to secure, improve and provide our Business Services, as described below. 
 
  • Payments. We use your Transaction Data to provide our Payments related Business Services to Business Users, including to process online payment transactions, to calculate applicable sales tax, to invoice and bill, and to calculate their revenue. Learn More. We may also use Personal Data to provide and improve our Business Services. 
 
  • For payment transactions, your Personal Data is shared with a number of parties in connection with your transaction. Because we act as a service provider or processor, we share Personal Data to enable the transaction. For example, when you choose to use a payment method for the transaction (e.g. credit card, debit card, buy now pay later, or direct debit), your payment method will receive the Transaction Data that includes your Personal Data. Please review your payment method’s privacy policy to learn more about how they use and share this information.
 
  • The merchant you choose to do business with will also receive Transaction Data that includes your Personal Data and the merchant may share that Personal Data with others. Please review your merchant’s privacy policy to learn more. 
 
  • Other Financial Services. Some of our Business Users use our Services in order to offer financial services to you, through Stripe or its financial partners. For example, they may provide a card product that enables you to purchase goods and services. These cards may carry the Stripe brand, bank partner brand and/or the brands of Business Users. In addition to any Transaction Data we may produce or receive when these cards are used for purchases, we will also receive and use your Personal Data in order to provide and manage these products. Please also see the privacy policies of the Business User and our bank partner, if applicable, associated with the financial service (whose brands may be shown on the card).
 
  • Identity/Verification Services. We use Personal Data about your identity, including information provided by you and our service providers, to perform verification Services for Stripe or for the Business Users that you are doing business with and to reduce fraud and enhance security. If you provide a “selfie” along with an image of your identity document, we will use technology to compare and calculate whether they match and you can be verified. Learn More.
 
  • Fraud Detection Services. We use your Personal Data collected across our Services to detect and prevent fraud against us, our Business Users and financial partners (e.g. Stripe Radar), including to detect unauthorized log-ins using your online activity. We may provide Business Users (including card issuers and others involved in payment processing activities) that have requested our fraud Business Services with Personal Data about you (including your attempted transactions) so that they can assess the associated fraud risk with a transaction. You can learn more about how we may use technology to assess the fraud risk associated with an attempted transaction and what information we may share with Business Users about such risks here.
 
  • Our Business Users (their Authorized Third Parties). We share Personal Data of End Customers with their respective Business Users and with parties directly authorized by those Business Users to receive Personal Data. This includes sharing Personal Data of End Customers with Business Users when a Business User authorizes a third party application provider to access its Stripe account using Stripe Connect. For example, when the Business User uses Identity Services to verify an End Customer’s identity, Stripe shares with the Business User the information, documents or photos provided by the End Customer to verify their identity. The Business Users you choose to do business with may further share your Personal Data to third parties they authorize. Please review your merchant’s privacy policy to learn more. 
 
  • Advertising by Business Users. If you have begun a purchase, we share Personal Data with that Business User in connection with our provision of Services and that Business User may use your Personal Data to market and advertise their products or services. Please review your merchant’s privacy policy to learn more, including your rights to stop their use of your Personal Data for marketing purposes. We do not use or share End Customer Personal Data for our marketing or advertising, or for marketing and advertising by third parties who are not the Business User with which you have transacted or attempted to transact. We do not sell the data of End Customers.
 
  • More. Please see this link for information about additional ways in which we may use your Personal Data.

IF You have more questions, please reach out to Hello@strongasianlead.com