Effective June 28, 2019
“Personal Information” is any information that relates to you, and which, alone or in combination with other information, could reasonably be used to identify you.
Information We Collect
We may collect or receive Personal Information about you in various ways, depending on which of our applications and websites you use and how you interact with us.
Information You Provide and Information We Collect From Other Sources
You may choose to submit Personal Information and other information to us by purchasing or interacting with the MicroStrategy Offerings, such as when you create and manage a user account, join or connect with a network, request technical support services, request information or support from us, communicate with us by email, telephone, or online chat, upload information through the MicroStrategy Offerings, subscribe to newsletters or other subscription services, register for training or conferences, purchase products and services, submit job applications, or participate in surveys.
For certain of the MicroStrategy Offerings, we ask you to provide information including:
- Basic personal details (e.g., your name, title, and gender);
- Contact details (e.g., your email address, postal address, and phone number);
- Professional details (e.g., your company or organization name and any professional organization memberships);
- Usernames or URLs;
- Payment details (e.g., credit card information, bank account, etc.)
- Your photo; and
- Any other Personal Information you choose to provide us (e.g., in communications with technical support services, marketing teams, or during the provision of products/services).
Some of the information is necessary for us to provide particular MicroStrategy Offerings, and our ability to deliver the MicroStrategy Offerings to you may be affected by your not providing certain information.
We may also collect these categories of information from sources other than directly from you. In particular, we collect this information from publicly available sources (such as your employer's website or professional social networks such as LinkedIn), and may obtain Personal Information from third party data providers which maintain lists of individuals' contact information. Other users of the MicroStrategy Offerings may provide information about you when they submit content through the MicroStrategy Offerings. For example, you may be mentioned in a technical support case opened by someone else. Similarly, an administrator may provide your personal data such as when they designate you as the billing or technical contact on your company's account.
Please note that we may also have access to information about you that our customers may upload to our cloud services.
When using the Identity mobile application, you may be asked to allow access to the fingerprint scanner and/or camera on your device. This access is requested so that a fingerprint or facial profile may be collected to validate your credentialing information when logging into that device. This information, which may be considered biometric data (the “Biometric Information”) is not transmitted to us and we do not receive or retain it. We only maintain records of when your credentialing information has been validated by Identity.
The Biometric Information may be provided to individuals such as Identity Network administrators, User Mobile Users, and other users of the Identity Networks you choose to participate in, as a means of confirming credentialing information. Where this occurs, the Biometric Information is subject to those third-parties own privacy policies, terms and conditions and other policies. We encourage you to read those third-party policies and agreements before participating in such credentialing activities.
Information We Collect
When you access or use MicroStrategy Offerings, we may collect certain information about your device and your use of the MicroStrategy Offerings. Such information may include:
- information, including version information, about the web browser or application you are using;
- products/services you purchased, with related pricing;
- if you are using a mobile device, the model of the device and its operating system;
- crash data;
- a unique identifier we assign to you;
- your IP address; and
- information about your usage of the MicroStrategy Offerings, including what functions or pages you use, the frequency of your use, links that you click on, and how often you log in.
In addition to the above, to provide certain of the MicroStrategy Offerings, we may request your permission to access location information from your device. Some functions of the MicroStrategy Offerings may not work if you choose not to allow access to this location information. If you initially consent to sharing your location information through one of our applications or websites, you can subsequently stop the collection of this information by changing the settings of your device or by uninstalling the applications. In addition, even if you have not enabled location services for the applications or websites, we may derive your general location information from your use of the applications or websites, including from your Bluetooth signal when using Identity.
Cookies and Similar Technologies
Some of our websites may also feature cookies associated with certain unaffiliated companies. For example, we partner with other companies to provide you with connections to certain social networks, such as Facebook and Twitter, and to provide you with additional features such as YouTube. By engaging with such other companies’ sites, for instance, by clicking the Facebook "Like" button found on our Site, such companies may place session or persistent cookies on your device. This may allow these third-parties to collect information about your online activities over time and across websites. The use of these cookies is subject to such third-parties’ own cookie policies, which MicroStrategy strongly recommends you review.
Web Analytics and Interest-Based Advertising
We may use web analytics services on our websites, such as those of Google Analytics. The service providers that administer these services use technologies such as cookies to help us analyze how visitors use the site. The information collected through these means (including IP address) is disclosed to or collected directly by these service providers, who use the information to evaluate use of the website or for advertising purposes, as described below.
Some of our online advertising takes place through Google Display Advertising. As part of this program, we use Google Analytics features such as Retargeting. In connection with that feature and others offered by ad networks, we and the operators of ad networks, including Google, may use third-party cookies (such as the DoubleClick cookie) – and in some cases first-party cookies (such as the Google Analytics cookie) – to inform, optimize, and serve ads across the internet based on a user’s past visits to our website.
You can opt out of Google Analytics for Display Advertising or customize Google Display Network ads using the Google Ads Preferences Manager. To disable Google Analytics in general, please download the browser add-on for the deactivation of Google Analytics provided by Google at https://tools.google.com/dlpage/gaoptout. To learn more about other ad networks, including how to opt out, click here.
Do Not Track
Some web browsers and mobile devices incorporate a “do not track” feature that, when enabled, signals to websites and online services that you do not wish to be tracked. Because there is not yet an accepted standard for how to respond to such a do-not-track signal, we do not recognize or respond to these signals.
How We Use the Information We Collect
We may use the information we collect from you to:
- provide products/services to you;
- bill/invoice you;
- manage any accounts that you may have with us;
- validate your identity;
- send personalized marketing messages via email, post and telephone to you. Where required by applicable law, we will only send these messages with your consent, and you have the right to opt out of receiving marketing by contacting us;
- serve relevant advertising on our site and third-party sites related to our products and services which are personalized to your interests;
- provide you with notice of product releases, special events, trainings, promotions or other matters relevant to you;
- respond to your inquiries;
- improve the services you receive from us;
- solicit your feedback;
- prevent you from having to re-enter Personal Information about you on future visits to our websites or subsequent use of our applications;
- facilitate your access to third-party services and resources;
- keep track of your activities;
- process your payments and purchases;
- operate, evaluate and improve our business (including developing new products and services; enhancing and improving our services; managing our communications; analyzing our products; performing data analytics; and performing accounting, auditing and other internal functions);
- comply with applicable legal requirements, relevant industry standards and our policies.
We also use the information we obtain about you in other ways for which we provide specific notice at the time of collection.
If you are an individual in the E.U., we may be required to have a legal basis to process your Personal Information for these purposes under applicable E.U. law. We may ask for your consent in certain circumstances as indicated above, but if we do not ask for your specific consent:
- We use your Personal Information for certain purposes as it is necessary to comply with contractual obligations we have to you, including when we provide MicroStrategy Offerings to you in accordance with the applicable terms and conditions, or when we process payments and purchases you make;
- We may also use Personal Information to comply with our legal obligations, such as financial reporting obligations and compliance with subpoenas or similar court orders; and
- Where not strictly required by contract or by law, we use Personal Information to meet our legitimate business interests (when the use not overridden by your data protection interests) in running our business efficiently, in advertising our products and services to existing and prospective customers, understanding how our business is performing defending our interests and our legal rights, and keeping our records accurate and up to date. We take steps to ensure that your Personal Information is not used in ways other than those you would expect, and subject to laws in the country where you live, you have the right to object to our uses of Personal Information on this basis.
How We May Share Information
We disclose information about you: (i) to our third-party service providers; (ii) to other MicroStrategy group companies; (iii) if we are required to do so by law, regulation or legal process (such as a court order or subpoena), (iv) in response to requests by government agencies, such as law enforcement authorities, (v) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity (vi) to protect our legitimate business interests or (vii) in any other case, with your consent. We also reserve the right to transfer any information we have about you in connection with any sale or transfer of all or a portion of our business or assets, including in the event of a reorganization, dissolution or liquidation.
In addition, if you are using Identity, we may share certain of your information with the administrator of an Identity Network that you are a member of, with other users of the Identity application, or with third party services with which your Identity Badge is integrated.
Privacy Shield Notice
As described above, We may use third-party service providers to perform services on our behalf. If We transfer personal information received under the Privacy Shield to a third party, the third party's access, use, and disclosure of the personal data must also be in compliance with our Privacy Shield obligations, and We will remain liable under the Privacy Shield for any failure to do so by the third party unless We prove We are not responsible for the event giving rise to the damage.
To learn more about the Privacy Shield Framework, and to view our certification, please visit https://www.privacyshield.gov/. If you are an employee of MicroStrategy, please refer to the Code of Conduct and Employee Handbook for policies governing your information. In compliance with the Privacy Shield Principles, We commit to resolve complaints about our collection or use of your Personal Information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Roshan Popal (Chief Information Security Officer) at email@example.com.
We have further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit https://www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint. The services of JAMS are provided at no cost to you. Under certain conditions, more fully described in Annex I on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
For transfers to other jurisdictions, we have put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to ensure that Personal Information about you is adequately protected. For more information on the appropriate safeguards in place, please contact us at the details below.
The U.S. Federal Trade Commission has jurisdiction over our compliance with the Privacy Shield.
How We Protect Personal Information
We maintain administrative, technical and physical safeguards designed to protect the Personal Information you provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.
We also ensure that, in compliance with applicable law, we do not retain Personal Information longer than necessary. We will keep personal data about you for as long as we have a relationship with you, for example as long as you wish to keep receiving marketing messages from us, or as long as you are a customer (and for a reasonable period thereafter). When determining how long to retain Personal Information after we no longer have a relationship with you, we take into account how long our customers usually want to continue hearing from us, our legal obligations and the expectations of regulators, as well as the length of time information is needed for internal audit purposes and to exercise or defend our legal rights.
Links to Other Websites
The MicroStrategy Offerings may contain links to websites maintained by third parties, whose information and privacy practices differ from ours, including, for example, websites that process online payments. We are not responsible or liable for the content of any such websites, any use of such websites or the information or privacy practices employed by the providers of such websites. We encourage you to read the privacy statements of all third-party websites before using such websites or submitting any Personal Information or any other information on or through such websites.
Not for Use by Children
The Services are not directed to, and we do not knowingly contact or collect Personal Information from, individuals under the age of thirteen. If you are under the age of thirteen, these Services are not intended for you and you should not provide us with any Personal Information.
Access and Correction
To request a copy of the Personal Information we maintain about you, update or correct inaccuracies in that information, or request that we remove your Personal Information from our systems and stop contacting you at any time, please send an email to firstname.lastname@example.org that details your request and includes your exact name, physical address and email address. You also have in particular circumstances the right to object to our uses of your Personal Information, the right to restrict our uses of your Personal Information, and the right to have personal data transmitted in electronic form to you or to a third party (the right of “data portability”).
How to Contact Us
Attn: Office of the General Counsel
1850 Towers Crescent Plaza
Tysons Corner, Virginia 22182
If you are located in the E.U., you may also write to us at:
Building 10, Chiswick Park
566 Chiswick High Road
Chiswick, London, W4 5XS
Attn: Legal Department
We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to the data protection authority in the country in which you live via their website.