Privacy

Steer Lab LLC and its affiliates (collectively, “Steer Lab,” “we,” “our,” or “us”) respect your privacy and are committed to protecting your information. This Privacy Notice explains how we collect, use, disclose, safeguard, and otherwise process information that identifies, relates to, describes, or could reasonably be linked to an individual (“Personal Information”), as well as your rights with respect to your Personal Information.

This Privacy Notice applies to Personal Information provided by individuals (“you” or “your”) who access or use our websites (including, without limitation, www.steer-lab.com), mobile applications, social media pages, digital communications (including email), and other online services that display or link to this Privacy Notice, as well as offline interactions with us, such as at events or in connection with business opportunities (collectively, the “Services”).

By accessing or using the Services or otherwise providing Personal Information to us, you acknowledge and agree that your Personal Information will be collected, used, and disclosed as described in this Privacy Notice. If you do not agree with this Privacy Notice, please discontinue use of the Services.

We may update this Privacy Notice from time to time. When we do, we will revise the “Last Updated” date at the top of this Privacy Notice. If we make material changes to how we collect, use, or disclose Personal Information, we will take reasonable steps to provide notice prior to such changes becoming effective, such as by posting a prominent notice on our website.

Steer Lab is the data controller of the Personal Information processed under this Privacy Notice. This means that we determine the purposes and means of processing your Personal Information and are responsible for complying with applicable privacy laws.

This Privacy Notice does not apply to information that we process solely on behalf of a customer or business partner pursuant to a written agreement where Steer Lab acts as a service provider or processor. In those circumstances, the processing of Personal Information is governed by the applicable agreement and relevant data protection laws.

We may provide additional or different privacy notices that apply to certain products, services, features, or activities. In those cases, those additional notices will govern the specific activity or feature they describe.

If you have any questions or comments about this Privacy Notice or our privacy practices, please contact us at lab@steerllc.com.

The types of Personal Information we collect about you depend on how you interact with Steer Lab and our Services. This section describes the categories of Personal Information that we may have collected during the preceding twelve (12) months, the sources of that information, and how it is collected.

a. Information You Voluntarily Provide to Steer Lab

We collect Personal Information that you voluntarily provide to us when you interact with Steer Lab. This may include, for example, when you contact us; request information about our products or services; sign up for updates, newsletters, or events; register for a webinar or other program; complete a form; respond to a survey; submit inquiries through our website or other digital channels; request to be contacted by us; or otherwise communicate with us in the course of our business activities.

The categories of Personal Information we may collect directly from you include:

Identifiers, such as your name, business or physical address, email address, telephone number, online identifiers, account credentials, or other similar identifiers.
Demographic Information, such as age or other general demographic details you choose to provide. In limited circumstances, this information may include characteristics protected under applicable law.
Professional or Employment Information, such as your employer or organization, job title, role, industry, or other information relating to your professional affiliation.
User Content, such as comments, messages, or other content you submit through our websites, social media pages, surveys, or other forums we make available.
Preferences, such as your communication preferences, interests, or marketing choices.
Sensitive Personal Information, where voluntarily provided and permitted by law, such as government-issued identification numbers, account log-in credentials, financial information, precise geolocation data, or other sensitive data categories as defined under applicable privacy laws.
Any other information you choose to provide to us.

b. Information We Collect Automatically or Generate

We may automatically collect or generate certain Personal Information when you access or use our Services. This information may include:

Identifiers, such as device identifiers, cookie identifiers, mobile advertising identifiers, usernames, or other unique identifiers associated with your device or browser.
Device and Technical Information, such as your IP address, device type, operating system and version, browser type, language settings, and other technical information about the device used to access the Services.
Commercial Information, such as records of products or services obtained from us or inquiries made on behalf of an organization with which you are affiliated.
Internet or Other Electronic Network Activity Information, including information about your interactions with our Services, such as pages viewed, links clicked, time spent on pages, referring URLs, and other usage data.
Geolocation Information, such as general geographic location derived from your IP address.
Audio and Visual Information, such as photographs, video, or audio recordings, if you attend our events, visit our facilities, participate in recorded meetings, or leave us a voicemail.
Inferences, drawn from the Personal Information described above, which may be used to understand preferences, interests, or engagement with our Services.

c. Aggregated and De-Identified Data
We may create and use aggregated, de-identified, or statistical information derived from Personal Information. Aggregated or statistical information does not directly identify you. If we combine aggregated, de-identified, or statistical information with Personal Information so that it can identify an individual, we treat the combined information as Personal Information.

We, and our service providers or other third parties engaged on our behalf, may use cookies, pixel tags, and similar tracking technologies (collectively, “Collection Technologies”) to automatically collect certain information described above when you access, use, or otherwise interact with our Services. This section describes the Collection Technologies we use and the choices that may be available to you. We may use Collection Technologies to collect information about your online activities over time and across third-party websites or online services (sometimes referred to as “behavioral tracking”), where permitted by law. Using these technologies helps us operate and improve our Services and deliver a more relevant and personalized experience.

a. Types of Collection Technologies We Use

Cookies. Cookies are small text files stored on your device that help websites function properly, remember user preferences, and improve user experience.
Web Beacons, Pixel Tags, Clear GIFs, and Scripts. These technologies are small transparent images or lines of code that help us understand how users interact with our Services. For example, they may allow us to determine whether a particular webpage was visited or whether a link was clicked. We may also use these technologies in emails to understand whether messages were opened, forwarded, or otherwise engaged with.
Social Media Platforms. Our Services may include social media features, such as widgets, buttons, or interactive tools (e.g., a “share” button). These features may collect information such as your IP address and the page you are visiting. Your interactions with these features are governed by the privacy policies of the applicable social media platform.

b. Categories of Cookies and Similar Technologies

Our use of Collection Technologies generally falls into the following categories. Some technologies may fall into more than one category.

Strictly Necessary Technologies. These technologies are required for the Services to function and cannot be disabled in our systems. They are typically set in response to actions you take, such as setting privacy preferences, submitting forms, or requesting services.
Functional Technologies. These technologies enable enhanced functionality and personalization, such as remembering user preferences, language settings, or region.
Analytics and Performance Technologies. These technologies help us understand how users interact with our Services, including which pages are visited most frequently, how long users remain on pages, and whether errors occur. This information helps us improve the performance and usability of our Services.
Advertising and Targeting Technologies. These technologies may be used to collect information about your interactions with our Services in order to deliver advertising or content that may be more relevant to your interests, where permitted by law.

For information about managing your cookie preferences and available opt-out mechanisms, please see Section 6(c) below. To the extent our use of Collection Technologies constitutes targeted advertising, profiling, or a “sale” or “sharing” of Personal Information under applicable law, you may have the right to opt out as described in Section 6.

c. Third-Party Collection Technologies

When you interact with the Services, certain third parties may use Collection Technologies to collect information about you or your device. We do not control these third parties’ Collection Technologies or how they may be used. If you have questions about an advertisement or other targeted content, you should contact the relevant third party directly.

d. Information We Collect from Other Sources

We may obtain Personal Information from third-party sources, such as business partners, service providers, customers, referral sources, or business contact databases. We may also receive information from social media platforms when you interact with us or our content on those platforms. In addition, we may collect information from publicly available sources, such as public websites, publications, or social media profiles.

The categories of Personal Information we may collect from these sources include:

Identifiers, such as name, business contact information, email address, telephone number, or social media identifiers.
Professional or Educational Information, such as employer, job title, professional background, licenses, certifications, education history, languages, or professional affiliations.
User Content, such as publicly available posts, comments, or publications that you choose to make available online.

We use Personal Information for a variety of business and operational purposes, including to operate our Services, communicate with you, and improve our offerings. Transparency is important to us, and the following describes the primary purposes for which we use Personal Information:

To provide and operate the Services, including to make our websites, applications, and other digital properties available; maintain functionality; troubleshoot issues; and improve performance, security, and usability.
To communicate with you, including to respond to inquiries, comments, or requests; provide information you request; register you for events, webinars, or programs; send administrative messages, confirmations, technical notices, updates, or security alerts; and otherwise manage our relationship with you.
To manage and grow our business relationships, including to maintain and expand our contact lists; send newsletters, updates, marketing communications, or other information that may be of interest to you, in accordance with applicable law and your communication preferences.
To personalize your experience, including to remember your preferences, tailor content or communications, and facilitate interactions with Steer Lab.
For research, analytics, and improvement, including to understand how users interact with our Services, analyze usage trends, measure engagement, and develop, enhance, and improve our Services and business operations.
For marketing and promotional purposes, including to promote our products, services, events, publications, and other offerings; evaluate the effectiveness of marketing campaigns; and manage advertising activities where permitted by law.
For internal business purposes, including administration, data management, recordkeeping, billing, accounting, auditing, quality control, and other ordinary business operations permitted by law.
For security, fraud prevention, and legal compliance, including to detect, prevent, and respond to fraud, misuse, security incidents, or unlawful activity; protect the rights, property, and safety of Steer Lab, our users, and others; enforce our agreements; comply with applicable laws and regulations; and respond to lawful requests, court orders, subpoenas, or regulatory inquiries.
For other purposes disclosed at the time of collection or with your consent, including purposes you have expressly authorized.

Where the General Data Protection Regulation (“GDPR”) applies, Steer Lab processes Personal Information only where we have a valid legal basis to do so. Depending on the circumstances, these legal bases may include:

Performance of a contract, such as to provide the Services you request or to take steps at your request prior to entering into a contract;
Compliance with a legal obligation to which we are subject;
Our legitimate interests, such as operating, improving, and securing our Services, communicating with business contacts, conducting analytics, and managing our business relationships, where such interests are not overridden by your fundamental rights and freedoms; and
Your consent, where required by applicable law.

Where we rely on your consent as the legal basis for processing, you may withdraw your consent at any time as described below.

We may disclose Personal Information to the categories of third parties described below for business and operational purposes consistent with this Privacy Notice. We do not disclose Personal Information in exchange for money. However, certain disclosures (such as those involving cookies or similar technologies) may constitute a “sale” or “sharing” of Personal Information under applicable privacy laws, including the CPRA. Please see Section 6 for information about your rights and choices.

Affiliates. We may share Personal Information with our corporate parent, subsidiaries, and other affiliates for purposes consistent with this Privacy Notice, including business operations, analytics, and internal administration.
Service Providers. We may share Personal Information with third-party vendors and service providers that perform services on our behalf or help us operate our Services, such as website hosting, data storage, analytics, customer support, payment processing, email delivery, marketing support, database management, and security services. These service providers are permitted to use Personal Information only as necessary to provide services to us and are contractually restricted from using or disclosing the information for any other purpose.
Business Partners. We may share limited Personal Information, such as your name and contact information, with business partners in connection with joint offerings, co-sponsored events, collaborations, or publications that you choose to engage with.
Advertising and Analytics Providers. As described in Section 2 (Collection Technologies), we may disclose Personal Information to third-party analytics and advertising providers through our use of cookies and similar technologies to support our marketing, advertising, and analytics efforts. These disclosures may be used to:

- measure and analyze usage of our Services;
- deliver or evaluate interest-based advertising; and
- understand user engagement across websites and devices.
Such providers may collect information directly from your browser or device over time and across difference websites.

Google Analytics. To learn how Google uses data collected from sites that use its services, please visit Google’s privacy policy. You may opt out of Google Analytics by installing the Google Analytics Opt-out Browser Add-on.
Meta / Facebook Technologies. For information about how Meta uses Personal Information and how to manage your preferences, please see Meta’s Data Policy and ad settings.
Social Media Platforms. When you interact with social media features on our Services or choose to connect or share content through social media platforms (such as LinkedIn, Facebook, X, or Instagram), those platforms may collect or receive information about you. Your interactions with those platforms are governed by their respective privacy policies.
Professional Advisors. We may disclose Personal Information to professional advisors, such as accountants, auditors, consultants, insurers, and legal advisors, as necessary to obtain professional services.

Compliance, Fraud Prevention, and Safety. We may disclose Personal Information to comply with applicable laws and regulations, respond to lawful requests or legal process, enforce our agreements, protect our rights and property, and detect or prevent fraud, security incidents, or other unlawful activity, as described in Section 3.

Business Transfers. We may disclose or transfer Personal Information in connection with a merger, acquisition, financing, reorganization, sale of assets, bankruptcy, or similar transaction or proceeding involving all or part of our business.

With Your Consent or at Your Direction. We may disclose Personal Information where you have provided consent or directed us to do so.

De-Identified and Public Information. We may share aggregated or de-identified information that cannot reasonably be used to identify you for any lawful purpose.

Please note that any information you choose to post publicly on our Services or on social media (such as in comments, forums, or profiles) may be visible to others and, in some cases, publicly accessible.

We retain Personal Information for as long as reasonably necessary to fulfill the purposes described in this Privacy Notice, unless a longer retention period is required or permitted by applicable law.In determining appropriate retention periods, we consider factors such as the nature of the Personal Information, the purposes for which it was collected, our legal and regulatory obligations, and applicable statutes of limitation. In many circumstances, we must retain some or all of your Personal Information to comply with legal or regulatory requirements, resolve disputes, enforce our agreements, protect against fraudulent, deceptive, or unlawful activity, or for other legitimate business purposes permitted by law.When Personal Information is no longer required for these purposes, we take reasonable steps to delete, de-identify, or otherwise securely dispose of it in accordance with applicable laws and our internal data-retention practices.

Access Your Personal Information, including the right to:

confirm whether we process your Personal Information;
access the categories of Personal Information we collect or process; and
obtain a copy of your Personal Information in a portable and, where technically feasible, readily usable format.

Correct Your Personal Information, where it is inaccurate or incomplete, taking into account the nature of the information and the purposes of processing.

Delete Your Personal Information, subject to certain legal exceptions.

Opt Out of Certain Uses of Your Personal Information, including:

targeted advertising;
the “sale” or “sharing” of Personal Information (as defined under applicable privacy laws); and
certain profiling activities that produce legal or similarly significant effects.

Limit the Use or Disclosure of Sensitive Personal Information, where required by applicable law.

To exercise your privacy rights, please contact us at lab@steerllc.com.

We may need to verify your identity before processing your request. You may designate an authorized agent to submit a request on your behalf, where permitted by law, subject to verification requirements. If you have questions about your privacy rights or would like to appeal a decision related to a privacy request, please contact us using the email address above. We will not discriminate against you for exercising any of your privacy rights.

Nevada Residents. Nevada law provides residents with a limited right to opt out of certain sales of personal data. Nevada residents who wish to exercise this right may submit a request using the contact information in Section 12. If we engage in activity that triggers Nevada’s opt-out requirements, we will honor such requests as required by law.

When you first visit our website, you may be presented with a cookie or consent banner that allows you to manage your preferences regarding certain Collection Technologies, except for those that are strictly necessary to operate the Services.

You may update your preferences at any time by using the cookie-management or “Your Privacy Choices” link available on our website, where provided.

You can also control cookies through your browser or device settings. Please note that disabling certain cookies may affect the functionality of our Services.

Cookie-based opt-out mechanisms may not be effective on mobile applications. Where applicable, you may manage advertising preferences through your device settings.

Some browsers and browser extensions support the Global Privacy Control (“GPC”), which can send a signal to opt out of certain types of data processing, including certain data “sales” or “sharing” as defined under applicable laws. Where required by law, when we detect a GPC signal, we will make reasonable efforts to respect your choices.

Some browsers offer a “Do Not Track” (DNT) preference. Because there is not a common understanding of how to interpret DNT signals, our Services do not respond to DNT signals. You can use the other tools described in this Privacy Notice to manage data collection and use, including cookie controls and privacy choices that may be available on our website.

If you are located in the European Economic Area (“EEA”), the United Kingdom, or Switzerland, you have certain rights under the GDPR, subject to applicable limitations and exceptions, including the right to:

Access your Personal Information;
Rectify inaccurate or incomplete Personal Information;
Request the erasure of your Personal Information (“right to be forgotten”);
Restrict the processing of your Personal Information;
Object to the processing of your Personal Information where processing is based on legitimate interests or for direct marketing purposes;
Receive your Personal Information in a structured, commonly used, and machine-readable format and to request its transfer to another controller (data portability); and
Not be subject to a decision based solely on automated processing, including profiling, that produces legal or similarly significant effects.

Where we process Personal Information based on your consent, you have the right to withdraw your consent at any time. Withdrawal of consent will not affect the lawfulness of processing based on consent prior to its withdrawal.

To exercise these rights, please contact us using the information provided in Section 12.

We implement reasonable administrative, technical, and physical safeguards designed to protect Personal Information against unauthorized access, loss, misuse, alteration, or disclosure. These safeguards are intended to maintain the confidentiality, integrity, and security of Personal Information consistent with applicable laws and industry standards.

Despite these efforts, no method of transmitting information over the Internet or storing information electronically is completely secure. Accordingly, while we strive to protect your Personal Information, we cannot guarantee absolute security.

To the fullest extent permitted by applicable law, Steer Lab disclaims liability for any unauthorized access to, use of, or disclosure of Personal Information that occurs despite our reasonable security measures.

Email, text messages, and other communications sent to or from the Services may not be secure. You should carefully decide what information you send to us through these channels.

The safety and security of your information also depends on you. You are responsible for taking reasonable steps to protect your Personal Information against unauthorized access and use, including by using secure networks and protecting any account credentials.

Personal Information we collect may be transferred to, processed in, and stored in locations outside of your state, province, country, or other governmental jurisdiction, including the United States and other countries where data protection laws may differ from those in your place of residence.

We take reasonable steps to help ensure that Personal Information is protected in accordance with this Privacy Notice and applicable law when transferred internationally.

Where required by applicable data protection laws, including where Personal Information originating from the EEA, the United Kingdom, or Switzerland is transferred to a country that has not been determined to provide an adequate level of protection, we implement appropriate safeguards. These safeguards may include reliance on standard contractual clauses or other lawful transfer mechanisms recognized under applicable law.

If you would like more information about the safeguards we use in connection with international transfers of Personal Information, please contact us using the contact information provided in Section 12 (“How to Contact Us”).

If you are a California resident, you have specific rights under the California Consumer Privacy Act, as amended by the California Consumer Privacy Rights Act (“CCPA/CPRA”). These rights are described in Section 6 (Your Privacy Rights and Other Choices) of this Privacy Notice and include, subject to certain exceptions:

the right to know, access, correct, or delete your Personal Information;
the right to opt out of the “sale” or “sharing” of Personal Information;
the right to limit the use and disclosure of Sensitive Personal Information; and
the right not to receive discriminatory treatment for exercising your privacy rights.

Steer Lab does not knowingly sell or share the Personal Information of individuals under 16 years of age.

You may exercise your California privacy rights as described in Section 6, including by contacting us at: lab@steerllc.com.

Privacy Policy

1. Personal Information We Collect and How It Is Collected

2. Collection Technologies

3. How We Use Personal Information

4. How Personal Information Is Disclosed or Shared

5. Retention of Personal Information

6. Your Privacy Rights and Other Choices

7. Security Practices

8. International Data Transfers

9. Children’s Privacy

10. Links to Third-Party Websites and Services

11. Governing Law

12. How to Contact Us

13. Additional Information for California Residents