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STR3. Digital Privacy Policy

Sweep & Co LLC, dba STR3. 
Effective 7/31/25.  Last updated 7/15/26.

1. Introduction

STR3 ("we," "us," or "our") is the brand of Sweep & Co LLC, a brand and strategy agency serving B2B clients in healthcare and healthtech markets across North America, the United Kingdom, the European Union and Switzerland.
We respect the privacy of our clients, partners and prospects and are committed to handling business contact data with transparency, integrity and care. This policy outlines how we collect, process and protect your data in accordance with applicable privacy laws and best practices.

2. Scope and Applicability

This Privacy Policy applies to personal and business contact data that we collect through:

  • Contact forms, newsletter sign-ups and intake submissions on our website

  • Diagnostic intake submissions through nunNEO, our brand intelligence tool

  • Email communication and outbound outreach

  • CRM and marketing platforms

  • Event participation and webinar registrations

  • Social platforms like LinkedIn

  • Analytics and website performance tracking

We do not collect sensitive personal, consumer or health-related data. All data processed pertains to professional interactions in a business context.

3. Types of Data We Collect

  • Professional identifiers: Full name, title, company name, business website, work email and phone number

  • Organizational details: Company size, sector, location and job function

  • Diagnostic intake data: The business and brand context you voluntarily provide when you request a nunNEO diagnostic, such as your role, market segment and the brand or go-to-market challenge you describe

  • Interaction data: Emails opened, links clicked and website form submissions

  • Technical data: Browser type, IP address, referring URL and cookie identifiers

We collect only what is necessary for relevant business purposes.

4. How We Use Your Data

  • Respond to service inquiries and requests

  • Run nunNEO brand and go-to-market diagnostics and deliver the resulting reports to you

  • Send relevant marketing communications and newsletters (opt-out always available)

  • Share insights, reports and event invites

  • Personalize outreach and improve relevance

  • Deliver service projects as part of client engagements

  • Analyze the performance of campaigns and website activity

5. Legal Basis for Processing (GDPR / UK GDPR / Canada PIPEDA)

  • Legitimate interests (e.g., business development, marketing to relevant professionals)

  • Consent (where required by law or for newsletters, form opt-ins, cookie preferences and nunNEO diagnostic requests)

  • Contractual necessity (e.g., responding to your request, proposal, onboarding and project delivery)

  • Legal compliance (e.g., data rights management and audits)

STR3 does not use your data for profiling or automated decision-making about individuals.

6. Data Sharing and International Transfers

  • We do not sell or rent data. We may share your data with:

  • Cloud, hosting and productivity providers

  • CRM and marketing platforms

  • Operational, form and workflow tools

  • Proprietary tools: nunNEO, our brand intelligence tool, which processes the business information you submit in order to generate diagnostic reports

  • AI subprocessors that support our analysis and content work, operating under confidentiality and data-protection obligations

  • Marketing and social platforms, including advertising and scheduling tools

  • Compliance services: DataRep for GDPR representation

  • Legal or regulatory bodies, if legally required

All providers are bound by confidentiality and process data under strict contractual safeguards. If data is transferred outside the EU/UK/Switzerland, we rely on Standard Contractual Clauses (SCCs) and vendor compliance frameworks.

7. GDPR/UK GDPR/FADP Representative

As required under Article 27 of the EU and UK GDPR and Swiss FADP, Sweep & Co LLC has appointed DataRep as our representative.

To contact DataRep: https://www.datarep.com

Choose your local office or contact via the web form to submit inquiries related to personal data or data rights.

8. AI Tools and Automated Processing

STR3 uses AI and automation tools to support our operations and deliver client services. These include:

  • nunNEO, our proprietary brand intelligence tool. When you request a nunNEO diagnostic, the business information you provide is analyzed to produce a brand or go-to-market diagnostic and report. nunNEO assesses your company's brand and go-to-market, not you as an individual, and it does not make automated decisions about individuals.

  • AI subprocessors that support strategy, analysis and content development, operating under confidentiality and data-protection obligations

We also use industry-standard platforms for project management, design collaboration and social media scheduling.

Any content or analysis generated with AI is reviewed and approved by a human before it is used or delivered. The information you submit to us, including nunNEO diagnostic submissions, is not used to train AI models. All third-party tools used comply with data protection obligations under GDPR, PIPEDA and U.S. standards.

9. Data Retention

  • Up to 24 months for inactive contacts

  • nunNEO diagnostic submissions and the reports we generate, retained for up to 24 months unless you request earlier deletion

  • For the duration of client projects and legal obligations

  • Immediately removed upon request or opt-out

We conduct periodic data reviews and system cleanups to avoid unnecessary retention.

10. Your Rights

Depending on your jurisdiction (EU, UK, CH, CA or U.S. states like CA or CO), you may have the right to:

  • Request access to your data

  • Correct inaccuracies

  • Withdraw consent or unsubscribe

  • Request deletion ("right to be forgotten")

  • Restrict or object to processing

  • File a complaint with a supervisory authority

To exercise your rights, contact: privacy@str3.com

11. Children's Privacy

Our website and services are directed to businesses and professionals, not to children. We do not knowingly collect personal information from anyone under the age of 16. If you believe a child has provided us with personal data, contact us at privacy@str3.com and we will delete it.

12. Cookies and Tracking

This section explains how STR3 uses cookies and similar technologies, such as pixels and tags, to operate our site and understand how it is used.

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12.1 What Cookies Are.

Cookies are small data files stored on your browser or device that help us recognize returning visitors and analyze how our site is used. Similar technologies, such as pixels and tags, perform comparable functions.

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12.2 The Cookies We Use.

  • Essential cookies: enable secure site functionality and operate interactive features, including diagnostic tools such as nunNEO

  • Analytics cookies: Google Analytics, to monitor traffic and performance

  • Marketing cookies: LinkedIn Ads tracking, for remarketing and campaign performance

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12.3 Consent Mechanism.

For users in the EU, UK and Switzerland:

  • A consent banner appears on your first visit, allowing you to accept, reject or customize non-essential cookies

  • Non-essential cookies, including analytics and marketing cookies, are not set until you provide consent

  • You may update or withdraw your consent at any time through our cookie preferences link

  • We maintain records of consent as required by applicable law

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12.4 Managing Cookies.

You can review and change your cookie choices at any time using the cookie preferences link on our website. You can also clear or block cookies through your browser settings, or opt out of analytics tracking through tools such as the Google Analytics Opt-Out Add-on and Your Online Choices (EU).

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12.5 Data Collected via Cookies.

Cookies and similar technologies may collect technical information such as browser type, IP address, session duration, and device and location metadata. Some of this information, including IP address, may constitute personal data under GDPR and similar laws, and we handle it accordingly. We do not collect sensitive personal data or health data through cookies.

13. Security Measures

  • Healthcare-grade hosting: although we do not collect or process protected health information, our website is hosted on Wix's HIPAA-compliant infrastructure as an added layer of protection for the business data we handle

  • Encrypted storage and 2FA across core platforms

  • Role-based access to client and project data

  • Data minimization and encryption

  • Vendor reviews and contracts for data processors

  • ncident response procedures (under development for SOC 2 alignment)

We are actively working toward SOC 2 self-certification (Type I) through structured documentation, internal audits and platform-based controls.

14. Policy Updates

We may revise this policy periodically to reflect changes in laws, tools or data practices. All updates will be posted here with a new "Last Updated" date.

15. Contact Us

Sweep & Co LLC, dba STR3

68 Harrison Street STE 605, Boston, MA 02111, United States

Email: privacy@str3.com

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