Privacy Policy

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Last Updated: March 24, 2025

Introduction

Seneka, LLC ("Seneka," "we," "our," or "us") respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our website, seneka(dot)global, and services. We are committed to complying with applicable data protection laws, including the U.S. Federal Acquisition Regulation (FAR), Defense Federal Acquisition Regulation Supplement (DFARS), National Institute of Standards and Technology (NIST) SP 800-171, Virginia Consumer Data Protection Act (VCDPA), and the European General Data Protection Regulation (GDPR).

Data and Information Collection and Processing

Data Controller Information. Seneka, LLC is the data controller responsible for your personal data. Contact details: legal(at)seneka(dot)global

Information We Collect. We collect and process the following categories of personal data:

• Identifiers: Such as name, postal address, email address, phone number, IP address, and account login credentials
• Commercial Information: Records of services purchased or considered
• Internet Activity: Information regarding interaction with our website
• Geolocation Data: General location information derived from IP addresses
• Inferences: Derived information reflecting preferences and characteristics

Information You Provide to Us. We may collect the following types of information when you use our website, contact us, or engage our services:

• Contact information, such as name, email address, postal address, and telephone number
• Business information, such as company name, job title, and industry
• Account information, such as username and password if you create an account
• Communications, including questions, feedback, or other information you send to us
• Service-related information necessary to provide our R&D, innovation, and strategy development services

Information We Collect Automatically. When you visit our website, we may automatically collect:

• Device information, such as your IP address, browser type, operating system, and device type
• Usage information, including pages viewed, time spent on pages, links clicked, and the page you visited before coming to our site
• Cookies and similar technologies as described in the Cookies section below
• Information From Other Sources. We may receive information about you from other sources, including:
• Business partners with whom we offer co-branded services or joint marketing activities
• Publicly available sources, such as business directories, LinkedIn, and other professional platforms

Sensitive Data. We do not collect sensitive data as defined under VCDPA or GDPR (such as racial or ethnic origin, religious beliefs, mental or physical health diagnosis, sexual orientation, citizenship status, genetic or biometric data, precise geolocation, or personal data of known children).

Data and Information Processing

Lawful Basis for Processing. Under the GDPR, we process your personal data based on one or more of the following lawful bases:

• Consent: You have given clear consent for us to process your personal data for a specific purpose.
• Contractual Necessity: The processing is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract.
• Legal Obligation: The processing is necessary for us to comply with the law.
• Legitimate Interests: The processing is necessary for our legitimate interests or the legitimate interests of a third party, unless there is a good reason to protect your personal data which overrides those legitimate interests.

Purposes for Processing. We may use the information we collect for the following specific purposes:

• To provide and maintain our professional services in R&D, innovation, and strategy development (Lawful basis: Contractual Necessity)
• To process and fulfill requests, orders, and transactions (Lawful basis: Contractual Necessity)
• To respond to your inquiries and communicate with you about our services (Lawful basis: Legitimate Interests)
• To improve and maintain our website, services, and user experience (Lawful basis: Legitimate Interests)
• To send you marketing communications about our services, events, and other information that may be of interest to you (Lawful basis: Consent or Legitimate Interests)
• To detect security incidents and protect against malicious, deceptive, or illegal activity (Lawful basis: Legal Obligation and Legitimate Interests)
• To debug to identify and repair errors in our systems (Lawful basis: Legitimate Interests)
• To comply with legal obligations and enforce our legal rights (Lawful basis: Legal Obligation)
• To protect against fraud and security risks (Lawful basis: Legitimate Interests)
• For other purposes as described at the time of collection or with your consent (Lawful basis: Consent)

Data Limitation. We adhere to the data limitation principle and only collect and process personal data that is adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed. We will not retain personal data longer than is necessary for the purposes for which it is processed, unless otherwise required by law.

Data and Information Sharing

How We Share Your Information. We may share your information with the following categories of third parties:

• Service Providers: Companies that provide services on our behalf, such as website hosting, data analysis, payment processing, IT services, customer service, and email delivery
• Professional Advisors: Lawyers, auditors, bankers, and insurers who provide consultancy, legal, banking, and insurance services
• Business Partners. Companies with whom we jointly offer services or engage in marketing activities
• Government Entities. We may disclose your information to comply with applicable laws, regulations, legal processes, or governmental requests, or to protect our rights, privacy, safety, or property, or that of our clients and others.
• Business Transfers. If we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution, or liquidation), your information may be transferred as part of that transaction.
• Sale of Personal Data. We do not sell personal data as traditionally defined. However, under some state laws, including the VCDPA, certain sharing of personal information might be considered a "sale." If applicable, you have the right to opt out of such sales.
• Targeted Advertising and Profiling. We may engage in targeted advertising based on your personal data. Additionally, we may use automated processing to analyze or predict aspects concerning your economic situation, preferences, interests, behavior, or location. Under the VCDPA and GDPR, you have the right to opt out of these processing activities.

Cookies and Similar Technologies

We use cookies and similar technologies to collect information about your browsing activities and to improve your experience on our website. Cookies are small text files that are stored on your device when you visit a website. Types of Cookies We Use:

• Essential cookies: Necessary for the website to function properly
• Functional cookies: Enable enhanced functionality and personalization
• Analytics cookies: Help us understand how visitors interact with our website
• Marketing cookies: Used to track visitors across websites to display relevant advertisements

Cookie Consent. We use a cookie consent management platform to obtain your explicit consent for non-essential cookies. You can decline your cookie preferences at any time by clicking “Decline” on the cookie notification popup on our website.

Your Cookie Choices. You can manage cookies through your browser settings. Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our website.

Data Security

We implement reasonable security measures to protect your information from unauthorized access, disclosure, alteration, or destruction. These measures include administrative, technical, and physical safeguards appropriate to the nature of the information and the processing activities. However, no data transmission over the Internet or storage system can be guaranteed to be 100% secure.

Data Retention. We retain your information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. 

Automated Decision-Making and Profiling. We do not engage in automated decision-making or profiling that would produce legal effects or similarly significant effects on you. If this changes in the future, we will update this policy and provide you with meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you.

Data Breach Notification. In the event of a personal data breach, we will notify you and any applicable regulator when we are legally required to do so. We will provide you with information about the breach, its likely consequences, and the measures we have taken or propose to take to address the breach and mitigate its possible adverse effects.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The "Last Updated" date at the top of this policy indicates when it was last revised. We encourage you to review this Privacy Policy periodically.