Last updated: 20/09/2018

Stra-Target Consulting prepared this Privacy Policy to provide an overview of the personal information we may collect from users and how we process and/or use that information. The use of personal information collected through our services shall be limited to the purposes described in this Privacy Policy.

IMPORTANT NOTICE FOR USERS: This Privacy Policy does not govern the collection, use, or disclosure of personal information through the Service by the organization or institution which has given you (or your child) access to the service, or which is providing a course you are taking via Shene Solutions’ services. Please contact the controlling organization to better understand its privacy practices. Shene Solutions will retain personal information we process on behalf of organizations for as long as needed to provide services and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.


Stra-Target Consulting complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union (“EU”) and Switzerland to the United States (“U.S.”) respectively, as that term is defined in the Privacy Shield Framework. Shene Solutions has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. We are committed to subjecting all personal data received from the EU and Switzerland, in reliance on the Privacy Shield Framework, to the Framework’s applicable principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield:

Stra-Target Consulting’s privacy policy, provided below, describes the types of personal information that we collect, the types of third parties to which we disclose personal data, and the purposes for which we do so. Stra-Target Consulting collects contact and demographic information to respond to requests or to personalize and deliver the services. eThink transfers this information to third parties acting as an agent on our behalf. We are accountable for the processing of personal data we receive, under the Privacy Shield Framework, and subsequently transfer to a third party. Stra-Target Consulting complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.

Residents of the EU and Switzerland have the right to access the personal information that Shene Solutions maintains, and in some cases, may have the right to correct or amend information that is inaccurate or has been processed in violation of the Privacy Shield Principles, to the extent allowed by law. To exercise this right, contact us using the up to date to date contact information listed below.

With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Shene Solutions is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Shene Solutions may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Residents of the EU and Switzerland with inquiries or complaints regarding this Privacy Policy should first contact Stra-Target Consulting at: or +358 44 954 5710

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 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 on the Privacy Shield website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.


We collect information from you, such as first and last name and e-mail address when you create an account to log in to one of our services or support tools. We may also collect mailing addresses, phone numbers, professional title, company name, user names, and a password, as needed to provide services.

We also may retain information on your behalf, such as files and messages that you store using your account. If you provide us feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail. We also collect other types of personal information and demographic information that you provide to us voluntarily.


To make our services more useful to you, our servers (which may be hosted by a third party service provider) collect information from you, including browser type, operating system, Internet Protocol (IP) address, referring domain name, unique device identifiers, information about how you use our Services and/or a date/time stamp for your visit. We also use cookies and navigational data like Uniform Resource Locators (URL) to gather information regarding the date and time of your visit and the solutions and information for which you searched and which you viewed. We automatically gather this data and store it in log files each time you use our services.

In accepting this Privacy Policy, you consent to our placement and continued use of cookies on your device.

Internet cookies are small pieces of information that a website sends to your computer’s hard drive while you are viewing a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our websites.

Services we use (such as Google Analytics) may use cookies and/or scripts to collect and store information such as how users interact with our services, browser and site performance metrics, errors users encounter when using our services, device identifiers, how often users visit the websites, what pages they visit, and what other sites they used prior to coming to the websites. We use the information we get from Google Analytics only to improve our websites and services. Please see the following links for more information about Google Analytics:, and We do not tie the information gathered using third party analytics to your personal information.

Managing cookies:

  • Most web browsers are set to accept cookies by default. You can usually remove and reject cookies from our site via your browser settings. If you remove or reject our cookies, it may affect how our websites and services work.
  • If you do not wish us to track emails we send you, some email services allow you to adjust your display to turn off HTML or disable download of images which should effectively disable our email tracking, or you may unsubscribe from our marketing emails.
  • You may opt out of tracking of certain information collected by Google Analytics, one of our analytics providers as discussed above, by clicking here.

While we and others give you the choices described in this Privacy Policy, there are many ways web browser signals and other similar mechanisms can indicate your choice to disable tracking, and we may not be aware of or honor every mechanism.


Personal information you submit to us is used either to respond to requests that you make, or to aid us in serving you better. Shene Solutions uses your personal information in the following ways: to create and maintain your account; to identify you as a user in our system; to process support tickets that you may initiate; to operate, maintain, and improve our services; to personalize and improve your experience; to send you administrative e-mail; to respond to your comments or inquiries; to send you surveys, promotional communications about our products and services with your permission; to protect, investigate, and deter against fraudulent, unauthorized, or illegal activity; and to make telephone calls to you, or to solicit your feedback with your permission. We may use data which has been de-identified and aggregated data for additional purposes.


We will share your personal information with third parties only in the ways that are described as follows or with your express consent.


Stra-Target Consulting does not currently have any affiliates (such as a parent company). However, if this changes we shall update this privacy policy and Shene Solutions will ensure that any affiliates with whom we share data honors this Privacy Policy.


We may share your personal information with third party service providers for the sole purpose of providing you with the services that we provide. For example, we may share data with service providers who host our websites (such as Rackspace or Amazon Web Services), provide client relationship management service (Zendesk), or provide email services on our behalf.


We will share your information with the educational institution, corporation, or organization (the data controller) which is linked to your use of Stra-Target Consulting’s services. In this context Stra-Target Consulting is a data processor. For example, this would apply:

  • If your educational institution hosts Moodle or Totara with us and has given you access to the system
  • Your employer uses Stra-Target Consulting to host its learning management system.


Stra-Target Consulting may disclose information about you if it believes such disclosure is necessary to (a) comply with laws or to respond to lawful requests and legal process; or (b) protect or defend the rights, safety, or property of Stra-Target Consulting, users of our services, or any person including to enforce our agreements, policies, and terms of use, or (c) in an emergency to protect the personal safety of any person.

We may also share de-identified and aggregated data with others for their own uses.


MARKETING CHOICES: By accepting this Privacy Policy when submitting your personal information, you consent to us contacting you with newsletter and promotions by email. When you receive newsletters or promotional communications from us, you may “opt-out” by following the unsubscribe instructions provided in e-mails you receive from us or by contacting us directly at the contact information below. You do not have to provide us with any personal information, however if you do not do so we may not be able to provide services to you.

SECURITY OF YOUR PERSONAL INFORMATION: Stra-Target Consulting takes reasonable steps to help protect your personal information in an effort to prevent unauthorized access, use, or disclosure. Despite these measures, you should know that Stra-Target Consulting cannot fully eliminate security risks associated with personal information. No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security. Any content you post while using our services is at your own risk.


Stra-Target Consulting may change this Privacy Policy from time to time. If we make any changes to this Policy, we will change the “Last Updated” date above. If such changes are material, a notice of the changes will be posted along with the revised Privacy Policy. All efforts will be made to posted changes prior to the change becoming effective. We encourage you to visit this page from time to time for the latest on our privacy practices.

If you have any questions or concerns about this privacy policy, please contact us using the information below: