Last modified: 05/2018
StoneCalibre, LLC (“StoneCalibre”) respects your concerns about privacy.
We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO at: firstname.lastname@example.org.
Information We Collect
StoneCalibre may collect personally identifiable information including:
- Personal and business contact information (such as name, postal/email address, and telephone number)
- Other personal information you submit to us that is relevant to our business services such as information you provide to register for email alerts
Information We Obtain by Automated Means
Cookies are text files placed on your computer or other internet-connected device to uniquely identify your browser. StoneCalibre, and certain third-party web provides, may use these and/or similar technology in order to obtain marketing and website analytics. In the event of third-party use information will be disclosed and/or collected by these service providers.
You may choose to block or delete cookies from your browser.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Thereafter, we will delete (or otherwise erase, de-identify or pseudonymise or equivalent) any such personal data except as required or permitted by applicable law or regulation.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Use of and Purposes for Processing Personal Data
StoneCalibre processes your personal data in order to comply with our legal and regulatory obligations, our contractual obligations to provide our programs and services to you and/or the legitimate interests of StoneCalibre, and for other purposes for which StoneCalibre has a lawful basis under applicable law, including but not limited to: (i) providing updates regarding services and business activity; (ii) responding to your inquiries; (iii) performing regular business operations; (iv) complying with legal and regulatory requirements; and (iv) participating in litigation, investigations, regulatory or governmental enquiries or for other legal or regulatory purposes involving StoneCalibre.
If you provide your email address, we may use your email address to send you promotional materials, newsletters and other communications. If you wish to opt out of promotional emails, you may do so by following the “unsubscribe” instructions in the email.
How We Share Collected Information
StoneCalibre may disclose your personal information with contracted third parties who require the data to perform services based on our legitimate business interests, contractual obligations or with our legal and regulatory requirements.
We may share your personal information with our affiliates and subsidiaries so that they may contact you regarding their products and services. You can opt out from marketing communications at a later date. We may share personal information with other affiliated entities for any of the purposes set out above. Our affiliated entities, in turn, are not permitted to share personal information with other non-affiliates entities, except as described herein or otherwise permitted by the Privacy Laws or other applicable laws.
In the event that we undergo a business transition, like a merger, acquisition by another company, or sale of assets, either partial or full, we may transfer information that you have shared with us to the successor company.
Data Transfers out of the EEA
If you are resident in the UK or European Economic Area (“EEA”), personal information may be transferred to recipients in countries that may not have the same data protection laws as the country in which the information was originally shared. In the event of such a transfer, we will ensure data is processed with an adequate level of protection in accordance with applicable law.
Except for those circumstances where we believe that it is appropriate to rely on contractual necessity or your express consent, whenever we transfer personal data of EU data subjects out of the EEA, we ensure a similar degree of protection is afforded to it by using specific contracts approved by the European Commission which give personal data the same level of protection as it has in the EEA. Please contact us if you require further information on the specific mechanism used by us when transferring your personal data.
Your EU Privacy Rights
If you reside in the UK or in the EEA, you have certain rights relating to the personal information we hold in accordance with and subject to applicable Privacy Laws. You have the right to:
- Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
With your consent, we may share your personal information with our affiliates and subsidiaries so that they may contact you regarding their products and services. If you have consented, you have the right to opt out from marketing communications at a later date.
You have the right to make a complaint at any time to a supervisory authority in your country. We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority so please contact us in the first instance.
Access to Your Information
To the extent provided by the law of your jurisdiction, you may request:
- A copy of the data we have on file
- To amend, delete or block information
- To withdraw consent previously provided
- To object, on a legitimate basis, to the processing of your personal information
How to Contact Us
If you have questions, comments, concerns or request related to your personal information please contact us using one of the following methods:
- Email: email@example.com
- Telephone: +1 (310) 774-0014
- Mail: StoneCalibre Privacy - 2049 Century Park East, Suite 2550, Los Angeles, CA 90067