STONETURN GROUP, LLP PRIVACY POLICY

Privacy Principles

Your privacy is important to us. This Privacy Policy explains how we collect, store and use your Personal Information when you visit or use this and other online services offered by StoneTurn Group, LLP and its affiliates (“StoneTurn”). For purposes of this Privacy Policy, Personal Information includes any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly with a particular individual, including, but not limited to, a first and last name, email address, a home, postal or other physical address, an IP address, and phone number (“Personal Information”).

Please carefully review this Privacy Policy to learn more about how we collect, store and use the Personal Information that we have obtained. By using this website, you consent to the processing of your information as described in this Privacy Policy. If you have any questions or concerns relating to StoneTurn’s website or would like to find out more about how we collect, store and use your Personal Information, please email us at privacy@stoneturn.com.

We Protect Your Information

We take our responsibility to protect the privacy and confidentiality of your Information, including Personal Information, very seriously. We maintain physical, electronic and procedural safeguards that comply with applicable legal standards to secure such Information from unauthorized access and use, alteration and destruction. We hold our employees accountable for complying with relevant policies, procedures, rules and regulations concerning the privacy and confidentiality of Information.

What Information Do We Collect?

StoneTurn collects any information that you provide us when you use our website. While you can visit most pages on our website without giving us any information about yourself (i.e., name, email address, phone number, fax number, and contact information), there are instances where you can choose to provide us with your Personal Information. For example, you may provide us with basic Personal Information when you submit inquiries to us or in order to receive news, special offers and general information about our services and events that are similar to those that you have already purchased or inquired about unless you have opted not to receive such information. You may also provide us with certain employment information in connection with an application for employment with StoneTurn in the “Careers” section of StoneTurn’s website or you may sign up for job alerts.

StoneTurn does not sell Personal Information it collects from consumers. Rather, we use the Information we collect and receive from you to provide you with requested services, to communicate with you, and to fulfill your specific requests. For example, if you send us an email requesting information about StoneTurn, we will use your email address and other information you send us to respond to your request. Your Personal Information is not used for other purposes, unless we obtain your permission, or unless otherwise required or permitted by law or professional standards. Our goal is to collect and use only that information that we think is necessary for our legitimate business interests.

In addition to the information identified above, other information about you that StoneTurn collects and processes, includes:

  • Cookies and similar tracking technologies. This website utilizes session cookies, which are small text files placed on your computer or mobile device when you visit our site. Session cookies enable you to move from page to page on our website, and allow information you enter to be remembered. A session cookie is deleted when you close your browser or after a short period of time. Cookies are used in the following ways on our website:
    • Website statistics. We utilize statistical services, such as Google Analytics, to review how visitors use our website. This information helps us improve our website navigation and the content we offer. Google and other service providers use cookies as part of this process to collect anonymous information, including the number of visitors to our website, how visitors are entering our site, the pages they visit and the length of time they spend on our site.
    • Contact Us page. We use a session cookie on this page to allow you to contact us via the site.

Using cookies as described above helps us improve the functionality of our website and enhances your experience when using it. Cookies can be disabled by changing the settings on your browser. If you do decide to disable cookies, certain areas and features of our website may not perform as designed. By using our website, you consent to our use of cookies as described above. Please note that non-StoneTurn websites you are directed to from our website may have their own cookie policies. Please refer to those non-StoneTurn websites’ privacy policies and terms of use to learn more about their privacy practices, which we do not control.

Who Will Your Personal Information Be Shared With?

Personal Information collected on the website may be shared with:

  • Employees internally within StoneTurn, including with members of the Human Resources department and IT staff if access to the information is necessary for the performance of their duties at StoneTurn.
  • Service providers and other third parties under contract who help with our business operations (such as, but not limited to, fraud investigations, software development, email delivery, marketing communications, bill collection, payroll, payment processing and site analytics and operations).
  • Partners or professional organizations who promote similar services related to your area of interest. StoneTurn requires that these entities protect Personal Information in the same manner as StoneTurn.
  • Third parties in the context of a sale of some or all of StoneTurn’s business. In those circumstances, we will provide notice before your Personal Information is transferred and becomes subject to a different Privacy Policy.
  • Government or law enforcement agencies in order to respond to lawful requests, including where disclosure is required by applicable laws, court orders, or government regulations.
  • Any information obtained as part of SMS consent will not be shared with third parties of affiliates.

How Does StoneTurn Protect Personal Information?

StoneTurn takes the security of your information very seriously. StoneTurn has internal policies and controls in place in an effort to ensure that your information is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by its employees in the performance of their duties for StoneTurn. Personal Information may be stored in a variety of different storage locations, including in StoneTurn’s servers and IT systems (including StoneTurn’s email system). Access to all of our clients’ information is restricted in our offices.

Where StoneTurn engages third parties to process Personal Information on its behalf, your Information is provided to the third parties pursuant to written contracts, which obligate them to implement appropriate technical measures to maintain the security of the information in an effort to ensure that your Information is not lost, accidentally destroyed, misused or disclosed.

StoneTurn retains data for the duration of the client’s business relationship with StoneTurn. For more information on where and how long your personal data is stored, and for more information on your rights to be forgotten/of erasure, please contact us at privacy@stoneturn.com.

Will StoneTurn Transfer My Personal Information Across Borders?

StoneTurn may transfer certain Personal Information across geographical borders to other StoneTurn offices or outside companies working with us or on our behalf. StoneTurn may also store Personal Information in a jurisdiction other than where you are based and such jurisdiction may not provide the same level of protection for your Personal Information as your home country. StoneTurn will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other Personal Information. By providing your information to StoneTurn, you are consenting to this transfer and/or storage of your Information across borders.

Children’s Privacy

StoneTurn understands the importance of protecting children’s privacy, especially in an online environment. It is our policy never to knowingly collect or maintain information about children, except as part of an engagement to provide professional services. If you are a parent or guardian of a child under the age of 13 and believe he or she has disclosed personally identifiable information to us please contact us at privacy@stoneturn.com. A parent or guardian of a child under age 13 may review and request deletion of the child’s Personal Information.

Social Media Platforms

At various times, StoneTurn may host blogs, forums, crowd-sourcing and other applications or services (collectively, “Social Media Platforms”). Any information you share on these Social Media Platforms may become public on the internet and we cannot prevent further use of this information. You can control what data you share through privacy settings available on some Social Media Platforms. Please refer to those third-party sites’ privacy policies and terms of use to learn more about their privacy practices, which we do not control.

Your Choices

You can control how and when you want to receive notifications regarding marketing-related emails for services described on StoneTurn’s website by sending a request to privacy@stoneturn.com from the email address that is receiving marketing-related emails or by opting-out within the notices.

If you opt-in for particular services or communications, you will be able to unsubscribe at any time by following the instructions included in each communication.

If you wish to prevent cookies from tracking you as you navigate our website, you may be able to do so by changing your browser settings. Note, however, that some portions of the website may not work properly if you elect to refuse cookies. You may also delete your data by contacting us at privacy@stoneturn.com with the subject line “My data”.

Your Rights

You have a number of rights with respect to your Personal Information collected by StoneTurn. Specifically, you have the right to:

  • Right to Know:
    • You have the right to know the Personal Information we collect, use, and disclose about you. You have the right to request in writing from us a copy of the categories of Personal Information we have collected about you, the categories of sources from which we collected that information, why we collected that information about you, the categories of third parties with whom we share your Personal Information, the categories of Personal Information that we disclosed about you for a business purpose, and the specific pieces of Personal Information we have collected about you. To request a copy of such disclosure in a readily useable format, please contact StoneTurn via the email or mailing address provided below.
  • Right to Rectification:
    • You have the right to require StoneTurn to update incorrect or incomplete Personal Information. To request rectification of incorrect or incomplete Personal Information, please contact StoneTurn via the email or mailing address provided below.
  • Right to Deletion:
    • You have the right to require StoneTurn to delete or stop processing your Personal Information, for example where the information is no longer necessary for business purposes.
  • Right to Opt-Out of the Sale of Your Personal Information:
    • You have the right to opt-out of having your Personal Information sold. As noted above, StoneTurn does not sell Personal Information to third parties.
  • Right to Object:
    • You have the right to object to the processing of your Personal Information where StoneTurn is relying on its legitimate interests as the legal ground for processing.
  • Right to Non-Discrimination:
    • StoneTurn will not discriminate against those who exercise their Rights. Specifically, if you exercise your Rights, we will not deny you goods or Services, charge you different prices or rates for goods or Services or provide you a different level or quality of goods or Services.

We may ask you for proof of identity or other additional Personal Information before complying with the above requests. This measure is in place to help protect your Personal Information. The information collected through this process will be used for verification purposes only.

If you have any questions relating to the information collected by StoneTurn or to exercise any of the rights listed above, please contact us using one of the following methods:

Email: privacy@stoneturn.com

By mail:

Chief Privacy Officer, StoneTurn Group, LLP, 75 State Street, Suite 1710, Boston, MA 02109. info@stoneturn.com, +1 617 570 3700

StoneTurn Group (Germany) GmbH, Bockenheimer Landstraße 2-4, 16th Floor, 60306 Frankfurt am Main, Germany. info@stoneturn.com, +49 695 060 4439

StoneTurn Group South Africa (PTY) LTD, 244 Jean Avenue, Norma Jean Square, Unit 5, Centurion, Gauteng 0046. info@stoneturn.com, +1 617 570 3700

StoneTurn UK Limited, Genesis House, 17 Godliman Street, London, EC4V 5BD. info@stoneturn.com, +44 20 7427 0400

StoneTurn Brasil Consultoria Empresarial Ltda, Rua Leopoldo Couto, Magalhães Júnior, 1098, 7⁰ andar, Itaim Bibi, São Paulo, SP, Brazil 04542-001. info@stoneturn.com, +55 11 49355460

StoneTurn Singapore Private Limited, 88 Market Street, Suite 21-01, CapitaSpring, Singapore, 048948. info@stoneturn.com, +1 617 570 3700

California Residents

If you are a California resident, California law may provide you with additional rights regarding your Personal Information. To learn more about your California privacy rights, please see the California Privacy Notice.

Brazilian residents

If you are in Brazil, Brazilian law may provide you with additional rights regarding your Personal Information. With this in mind, in addition to the other terms and conditions set forth herein, we want to let you know that we do not have the intention to collect or in any form request Personal Information from people under 18 years old (“Minor”), given that our website is intended to be used only by those who are over 18 years old. Therefore, if we become aware that we collected Personal Information from a Minor, we will disregard and exclude the information relating to this person.

What If You Do Not Provide Personal Information?

The Personal Information you provide is being used for legitimate business interests. If you do not provide the information requested, we may be unable to process your requests.

Changes to this Policy

We may change this Privacy Policy from time to time. When we do, we will let you know by appropriate means such as by posting the revised policy on this page with a new “Last Updated” date. All changes will become effective when posted unless indicated otherwise.

Links to Other Websites

Please be aware that StoneTurn’s website contains links to other websites. We strongly advise you to review the privacy policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

Questions and Comments

If you have any questions regarding this Privacy Policy, please contact at privacy@stoneturn.com or via your usual StoneTurn representative.

Last Updated: July 19, 2024

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